PRIVACY POLICY

Last updated: 18 September 2026

E-Repair S.r.l. considers the protection of personal data and the confidentiality of information to be an integral part of its business activities.

This Privacy Policy describes how E-Repair S.r.l. processes the personal data of users who visit the www.e-repair.com website, use the services available online or contact the Company through the forms and contact details available on the website.

Personal data are processed in compliance with Regulation (EU) 2016/679 (“GDPR”), Italian Legislative Decree No. 196/2003 (“Italian Data Protection Code”), as amended by Legislative Decree No. 101/2018, and any other applicable legislation concerning the protection of personal data.

1. Data Controller

The Data Controller is:

E-Repair S.r.l.
Via degli Arrotini, 19
57121 Livorno (LI) – Italy

VAT No.: 01642720492
Livorno Companies Register: LI 145181

Sales email: commerciale@e-repair.it
ESG email: esg@e-repair.it
Email for privacy-related requests: amministrazione@e-repair.it

E-Repair S.r.l. operates in the field of products, services and solutions for the repair, servicing, refurbishment and maintenance of industrial electronics.

2. Scope of this Privacy Policy

This Privacy Policy applies to the processing of personal data relating to users who:

• visit the www.e-repair.com website;
• use the forms available on the website;
• request information;
• request an appointment or a call-back;
• request assistance or technical support;
• communicate with E-Repair using the contact details published on the website;
• use any other services that may be available through the website.

This Privacy Policy applies exclusively to processing activities carried out by E-Repair through its website and related contact tools.

Separate privacy notices may be provided in relation to commercial, contractual and administrative relationships with customers, suppliers and partners.

3. Categories of Personal Data Processed

3.1 Data voluntarily provided by the user

When a user completes a contact form, submits a request or communicates directly with E-Repair, the following personal data may be processed:

• first name and surname;
• company or business name;
• job title or corporate role, where provided;
• email address;
• telephone number;
• type of request;
• information relating to products or services of interest;
• information relating to requests for assistance or technical support;
• contents of messages sent;
• any additional information voluntarily provided by the user.

Certain fields within the forms available on the website may be mandatory where such information is necessary in order to properly process the user’s request.

Users are requested not to provide special categories of personal data within the meaning of Article 9 GDPR, including information concerning health, racial or ethnic origin, religious or philosophical beliefs, political opinions or other particularly sensitive information, unless this is strictly necessary and permitted under applicable law.

3.2 Browsing Data

The information systems and software procedures used to operate the website may, during their normal operation, collect certain data whose transmission is inherent in the use of Internet communication protocols.

By way of example, the following data may be processed:

• IP address;
• technical identifiers;
• URI/URL addresses of requested resources;
• date and time of the request;
• method used to submit the request to the server;
• size of the files received in response;
• numerical code indicating the status of the server response;
• information concerning the browser used;
• information concerning the operating system;
• other parameters relating to the user’s IT environment.

Such data are mainly used to:

• ensure the proper functioning of the website;
• ensure system security;
• detect possible anomalies;
• prevent unauthorised access and unlawful activities;
• obtain aggregated statistical information concerning the use of the website, where applicable.

4. Purposes of Processing

Personal data may be processed for the purposes set out below.

A. Management of Contact Requests

For the purpose of:

• responding to requests submitted through the website forms;
• providing information about E-Repair products and services;
• responding to communications received by email or telephone;
• contacting the user where requested.

B. Management of Appointment and Technical Support Requests

For the purpose of:

• arranging telephone appointments;
• managing call-back requests;
• managing requests for assistance;
• arranging technical support or on-site services, where applicable;
• collecting the information required to properly manage the request.

C. Management of Pre-Contractual and Contractual Relationships

For the purpose of:

• preparing quotations and offers;
• providing consultancy;
• managing requests concerning products and services;
• establishing and managing commercial relationships;
• providing the products and services requested.

D. Administrative and Accounting Management

Where a user’s request results in a commercial or contractual relationship, personal data may be processed for:

• administrative management;
• invoicing;
• accounting;
• tax management;
• compliance with civil-law obligations;
• payment management.

E. Website and IT System Security

For the purpose of:

• preventing unauthorised access;
• detecting intrusion attempts;
• preventing fraud;
• countering cyberattacks;
• detecting anomalies;
• protecting the security of technological infrastructure.

F. Compliance with Legal Obligations

For the purpose of complying with obligations arising from:

• laws;
• regulations;
• national and European legislation;
• provisions issued by competent Authorities.

G. Protection of E-Repair’s Rights

For the purpose of:

• establishing a legal right;
• exercising a legal right;
• defending a legal right;
• preventing and managing disputes;
• protecting E-Repair in judicial or out-of-court proceedings.

H. Information and Marketing Communications

Where permitted by applicable law, E-Repair may use contact details to:

• provide information about its products and services;
• communicate company news;
• send newsletters;
• communicate events and initiatives;
• send technical updates;
• send promotional and marketing communications.

Where processing for marketing purposes requires the Data Subject’s consent, such consent shall be requested in a manner that is freely given, specific, informed and capable of being documented.

Failure to consent to marketing activities shall not prevent the user from using E-Repair’s other services.

5. Legal Bases for Processing

Personal data are processed on one or more of the following legal bases provided for under Article 6 GDPR.

Performance of Pre-Contractual Measures or a Contract

Article 6(1)(b) GDPR

This legal basis applies where processing is necessary to:

• respond to a request from the Data Subject;
• prepare a quotation;
• organise a service;
• provide assistance;
• manage a contractual relationship.

Compliance with a Legal Obligation

Article 6(1)(c) GDPR

This legal basis applies where processing is necessary to comply with administrative, accounting, tax, civil-law or other obligations provided for by applicable legislation.

Legitimate Interests of the Data Controller

Article 6(1)(f) GDPR

Legitimate interests may constitute the legal basis for processing, where permitted by law, for the purposes of:

• ensuring the security of the website and systems;
• preventing fraud and unlawful conduct;
• protecting E-Repair’s rights;
• properly managing and organising its business activities.

Legitimate interests are pursued with due regard for the fundamental rights and freedoms of Data Subjects.

Consent of the Data Subject

Article 6(1)(a) GDPR

Consent is used where required by applicable legislation, particularly in relation to:

• certain marketing activities;
• promotional newsletters;
• any non-essential cookies or tracking technologies.

Consent may be withdrawn at any time without affecting the lawfulness of processing carried out prior to its withdrawal.

6. Provision of Personal Data

The provision of data marked as mandatory in the website forms is necessary to enable E-Repair to process the user’s request.

Failure to provide the necessary information may make it impossible to:

• respond to the request;
• contact the user;
• prepare a quotation;
• arrange an appointment;
• provide the requested service or assistance.

The provision of any additional, non-mandatory information is optional.

The provision of personal data and consent for promotional and marketing purposes, where required, is optional. Failure to provide such consent shall have no effect on the user’s ability to use E-Repair’s other services.

7. Methods of Processing

Personal data are processed using:

• IT systems;
• electronic tools;
• telematic systems;
• business management systems;
• email;
• paper documentation, where necessary.

Processing is carried out in compliance with the principles established by the GDPR, including:

• lawfulness;
• fairness;
• transparency;
• data minimisation;
• accuracy;
• purpose limitation;
• storage limitation;
• integrity;
• confidentiality.

E-Repair implements technical and organisational measures appropriate to the nature of the personal data processed and the risks associated with the processing.

Such measures are designed to protect personal data against unauthorised access, loss, destruction, alteration, unauthorised disclosure or other unlawful processing.

8. Recipients of Personal Data

Personal data may be processed, to the extent strictly necessary for the purposes set out above, by:

• E-Repair personnel authorised to process personal data;
• collaborators;
• consultants;
• IT and technology service providers;
• software providers;
• cloud service providers;
• hosting and technology infrastructure providers;
• email service providers;
• administrative, tax and accounting advisers;
• legal professionals and advisers;
• parties responsible for system maintenance and security;
• parties involved in the provision of the requested products and services;
• public Authorities;
• entities and parties to whom disclosure of personal data is required by law.

Where such parties process personal data on behalf of E-Repair, they shall, where required, be appointed as Data Processors pursuant to Article 28 GDPR.

Other parties may act as independent Data Controllers on the basis of their respective responsibilities and activities.

Personal data shall not be disclosed to the public indiscriminately.

9. Transfers of Personal Data Outside the European Economic Area

Certain technology services used by E-Repair may involve the processing or transfer of personal data to countries located outside the European Economic Area (EEA).

In such cases, E-Repair ensures that any transfer is carried out in compliance with Articles 44 et seq. of the GDPR.

Depending on the circumstances, transfers may be based on:

• an adequacy decision adopted by the European Commission pursuant to Article 45 GDPR;
• appropriate safeguards pursuant to Article 46 GDPR;
• Standard Contractual Clauses approved by the European Commission;
• other safeguards permitted by applicable legislation;
• specific derogations under Article 49 GDPR, only where the relevant requirements are met.

Data Subjects may request further information concerning international transfers and any safeguards adopted by contacting E-Repair at:

amministrazione@e-repair.it

10. Data Retention Periods

Personal data are retained for no longer than is necessary to achieve the purposes for which they were collected, in accordance with the principle of storage limitation.

In particular:

• data relating to contact requests are retained for the time required to process the request and any subsequent communications;
• data relating to quotations and pre-contractual relationships are retained for the period necessary to manage negotiations and any subsequent requirements relating to the relationship;
• data relating to contractual relationships are retained for the duration of the relationship and subsequently for the period required under civil, administrative, tax and accounting legislation;
• administrative, accounting and tax documentation is generally retained for 10 years, without prejudice to any different periods required by law;
• data necessary to protect E-Repair’s rights may be retained until the relevant limitation periods have expired or until any dispute has been finally resolved;
• data processed on the basis of consent for marketing and promotional communications are generally retained for a maximum period of 24 months, unless consent is withdrawn earlier, the Data Subject exercises the right to object or a different retention period is appropriately justified;
• technical and security data are retained only for the period strictly necessary for the purposes for which they were collected, in accordance with the principles of proportionality and data minimisation.

Withdrawal of consent or objection to marketing shall result in the discontinuation of the relevant communications.

E-Repair may retain only the minimum information necessary to document the objection request and prevent further unwanted communications.

Once the applicable retention periods have expired, personal data shall be deleted, anonymised or otherwise made unavailable for further use, unless their continued retention is required by law or necessary to protect the Data Controller’s rights.

11. Cookies and Tracking Technologies

The www.e-repair.com website may use cookies and similar technologies.

Depending on their characteristics and purposes, the following may be used:

• technical and strictly necessary cookies;
• functional cookies;
• analytics cookies;
• profiling or marketing cookies;
• third-party cookies and tracking technologies.

Strictly necessary technical cookies may be used without the user’s consent where permitted by applicable legislation.

Where the use of cookies or other tracking technologies requires consent, users must be able to make a choice that is:

• freely given;
• specific;
• informed;
• unambiguous;
• capable of being documented.

Users must also be able to refuse or withdraw consent through simple procedures.

Merely scrolling through a page or continuing to browse does not, in itself, constitute valid consent.

Cookie preferences may be managed through the consent management system available on the website.

For information concerning:

• the cookies actually used;
• their purposes;
• their duration;
• the third parties involved;
• how consent can be managed and withdrawn,

users are invited to consult the Cookie Policy available on the website.

12. Rights of the Data Subject

Pursuant to Articles 15-22 GDPR, Data Subjects may exercise, where applicable, the following rights:

1. obtain confirmation as to whether or not personal data concerning them are being processed;
2. obtain access to their personal data;
3. obtain rectification of inaccurate personal data;
4. obtain completion of incomplete personal data;
5. obtain erasure of personal data in the circumstances provided for under Article 17 GDPR;
6. obtain restriction of processing in the circumstances provided for under Article 18 GDPR;
7. receive their personal data in a structured, commonly used and machine-readable format in the circumstances provided for under Article 20 GDPR;
8. request, where applicable, the transmission of their data to another Data Controller;
9. object to processing in the circumstances provided for under Article 21 GDPR;
10. withdraw previously given consent at any time;
11. not be subject, in the circumstances provided for under Article 22 GDPR, to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.

Withdrawal of consent shall not affect the lawfulness of processing carried out before consent was withdrawn.

13. How to Exercise Data Subject Rights

To exercise their rights or request information concerning the processing of personal data, Data Subjects may contact:

E-Repair S.r.l.
Via degli Arrotini, 19
57121 Livorno (LI) – Italy

Email: amministrazione@e-repair.it

The request should preferably include:

• first name and surname;
• contact details for receiving a response;
• the right the Data Subject wishes to exercise;
• any information necessary to identify the relevant personal data or processing activity.

E-Repair shall respond without undue delay and, as a general rule, within one month of receiving the request, in accordance with the terms and procedures set out in Article 12 GDPR.

Where requests are particularly complex, the response period may be extended within the limits permitted by the GDPR, and the Data Subject shall be informed accordingly.

Where E-Repair has reasonable doubts concerning the identity of the person submitting the request, it may request only such additional information as is necessary to verify that person’s identity.

14. Right to Lodge a Complaint

A Data Subject who believes that their personal data are being processed in breach of applicable data protection legislation has the right to lodge a complaint with the competent Supervisory Authority pursuant to Article 77 GDPR.

In Italy, the competent Supervisory Authority is:

Garante per la protezione dei dati personali
(Italian Data Protection Authority)

This is without prejudice to any other administrative or judicial remedy available under applicable law.

15. Data Security

E-Repair implements appropriate technical and organisational measures designed to protect personal data against:

• unauthorised access;
• accidental loss;
• destruction;
• alteration;
• unauthorised disclosure;
• unlawful processing;
• use inconsistent with the purposes for which the data were collected.

Security measures are assessed and updated taking into account:

• technological developments;
• the nature of the personal data processed;
• the methods of processing;
• the risks to the rights and freedoms of Data Subjects.

Access to personal data is restricted to individuals who require such access for the performance of their duties and who are duly authorised or otherwise lawfully entitled to process such data.

16. Links to External Websites

The E-Repair website may contain links to websites, platforms and services operated by third parties.

E-Repair does not control the manner in which such third parties process users’ personal data and is not responsible for processing activities carried out independently by external websites or services.

When users access an external website through a link available on www.e-repair.com, they are encouraged to review the relevant privacy policy of that website or service.

17. Processing through Online Forms

Personal data entered in the forms available on the website are used for purposes related to the specific request submitted by the user.

The forms may include, by way of example:

• requests for information;
• requests for consultancy;
• requests concerning products and services;
• requests for assistance;
• requests for technical support;
• requests for telephone appointments;
• call-back requests.

Any additional processing shall be carried out only where an appropriate legal basis applies and, where required, after obtaining the Data Subject’s consent.

Users are requested to provide accurate and up-to-date information and not to provide personal data relating to third parties unless they have a valid legal basis for doing so.

18. Minors

The website and services offered by E-Repair are primarily intended for businesses and professionals and are not specifically directed at minors.

E-Repair does not knowingly intend to collect personal data relating to minors through the forms available on the website.

If a parent or person exercising parental responsibility believes that a minor has provided personal data to E-Repair without the necessary legal conditions being met, they may contact the Company at:

amministrazione@e-repair.it

19. Changes to this Privacy Policy

E-Repair may amend or update this Privacy Policy in order to reflect:

• changes in applicable legislation;
• guidance issued by competent Authorities;
• technological developments;
• changes made to the website;
• the introduction of new services;
• changes in the manner in which personal data are processed.

The updated version of the Privacy Policy shall be published on the website together with the date of the latest update.

Where significant changes affect the processing activities carried out, E-Repair shall adopt appropriate measures to inform Data Subjects, taking into account the nature of the changes.

20. Company Information and Contact Details

E-Repair S.r.l.
Via degli Arrotini, 19
57121 Livorno (LI) – Italy

VAT No.: 01642720492
Livorno Companies Register: LI 145181

Website: www.e-repair.com
Sales email: commerciale@e-repair.it
ESG email: esg@e-repair.it
Email for privacy matters and the exercise of Data Subject rights: amministrazione@e-repair.it

Last updated: 18 September 2026