Privacy policy

TERMS AND CONDITIONS OF USE

Welcome to the www.anti-do-to.com website (the “Website”), owned by PLAN B S.R.L. – a company having its registered offices in Via Jacopo Barozzi 3/A, 40126 Bologna, Italy – registered with the Companies’ Registry of Milan, share capital of € 10.000 fully paid in – VAT n. 03854271206, (“ANTI-DO-TO” or “Website Operator”).

Access to and use of the Website are conditional on your review, understanding and acceptance of these General Conditions of Use. If you do not agree with these General Conditions of Use or with part of them, please do not use and do not access the Website.

1. INTELLECTUAL PROPERTY RIGHTS

The contents present on the Website, such as, without limitation, works, images, photographs, dialogues, music, sounds and videos, documents, drawings, pictures, logos and any other material, whatever their format, posted on the Website including, the menus, web pages, graphics, colours, patterns, tools, characters, and design of the Website, diagrams, layouts, methods, processes, functions and software that are part of the Website, are protected by copyright and by all other IP rights of ANTI-DO-TO or of the third parties, if any, that ANTI-DO-TO has engaged. It is forbidden to reproduce, in whole or in part, in whatever form and on any medium, the Website and its contents without ANTI-DO-TO’s express written consent.

You are not authorized to remove and/or try to remove the elements protected by copyright, trademarks and/or other distinctive signs of the Website Operator or of the latter’s suppliers exhibited in any way whatsoever on the Website.

You are only permitted to view the Website and its contents benefiting from the services made available on it and to make any other browsing operations that are performed solely for the purpose of legitimately using the same. Under no circumstances may you be authorized to reproduce, on any medium, in whole or in part, the Website and its contents save under express written authorization released each time by ANTI-DO-TO or, where appropriate, by the authors of the individual works contained in the Website. Such reproductions must in any case be made for lawful purposes and in compliance with the copyright and the other IP rights of ANTI-DO-TO and of the authors of the individual works contained in the Website. You are also not authorized to use, alter or otherwise modify, neither to allow the duplication, creation of derivative works or elaborations or the distribution to third parties, under no circumstances, in any manner, medium and form, of the contents of the Website and the individual works protected by copyright and by any other IP right. You may not alter or modify the contents and the copyrighted works without ANTI-DO-TO’s prior written consent and, where necessary, without the prior consent of the relevant authors. The authors of the individual works published on the Website shall be entitled to claim, at any time, the authorship of their work and to oppose to any deformation, mutilation or other modification of the works including any damage caused to the works that is prejudicial to their honor or reputation. You undertake to comply with the copyright of the artists who have chosen to publish their works on the Website and to hold harmless ANTI-DO-TO from any direct and/or indirect damage that may be caused to ANTI-DO-TO and/or the said artists by any breach by you of these General Conditions of Use

2. TRADEMARKS AND DOMAINS

The exclusive owner of all trademarks and distinctive signs uploaded and represented on the Website, also for the purposes of distinguishing the products, is ANTI-DO-TO, who has also the exclusive right to use them. Any unauthorized use or use that is not compliant with applicable laws and regulations is strictly forbidden and can have legal consequences. Under no circumstances will you be entitled to use said trademarks and the other distinctive signs present on the Website to obtain, also indirectly, an improper benefit from the distinctive character or from the popularity of ANTI-DO-TO’s trademarks in a way that is prejudicial to the same or to their owners.

The anti-do-to.com domain, as well as any declination of the same and any sub-domain, are in the ownership of the ANTI-DO-TO. It is not permitted, not even indirectly, to use them without the express written consent of their owners.

3. INBOUND AND OUTBOUND LINKS FROM THE WEBSITE TO THIRD PARTY SITES

The Website may contain hypertext links (the "links") to other sites that are unrelated to the Website. Such third-party sites are not controlled or monitored by the Website Operator who therefore gives no warranty as to their contents and to the manner in which they process personal data. You must therefore carefully read the conditions of use of the third-party sites you visit and their privacy policies, as these General Conditions of Use and the Privacy Policy (here for reference) refer exclusively to the Website. 
Any unauthorized activation of links shall result in the Website Operator be entitled to take any action to have the unlawful links immediately deactivated, and to have the wrongful business practice, the unfair competition or the action ruining the good name and popularity of the Website Operator, its products and companies of its group, acknowledged and, where necessary, challenged in the appropriate fora. Posting hypertext links (such as deep frames and deep links) to the Website or using unauthorized  meta-tags is in any case and manner forbidden.

4. CORRECT USE OF THE WEBSITE AND OF THE CONTENTS HEREIN – WEBSITE OPERATOR LIMITATION OF LIABILITY

The access, use and browsing of the Website are for your personal use only, and must always be unrelated to your commercial, entrepreneurial, and professional activities. Using and browsing the Website are activities performed by you and, as such, no liability can be attributed to the Website Operator for the incorrect use of the Website. The Website Operator shall therefore not be liable if during your downloading activities your device is damaged or if your data are lost, unless any such damage and loss are attributable to the gross negligence and willful misconduct of the same Website Operator.
You acknowledges that the internet network – required for the use of the Website – is not controlled by the Website Operator and that no public or private entity and not even the Website Operator is capable to guarantee and monitor the functionality of the network. Therefore, the Website Operator accepts no responsibility for damages deriving from the inaccessibility to the services present on the Website, disruption of the service, content cancellation, problems related to the networks, providers or telephone and/or internet connections, unauthorized accesses, data alteration, failure and/or malfunction of your electronic equipment.

You shall not, directly or indirectly (for example, through the activity of third parties): (a) bypass or try to bypass the technical protection measures or the technical restrictions applied to the Website for the purpose of identifying any code and/or algorithm whatsoever (by way of example without limitations, any source code and object code); (b) analyse, decrypt, decompile, disassemble and/or reverse engineer the software and the code on which the Website run upon or try to put in place said activities; (c) alter, modify and/or process in any whatsoever the elements and contents of the Website; and (d) retrieve, copy, duplicate, retain and/or collect, directly or indirectly, manually or through the use of specific software, any data, information, code and/or algorithm of any kind whatsoever, used by or to operate the Website and/or loaded and contained into it (so-called data scraping).

It will be your responsibility to protect and correctly use your personal data, including the credentials allowing you to access the restricted services. You will also be responsible for any damaging consequence or prejudice that may derive to the Website Operator or third party from the incorrect use, loss or theft of your data unless any such consequence is attributable to the gross negligence and willful misconduct of the same Website Operator according to applicable laws.

The Website Operator has adopted all reasonable measures aimed at preventing the posting on the Website of contents and images that are likely to infringe a person’s human rights and dignity, in all possible forms and expressions. The Website Operator however warns you that the access, if any, to the contents deemed infringing or offensive is a deliberate act of yours and you are therefore the only person responsible for that. 
The Website Operator has also adopted any useful precautions to ensure that all information present on the Website is correct, complete and updated. The Website Operator accepts however no responsibility for the accuracy and completeness of the contents posted on the Website, unless otherwise envisaged by the law.

5. APPLICABLE LAW AND DISPUTE RESOLUTION

These General Conditions of Use are governed by Italian law.

Any dispute arising out of these General Conditions of Use between the Website Operator and you, may be resolved through the Alternative Dispute Resolution tool made available on the website of the Chamber of Commerce of Milan (www.risolvionline.com).

These General Conditions of Use may be updated or modified from time to time by the Website Operator. Any such modification shall become effective when posted on the Website. We therefore suggest that you review this document regularly.

TERMS AND CONDITIONS OF SALE

These terms and conditions of sale (“Terms and Conditions of Sale”) govern the offer and sale of goods on this website www.anti-do-to.com (the “Site”).

The goods bought on the Site (the “Products”) are sold directly by Diana E-Commerce Corporation SRL headquartered at Torreglia (PD) in Via San Daniele no. 137/139, 35038, tax code and VAT no. 05097740285, listed on the Padua Companies Register at number 442830, a company with sole shareholder, subject to direction and coordination by The White Dog S.r.l., share capital €500,000 fully paid (the “Seller”) with the authorization of PLAN B S.R.L. headquartered at Via Jacopo Barozzi 3/A, 40126 Bologna, Italy - listed on the Milan Companies Register, share capital € 10,000 fully paid – VAT no. 03854271206 as owner of the Products and of ANTI-DO-TO trademark under which the Products are sold (the “Owner” or “PLAN B”).

These Terms and Conditions of Sale must be read and accepted before a purchase order is placed by the user of the Site (the “Site User”). Failure to accept these Terms and Conditions of Sale will make it impossible to make purchases on the Site.

1. INTRODUCTIONS

1.1.     This Terms and Conditions of Sale only govern the offer, placement and acceptance of purchase orders for the Products on the Site, between the Seller and the Site Users.

1.2.     Through the Site, the Seller offers the Products for sale and carries out its e-commerce activities only for its end customers who are over the age of 18 and who are “consumers” according to relevant legislation, namely individuals who are acting for purposes which are outside their trade, business, craft or profession (the “Customer”).

1.3.     The offer and sale of the Products refers only to those countries listed in the Shipping page, which can be reached through the home page footer.

1.4.     The Seller therefore reserves the right not to fulfil any orders from non-consumers and/or from persons under the age of 18, or from any country not included among those indicated among the countries of shipment or, in any case, to orders that do not comply with its commercial policy.

1.5.     The Terms and Conditions of Sale do not govern the sale of goods or the provision of services by parties other than the Seller, even if they are present on the Site through links, banners or other forms of connection. It is the Customer’s responsibility to check the conditions of sale before submitting an order or buying goods and services from parties other than the Seller. The Seller shall not therefore be held liable for the sale of any goods and/or the provision of any services by third parties and/or for the conclusion of agreements between the Customer and third parties.

2. PURCHASE ORDERS

2.1.      In order to purchase one or more Products on the Site, the Customer must select the Products he/she intends to purchase and add them to the shopping cart. Once the selection of the chosen Products has been completed, the Customer must continue with the checkout at the shopping cart web page, fill in the electronic order form according to the relevant instructions, and send it to the Seller.

2.2.     Purchase orders may be completed in the following languages: English.

2.3.     The purchase order of the Products may be made by the Customer either through his/her personal account, if registered on the Site, or through the "guest" user mode, providing in this case the personal information required to proceed with the order processing.

2.4.     The order form contains a summary of the information on the main characteristics of each Product ordered and its price (including all applicable taxes or duties), the accepted methods of payment and the delivery methods of the Products purchased, the shipping costs and estimated delivery times, and a reference to the Terms and Conditions of Sale concerning the conditions for exercising the right of return and the methods and times for returning the Products purchased.

2.5.     Before proceeding with the purchase of the Products by sending the order form, the Customer must carefully read the Terms and Conditions of Sale, which can also be printed, stored or copied for personal use. By sending the order form, the Customer declares to have understood and approved the contents of the order form, as well as to have accepted the General Conditions of Sale and Use of the Site, while, failing this, the purchase order cannot be proceeded with.

2.6.     Before submitting the purchase order, the Customer may check the order’s details and identify or correct any data entry errors.  The Customer represents and warrants that the data and information provided to the Seller in making the purchase order are true, exact and such to allow its identification.

2.7.     The submission of the order form by the Customer implies for the latter the obligation to pay the price indicated in the order.

2.8.     Once the order form has been accepted, the Seller shall send the Customer, by email, a receipt of the purchase order. This will contain, information regarding the essential characteristics of the Products and a detailed indication of the price (including all applicable taxes or duties), means of payment, conditions, and methods of exercising the right of return and delivery costs, as well as a full reference to the Legal Area on the relevant e-mail footer, containing a link to the Terms and Conditions of Sale.

2.9.   The Seller may refuse a purchase order if it is incomplete or inaccurate, or if there is an insufficient guarantee of solvency, or if the Products are unavailable. In such cases the Seller shall, promptly and within 14 days from the day after the order has been sent to the Seller, inform the Customer by e-mail that the contract has not been concluded and that the Seller has not followed up the purchase order. If the Customer has already submitted the order form and paid the price, the Seller will refund the full amount paid.

2.10.   The order form will be stored in the Seller’s database for the period of time necessary to fulfil the order, in compliance with the legal period. Once registered on the Site, the Customer may view the orders placed by accessing their personal account and browsing the relevant section of the Site. Customers purchasing goods as a “guest” users can check the orders they have placed by contacting Customer Service, as indicated in paragraph 11 “Customer Service” below.

3. CHARACTERISTICS OF THE PRODUCTS

3.1.     On the Site are offered for sale only original products bearing the ANTI-DO-TO trademark upon authorization of PLAN B as well as the trademarks of the relevant partners.

3.2.     The main characteristics of the Products are displayed on the Site, on each Product page. The images and colors of the Products offered for sale may not correspond to the actual colors due to the effect of the web browser and/or monitor. The Seller and/or the Owner shall not therefore be held liable for differences in the shade or brightness of Product colors due to the above reasons.

3.3.     Each Product is sold on the Site together with an identification tag which forms an integral part of the Product.

4. PAYMENTS

4.1.     The prices of the Products indicated on the Site are stated in Euros (€), US Dollars ($) and Pounds (£) and already include all the applicable taxes and duties. The Product prices do not include the shipping and delivery costs. These will be clearly indicated when the Product purchase process begins and during it, as well as in the receipt of the purchase order.

4.2.     The prices of the Products may be subject to change. The Customer must therefore check the final sale price before submitting the order form.

4.3.     The methods of payment can be found on the FAQ page which can be reached through the home page footer. The methods of payment are also indicated on each purchase order and form an integral part of the Terms and Conditions of Sale.

4.4.     The price of the Products and delivery costs as indicated on the order form will be charged when the Products are shipped by the Seller.

4.5.     If payment by credit card is chosen, the payment details (such as the debit/credit card number or date of expiry) will be forwarded using an encrypted protocol to the bank or payment services provider, without the possibility of any third party accessing such data. This information will never be used by the Seller except (i) to complete the purchase process for which it was provided, or (ii) to issue a refund if the Products are returned, if the customer exercises the right of withdraw, or (iii) if use of the data is necessary in order to prevent fraud or report to the police any fraud on the Site.

4.6.     If the Product is delivered in an EU country, the Product will not be subject to any customs charges such as import tax and/or duty.

For deliveries to countries outside the EU, the Product may be subject to customs charges, such as import taxes and/or duty, which will be payable when the Product arrives in the country of delivery. Customs charges cannot be foreseen in advance by the Seller and will be borne by the Customer.

For further information, please contact the customs authority in the country in which the Product is to be delivered.

5. DELIVERY OF THE PRODUCTS

5.1.     The Product ordered on the Site will be delivered by express courier. Costs, terms and conditions for delivery of the Products are indicated on the Shipping page, and on each receipt of the purchase order e-mailed to the Customer. They constitute an integral part of the Terms and Conditions of Sale.

5.2.     The timely delivery of the Products indicated on the Site refers only to working days, with the express exclusion of non-working days.

5.3.     The Customer must purchase the order directly from the page on the Site relating to the country to which the purchase Product will be delivered. The Site shall be able to automatically recognize the country from which the Customer is logging in, but the reference country can be changed using the Countries page, which can be reached through the home page footer.

Orders placed from a section of the Site relating to a country other than the destination country, or to an address that is not accepted by the Seller’s courier (such as PO boxes or “Hold Mail” addresses), will not be accepted. For Italy only, the Site is not authorized to send deliveries to Livigno, Campione d’Italia, San Marino or the Vatican City.

6. RIGHT OF RETURN

Exercise of the right to return

6.1.     The Customer may withdraw from the contract with the Seller free of charge, without having to give a reason, within 30 days from the date on which he/she received and acquired physical possession of the Products purchased on the Site. The Seller will not accept returns orders from US.

6.2.     To exercise the right of return, the Customer may communicate his/her decision using the return form available on the Site. For this purpose, the Customer must access the Returns page, which can be reached through the home page footer, complete the return form and send it electronically to the Seller.

6.3.     Alternatively, the Customer may send a written notice of the intention to withdraw, providing their details (name, surname, address and email), the date of the order and the date of receipt, the order number and details of the Products purchased; for this purpose, the Customer may use the standard return form ** below, which is not mandatory, as set out in Annex 1 of legislative decree no. 21 of 21 February 2014. If the Customer chooses this option, the notification of return must be sent to the Seller by

- post: to Diana E-Commerce Corporation SRL headquartered in Torreglia (PD) at Via San Daniele no. 137/139, 35038 or
- e-mail: to help@anti-do-to.com

6.4.     If the right of return is exercised, the Product chosen may not be directly replaced with another; to purchase a new Product, the Customer must place a new order, separate from the previous one.

6.5.     The Customer is liable for any loss of value of the Products resulting from any handling of the Products other than that necessary to determine their nature, characteristics and functioning.

6.6.     The Seller may decide not to accept the return if the Products are returned without the identification tag.

6.7.     The right of return may not be exercised in cases where:

- Products have been made to measure or customized;
- Products may deteriorate rapidly;
- after delivery, the Products have been inseparably mixed with other goods;
- sealed Products may not be returned for hygienic and health reasons if they have been opened after delivery.

Terms and conditions of product returns

6.8.     Products subject to return must be returned to the Seller. In order to proceed with the return, the Customer must return the Products within 14 days from the date on which the Customer sent the return form, by electronic or paper mean, to the Seller (i.e. to Diana E-Commerce Corporation SRL, at Movimoda Spa, Via Vincenzo Mari n° 5/7, 42047 Rolo (RE) - Italy.

6.9.     The Customer will pay the direct costs of returning the Products. The Seller may offer a list of selected and accepted methods of delivery.

6.10.   Where possible, the Products should be returned inside the package sent by the Seller.

6.11. The Seller will not accept returns orders from US.

Terms and conditions of refund

6.11.   Upon receipt of the Products the Seller will carry out necessary checks regarding their conformity to the terms and conditions of this Article 6.

6.12.   In the event that the checks procedures are concluded successfully, the Seller will send the Customer, by email, confirmation of acceptance of the returned Products and will then refund all the payments received from the Customer including the delivery costs. The Seller is not required to refund the additional costs of delivery expenses, if the Customer has expressly chosen a different type of delivery from the less expensive type offered.

6.13.   Whatever method of payment is used by the Customer, the refund will be completed as quickly as possible by the Seller, after checking that the right of return has been properly exercised but, in any case, within 14 days from the date on which the Seller received the notice of return. The Seller may suspend the refund until receipt of the Products or until the Customer can demonstrated that the Products have been returned, whichever is earlier.

6.14.   The Seller will make the refund using the same methods of payment used by the Customer for the initial purchase, unless the Customer has expressly agreed otherwise. If the recipient of the Products indicated on the order form does not correspond to the person who paid for them, the refund will be completed by the Seller to the person who made the payment, unless agreed otherwise.

6.15.   If the terms and conditions for exercising the right of return as specified in this Article 6 have not been respected, the Customer shall have no right to the refund of any sums already paid to the Seller; however, the Customer may, at their own expense, re-obtain the Products in the condition in which they were returned to the Seller.

7. LEGAL WARRANTY OF CONFORMITY

7.1.     In addition to the warranty for defects in the sold Products, the Seller shall provide a legal guarantee of conformity of the Product in accordance with Title III of Part IV of Legislative Decree number 206 of 6 September 2005 (so-called the “Consumer Code”). The warranty provides that the Seller is liable for any defects in the products that appear within 2 (two) years from delivery.

7.2.     Unless proved otherwise, it will be assumed that conformity defects arising within 6 (six) months from delivery of the Product already existed on that date unless such a scenario is incompatible with the nature of the goods or with the nature of the conformity defect.

7.3.     In order to take advantage of the conformity guarantee, the Consumer must notify any defects in the Product within 2 (two) months from discovery, under penalty of forfeiture. Any claims to enforce a conformity defect that was not fraudulently concealed by the Seller will be time-limited, in any case, to 26 (twenty-six) months from delivery of the Product.

7.4.     In the event of a lack of conformity reported within the terms provided, the Consumer may, at his/her discretion, ask the Seller to repair or replace the Products, in both cases without incurring any expense, unless the requested remedy is objectively impossible or excessively expensive compared to the other option. The Consumer may also request, at his/her discretion, an appropriate reduction in the price or termination of the contract if repair or replacement is impossible or excessively expensive, or if the Seller has not repaired or replaced the goods within a reasonable period or if the previous replacement or repair has caused considerable inconvenience to the Consumer.

7.5.     In order to benefit from the warranty of conformity it is recommended to keep and show the purchase documents of the Product. For more information about the legal guarantee of conformity for consumers, and to take advantage of the remedies provided by the legal guarantee in relation to Products purchased from the Seller, the Consumer can contact the Customer Service.

8. PRIVACY

8.1.       With regard to the processing of the Customers’ personal data, please see the Privacy Policy.

9. GOVERNING LAW AND DISPUTE RESOLUTION

9.1.     These Terms and Conditions of Sale are governed by the Italian law and by the provisions of legislative decree no. 206 of 6 September 2005 containing the “Consumer Code”, with specific reference to provisions regarding distance contracts and legislative decree no. 70 of 9 April 2003 on certain aspects of e-commerce.

9.2.     In the event of any dispute between the Seller and the Customer arising from the Terms and Conditions of Sale, the Customer may access the European Commission’s online dispute resolution platform at https://webgate.ec.europa.eu/odr.

10. AMENDMENTS TO TERMS AND CONDITIONS OF SALE

10.1.   These Terms and Conditions of Sale may be amended by the Seller at any time, also in consideration of any regulatory changes. The new Terms and Conditions of Sale will be effective from the date of publication on the Site. Customers are therefore asked to visit the Site regularly and to read the latest version of the Terms and Conditions of Sale before making any purchase.

10.2.   The Terms and Conditions of Sale applicable to each contract made by the Customer on the Site are those in force on the date on which the purchase order is sent.

11. CUSTOMER SERVICE

11.1.   For assistance with the Products, or for more information, suggestions, complaints and/or any other requests, the Customer may contact the Seller’s customer service department at any time using the Contact form or using the following contact details:

- by e-mail: help@anti-do-to.com
- by post: Diana E-Commerce Corporation SRL headquartered in Torreglia (PD) at Via San Daniele no. 137/139, 35038.

** Model return form pursuant to art. 49, paragraph 1, letter h) of Legislative Decree no. 206 of 6 September 2005 (fill in and return this form only if you wish to withdraw from the contract)

To Diana E-Commerce Corporation SRL

At Movimoda Spa, Via Vincenzo Mari n° 5/7, 42047 Rolo (RE) - Italy

- telephone number: +39 0497852221

- email address: help@anti-do-to.com

I/We hereby give notice that I/We withdraw from my/our contract of sale of the following goods /for the provision of the following service,

-       Ordered on /received on*

-       Name of consumer(s),

-       Address of consumer(s),

-       Signature of consumer(s) (only if this form is notified on paper),

-       Date

* delete as appropriate

PRIVACY POLICY

Welcome to the ANTI-DO-TO Website ("Website"). On this page, we will provide you with information pursuant to art. 13 of Regulation (EU) 2016/679 ("GDPR") regarding the processing of your personal data that we collect when you browse our Website or interact with the related services.

The information provided here refers only to our Website and its possible subdomains and not to any other websites that may be visited through hyperlinks or links.

Please read this information carefully before providing us with your personal data.

1. DATA CONTROLLER

Plan B S.r.l., with registered office at Via Jacopo Barozzi 3/A, Bologna, zip code 40128, e-mail: help@anti-do-to.com ("ANTI-DO-TO") and DIANA E-COMMERCE CORPORATION SRL, with registered office in Torreglia (PD) at 137/139 via San Daniele, zip code 35038, VAT No. 05097740285, e-mail: privacy@dianacorp.com ("Diana") are Joint Controllers of the personal data processed for all activities related to the browse of the Website and the sale of products offered on the Website, such as placing an order and after-sales assistance (for example, for returns and complaints). Pursuant to art. 26 GDPR, you can view the basic agreement between Diana and ANTI-DO-TO by writing to help@anti-do-to.com.

ANTI-DO-TO is also the independent data controller for the purposes of managing the Website and your registration on the Website (i.e., personal account) as well as for marketing purposes.

Hereinafter, when we use the expression "Joint Controllers", we will be referring to both ANTI-DO-TO and Diana. Vice versa, when you find a reference to Diana or to ANTI-DO-TO separately, it refers to only one of the two data controllers.

2. DATA PROTECTION OFFICER (DPO)

Diana has appointed a data protection officer (DPO) that you can contact by writing to the following address privacy@dianacorp.com

3. PEOPLE UNDER 18 YEARS OLD

The Website and the related services are intended for the sale of products and services to adults. Therefore, the Joint Controllers do not intentionally collect the personal data of persons under the age of 18. If you access the services of the Joint Controllers, you are declaring that you are older than 18.

4. PERSONAL DATA CATEGORIES

a) Navigation data

Browsing the Website and accessing the related services involve the acquisition of certain personal browsing data, such as, the IP addresses or domain names of the computers you are using when connecting to the Website, the URIs (Uniform Resource Identifier) of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the IT environment you use (the “Navigation Data”).

b) Personal data you voluntarily provide us with

ANTI-DO-TO and Diana process the personal data you voluntarily provide to contact and inquire ANTI-DO-TO by using the general inquires contact form or by calling the customer care at +39 049 7852221 or by emailing at help@anti-do-to.com or press@anti-do-to.com (the “Voluntary Data”).

c) Personal data provided to access Website services: personal account, sales of products, after-sales assistance and marketing

ANTI-DO-TO and Diana process the personal data (the “Service Data”)

c) Cookies

The Website uses Cookies. For further information on cookies and their use on the Website, see the cookies page.

4. PURPOSE, LEGAL BASIS AND CONSERVATION PERIOD

Your personal data will be processed by ANTI-DO-TO for the following:

II. Your personal data will be processed by ANTI-DO-TO and Diana for the following:

6. NATURE OF DATA PROVIDED

The provision of compulsory data in the fields marked with an asterisk (*) for the purposes referred to in art. 4, I) and (II), concerning data categories A, B, C(i) and C(ii) above, is required for browsing and registering on the Website, using the related services and purchasing products. Failure to provide this data makes it impossible to obtain the products and services requested.

On the other hand, providing data in the fields not marked with an asterisk, while useful for facilitating relations with Diana and ANTI-DO-TO, is optional and failure to give these details does not affect the possibility of browsing the Website, obtaining the requested products and services.

With reference to the marketing purposes referred to in art. 4, I), data category C(iii), the provision of data is optional and your refusal prevents ANTI-DO-TO from processing the data you have provided for marketing purposes, but it does not prevent you from browsing and registering on the Website, purchasing products and using the related services in accordance with the provisions of art. 4 above.

7. PROCESSING METHOD

Your data will be processed by the Joint Controllers with mainly IT and telematic methods.
Specific security measures are observed to prevent data loss, and any unlawful or incorrect usage and unauthorized access. The Joint Controllers have adopted all the appropriate security measures required by law to ensure protection, security and confidentiality of data processed.

8. ADDRESSEE PERSONAL DATA AND DATA DIFFUSION CATEGORIES

To achieve the purposes the data are collected for, the Joint Controllers may use the following categories of entities to whom the data may be communicated to or accessed by in their role as data processors:

• - IT service providers, such as internet services and cloud computing;
• - entities who carry out activities involving the logistics, storage, promotion or delivery of the Joint Controllers' products and services;
• - entities who carry out customer assistance activities;
• - firms and other entities that provide assistance, consultancy and services such as legal, fiscal, accounting, economic-financial, technical-organizational, data processing or communication services;
• - entities that provide banking, financial, insurance and credit recovery services;
• - entities that carry out anti-fraud control activities on payments;
• - subsidiaries, parent companies, affiliated companies and associates;
• - public authorities and supervisory and control bodies.

An updated list of data processors is available by sending a specific request to the Joint Controllers using the methods given in section 11.

Exclusively for the purposes specified above, your personal data may also be accessed by the Joint Controllers’ employees who are authorized to process them.

No data collected on the Website is subject to disclosure and diffusion.

9. TRASFERRING THE DATA TO A THIRD COUNTRY AND/OR INTERNATIONAL ORGANIZATION

Your personal data may be transferred, for the purposes for which they are collected, to the United States of America which does not belong to the European Union. The transfer of personal data to entities located in the USA will take place exclusively in accordance with either adopted or approved standard contractual clauses of the European Union Commission (Article 46, section II, letters c and d of the Regulations).

To obtain a copy of this data, you can contact the Joint Controllers, as stipulated in section 11.

10. SOCIAL BUTTONS AND WIDGETS

The website also contains social buttons/widgets. They are the icons of social networks, such as Facebook, Twitter, Pinterest, Google+, Youtube, Linkedin and Instagram, which allow you to reach the social networks in question by "clicking" on the icon. Thanks to these tools, you can share content or recommend products from the website on social networks.
After clicking on the social buttons/widgets, the social network may collect data relating to your visit to the Website. As stipulated in the introduction, this privacy statement does not concern the processing of your data by social networks. In these cases, you should refer exclusively to the privacy policy provided by the social network in question.
Apart from the cases in which you spontaneously share your data with the selected social networks by clicking on the social buttons/widgets, the Joint Controllers do not communicate or share any personal data with the social network.

11. RIGHTS OF DATA SUBJECTS

In relation to the personal data you have provided, you have the right at any time to request the following:

• - confirmation that your personal details are being processed and, in this case, to obtainaccess to your personal data and a copy of them (Right of access - Article 15 of the GDPR);
• - the correction of inaccurate personal data and the integration of incomplete data, in relation to the purposes of processing (Right to rectification - Article 16 of the GDPR);
• - the deletion of personal data in the cases given in Art. 17 of the GDPR (Right to erasure);
• - processing to be limited in the cases given in Art. 18 of the GDPR (Right to restriction of processing);
• - opposition to the processing of personal data in accordance with the provisions of Art. 21 of the GDPR (Right to object);
• - data portability, if processing is based on your consent or on a contract and is carried out by automated means (Right to data portability - Article 20 of the GDPR);
• - if you have given explicit consent to the processing of your personal data for one or more specific purposes (Article 6, section 1, letter a, of the GDPR), thisconsent can be withdrawn without affecting the lawfulness of the processing based on the consent given before it was withdrawn (Right to revoke consent).

To exercise these rights, you can write to: help@anti-do-to.com.

However, you can also exercise your rights with each Joint Controller by writing to the addresses given in section 1.

Finally, please note that, if the conditions are met, you have the right to lodge a complaint with the Guarantor Authority for the protection of personal data as the supervisory authority according to the established procedures.

CODE OF ETHICS

PREAMBLE

Plan B has adopted this Code of Ethics in order to provide a clear and transparent definition of the values it is inspired by.

Plan B conducts its business in compliance with the principles contained in the Code of Ethics, in the belief that an attitude of respect and collaboration towards all Stakeholders is a precondition for creating value, and the success of a healthy company that reflects the area it is based in, and from where it receives and redistributes resources. 

In particular, Plan B pursues the following goals for the common good and sustainable development when conducting its business, and in relation to the environmental and social context of the areas it operates in:

• the procurement of products from manufacturers and suppliers who promote a fairer and more sustainable, ethical and responsible economy that respects people and protects the environment;
• the creation of products with a low environmental impact;
• the promotion and support of initiatives that support sustainable development and environmental protection, the fight against racial discrimination, vulnerable categories, and health and safety;
• the provision of support for and collaboration with organizations that operate with respect for the environment and people.        

1. USER’S GUIDE TO THE CODE OF ETHICS

Recipients of the Code of Ethics

1.1 “Recipients” of the Code of Ethics: Directors, members of control bodies, Human Resources, as well as Plan B’s Other Collaborators, including temporary ones.

1.2 “Human Resources”: all employees, temporary employees and posted workers, as well as quasi-subordinate workers and other individuals who are part of the Company’s staff, regardless of the type of contract and reference legislation.

1.3 “Other Collaborators”: for example, other individuals who occasionally collaborate with Plan B, regardless of their professional category or the type of contract.

1.4 Other parties that must comply with the Code of Ethics include Manufacturers, Suppliers, “Licensees”, commercial and corporate partners (hereinafter referred to as “Partners”) and “Other Parties” with whom Plan B has a contractual relationship, as well as anyone undertaking activities in the name of or on behalf of Plan B, or under the control thereof, whether they are natural or legal persons. 

1.5 Recipients are obliged, where applicable, to observe the principles contained in the Code of Ethics and shall be subject to penalties for the breach of any of its provisions. The penalties depend on the type of relationship that binds them to Plan B.

Dissemination and awareness of the Code of Ethics

1.6 The Code of Ethics is published on the Company’s website (www.anti-do-to.com).

1.7 The Company ensures the maximum dissemination and awareness of this Code of Ethics at all levels of its organization. By virtue of the employment relationship or the contract that binds them to Plan B, all Recipients are required to comply with the Code.

1.8 With regard to the contractual relationships with external parties, referred to in Article 1.5, Plan B requires the counterparty to read and accept this Code of Ethics, unless said party has its own code of ethics, in which case Plan B and the counterparty shall both acknowledge that they have read the respective codes of conduct, on the condition that the principles contained in the counterparty’s Code of Ethics are compatible with those of Plan B.

2.GENERAL PRINCIPLES

Impartiality

2.1 Plan B is opposed to all forms of discrimination, including social discrimination, racism, xenophobia and intolerance.

2.2 Plan B undertakes to avoid any discrimination in its conduct and to respect, in relations with its stakeholders, any differences in age, gender, sexual orientation and identity, ethnicity, religion, health status, political and trade union affiliation, language or diverse abilities. 

Probity

2.3 Within the scope of activities carried out for Plan B, Recipients are required to comply with the laws in force for each of the set of rules within which the Company and the Code of Ethics operates. In no event may the pursuit of Plan B’s interests be used to justify failure to comply with said laws.

2.4 Plan B is against all forms of violence. All of Plan B’s activities must always be carried out with honesty, integrity and fairness with respect to the stakeholders in question, and within a framework of fair business practices.

2.5 In particular, Plan B expects its Human Resources to maintain high ethical and professional standards when carrying out their jobs, and to comply with the law, in order to strengthen mutual trust and consolidate the Company’s reputation, while avoiding any behavior that could damage it. They must maintain integrity and probity in their relationships with each other and with Plan B’s Directors and shareholders, competitors, representatives of Public Authorities and with all third parties in general, whether they are negotiating counterparties or other stakeholders.

Conduct in the event of potential conflicts of interest

2.6 When conducting any type of business for or on behalf of Plan B, Recipients must always avoid situations where there is an actual or apparent conflict of interest between themselves and the other parties involved. Recipients are required to report said situations.

2.7 Recipients must not seek to derive any undue personal benefit, pursue interests other than Plan B’s corporate goals, or act against the contractual and/or fiduciary duties that bind them to the Company.

2.8 Particular attention must also be paid, where applicable, when carrying out transactions with parties they are closely associated with. These must be carried out in full compliance with the applicable laws and regulations and must ensure full transparency, correctness and good reason for said transactions.

Transparency and completeness of information

2.9 In relations with third parties, whether they are negotiating counterparts or other stakeholders, Plan B’s Human Resources are required to provide complete, transparent, understandable and accurate information, without prejudice to the protection of confidentiality concerning information and personal data (see Articles 9 and 10), in such a way that third parties entering into a relationship with the Company are able to make independent decisions, while being aware of the interests involved, any alternatives and any relevant consequences. In particular, when stipulating any contract, Plan B will specify the conduct that must be maintained in all foreseen circumstances, so it is clear and understandable to the contracting parties.

Sustainability and social impact

2.10 Plan B is committed to creating a positive impact on society and the environment, in order to create long-term sustainable value for all stakeholders, as well as generate profit. Sustainability is an integral part of its business model: to create favorable conditions for social and environmental prosperity, today and in the future.

2.11 Plan B undertakes to build a relationship of trust and continuous dialogue with Stakeholders, informing and involving them in everything that interests and/or concerns them.

2.12 Plan B promotes a culture of environmentally-sustainable production, based on making continuous improvements for the protection of the environment, minimizing the environmental impact of its activities to protect the growth and health of people, and creating better conditions for future generations. 

2.13 Sustainability means offering a range of products whose entire production line respects human and social rights and the strictest environmental, health and safety standards, all based on transparency and continuous dialogue with Stakeholders. To this end, Plan B undertakes to adopt environmentally responsible behavior, and act in strict compliance with all applicable regulations, as well as within the boundaries established by any permits or regulations received from competent bodies.

3. HUMAN RESOURCES

3.1 Relations between colleagues, even if they are at different hierarchical levels and in respect of their roles, must always be based on the principles of civil coexistence, loyalty and correctness, and must maintain mutual respect for the rights and freedom of the other person.

3.2 Managers responsible for organizational structures and specific activities must exercise the powers that come with their job and/or the authorization received in an objective and balanced manner, while maintaining loyalty to Plan B and its administrative bodies, and at the same time respecting the dignity of their co-workers, whose professional growth they are responsible for. With regard to the procedures for exercising the powers that have been granted, refer to the Company’s Articles of Association and the system for the delegation of powers.

3.3 When carrying out their duties, all Human Resources must cooperate fully by observing the provisions for the execution and protocol of the work assigned by their manager(s) and the Company in general.

Human resource management policy

3.4 Plan B recognizes the centrality and importance of the individual and of each individual’s contribution in the sharing of individual skills; for this reason, it is committed to creating a serene work environment in which everyone is able to work in compliance with laws, principles and shared ethical values, where every single person is valorized without direct or indirect discrimination.

3.5 Plan B ensures that Human Resources behave and are treated with dignity and respect, within the framework of the provisions of the laws governing employment relations.

3.6 Plan B does not tolerate any form of discrimination, exploitation, harassment, bullying or isolation for either personal or work reasons within its organization; situations of this magnitude will be prosecuted and punished with the termination of the contract of employment or collaborative relationship.

3.7 Plan B shall not apply any disciplinary or contractual sanctions against employees or other collaborators who have legitimately refused to provide a work service that has been unduly requested of them by any person linked to the Company. Plan B shall protect those who provide a detailed report of such situations in good faith, as specified under Article 17.

3.8 Plan B is opposed to “undeclared work” and child/underage labor, as well as any other conduct involving labor exploitation or which offends individual personality. All employees and collaborators are hired through standard employment contracts. Human Resources are duly and fully informed of all the rights, duties and obligations set out in the contract.

3.9 Plan B promotes the cultural growth of its staff and improves their professionalism and personality by providing appropriate training tools.

3.10 The procedures for the selection of new Human Resources and the management of remuneration policies and career paths, are based on purely meritocratic criteria.

4. HEALTH AND SAFETY AT WORK

4.1 Plan B is committed to disseminating and reinforcing the culture of safety and health in the workplace, by developing awareness of the dangers and risks involved, promoting responsible behavior on the part of Human Resources, and working to protect the health and safety of workers, primarily through preventive measures.

4.2 The company’s activities are carried out in compliance with existing Occupational Health and Safety legislation. In particular, the OHS management system is based on the following principles:

• assessing and managing risk, including unavoidable risks;
• dealing with risks at their source;
• adapting the working environment to the people in it, particularly with regard to the design of workstations and the choice of working methods and tools;
• taking technical developments into account;
• replacing dangerous items and practices with non-dangerous or less dangerous alternatives;
• planning prevention with consistent actions that integrate technique, work organization, working conditions, social relations and the influence of workplace factors;
• giving priority to collective protection measures over individual protection measures;
• providing workers with the necessary instructions.

5. RELATIONS WITH PUBLIC AUTHORITIES

5.1 Plan B’s Human Resources must maintain lawful, ethical and respectful relationships with authorities and public institutions, ensuring that their conduct in all areas that Plan B operates in conforms to the principles of fairness and transparency when dealing with Public Authorities and their representatives. In particular:

• when making a request to a Public Authority for the provision of measures relating to company activities;
• on any occasion that involves contact with bodies/parties engaged in carrying out inspections or surveys at Plan B’s sites to verify compliance with legal provisions and/or requirements;
• on any occasion that involves contact with a Public Authority for institutional, commercial or supply purposes;
• when fulfilling obligations or regulations established by a Public Authority.

5.2         Plan B ensures correctness and transparency in its business dealings and negotiations with Public Authorities, as well as in the execution of any legal or regulation requirements dictated by the same.

5.3         Plan B’s relations with public officials (including public employees - regardless of whether or not they are in charge of a public service - and public service concessionaires) are based on transparency, loyalty and fairness: Plan B does not intend to create the slightest suspicion of wanting to unduly influence these subjects to obtain benefits by illicit means.

5.4         Plan B condemns any behavior that may constitute the corruption of private individuals, set out in detail under Article 7.6 of this document. Any attempt to extort, bribe or induce a public official or public service representative to provide an undue advantage must be reported without delay.

5.5         Recipients of the Code of Ethics must disclose any personal business relationships or financial activities undertaken with public officials.

5.6         In light of the above, Recipient’s must not:

• attempt to improperly influence the decisions of the various Administrations concerned, with particular regard to officials who negotiate or make decisions on behalf of said administrations;
• promise or grant money, goods, favorable conditions or other advantages, in any form, directly or indirectly, to any individual (regardless of whether the individual in question is a manager, officer or employee of a Public Authority or a private individual employed in public services, or directly related or related by marriage, cohabiting or in any other way associated with said individual), in order to incite said individual to perform an official act or exert undue influence over a decision to promote or favor the Company’s interests, even if it is induced by the illicit pressure or persuasion of said beneficiary. Human Resources are permitted to offer business gifts and courtesies of modest value, as long as they are considered fair and reasonable for any normal business or courtesy relationship. In any event, any gifts or presents will be duly monitored, evaluated and recorded by Plan B;
• send false or manipulated documents, attest to non-existent requirements or provide guarantees that do not correspond to the truth;
• unduly procure any other type of advantage (licenses, permits, relief from social security charges, etc.) through deception or trickery (for example: sending false documents or certifying things that are not true);
• confer professional duties, give or promise gifts, money, or any other advantage to public officials or public employees involved in administrative proceedings, nor engage in any financial activities with them, that could benefit Plan B;
• alter in any way the function of the IT or on-line system of a Public Authority or third-party, or in any way unlawfully modify the data, information or programs contained in any of the aforementioned systems;
• unlawfully receive contributions, funding, facilitated loans or any other disbursements granted or paid by public authorities, through the use or submission of false or untruthful documents, or the omission of information;
• use contributions, subsidies or funding designated for public works or activities in the public’s interest for purposes other than those for which the same were granted;
• illegally exchange information on bids with participants of any tenders or public procedures.

5.7         Any corrupt conduct that constitutes a criminal offence, even if it is done in foreign countries where such conduct is not punishable or otherwise prohibited, is a violation of Plan B's institutional policy

5.8         In general terms, relations with a Public Authority on behalf of Plan B must be managed by delegated or duly authorized parties.

5.9         Plan B acts in compliance with the law and upholds, within its purview, the proper administration of justice.

5.10      When conducting its business, Plan B operates lawfully and properly by cooperating with any judicial authority, law enforcement agency or public official that has the power to investigate it.

5.11      In the event of a judicial proceeding, an investigation or inspection by a Public Authority or Supervisory Authorities, no one may destroy or alter any records, minutes, accounting records or other type of document, or lie or make false statements to the competent authorities.

5.12      No one must try to persuade others to provide false or misleading information to the competent authorities.

5.13      No one may confer professional appointments, give or promise gifts, money or other benefits to those carrying out verifications or inspections, or to the competent authorities, nor engage in any financial activities with them.

6. DONATIONS FOR POLITICAL PURPOSES

6.1 These contributions require the prior approval of the Company’s Board of Directors and must be made within the limits and in the forms provided for by the applicable regulations.

7. RELATIONS WITH SUPPLIERS, LICENSEES, PARTNERS AND OTHER CONTRACTUAL COUNTERPARTIES

7.1 Plan B establishes relationships with Suppliers, Manufacturers, Licensees and Partners solely on the basis of trust, quality, competitiveness and professionalism, and avoids agreements with parties that have, for example, questionable respect for the environment, working conditions and human rights.

7.2 In particular, Plan B’s evaluation criteria for selecting Suppliers and Licensees also include - in addition to quality and competitiveness - reputation, reliability, professionalism, efficiency and sustainability (environmental and ethical certifications), in order to establish a solid and long-lasting fiduciary relationship. Plan B avoids agreements with suppliers that have a dubious reputation that may not reflect the values set out in this Code of Ethics, which are in line with the principles of the United Nations Global Compact, such as respect for the environment, working conditions, human rights and the principles of legality, respect for competition and the fight against corruption. 

7.3 The same principles are adopted in the evaluation of Partners, who are required to share the values set out in this Code of Ethics, also to safeguard the reputation of Plan B’s brand and company.

7.4 Plan B expects that no undue pressure will be put on Suppliers, Licensees and Partners to perform services that are not contractually provided for.

7.5 In requesting adherence to this Code of Ethics, Plan B expects Suppliers, Licensees, Partners and Other Parties to behave in compliance with the principles that apply to them. Contradictory behavior may be considered a serious breach of the duties of correctness and good faith set out in the contract with Plan B, and this may cause damage to the fiduciary relationship and therefore become a just cause for termination of the contract itself.

7.6 No Recipient of this Code of Ethics may promise or grant money, in-kind gifts, facilitation or any other benefits, in any form, directly or indirectly, to any individual representing any of Plan B’s counterparties (whether they are a director, general manager, manager or employee of a private company, a statutory auditor or liquidator) for the purpose of influencing a decision or in return for them performing actions or concluding business agreements or, in general, to promote or favor Plan B’s interests or cause damage to a competitor. Business gifts and courtesies of modest value are allowed, as long as they are considered fair and reasonable according to local laws, transparent for reasons related to legitimate and socially accepted interests, or of an occasional nature, in order to avoid that their contents or occurrence could lead any independent third party to question the good faith of Human Resources or Plan B. Cash gifts are expressly prohibited. All Human Resources are obliged to ensure that they are duly informed about local practices and to evaluate said practices adequately, taking the interests and reputation of Plan B into consideration. In any event, the practices in use regarding gifts and presents will be duly monitored, evaluated and recorded by Plan B.

8. PROTECTION OF ETHICAL STANDARDS IN SUPPLIES

8.1 With a view to ensuring that its procurement activities conform to its adopted ethical principles, Plan B undertakes to introduce social requirements for certain supplies: for example, the presence of an environmental management system or workers protection system.

8.2 To this end, contractual clauses providing for the following can be included in contracts with suppliers:

• self-certification or declaration by the supplier, regarding adherence to specific social obligations: for example, the adoption of measures that guarantee workers respect for fundamental rights, the principle of equality and non-discrimination, protection against child labor and compliance with the quality standards of the product or service.
• the possibility for Plan B to carry out checks at the factories or offices of the supplier company, in order to verify the fulfilment of these requirements.

9. CUSTOMERS

9.1 Plan B recognizes the customer’s central role in its business and undertakes to fully understand their needs and to provide products and services that meet the latter, in order to achieve a high level of customer satisfaction.

9.2 Plan B is committed to communicating with its customers in a clear and transparent manner and to providing safe products and services. With regard to products, Plan B is committed to offering customers a high standard of excellence, quality, health and safety. All products will be made ethically and responsibly. The most important principles governing the relationship between the products sold by Plan B and its customers are as follows:

• Responsible design and ethical and responsible production of garments, achieved by evaluating the environmental impact of its products (recycling, biodegradability, eco-friendly textile fibers)
• Compliance with the strictest health and safety standards for products
• Product promotion based on objective standards, with no distorted descriptions or characteristics and no false or ambiguous information that could mislead customers or third parties.

9.3 Plan B guarantees the security of any means of payment used in its shops (whether physical or online), in order to ensure adequate traceability of billing and collection procedures, customer data protection and the prevention of fraud.

10. THE ENVIRONMENT

10.1 Plan B believes that safeguarding the environment is a necessity for long-term survival and therefore protecting the environment is one of the company’s main priorities. To achieve this, Plan B undertakes to comply with the environmental laws and regulations that apply to its activities, to evaluate the environmental impact of its products, and to choose Suppliers and Manufacturers who promote environmental protection and adopt systems and technologies that aim to reduce environmental impact as much as possible.

11.THE COMMUNITY

11.1 Plan B encourages and supports the promotion of human rights in the local, national and international communities in which it operates. Plan B participates in socially responsible practices that create value within the community and the company. This support is provided both through the promotion and/or organization of events and/or initiatives with high social and cultural value, and by supporting organizations that operate in the voluntary sector.

12. ACCOUNTING TRANSPARENCY AND INTERNAL CONTROLS

Corporate communications and accounting records

12.1 Accounting transparency is based on the truth, accuracy and completeness of the basic information in the related accounting records. Those responsible for the company’s accounting records are required to take action to ensure that all accounting events are represented in the accounting records correctly and promptly.

12.2 A record is kept of all supporting documentation, which allows: (i) accounts to be recorded more easily; (ii) authorization levels to be identified; and (iii) transactions to be reconstructed accurately and the probability of interpretation errors to be reduced.

12.3 Each entry must reflect exactly what is shown in the supporting documentation. It is the job of those responsible for the company’s accounting records to ensure that the documentation is easily traceable and that the entries are based on logical criteria.

Internal Controls

12.4 Plan B’s policy is to promote a control culture at all levels by ensuring awareness of internal control procedures and the positive effects these have on improving efficiency.

12.5 Internal controls are all the tools necessary or useful for supervising, managing and verifying the Company’s activities, with the aim of ensuring the credibility, accuracy, reliability and timeliness of the information provided to corporate bodies and the market; safeguarding company assets; checking the effectiveness of company processes; and guaranteeing compliance with laws and regulations, as well as with the Articles of Association and internal procedures.

12.6 All levels of the organizational structure are responsible, in various ways, for creating an effective internal control and risk management system; consequently, directors, members of control bodies and all Human Resources, each within their own role, must contribute to the definition, operation and monitoring of the internal control and risk management system.

12.7 Within the scope of their duties, the heads of organizational units are required to participate in the internal control and risk management system and to involve their co-workers.

12.8 The appointed accounting firm must always have free access to all the data, documentation and information needed to carry out audits.

12.9 Directors and Human Resources must not impede or hinder in any way the auditing activities carried out by statutory auditors, shareholders or the accounting firm.

12.10 In view of the above:

• Equity, assets, receivables and shares must be entered with the correct values, and the same must not be assigned values above or below what they actually are;
• Performing share capital transactions, or any other type of transaction that involves the use of non-distributable profits or reserves required by law is prohibited;
• the share capital may not be reduced, except in the event of losses or depreciation;
• Directors cannot purchase or underwrite company shares or quotas unless they use their own funds;
• only the objectives in the Articles of Association can be pursued;
• the management of the company’s equity must be in line with Plan B’s organizational and business policies, which operate according to the principles of transparency and morality;
• shareholders may not be released from the obligation to make contributions.

12.11    The same principles must be adopted in evaluations and any other extra-ordinary operations (mergers, divisions, etc.).

12.12    It is strictly forbidden for any party to influence the regular occurrence and decisions of shareholders’ meetings by seeking to deceive or mislead shareholders.

13. COMPANY COMMUNICATIONS AND CONFIDENTIALITY

13.1 Internal and external company communications must be clear, accurate and truthful in order to avoid inaccurate news and information being made public, or the creation of situations that the company could in any way be held liable for.

13.2 To protect the Company’s reputation, the value of the brand and confidentiality, the disclosure of any information concerning Plan B to the media or general public is managed solely by the spokespersons and organizational structures that are expressly responsible: no other Recipient may disclose information.

13.3 Confidential information concerning Plan B that has not already been made public, must not be communicated externally, including via digital and social media; the unauthorized dissemination of any content, images, written or audio-video documents owned by Plan B is also prohibited.

13.4 Recipients must not disclose any information that is untrue, defamatory, damaging to Plan B’s image, or detrimental to the dignity of any other external person who is in some way connected to or associated with Plan B.

13.5 Confidential information and documents, work projects and know-how must be appropriately and consistently stored and protected against access from third parties and colleagues who are not directly involved with them. Those who have access to the above for work-related purposes, must in any case follow the instructions and procedures established by the company.

13.6 If a third party should seek to obtain confidential information from a Recipient of this Code of Ethics, either deliberately and/or fraudulently, the latter must promptly notify his/her contact person within the organization.

14. PROTECTION OF PERSONAL DATA

14.1 Plan B adopts organizational and security measures for the correct processing of the personal data in its possession, in compliance with applicable European and national legislation.

14.2 Personal data must be processed on the basis of consent and specific purposes, and must not be disclosed externally without consent. Individuals who have access to these data for work-related purposes must follow the Company’s instructions and procedures.

15. COLLECTIONS AND PAYMENTS

15.1 Plan B conducts its business in full compliance with current anti-money laundering regulations, where applicable, and the provisions issued by the competent Authorities.

15.2 To this end, Human Resources must operate in compliance with company procedures, and avoid carrying out any transactions that are suspicious in terms of fairness and transparency. In particular, it is necessary to verify the available information concerning active and passive counterparties (suppliers, partners, other collaborators) in advance, in order to verify their respectability and the legitimacy of their business;

15.3 Plan B’s counterparties also undertake to operate in such a way as to avoid their involvement in transactions that could potentially favor the laundering of money deriving from illicit or criminal activities.

15.4 With specific reference to the traceability and storage of records, Recipients must observe the following rules:

• No payments or other money transfers made by or to the company must be made in cash, bearer forms or any other means considered to be a cash equivalent;
• An accurate and complete record must be kept of all payments and other transfers made by or to the company in the accounting books and mandatory records;
• Payments must only be made to Recipients for work that has been carried out under a formal contract and/or approved by delegated Subjects;
• No false, incomplete or misleading entries must be made. Setting up hidden or unregistered funds, depositing funds in personal accounts or any account that does not belong to the Company, and using Company funds or resources without full and proper authorization are also strictly forbidden.

16.PROTECTION OF COMPANY ASSETS

16.1 Plan B’s assets must be managed efficiently and honestly, and therefore all subjects required to comply with this Code of Ethics must contribute to the preservation of the integrity and value of said assets, in order to protect shareholders, creditors and investors.

16.2 Human Resources are responsible for the conservation and protection of all assets and tools entrusted to them by Plan B, and must contribute to ensuring the protection of all company assets by respecting the operational and safety procedures established by the Company.

16.3 The Plan B brand, in all its forms, must be protected and valued. All Recipients must comply with the contractual limitations and provisions governing the use of the brand and the enjoyment of contractual rights.

16.4 In any event, any documents relating to the Company’s activities, equipment, work tools or any other tangible or intangible asset made available and/or supplied by the same, must be used exclusively for Company purposes, using the procedures established by the same. They may not be used for personal purposes, or transferred or made available, even temporarily, to third parties.

17.CRIME PREVENTION

17.1 Plan B expects Recipients, each within the scope of the activities they carry out for Plan B, to not engage in any unlawful conduct stipulated amongst the violations referred to in Legislative Decree 231/2001.

18. IMPLEMENTATION OF THE SANCTIONS SYSTEM

18.1 The Company undertakes to focus on ensuring best practices in relation to its business, ethical and social responsibilities towards its shareholders, human resources and other stakeholders. This Code of Ethics defines the Company’s expectations concerning the Recipients and the responsibilities they must assume to transform these policies into concrete actions.

18.2 The Company and, above all, its directors and managers, undertake to ensure that these policies and expectations are understood and put into practice within the organization. They are accountable to the Company’s control bodies and are required to play an active role in order to implement the commitments set out in the Code of Ethics.

18.3 Breaches of the Code of Ethics are subject to penalties, proportionate to the seriousness of the offense and determined on the basis of the type of relationship that the Recipient in question has with Plan B. Measures also include the termination of the fiduciary relationship with the Company, with the expected and permitted contractual consequences established by current regulations.

18.4 Any sanctions against Human Resources for breaches of the Code of Ethics will be applied in compliance with the provisions of the law and collective bargaining, and will be proportionate to the gravity and nature of the offense. Verification of said breaches/non-compliance, as well as the management of the penalties and sanctions, will be the responsibility of the Company's assigned or delegated bodies or individuals.

18.5 With regard to Other Collaborators, Suppliers, Licensees and Partners, Plan B reserves the right to terminate the contract agreed on with them or to apply other contractual actions, by virtue of clauses specifically provided for this purpose, as set out under Article 7.5.

18.6 The Company Directors will continuously assess and judge this Code of Ethics to ensure it is suited to the   evolution of the company and all relevant primary legislation.

19. REPORTING BREACHES OF THE CODE OF ETHICS

19.1 Any Recipient can report, without delay, a suspected breach of the provisions in this Code of Ethics by one or more Recipients, provided that the report is in good faith and circumstantiated, or based on precise and concordant facts.

19.2 Alternatively, reports can be made using the following communication channels:

1. a) by e-mail to: ethics@anti-do-to.com;
2. b) by ordinary mail: reports should be sent to Plan B’s registered office in a sealed envelope, for the confidential and personal attention of the Chairman of the Board of Directors.

19.3      Reports shall be processed promptly using a predefined procedure. Plan B requires that named reports be made, and undertakes to keep the identity of the Reporting Party confidential, without compromising legal obligations or the protection of the rights of Plan B or of those accused wrongly and/or in bad faith.

19.4      Plan B will protect the Reporting Party against any form of retaliation, discrimination and/or penalty in good faith: if such conduct occurs, Plan B will act accordingly.

19.5      Likewise, Plan B may take action under applicable law against those who knowingly make false, unfounded or specious reports.