Legislative Decree 196/2003 Code regarding the protection of personal data and Regulation (EU) 2016/679. Hereby, Lucidivia Srls C.F. /P.IVA 15938351002, with registered office in Via Antonino Saetta 23 00173 Rome, intends to inform users visiting the site www.lucidivia.com (hereinafter the “Site”) of the policy adopted regarding the protection of personal data, emphasising its commitment and attention with reference to the protection of the privacy of visitors to the Site. Navigation within the Site is free and does not require any registration, with the exception of some areas where the user can freely and expressly provide a series of data concerning him to access specifically identified services. Therefore, where the visitor intends to provide his personal data to access these additional services, he will be expressly informed pursuant to art. 13 of Legislative Decree 30 June 2003, n. 196 and Regulation (EU) 2016/679, Code regarding the protection of personal data, with indication (by way of example) of the purposes and methods of use of the data by us as well as the right to request at any time the cancellation of the data or the updating of the same. Information on the protection of personal data Pursuant to and for the purposes of Legislative Decree no. 196/2003 Code on the protection of personal data and Regulation (EU) 2016/679 (hereinafter the “Code”), we provide the following information.

1. The Data Controller and Data Controller The Data Controller of personal data is Lucidivia Srls CF/PIVA 15938351002, with registered office in Via Antonino Saetta 23 00173 Rome, (hereinafter “Lucidivia Srls”). 2. Types of personal data processed To access the Site it is not necessary to proceed with any registration. However, there are services within the Site for the use of which it is necessary to provide their data (e.g. your data may be requested to access online sales services, to register on the Site, to contact us, or request information, etc.). Where necessary, the specific consent of the user to the relative use of the data will be obtained. By way of example, personal data may be requested such as name and surname, address, telephone number, tax code, VAT number, e-mail address and other information that the user agrees to provide to use the services of the Site by filling out a specific registration form. The personal data collected online will be used only for the purposes indicated during registration. The personal data provided during registration and/or online sales remain available to the consumer for verification, modification or cancellation and for the exercise of any other right provided for by Article 13 of Law No. 675/96 and ss.mm. The data is entered in a customer registry at the time of the first order or registration. With reference to such data, Lucidivia Srls communicates that: – the collection and processing of consumer data are necessary if he wants to place an order for products or to access particular services (in this case a refusal of the consumer would make it impossible to fulfil the order or access to the service), while it is optional in any other case; – the consumer’s data may be processed in writing and on electronic, telematic, magnetic and paper medium; their processing will take place in relation to contractual needs, including the payment, payment and delivery of the ordered products, to fulfil obligations Provided for by law or provided by the Authorities and, on explicit authorisation, for the purposes of interactive commercial and promotional information and for market research. – consumer data will not be disclosed except to the subjects necessary or functional for the performance of the contractual activity of Lucidivia Srls: banking institutions for the management of payments and forwarders for the transport, in the place indicated by the consumer, of the products purchased, third parties who provide activities and services necessary for the execution of the services necessary for Lucidivia Srls for the completion of purchase and sale transactions. The data relating to the connection and navigation within the Site (such as the URI-Uniform Resource Identifier addresses 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 (good result, error, etc.) and other parameters relating to the operating system and the user’s computer environment) are collected for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct operation and are deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the Site: with the exclusion of this eventuality, the data will be deleted after the time useful for the provision of the services illustrated on the Site. With reference to the data relating to navigation within the Site, see also the following point 6 concerning the profiling tools used by the Site.

3. Optionality of the provision of personal data The provision of personal data is generally optional (e.g. to receive advertising/informative communications). Only in certain cases can the failure to provide data make it impossible to access specific services and obtain what may be requested. The user is required to indicate on the Site only personal data relating to him. If personal data of third parties are indicated, the user expressly declares and acknowledges having obtained from such third parties the consent to the processing of the relative personal data by us, or other data controllers (as requested from time to time in the specific information provided at the time of data collection).

4. Data processing methods and scope of communication The data may be processed both electronically and on paper. We guarantee the lawful and correct processing of the personal data provided through the Site, in full compliance with current legislation, as well as the maximum confidentiality of the data provided during registration. All information collected is transmitted in a secure connection so as to prevent it from being intercepted by strangers. The security of the Site is guaranteed and certified by a leading company among Internet security service providers. The data will not be communicated or disclosed to third parties unless within the limits and under the conditions expressly indicated in the information from time to time provided to the user and subject to authorisation by the same.

5. Links to other sites This information is provided only for the website www.lucidivia.com, and not also for other websites that may be consulted by the user through links. The owner of the Site cannot be held responsible for the personal data provided by users to external subjects or to any websites linked to this Site.

6. “Profiling” and/or personalisation tools The owner of the Site does not carry out any promotional and/or advertising communication activity without the prior express consent of the user. The Site uses automatic data collection systems, such as “Cookies”, flash cookies and browser cookies: these are devices that are sent from the website server to the user’s browser (Internet Explorer, Mozilla Firefox, Google Chrome, etc.) and stored on the hard drive of the user’s PC when they visit the Site. The cookie allows the Site to identify the user’s PC, through the information stored in it, whenever the User reconnects to the Site through the same PC. Through the use of cookies it is possible for us to facilitate the user’s navigation within the Site. Cookies do not collect information that directly identifies the user. In fact, we cannot, through cookies, trace any directly identifying personal information (e.g. name, surname), if not provided directly by the user. In general, cookies differ depending on their duration, the domain that installed them and their function. According to their duration, they are distinguished: Session cookies: these are temporary files that are stored until the site is abandoned (or the browser is closed). Persistent cookies: these are files that are stored and maintained even after leaving the site and closing the browser. They are deleted only after the expiration date indicated in the cookie itself or in case of cancellation by the user. Based on the domain (website) that installed them, they are distinguished: “owner” cookies: these are files that are installed on the user’s device directly from the site on which they are browsing. “Third-party” cookies: these are files that are installed from external sites, through a code integrated into the pages of the site you are browsing. Examples of third-party cookies are those installed by social plugins (e.g. Facebook or Twitter, for sharing content), or visit analysis cookies. According to their function, they are distinguished: “technical” cookies which are functional to the operation of the site and can be grouped into: the essential “technical” cookies: they are essential for the proper functioning of the site pages. Without these cookies, some features may be compromised and access to content may be limited. They allow, for example, to keep track of the authentication carried out by a user. ii – “technical” functionality cookies: these are cookies used to store choices made by the user to improve navigation (for example the language, or pre-fill a form with the name used previously). This type of cookie may include personal information (for example, the username or e-mail address already filled in previously). Without these cookies some features and navigation between pages could be compromised or made slower. iii – “technical” performance cookies: These are cookies used to understand (i) if users who visit the site are new or have already visited the site before, (ii) how they use the site, (iii) how they move between pages, (iv) how long they stay on the pages and on the site, (v) from which geographical area they came to the site. The data collected by these cookies do not identify the user as a person, but are aggregated anonymously by the analysis tools. The deactivation of these cookies does not in any way compromise the functionalities offered by the Site. iv – “technical” cookies related to social widgets: some widgets made available by social networks (for example Facebook, Twitter, YouTube, Google +, Pinterest, Google Map, etc.) may use their own cookies to allow the operation of the connection to the social network. The deactivation of these cookies does not compromise the use of the site, exction in the sections where widgets can be installed (for example for video or map integration) and in some cases the possibility of quick content sharing or the possibility of commenting on certain areas of the site. “Profiling and advertising” cookies: these cookies are installed to show site visitors content related to their preferences. They can then be used to show advertising content targeted to the interests of the person. Cookies of this type work in collaboration with third-party sites and can track the user’s navigation on pages on different domains. Cookies of this type usually track the user’s IP address in addition to other information, some of which may be personal. Cookies are placed by the Site’s server and no one can access the information contained on it. Once saved on your computer, the cookie can only be read by the website that created it or, in the case of the use of third-party cookies, by the third-party servers that have installed the cookies).

6.1 What types of cookies do we use Technical cookies The Site uses technical cookies. They are cookies used in order to ensure better navigation on the Site or strictly necessary for the provision of services provided by the Site itself. In particular, the following are used: “owner” technical cookies (i.e. released by the Site) that allow us to memorise the choices made by the user to improve navigation. Analytical cookies, third parties (i.e. released by external websites not owned by us) that allow us to verify and store how visitors navigate within the Site, in aggregate and anonymous form. Thanks to these cookies we can improve the service we offer you, making sure that our users easily find the information they are looking for. Third-party social cookies (external websites not owned by us) necessary to allow social networks (Facebook, Google and Twitter) to control the interaction with social widgets on the website and therefore allow the interaction of the Site with social networks and external platforms. These cookies do not require the acquisition of the prior and express consent of the user as they are strictly necessary to provide the service provided by the site (art. 122, paragraph 1, of the Code). Profiling cookies The site also uses profiling cookies from other sites (in particular Google Analytics and Gigya). They are cookies aimed at creating profiles related to the user and understanding his preferences, also in order to improve the content of the Site. The use of these cookies requires the express and informed consent of the user (art. 122, paragraph 1, of the Code). The user, by accessing the Home Page (or another page) of the Site, viewing the cookie information banner present therein and reading the information provided, if he proceeds with the navigation (for example by clicking on the web page of the Site or on a link present there) provides his specific consent to the use of cookies. It is also considered a valid consent on the part of the user to have configured their Internet browser (e.g. Explorer, Firefox, Chrome) in order to accept the use of cookies (art. 122, paragraph 2, of the Code). We would like to point out that consent will only be requested on first access to the Site: subsequently, thanks to the use of a technical cookie, we will store the consent given to allow direct access to the pages of the Site at the next visit (the right to deactivate/activate cookies at any time, or to delete them (see point 6.5 below): in this case, upon the return of the user, the Site will request consent again).

6.2 Information on cookies released by the Site: Regarding the cookies used on the Site we provide the following information: 1) The domain name from which the Site server transmits cookies is www.lucidivia.com, for the cookies issued by this Site. For third-party cookies, see paragraph 6.3. 2) Purpose of the collection: cookies are used to allow easier and faster navigation inside, improve the experience of using the Site and the interaction with Social Networks (technical cookies). 3) Data collected: the following information is stored: the addresses in URI (Uniform Resource Identifier) notation 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 (good end, error, etc.) and other parameters related to the operating system and the user’s computer environment. 4) Validity of cookies: the Site uses both session cookies (i.e. cookies that are automatically deleted when the browser is closed), as well as permanent cookies (i.e. cookies that are stored until any deletion by the user), whose duration does not exceed six months in any case. 5) Need to accept cookies: the user’s consent to the use of technical cookies is not necessary and the acceptance of these cookies is optional; however, the non-acceptance of technical cookies, although it allows navigation, may not make it possible to release some content and functionality of the Site. 6) Data communication: the information collected through cookies is confidential and is not communicated to third parties. The Site uses technical cookies. They are cookies used in order to ensure better navigation on the Site or strictly necessary for the provision of services provided by the Site itself. These cookies do not require the acquisition of the prior and express consent of the user as they are strictly necessary to provide the service provided by the site (art. 122, paragraph 1, of the Code). 7) Profiling cookies: The site only uses profiling cookies from other sites (in particular Google Analytics). They are cookies aimed at creating profiles related to the user and understanding his preferences, also in order to improve the content of the Site. The use of these cookies requires the express and informed consent of the user (art. 122, paragraph 1, of the Code). The user, by accessing the Home Page (or another page) of the Site, viewing the cookie information banner present therein and reading the information provided, if he proceeds with the navigation (for example by clicking on the web page of the Site or on a link present there) provides his specific consent to the use of cookies. It is also considered a valid consent on the part of the user to have configured their Internet browser (e.g. Explorer, Firefox, Chrome) in order to accept the use of cookies (art. 122, paragraph 2, of the Code). We would like to point out that your consent will only be required on your first access to the Site: subsequently, thanks to the use of a technical cookie we will memorise your consent to allow you to directly access the pages of the Site upon your return (your right to deactivate/activate cookies at any time, or to delete them in this case, upon your return, the site will request your consent again). No other user profiling tools are used on this site (e.g. spyware).

6.3 Third-party cookies The Site uses so-called “third-party cookies”, or cookies that are released and managed by subjects other than us for the purposes of such subjects, including profiling.

6.4 Deactivation/cancellation of cookies via web browser It is in any case possible to deactivate/activate or delete cookies at any time by using the settings of your web browser. In particular, if you do not wish to receive cookies, you can set your browser in such a way that you are warned of the presence of a cookie and thus being able to decide whether to accept it or not; you can also automatically reject all cookies, by activating the appropriate option in the browser. To do so, you can consult the information in the browser user manual (c.d. Help Page) or follow the following instructions: Google Chrome 1. Click on “Tools” at the top of the browser window and select Options. 2. Click on the ‘Stuff’ tab, locate the ‘Privacy’ section, and select the “Content Settings” button. 3. Now select ‘Allow local data to set’. Microsoft Internet Explorer 6.0, 7.0, 8.0, 9.0 1. Click on “Tools” at the top of the browser window and select ‘Internet Options’, then click on the ‘Privacy’ tab. 2. To activate cookies in your browser, make sure that the privacy level is set to Medium or below,. 3. By setting the privacy level above the Medium you will disable the use of cookies. Mozilla Firefox 1. Click on “Tools” at the top of the browser window and select “Options”. 2. Then select the Privacy icon. 3. Click on Cookie, then select ‘I allow sites to use cookies’. Safari on OSX 1. Click on ‘Safari’ at the top of the browser window and select the “Preferences” option. 2. Click on ‘Security’ and then ‘Accept cookies. 3. Select “Only from site” Mozilla and Netscape on OSX 1. Click on ‘Mozilla’ or ‘Netscape’ at the top of the browser window and select the “Preferences” option. 2. Scroll down until you see cookies under ‘Privacy and security. 3. Select ‘Enable cookies only for the source site’. Labour 1. Click on ‘Menu’ at the top of the browser window and select “Settings”. 2. Then select “Preferences”, select the ‘Advanced’ tab. 3. Then select the ‘Accept cookies’ option. You can also manage your cookie preferences on http://www.youronlinechoices.com.

7. Place of data processing and scope of data communication The processing related to the services provided by the Site is carried out at the headquarters of Lucidivia Srls, indicated in point 1 above and is carried out by the processing officers of Lucidivia Srls. Some treatments will also be carried out at the headquarters of external suppliers of Lucidivia Srls in charge of carrying out activities related to the management and maintenance of the Site. For these purposes, the data may also be temporarily transferred abroad, in compliance with and with the guarantees provided for in articles 43 to 45 of the Code. We ask users to carefully read the information provided in the sections of the Site dedicated to the registration or collection of personal data to access certain services: in fact, the subjects to whom personal data may be collected are specifically indicated in this information, and possibly the other subjects who will process the personal data provided as independent data controllers.

8. Rights of data subjects You have the right to obtain information on the processing of your data, including, 1) obtain, without delay, confirmation of the existence or not of personal data concerning them; 2) obtain: a) the indication of the origin of the personal data, the purposes and methods of the processing, the logic of the processing carried out with the aid of electronic tools, the identification details of the owner or the managers, the subjects or categories of subjects to whom the data may be communicated or who may become aware of them as managers or agents; the updating, rectification or, if there is interest, the integration of the data; b) The cancellation, transformation into anonymous form or blocking of data processed in violation of the law; 3) oppose, in whole or in part, the processing of personal data concerning him, provided for the purposes of commercial information or sending advertising material or direct sales or for carrying out market research or commercial communication. You can exercise your rights at any time by sending an e-mail to info@lucidivia.com.

9. Applicable Law This Privacy Policy is governed by Italian law and in particular by the Code, which governs the processing of personal data, including held abroad, carried out by anyone established in Italy or carried out through instruments located in Italy. The Code guarantees that the processing of personal data is carried out in compliance with fundamental rights and freedoms, as well as the dignity of the data subject, with particular reference to confidentiality, personal identity and the right to the protection of personal data.

10. Revision clause We reserve the right to revise, modify or simply update, in whole or in part, at its sole discretion, in any way and/or at any time, without notice, this Privacy Policy also in consideration of changes to the laws or regulations on the protection of personal data. Changes and updates to the Privacy Policy will be notified to users on the Home Page of the Site as soon as they are adopted and will be binding as soon as they are published on the Site in this same section. We therefore ask you to regularly access this section to verify the publication of the most recent and updated Privacy Policy. The full text of Legislative Decree 30 June 2003, n. 196 is available on the website of the Guarantor for the Protection of personal data www.garanteprivacy.it/.