The following Privacy Policy – according to article 13 of General European Regulation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as “GDPR”) aims to describe how the personal data of web site users are processed and to inform the data subject about cookies. UPDATE AT NOVEMBER 2020

The following Privacy Policy (the “Policy”) – according to article 13 of General European Regulation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (hereinafter referred to as “GDPR”) aims at describing how the personal data of web site users are processed and collected by browsing or using the website www.nhoa.energy (the “Website”).

For sake of clarity, this Policy does not cover the data processing underlying the job application(s) that you submit in the “Careers” section of the Website. For more information in this regard, please see the Applicant Privacy Policy.

Please read this Policy carefully before using this Website because it explains how we will process personal data (the “Data”).

NHOA Corporate S.r.l. (hereinafter “NHOA” or the “Company”, “we”) subject to the direction and coordination of NHOA S.A., registered office at Milan, Piazzale Lodi, 3 – 20137 is Data Controller of the user Data gathered during the browsing activity on the Website and the provision of our services.  As for the information collected through the cookies, please refer to our Cookie Policy on www.nhoa.energy/privacy

1. INFORMATION ABOUT THE PROCESSING OF PERSONAL DATA

Your Data will be processed as follows:

Purposes	Data / Data Categories (mandatory data is marked with an *)	Legal basis and consequences of failure to provide data
A) Deal with your enquiries and requests (e.g. if you were to contact us to ask for more information about our Company, we would need to process your contact details	Name*, surname*, email address*	If you make your request / enquire in the context of potentially entering into a contract with us, this data processing is necessary in order to take steps at your request / enquire prior to entering into a contract. The failure to process your data (or at least your e-mail) will not let us answer you. In other circumstances, this data processing is based on our legitimate interests in responding to your enquiries and requests.
B) Send you our newsletter	Name*, surname*, email address*, phone*	This data processing will take place only with your prior consent.
C) Website maintenance and troubleshooting	Browsing data like e.g. IP address, location – country, information on pages you visited within the Website, access time on the Website, navigation time on each page, clickstream analysis	This data processing is based on our legitimate interests for the maintenance of the Website and when you report a problem with our Website
D) Processing in the context of any corporate events (sale of the Company or going concerns), due diligence exercises	Data included in Company’s database collected from the Website	This data processing is based on our legitimate interests in managing possible corporate events/td>
E) Defend of our rights and interests and litigation management	Data which may be relevant to defend our rights and interests related to the Website (e.g. address, location – country, information on pages you visited within the Website, access time on the Website, navigation time on each page, clickstream analysis)	This data processing is based on our legitimate interest in defending its rights, interests, assets related to the Website and managing possible disputes, also potentially and whether inside or outside a court.

The Data may be processed in hardcopy, by automated or electronic means.

2. HOW WE PROCESS PERSONAL DATA

The data processing carries out with information system and organizational and logical methods strictly related to indicated purposes and the Company implemented all technical and organizational security measures to ensure the confidentiality, integrity, availability and resilience of data processing, in compliance with the article 32 of GDPR.

3. DATA RETENTION

Your Data will be stored in compliance with the applicable laws, for a period of time not exceeding what is necessary to achieve the purposes for which they are processed. The criteria for determining the data retention period take into account the lawful processing period and applicable laws (for example, tax or anti-money laundering laws), the statute of limitation periods and the nature of legitimate interests where they are the legal basis of the processing.

Your Data may be stored for a longer period than the one originally planned, in the event of any disputes or requests by the relevant authorities.

The Data processed to provide the newsletter service as described above will be stored until you withdraw your consent.

Provided that your Data are only held for as long as necessary, they will be cancelled, aggregated or anonymized in a secure manner once they are no longer needed.

4. COMMUNICATION OF PERSONAL DATA

The Data will be disclosed to the persons authorized for the processing within the Company’s staff.

The Data may be disclosed by the Company solely and exclusively for the purposes indicated and where necessary, to the following categories of subjects:

where required, the competent judicial authorities
where required, public administrations and supervisory and control authorities
service suppliers (e.g. legal consultants, marketing consultants)
information technology suppliers (e.g. cloud and software suppliers).

Your Data will not be publicly disclosed.

Entities belonging to the categories listed above, may act, as the case may be, as data processors (and in this case they will receive appropriate instructions from the Company) or as autonomous data controllers.

5. DATA TRANSFER OUTSIDE OF THE EEA

If this is instrumental to the pursuit of the purposes set out above, your Data may also be transferred abroad to companies located both within and outside the European Economic Area (EEA). Some of these jurisdictions may not guarantee the same level of data protection guaranteed by the European laws. In this case, the Company undertakes to ensure that the data is processed with the utmost confidentiality, stipulating, if necessary, agreements that guarantee an adequate level of protection and / or adopting the standard contractual clauses provided by the European Commission.

6. DATA SUBJECTS RIGHTS

At any time you will be entitled to exercise the following rights and therefore:

obtain confirmation as to whether your Data are being processed, and, where that is the case, access to the Data, under Article 15 of GDPR (Right of access);

obtain the rectification of inaccurate Data concerning you or, taking into account the purpose of the processing, the integration of incomplete Data (Right to rectification);

obtain the erasure of your Data where one of the grounds under Article 17 of GDPR applies (Right to be forgotten);

obtain the restriction of processing your Data, when one or more of the cases under Article 18 of GDPR applies (Right to restriction);

object to the processing of your Data on grounds relating to your particular position, where applicable, under Article 21 of GDPR (Right to object);

receive your Data in a structured, commonly used and machine-readable format as well as to transmit those data to another controller in the cases and within the limits referred to in Article 20 of GDPR, where applicable (Right to data portability)

Moreover, where provided, you have the right to withdraw your consent to process your Data, at any time, without prejudice to the lawfulness of the processing based on the consent given before the withdrawal.

According with the GDPR, the Company may not charge for complying with any of the requests mentioned in this paragraph, unless they are clearly unfounded or excessive and repetitive.
Should you request more than one copy of your Data or in cases of excessive or unfounded requests, the Company may: (i) charge a reasonable expense, considering the administrative costs incurred to fulfil the request; or (ii) refuse to fulfil the request. In these cases the Company will inform you of the costs before fulfilling the request.

The Company may ask for further information before fulfilling the requests if it needs to verify the identity of the person who has made them.

To exercise your rights, you can send an email with the following subject “PRIVACY”, to privacy@nhoa.energy. Remember that you can also use the unsubcribe link included in our marketing emails.

Without prejudice to any administrative or legal remedy, you also have the right to lodge a complaint to the relevant supervisory Authority, if you believe that processing of your Data is in breach of the GDPR. More information is available on the website https://www.garanteprivacy.it/.

In any case, the Company is interested in knowing the reasons for the complaint and requests that you use the above contact methods before turning to the authorities, in order to prevent and resolve any disputes, amicably and promptly.

7. LINKS TO THIRD PARTY WEBSITES

Third party websites accessible from this Website are under the third party responsibility. Company declines all responsibility concerning requests and/or provision of Data to third party websites. The Company does not control any data processing underlying such websites.

This Website can also contain iFrames with content of third parties. Company is not responsible for third-party content presented in iFrames. The information presented therein is the sole responsibility of those website owners.

Company has no control or responsibility for the content of independent websites and provides this external content to its visitors for their convenience. As a result, when you visit a page containing such content, you may be presented with cookies from these third party websites.

Company does not control the distribution of these cookies.

Please check the third party’s cookies policy and privacy policy for more information.

8. LINKS TO SOCIAL NETWORKS

Our website includes links to social networks.

In order to protect your Data while visiting our Website we do not use social plugins. Instead HTML-links are embedded onto the Website, enabling easy sharing onto social media platforms. Embedding the link prevents a direct connection with various social media network servers when opening a page from our Website. When clicking on one of the buttons, a browser window opens and directs the user to the respective service provider website on which (after having logged in) for example, the “Like” or “Share” button can be used.

For more information on the purpose and scope of data processing and further use of your Data by the provider and their websites as well as your rights and possible settings to protect your privacy, please refer to the data protection information of the respective service provider.

9. AMENDMENTS

The Company reserves the right to partly or fully amend the Privacy Policy, or simply to update its content (e.g. as a result of changes in applicable law). We will publish any update on this Website. You should therefore periodically review these for changes to our Privacy Policy.

10. CONTACTING US

NHOA Corporate S.r.l., Milan, Piazzale Lodi, 3 – 20137, Italy.

You can contact the Company writing to the following email address privacy@nhoa.energy.

UPDATED ON DECEMBER 2023

In accordance with the law, we invite you to read these conditions of use (hereinafter the “Conditions”) as well as any specific condition appearing on the pages of the Site, governing your use of the Site. These Conditions relate to your legal rights and responsibilities applicable when you browse the Site.
The Site is made available to you free of charge (excluding connection fees to the Site) for your personal use, subject to compliance with the Conditions defined below.
By accessing or using the Site, you acknowledge that you have read, that you understand and that you agree to be bound by these Conditions, as well as that you agree to comply with all of the laws and regulations applicable. If you do not accept these Conditions, please do not use this Site.
You agree to access the information on the Site only for personal, non-commercial use. You can only use the Site for a legitimate purpose; no use or diversion is authorized, in particular for purposes contrary to public order and morality.
NHOA reserves the right, at its sole discretion, to modify any element of the Site at any time. As part of its policy of updating and optimizing the Site, NHOA may decide to modify the content of these Conditions. We therefore invite you to consult them very regularly.

As a user of the Site, you acknowledge that you have the skills and means required to access and use it. NHOA and its contributors make every effort to ensure that the information displayed on the Site is accurate and up to date, by reserving the right to modify the content at any time without notice. However, they cannot guarantee that this information is complete, or that it will not be modified by a third party (hacking, virus). NHOA and its contributors also decline any responsibility (direct or indirect) in the event of delay, error or omission with regard to the content and use of these pages, as well as in the event of interruption or of unavailability of the service. You acknowledge that you have been informed that the Site is accessible 24 hours a day, 7 days a week, except in cases of force majeure, computer difficulties, difficulties related to the structure of telecommunications networks or other technical difficulties. For maintenance reasons, NHOA may interrupt the Site. NHOA will endeavor to notify users in advance. NHOA is not responsible for delays, difficulty of use, or incompatibility between this Site and files, your browser or any other program for accessing the Site. NHOA cannot in any case be held responsible for any direct or indirect damage resulting from or consecutive to the dissemination by a third person of a virus via the Site and likely to infect your computer system following your connection to the Site, to the use of the Site or to navigation on the Site. Likewise NHOA cannot be held liable for any material or incidental damage (including, but not limited to, technical failure, disclosure of confidential documents, loss of data), or for any other indirect damage whatsoever occurring during or related to the use of the Site. NHOA strives to ensure to the best of its ability the accuracy and updating of the information published on the Site, the content of which it reserves the right to correct at any time and without prior notice.
However, NHOA and its contributors do not give any guarantee or assume any responsibility, in any case, as for the adequacy, the sequence, the accuracy, the absence of errors, the veracity, the news, the loyal and commercial character, the quality, the merits, and the availability of the information contained on the Site. Each internet user fully assumes the risks linked to the credit they grant to this information. Erroneous information or omissions may be noted due in particular to typographical or layout errors. If you find any errors, you are invited to report them to us so that the appropriate corrections can be made. The elements of the Site are provided “as is” without any warranty of any kind, implicit or explicit. Any dated information that is published on the Site only applies to the date specified only. It is also recalled that the secrecy of correspondence is not guaranteed on the network and that it is up to each Internet user to take all appropriate measures in order to protect their own data and / or software from contamination from possible viruses circulating on the Internet.

The hypertext links set up towards other applications or websites cannot engage the responsibility of NHOA, in particular with regard to the content of these sites and applications. NHOA is not responsible for the hypertext links which lead to the Site.

The absence of exercise by NHOA or you (hereinafter “the Parties”) of a right or legal action under these Conditions cannot be considered as a waiver of such a right or to such an action. The Site is governed by Italian law. These Conditions will be governed by Italian law and interpreted in accordance with Italian law. In the event of a dispute, the Parties must, before any referral, find an amicable solution. In the absence of an amicable solution, the courts competent to hear the dispute will be the Italian courts materially and territorially competent. If, for any reason whatsoever, a competent court considers that a provision of these Conditions is invalid, the invalidity of this provision will in no way affect the validity of the rest of the Conditions, which will remain in force.

The cookies are small text strings send by web server to the user browser, where the cookie is automatically stored and re-send automatically to the server, each time that the same website is visited again.
The cookies can be first-party cookies, which are provided by NHOA, or third-parties cookies. The cookies are able to allow to recognize the user device and browse the web, pointing out the user preferences and improving the user experience. The cookies aim to send customized advertising to the user.

Technical cookies are strictly necessary to service provisioning and they are automatically setup after the website is visited:

• Cookies allow to browse the web in the right way. In example, the user can stay connected, avoiding that the web site connects several times for accessing the next pages;
• Cookies allow to point out the user preferences during the browsing, in example, they allow to set the language;
• Cookies help to understand, through anonymous and aggregate data gathered, how the user browse the web site, providing information about visited sections, time spent on the web site or any malfunctions.

Analytical cookies are used to collect information about website usage. The website will use this information about statistical analysis in order to improve the usage website and make the content website more interesting and relevant. This type of cookie gathers information about user activities and how he arrived on the website which are pseudonymized.

Third party cookies are used in order to gather aggregated information about usage website by the user, such as Pages visited, time spent, traffic source, geographical location, age, gender andinterest.

This typology of cookie incorporates features developed by third parties within the pages of the site, such as icons or preferences expressed on social network in order to share web site content or to use third party software services (i.e. map generating software and software offering other services). These cookies are sent by third party domains and partner sites that offer their functionality within the page of the site.

This typology of cookie incorporates features developed by third parties within the pages of the site, such as icons or preferences expressed on social network in order to share web site content or to use third party software services (i.e. map generating software and software offering other services). These cookies are sent by third party domains and partner sites that offer their functionality within the page of the site.

Profiling cookies are useful to create user profile in order to send him customized advertising message to user needs showed by the user using the web site.

Technical cookies used in this website are strictly necessary to perform the web site. The cookies are the following:

• nhoa_i18n_redirected – Needed to guarantee the website performances
• vuid, drift_aid, __pdst, _abexps, driftt_aid – Used to embed videos inside the webside

This web site uses first- and third-party cookies, also profiling. These are the following:

• Google.com – https://policies.google.com/privacy
• Vimeo.com – https://vimeo.com/cookie_policy

Generally, it is possible to stop all cookies, but this is could have an impact on web site usage. All new browser allows to modify the cookie setting, that you can find in the “preference” or “option” section of the menu of your browser. To understand how to set them up, please refer to the following links:

Your preferences with regard to cookies will have to be reset if different devices or browsers are used to access the Website.

You are able to select/deselect in advance through the cookie banner which cookies you want to authorize the first time you access the Website, or keep only the cookies strictly necessary for the functioning of the Website or accept all the cookies.
Moreover, you can withdraw your consent (when you have provided it) or review the settings at any time by accessing the “View preferences” button and the “Manage consent” section included in the consent management system: to this purpose, you can click at any time also on the button at the bottom right of any page of the Website.