Dear User,

below we provide you with information regarding the processing of your personal data that may provided by you to Manuli Ryco S.p.A. through the website www.manuliryco.com.

Data Controller details

The Data Controller is Manuli Ryco S.p.A. (hereinafter “MR” or “Data Controller”), with  registered office at Via Pietro Paleocapa, 7 – 20121 Milan, Italy, part of Manuli Ryco group, who can be contacted at the e-mail address .

Introduction

We are committed, as Data Controller, to safeguarding the privacy of our website visitors and services users when we determinate the purpose and methods of processing their personal data, which will be processed, in accordance with the applicable law and the principles of fairness, loyalty and transparency.

Type of data processed

Below are the general categories of data that we may process:

1. Browsing data

If you access our website and online store, we inform you that we may process your data related to the use of our website and services to understand how users interact with our website so that we can improve our services.

In this case, the personal data that may be collected and processed include IP address, geographic position, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about when, how often and how you use the service.

The source of the usage data is our analytical tracking system. Those usage data may be processed for the analysis of website and service usage.

The legal basis of this processing is our legitimate interest to provide a secure website and to improve of our website and services.

2. Service-related data

We may process your personal data in order to fulfil requests, answer questions and handle reports you have submitted via the “Annual Report”, “Sustainability Report” and “Contact Us” sections of the website or through e-mail to the addresses indicated on this website.

In this case, the personal data that may be collected and processed are the user’s first name, last name, company, address and e-mail as well as any other personal data requested by the form or entered in the message.

The legal basis for this processing is our legitimate interest in responding to requests or questions raised through the various contact channel. This processing of your personal data is also beneficial to you insofar as it enables us to properly assist you and answer the questions you have asked.

The provision of this data is optional; failure to provide it will not allow the Data Controller to follow up on requests for information and/or provide the requested service.

3. Recruiting data

The processing of your data contained in your curriculum vitae, sent through the “Careers” section of the website (which involves the acquisition of you following data: first name, last name, address, phone number and e-mail as well as any other personal data requested by the form, entered in the message and contained in the resume) is aimed exclusively at evaluating the profile of candidates and selecting them. Those data may be disclosed to other company of the group but they will not be disclosed to third parties. In the event of a negative selection outcome, the data will be deleted according to the retention policies specified below. Any sensitive data included in resumes (relating, in particular, to racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, association s or organizations of a religious, philosophical, political or trade union nature, as well as personal data suitable for revealing the state of health and sex life) will be immediately deleted in the absence of a written declaration of consent to their processing by the Data Controller.

The legal basis of this processing is our legitimate interest namely the identification and selection of workforce.

The provision of data is optional; failure to provide it will not allow the Data Controller to follow up on requests for information and/or the selection process.

4. Account data for access to the restricted area

If you decide to become a registered user of our website we may process your account data in order to manage your registration and to be able to identify you as a user of the website and online store and authorise you to access the various features, products and services available to you as a registered user.

In this case, the personal data that may be collected and processed include the user’s first name, last name and cell phone, company to which the user belongs, job title, country and e-mail address.

For you identification on our website restricted area, several methods may be available that require a process to verify the ownership of the contact data used.

The legal basis of this processing is our legitimate interest to link you account, your purchase and the data collected through the website about your activity. Also, our legitimate interest in verifying access to the documentation published in the restricted area.

5. Online store and fulfilment of the purchase or service agreement concluded with us through the website

If you decide to purchase products through our online shop, we may process your account information to process and prepare your order, to contact you regarding updates or informational communications related to the features, products, or services you have contracted with us and changes to the Terms and Conditions. This data may also be used for quality surveys to determine customer satisfaction with the products and services provided.

Your data may also be used to process payment for products purchased (if, when purchasing one of our products through the Website, you decide to activate the function that allows you to save your payment details and shipping address for future purchases [where such function is available], we need to process the data indicated for the activation and provision of such function), for billing purposes and to provide you with receipts and invoices for purchases made through the website.

Your data may also be used to activate mechanisms necessary to prevent and detect unauthorised use of the website and potential fraud committed against you and the Data Controller.

The legal basis of this processing is the fulfilment of the sales or services agreement concluded with you, the fulfilmente of legal obligations and our legitimate interests (for example the recovery of any debts).

6. Marketing data

If and when you subscrive to our newsletter and if you provide consent to profiling and marketing activities, we will process your personal data to manage your subscription and to send you personalised information about our products or services.

The legal basis of this processing is your consent.

Such consent is optional and failure to give it will not prevent the provision of the service you have requested from us, but only the possibility that the Data Controller will send you material and/or informative/advertising communications deemed of interest.

Your consent can be withdrawn at anytime by contacting the Data Controller at the following address: .

Methods of process

The processing of your personal data may be carried out both by automated and non-automated means, by means of the following operations: collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, deletion and destruction of data. The processing is carried out in compliance with the rules of security and confidentiality provided by law. The processing is carried out exclusively by the Data Controller, external data processors in charge of providing the services requested from the user and by the persons in charge of the processing.

Recipients of personal data

The data collected for the purposes indicated above may be communicated to our personnel authorized to access and process your data on the basis of the actual need to access.

Your data may also be communicate to the companies of the Manuli Ryco group that carry out functions strictly connected and instrumental to the operation of the individual services requested.

In order to fulfill legal obligations, your data may also be communicate to competent authorities and public bodies.

The data collected for marketing and profiling purposes indicated above cloud be communicated to associated companies and/or part of the Manuli Ryco group involved in marketing and profiling activities, as well as to suppliers – specifically identified as external data processors – appointed by the Data Controller to carry out activities related and instrumental to marketing and profiling activities including, for example, companies that offer e-mailing services for marketing purposes, companies that offer support in carrying out market strudies or companies that offer profiling tools.

International transfers of personal data

As a result, personal data may be transferred outside Italy. We will do so only where we have a lawful basis, for example to recipients: (i) in countries which provide an adequate level of protection for personal data; or (ii) if adequacy is not available, under agreements which meet European Commission Decision 2021/914 requirements for those transfers, as appropriate.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or discosed.

We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

Data Retention

This section outlines our data retention policies and procedures designed to ensure compliace with legal obligations in relation to the retention and deletion of personal data.

Personal data that we process for any purpose or purposes will be retained no longer than is necessary for that purpose or those purposes.

We will retain your personal data as follows: in some cases it is not possible to specify in advance the retention periods for personal data. In these cases, we will determine the retention period based on the following criteria:

• necessity;
• obligation of law;
• our legitimate interest.

In some circustances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Right of data subjects

In relation to the processing operations described in this notice, as a data subject, you may exercise the rights enshring in articles 15 to 22 of the GDPR and, in particular, the following rights:

• right of access – right to obtain confirmation as to whether or not personal data concerning you are being processed and, if so, to obtain access to your personal data;
• right to rectification – right to obtain, without undue delay, the rectification of inaccurate personal data concerning you and/or the supplementation of incomplete data;
• right to erasure (right to be forgotten) – right to obtain, without undue delay, the erasure of personal data concerning you. The right to erasure does not apply to the extent that the processing is necessary for the performance of a legal obligation or the performance of a task carried out in the public interest or for the establishment, exercise of defense of a right in court;
• right to restriction of processing – right to obtain restriction of processing;
• right to data portability – right to receive, in a structured, commonly used and machine-readable format, personal data concerning you and to provide it to another Data Controller;
• right to object – right to object to the processing of personal data concerning you on grounds relating to your particular situation and in any case to the use of your data for marketing purposes;
• right not to be subjected to automated decision-making – right not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you;
• right to lodge a complaint to the competent authority;
• right to revoke the consent – right to revoke the consent given on any occasion without affecting the lawfulness of the processing previously carried out.

You may exercise any right in relation to his or her personal data by sending an email with the relevant request to the following address: .

Amendments

We keep our policy under regular review; this version was last updated on June 16, 2025.

We may update this policy from time to time by posting a new version on our website.

You should check this page occasionally to make sure you are happy with any changes to this policy.

We may notify you of significant changes to this policy via email or other communication systems. For this reason, it is important that the personal data we hold about you is accurate and updated. Please keep us informed if your personal data changes during your relationship with us.