PRIVACY DECLARATION AND STATEMENT

This document was drawn up in Italian. If there is a conflict between any of the translated versions of this document and the Italian version, the latter shall take precedence. Date of the last revision: 20 September 2011 (version 0.2)

Company Information

The SAFETY QR CODE service is owned and is provided by:

hereinafter referred to as SUPPLIERS.

Declaration of Rights and Responsibilities

Use of the SAFETY QR CODE service implies acceptance of this document.

1. Privacy
   • The SAFETY QR CODE service can be very useful and also help to protect the health of those that use it. To this end users can supply, through this service, personal data, including sensitive data, on their health. We therefore invite users to read the Privacy Policy and use it to make informed decisions.
     1. Sharing Contents and Information
     • The user is the owner of all the data registered on SAFETY QR CODE. It is aware and accepts that his/her data, registered on SAFETY QR CODE, may be freely accessed by anyone who accesses them using the QR code with which they are associated.
   • Furthermore:
     2. Any data protected by property rights (e.g. poems) registered on SAFETY QR CODE shall not oblige the SUPPLIERS to pay any royalties or any fees whatsoever.
     3. Data deleted by SAFETY QR CODE may be kept as backup copies for a certain period of time, without however being able to be accessed by other users (as is the case with data that are registered but not deleted).
     4. All suggestions from users relating to the SAFETY QR CODE service are welcome, but shall not entitle the user to receive any payment should the SUPPLIERS decide to use and put the suggestion into practice.

2. Safety
   • The SUPPLIERS make every effort to make the SAFETY QR CODE service safe and reliable, but they cannot guarantee that this will be the case, including, but not only, because of the oral nature of the data provided by the users in any language. In any event, the users, in order not to radically change the purpose of the SAFETY QR CODE service, undertake:
     1. Not to record data that are intentionally incorrect or which could mislead third parties.
     2. Not to record data that are offensive to third parties.
     3. Not to record data with the aim of hurting third parties.
     4. Not to load viruses or other harmful codes.
     5. Not to record content that is illegal or at any rate threatening or which encourages discrimination, hate or violence.
     6. Not to record data suitable for adults only.
     7. Not to undertake actions that could hinder, overload or jeopardise the proper functioning of the SAFETY QR CODE.
     8. Not to support or encourage any breach of this Declaration.

3. Account Registration and Security
   • Users of SAFETY QR CODE undertake to supply their own name and own true data. Therefore, each user undertakes:
     1. Not to provide false personal information or create an account on behalf of someone else without the authorisation of the latter or of the person exercising parental authority.
     2. Not to use his/her own personal profile to obtain commercial profit.
     3. Not to use SAFETY QR CODE if aged under 14.
     4. To ensure that his/her data are always correct and up-to-date.
     5. To provide a correct valid and active email address, ensuring that it remains as such and checking any messages from SUPPLIERS.
     6. Not to share his/her password (or, in the event of developers, the secret key) or allow others to access his/her account or undertake any action that could put the security of his/her account at risk.
     7. Not to transfer his/her account to third parties.
     8. If the user chooses a user name for his/her account, the SUPPLIERS reserve the right to remove it or lay claim to it as deemed appropriate (for example, if the owner of a trademark complains about the fact that a user name is not directly connected with the user's real name).

4. Mobile Services
   1. To use the SAFETY QR CODE service the user shall pay the cost of the connection based on his/her tariff plan.

5. Changes
   1. The SUPPLIERS reserve the right to change this Declaration after providing notification of the same (the change shall be published on the website www.safetyqrcode.com)

6. Cancellation
   • If the user's actions violate this Declaration in form and in substance or create legal risks for the SUPPLIERS or for the parties which through the SUPPLIERS participate in the SAFETY QR CODE service, the SUPPLIERS are entitled to suspend supply of all or part of the SAFETY QR CODE services to the user. In this case the user will be notified by an email at the address provided by the latter when the account was created or subsequently changed, which must be kept up-to-date and active at the responsibility of the user. The SUPPLIERS reserve the right to also notify the user in other manners (telephone, certified email, letter, etc.) The user may delete his/her account or deactivate his/her application at any time.

7. Disputes
   1. For any dispute between the user and the SUPPLIERS the competent court of jurisdiction shall be the court of Lecco (Italy), with the exclusion of any other court. This Declaration, as well as any disputes that may arise between the parties, are governed by Italian law, regardless of possible conflicts in the provisions of law.
   2. In the event of claims against the SUPPLIERS relating to actions, contents or information of the user linked to the SAFETY QR CODE service, the user will be required to hold the SUPPLIERS harmless from any damage, loss or expenses (including reasonable legal costs and expenses) deriving from said claim.
   3. The SUPPLIERS shall take the utmost care in keeping the SAFETY QR CODE service active and error-free, but the user accepts to use it at his/her own risk and danger. The service is provided as it is, without any express or implicit guarantee, such as, for example, its suitability for a specific use. The SUPPLIERS do not guarantee the safety of the SAFETY QR CODE service and are not responsible for the actions, contents, information or data of third parties, so that the SUPPLIERS, their managers, workers, employees or agents are relieved of any claims or liabilities for compensation (not only for actual damage but also for loss of earnings, in addition to consequential, accidental or indirect damage) which are linked to using the SAFETY QR CODE.
   4. If the law does not permit restrictions or exclusions to the liabilities or damages referred to above, the liability of the SUPPLIERS shall be limited to the minimum permitted by the applicable law.

8. Other
   1. This Declaration provides the user with information on the processing of confidential data and, at the same time, constitutes the contract between the user and SUPPLIERS relating to the SAFETY QR CODE service, taking precedence over any other previous agreement.
   2. If part of this Declaration proves to be infeasible, the remaining part shall remain valid and continue to have effect.
   3. The impossibility to enforce any part of this Declaration shall not constitute in any way waiver of the same.
   4. Any change or waiver to this Declaration must be made in writing and signed by the SUPPLIERS.
   5. The user may not transfer any of his/her rights or obligations stated in this Declaration without the consent of the SUPPLIERS.
   6. All rights and obligations relating to this Declaration may be assigned freely by the SUPPLIERS in the event of a merger, acquisition or sale of assets or through a legal operation or other transaction.
   7. This Declaration does not grant third parties any beneficial right.
   8. The user undertakes to respect all the applicable laws each time he/she uses the SAFETY QR CODE.

STATEMENT FOR THE PROCESSING OF PERSONAL DATA PURSUANT TO ART. 13 OF ITALIAN LEGISLATIVE DECREE 196/2003 "CONSOLIDATED ACT ON PRIVACY PROTECTION"

Dear Sir/Madam,

In accordance with Italian Legislative Decree 196/2003 on the protection of persons and other parties relating to the processing of personal data, your information shall be processed in accordance with the principles of correctness, lawfulness and transparency, protecting your privacy and your rights.

In particular, data that could reveal racial or ethnic origins, religious or philosophical beliefs or other types of convictions, political opinions, support for parties, trade unions, religious, philosophical, political or trade-union organisations or associations, as well as personal data that could reveal information on people's health or sex lives may be processed only with the written consent of the interested party and after obtaining authorisation from the Italian Personal Data Protection Watchdog (Article 26).

Pursuant to Article 13 of said decree, we hereby provide you with the following information.

1. Sensitive data provided by you will be processed for the following purposes: The SUPPLIERS shall use the information received in relation to the services and functions offered to you and to other users, maintaining it accessible via the SAFETY QR CODE service in order to allow anyone access via the QR code inherent to the type of service in question. You are therefore responsible for obtaining the informed consent of the third parties whose data you provide to the SAFETY QR CODE service (e.g. telephone numbers, emails or addresses of the parties to be contacted on your behalf).

You will at any rate always be the owner of the information provided to the SUPPLIERS or to the SAFETY QR CODE service. For this reason the SUPPLIERS do not share the information received from you with others, unless:

• They have been authorised by you to do so
• They have informed you that they would do so, for example, in the website rules.

2. The data will be processed as follows: computerised with IT or computerised system support carried out by specifically appointed parties.

3. The data are provided for the following purposes:
- Updating of the users' register;
- Fulfilment of all legal obligations relating to tax and accounting rules and for the administrative management of the relationship;
- Handling of administrative and commercial correspondence;
- Management of any disputes or legal and judicial consequences of the relationship;
- Gathering of the information necessary or useful for assessing any risks linked to the relationship.

4. Data relating to the account must be provided to allow the SAFETY QR CODE service to be supplied and any refusal to provide said data shall result in the SUPPLIERS being unable to provide the service.

5. The data will not be communicated to other parties nor will they be disclosed unless deemed necessary or provided for by law. The data may be stored even after the end of the contractual relationship for the fulfilment of all the obligations related to or deriving from the conclusion of the contractual relationship.

6. If you provide the SAFETY QR CODE service with data on your health (so-called sensitive data), you declare that you are aware and authorise that anyone may access them via said service (using access via the QR code). Indeed, data provided by you via the voice recording may be used by anyone, with no restrictions whatsoever. This may be useful in the event of an emergency and this is the reason why you must take the utmost care in providing data that are truthful, safe, up-to-date, clearly understandable and clearly traceable to you, fully aware that you will be solely liable for anything that may happen to you or others as a result of said data being used.

7. The data controller is: the SUPPLIERS

8. The data processor is the pro-tem Head of Information Systems (domiciled for this purpose at the office of the SUPPLIERS), who you can contact for all information relating to the processing of your data and for everything provided for by Art. 7, D.

9. You may exercise your rights against the data controller at any time in accordance with Article 7 of Italian Legislative Decree 196/2003, which for your convenience we have reproduced in its entirety below:

Italian Legislative Decree 196/2003
Art. 7 - Right of access to personal data and other rights

1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form.
2. A data subject shall have the right to be informed:

1. Of the source of the personal data;
2. Of the purposes and methods of the processing;
3. Of the logic applied to the processing, if the latter is carried out with the help of electronic means;
4. Of the identification data concerning data controller, data processors and the representative designated as per Section 5(2);
5. Of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing.

3. A data subject shall have the right to obtain:

1. Updating, rectification or, where interested therein, integration of the data;
2. Erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
3. Certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.

4. A data subject shall have the right to object, in whole or in part:

1. On legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
2. To the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.