Dear User,

Pursuant to Art. 13 and 14 of the GDPR, the companies of the Retelit Group indicated below, inform you that the personal data, (hereinafter, the "Data"), collected through navigation on our websites and their processing by means of cookies and other tracking tools relating to your Company and the natural persons acting on its behalf (hereinafter, the "User"), will be used and stored in compliance with the provisions of the European Regulation for the Protection of Personal Data EU 2016/679 (hereinafter, "GDPR"), the applicable legislation on the protection of personal data, and in accordance with this notice.

It is understood that it is your responsibility to inform the individuals acting on your behalf, of the processing of the Data referred to in this notice and to seek their consent where necessary.

1. Who we are.

The Companies, depending on the specific purposes pursued and indicated in this Policy, process your Data independently, as data controllers, or jointly, as Joint Controllers, through the conclusion of a specific agreement pursuant to Article 26 of the GDPR, the essential contents of which will be made available, upon your written request, to the contacts below.

The following is the list of co-owners:

Retelit S.p.A., Parent Company of the Companies in the list (hereinafter also the "Group") listed below, with registered office in Milan, Via Pola 9, 20124 tax code, VAT number 12897160151;

Retelit Digital Services S.p.A., with registered office in Milan, Via Pola 9, 20124 tax code, VAT number 12862140154;

Brennercom S.p.A. with registered office in Bolzano, Via Antonio Pacinotti 12 - 39100 - tax code, VAT number 01710910215;

PA ABS S.r.l., with registered office in Milan, Via Pola 9, 20124 tax code, VAT number 02690660309;

PA Expertise S.r.l., with registered office in Milan, Via Pola 9, 20124 tax code, VAT number 02204750976;

IRIDEOS S.p.A., with registered office in Milan, Viale Luigi Bodio 33/37, 20158 tax code, VAT number 09995550960;

IRIDEOS DATA CENTER ITALIA S.r.l. with registered office in Milan, Viale Luigi Bodio 33/37, 20158 tax code, VAT number 11920940969;

Brennercom Tirol GmbH, with registered office in Eduard-Bodem-Gasse 8 - A-6020 Innsbruck, VAT, ATU 628 358 19.

Alone the Controller(s), jointly the Joint Controllers or the "Retelit Group".

More information on the corporate structure of the Retelit Group, as well as contact details, can be found at www.retelit.it .

For any request regarding the processing of Data, it will in any case be possible to contact the Parent Company Retelit, by sending

• a registered letter with return receipt to the registered office
• a PEC to the address retelit@pec.retelit.com or
• an e-mail to the address privacy@retelit.it.

2. Data protection officer

The Retelit Group, in order to facilitate the relationship between you and each Data Controller, have designated a Personal Data Protection Officer (DPO) who can be contacted via

• PEC to the address retelit@pec.retelit.com - C.A. of the Data Protection Officer (DPO);
• e-mail, at dpo@retelit.it.

These contact methods are also made available on the website of the parent company Retelit www.retelit.it where any updates will also be posted.

3. Type of Data and Mode of Processing

The Contractors collect and process the following categories of Data:

NAVIGATION DATA:

The computer systems and software procedures necessary for the operation of our Websites automatically collect certain Personal Data, which is transmitted for the use of Internet communication protocols. This information does not individually allow us to recognize your Data but, when combined with data held by third parties, may make it possible to identify them. This category of Data includes, for example, the IP addresses or domain names of the computers used to connect to the Website and other parameters relating to your operating system and computer environment. This Data is used in order to obtain anonymous statistical information on the use of the website and to verify its proper functioning.

DATA VOLUNTARILY PROVIDED BY THE DATA SUBJECT

By connecting to our websites, you may be required to provide Data in order to access certain services or to make email requests. This involves the acquisition of your IP address and/or possibly other Data, which will be processed by the Data Controller exclusively to fulfill your requests and to provide our services or services we offer together with business partners. The Data provided may be disclosed to third parties only if the relevant disclosure is necessary to fulfill Your requests.

4. Cookie regulation

WHAT ARE COOKIES

Cookies are text files, containing small amounts of information, that are stored on the User's computer or mobile device when visiting a website. On each subsequent visit, cookies are sent back to the website that originated them ("first-party cookies"), or to another website and recognized by that website ("third-party cookies"). Cookies cannot retrieve any other data, nor can they transmit computer viruses or acquire e-mail addresses.

WHAT COOKIES ARE FOR

Cookies allow the website to "remember" Users for the duration of the visit (session cookies) or for multiple visits (persistent cookies).
Most of the cookies we use are session cookies and are used for the proper functioning of our websites. They are automatically deleted when you close your browser, while other types of cookies are stored on your computer's hard drive and can be read by the server that previously stored them. Thus, cookies are intended to store information regarding Users accessing our servers, making it easier and safer for them to consult and use the applications of our websites. In any case, the Companies' use of cookies is done in accordance with laws and regulations and for legitimate purposes such as storage for the time strictly necessary to transmit a communication or provide a specific service requested by the User.

5. Types of cookies, purposes and legal basis

6. Interaction with social networks and external platforms

Our websites may also incorporate social media plugins and/or buttons to enable easy sharing of content on the User's favorite social networks.
Such plugins do not set a cookie, but if it is already present on the User's computer they are able to read it and use it according to his settings.
The collection and use of information by these third parties is governed by their respective privacy policies to which please refer. Below are the social media links we use:

• Facebook
• Linkedin
• YouTube
• Instagram
• Twitter

7. Managing and deactivating cookies

When you first access any page on our Sites, you will see a banner that contains a simplified cookie policy.
By clicking on the "Reject All" or "Accept All" buttons, respectively, you will have the option of rejecting all cookies and/or accepting them while, by accessing the "Cookie Setup" feature of the banner (or clicking on the appropriate icon), you will be able to inquire about their use and/or proceed to disable them by changing the settings yourself.
To keep the default settings and continue browsing the site you can click the "X" at the top right of the banner.

You can manage your preferences on third-party cookies by also manually proceeding to change your browser configuration, according to the directions provided by the following providers:

• Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
• Google Chrome:https://support.google.com/chrome/answer/95647?hl=it
• Mozilla Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
• Safari: https://www.apple.com/legal/privacy/it/cookies/
• Microsoft Edge: https://support.microsoft.com/it-it/microsoft-edge/eliminare-i-cookie-in-microsoft-edge
• Opera: https://help.opera.com/en/latest/web-preferences/

Should you decide to disable or remove cookies, this action may make navigation less functional and/or some sections of our websites inaccessible.

8. How We Process Data

Your Data are collected, processed and stored in a lawful manner and for the purposes stated above with the aid of electronic and/or automated means, in such a way as to ensure their security and confidentiality.

9. Provision of Data

The provision of Data through cookies, except those collected through technical cookies, is done on the basis of your consent and is optional. In case of non-acceptance, refusal or subsequent deactivation of analytical, marketing and profiling cookies, you will still be able to browse the site, the performance of which may be reduced.

10. Recipients or categories of recipients

The Data may be made accessible to, brought to the attention of, and/or communicated to the following parties, who may be appointed by the Data Controllers - as appropriate - as processors, authorized persons for processing, co-processors, or will act as independent data controllers:

• employees or collaborators in any capacity, of the Group Companies;
• Subjects, natural or legal persons, of which the Companies make use for the performance of activities instrumental and/or related to enabling the navigation of the Websites;
• Third-party, autonomous controllers, in the event that you have consented to the use of third-party cookies. For more information about these autonomous controllers, please see their respective privacy policies as shown in the table;
• Public Administrations, Judicial Authorities, Police Forces, for the performance of institutional purposes, within the limits established by law or regulations.

11. Where we process Data

Data are stored in archives located in countries of the European Union.

Certain third-party cookies, however, may result in the transfer of related information outside the European Economic Area (EEA), particularly to the United States. In such cases, Data may be transferred by the Companies, to countries and/or international organizations, which guarantee a level of protection of personal data deemed adequate by the European Commission, or on the basis of other appropriate safeguards, such as, for example, standard contractual clauses adopted by the European Commission or the provision of your consent and/or any other means permitted by the relevant legislation, including adherence to the certification mechanism of the "EU-U.S. Data Privacy Framework."

12. How long we process the Data

Cookies may be stored for different periods of time, depending on the purpose for which they are collected by the Companies, in accordance with the time-to-time applicable privacy regulations. The retention times are indicated in the tables attached to this policy, while for third-party cookies, the retention period is indicated by them, on the relevant websites.

13. Your Rights

During the period in which the Data Controllers carry out the processing of your Data, you, as a data subject, may, at any time, exercise the rights provided in Articles 15 to 22 of the GDPR:

1. Right of Access: You have the right to obtain confirmation as to whether or not there is any processing concerning your Data, and, if applicable, the right to receive any information concerning the processing;
2. Right to Rectification: You have the right to have your Data rectified if it is incomplete or inaccurate;
3. Right to be Forgotten: in certain circumstances, You have the right to obtain the deletion of Your Data, if it is not relevant to the continuation of the contractual relationship and/or necessary to fulfill a legal obligation to which the Data Holders are subject and/or for the establishment, exercise and/or defense of a right in court;
4. Right to Limitation of Processing: You have the right to obtain the limitation of processing concerning your Data, in the cases provided for in Article 18 of the GDPR;
5. Right to portability: You have the right to receive personal data about you in a structured, commonly used, machine-readable format and request its transmission to another data controller, if technically feasible.
6. Right to object to processing carried out on the basis of legitimate interest: You have the right to object, at any time, for reasons related to your particular situation, to the processing of your Data, if based on the lawful condition of legitimate interest, unless there are legitimate reasons for the Data Controllers to continue the processing, which override the interests, rights and freedoms of the data subject, such as the establishment, exercise or defense of a right in court.
7. Revocation of consent in relation to processing carried out for marketing purposes: You have the right to revoke at any time any consent you may have given to the processing of your Data by clicking the appropriate link in the website's cookie banner or by sending specific request to privacy@retelit.it.

14. Right to file a complaint with the Guarantor

In the event that you believe that your rights under the GDPR have been violated, you have the right to file a complaint with the Garante per la Protezione dei Dati Personali, in the manner indicated on the Garante's website accessible at www.garanteprivacy.it.

15. Final Provisions.

The Retelit Group reserve the right to amend and/or update this policy also on the basis of developments in the applicable data protection legislation, as well as in the face of any changes in the corporate structure of the Group. The updated version of the disclosure can always be found on the Retelit Group website to the following link: https://www.retelit.it/it/privacy/cookie-policy .