Pursuant to Article 13 of EU Regulation 679/2016 General Data Protection Regulation (the “Regulation”) Otiara, as Data Controller (hereinafter: “Otiara” or “Site Manager”), provides you with the following information regarding the cookies installed on the sites www.otiara.com.

1 - WHAT ARE COOKIES

Cookies are text files that are sent from a web server (i.e. the computer where the website visited is “hosted”) to the user’s browser (Internet Explorer, Firefox, Google Chrome, etc.) and stored on the device, fixed or mobile (computer, smartphone, tablet), used for the user’s navigation. The cookie allows the Site to identify the user’s device, through the information stored in it, every time the user reconnects to the Site through that device.

Through the use of cookies, we can make it easier for the user to navigate the Site, as well as analyze their preferences and tastes by checking their navigation, and consequently offer products and services that are more consistent with the interests and expectations of the user.

Cookies can be "session" cookies (when they are stored exclusively for the duration of the browsing session on the site and are deleted when the browser is closed), or "permanent" cookies (when they are stored for a longer period of time, until they expire or until they are deleted by the user). Furthermore, cookies can be installed by the site that the user is visiting (so-called first-party cookies) or they can be installed by other websites (so-called third-party cookies).

Cookies do not collect information that directly identifies the user. In fact, Otiara cannot trace any directly identifying personal information (e.g. name, surname) through cookies unless provided directly by the user.

2 - WHAT TYPES OF COOKIES DOES OTIARA USE

Technical navigation or session cookies

Otiara uses technical navigation or session cookies to allow you to navigate and use the Site normally and efficiently. These cookies allow, for example, to make a purchase or, if you are a registered user, authentication to access the reserved areas of the Site. These cookies do not require the acquisition of prior and express consent from the user as they are strictly necessary to provide the service requested by the user of the Site.

Technical functionality cookies

Otiara uses technical functionality cookies that allow navigation based on the criteria you have selected (for example, the language or the products you have selected for purchase) in order to improve the services provided by the Site. On the Site, these cookies allow you to be recognized on subsequent visits, based on your express request. Functional cookies are not essential to the functioning of the Site, but they improve the quality and experience of navigation. These cookies do not require the acquisition of prior and express consent from the user as they are strictly necessary to provide the service requested by the user of the Site.

Analytical cookies

Otiara, as the manager of the Site, uses third-party analytical cookies to collect information on the use of the Site by users (number of visitors, pages visited, time spent on the site, etc.) to process statistical analyses, on an aggregate basis, on the number of users and how they navigate our Site. The criteria for masking the origin of the IP address have been adopted for the use of these cookies. These cookies do not require the acquisition of prior and express consent from the user.

Third-party profiling cookies

Otiara uses third-party profiling cookies (i.e. cookies that are issued and managed by parties other than Otiara) in order to send advertising messages in line with the preferences expressed by the user during navigation. This category of cookies also includes third-party social cookies that allow you to collect information about the user's use of social networks. The use of these cookies requires the express and informed consent of the user.

3 - CHARACTERISTICS OF THE COOKIES USED BY OTIARA ON THE SITES

a. Technical cookies installed through the site:

Cookie: Analytics from the Google Analytics platform

Purpose: Collects aggregate information on the pages visited by users and any other actions that they may take on these pages. It does not collect personal data relating to the user, but only data in anonymous form. The collection of this data is aimed at improving the user's browsing experience.

Type and Setting: 3rd Party | Settings: The IP address has been anonymized (in this way the IP address is masked at the origin) and therefore the possibility of accessing disaggregated data is inhibited at the origin; the account has been set so as not to share data with Google; the Google Analytics advertising service has been deactivated.

Duration: Persistent

User consent: Not required

Further information and links to third-party information and consent forms: FOR GOOGLE: Google's privacy policy is available at the following URL: https://www.google.de/intl/it/policies/privacy/ .

You can disable Google Analytics cookies by downloading a specific browser plug-in available at the following URL: https://tools.google.com/dlpage/gaoptout

Cookies: Clarity technical cookies

Purpose: Collects data to process aggregate statistics (tracks clicks, mouse movements in real time and page scrolling, records the pages visited, the actions performed by the user on the page, the type of device and browser used). The data is transmitted in a completely anonymous form.

Type and Setting: 3rd Party

Duration: Persistent

User Consent: Not Required

Further information and links to third-party information and consent forms: For more information, please consult the extended privacy policy https://clarity.microsoft.com/term

b. Profiling cookies installed via the site:

Google Adwords

Purpose: Cookies installed to study and improve advertising in order to send the user messages in line with their interests

Type and setting: 3rd party

Duration: Persistent

User consent: Required

Further information and links to third-party information and consent forms: Google Adwords: More information, also in relation to the methods with which to deactivate said cookies, can be found at the following link: https://support.google.com/adwords/answer/2407785?hl=it To select/deselect the cookie click http://www.google.com/settings/ads

Microsoft Bing

Purpose: installs cookies to study and improve advertising in order to send the user messages in line with their interests.

Type and setting: 3rd party

Duration: Persistent

User consent: Required

Further information and links to third-party information and consent forms: Microsoft Bing: Further information, including how to disable these cookies, can be found at the following link: http://advertise.bingads.microsoft.com/en-us/privacy-policy

Facebook

Purpose: uses cookies to offer the user sharing and “like” features on their dashboard.

Type and setting: 3rd party

Duration:

User consent: Required

Further information and links to third-party information and consent forms: Facebook: For more information, see https://www.facebook.com/about/privacy

Hotjar

Purpose: Collects data to process aggregate statistics (tracks clicks, mouse movements in real time and page scrolling, records the pages visited, the actions performed by the user on the page, the type of device and browser used). The data is transmitted in a completely anonymous form.

Type and setting: 3rd party

Duration:

User consent: Not required

Further information and links to third-party information and consent forms: Hotjar: For more information, please consult the extended privacy policy https://www.hotjar.com/privacy

Clarity

Purpose: Collects data to process aggregate statistics (tracks clicks, mouse movements in real time and page scrolling, records the pages visited, the actions performed by the user on the page, the type of device and browser used). The data is transmitted in a completely anonymous form.

Type and setting: 3rd party

Duration:

User consent: Not required

Further information and links to third-party information and consent forms: Clarity: For more information, please consult the extended privacy policy https://clarity.microsoft.com/terms

4 - MANAGING COOKIE PREFERENCES

When you access any page of the Sites, there is a banner containing a summary of the cookies used by Otiara.

By providing your authorization via the banner, you provide your consent to the use of profiling cookies.

Please note that your consent will only be requested upon your first access to the Sites: subsequently, thanks to the use of a technical cookie, we will store your consent to allow you to directly access the pages of the Sites upon your return (your right to deactivate/activate cookies at any time or to delete them remains unchanged: in this case, upon your return, the Site will request your consent again). You can in any case modify and manage your cookie preferences by accepting or refusing to receive the cookies you prefer, by selecting the appropriate “Yes/No” box in the “consent” column of the table above, where permitted.

You can also find out the information and methods for disabling third-party cookies by clicking on the links in the column “Further information and links to third-party information and consent forms” in the table above. After this operation, however, some functions of the web pages may not be performed correctly.

5 - HOW TO CHANGE BROWSER SETTINGS ON COOKIES

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 so that you are warned of the presence of a cookie, thus being able to decide whether to accept it or not; you can also automatically refuse all cookies by activating the appropriate option in the browser. It is also possible to delete specific cookies that have already been stored in the browser, or block the storage of cookies on your computer by specific websites, or block third-party cookies. Below we report the methods offered by the main browsers:

CHROME

Run the Chrome Browser Click on the menu in the browser toolbar next to the URL entry window for navigation Select Settings Click on Show Advanced Settings In the “Privacy” section click on the “Content Settings” button In the “Cookies” section you can change the following settings relating to cookies: Allow local data saving Modify local data only until the browser is closed Prevent sites from setting cookies Block third-party cookies and site data Manage exceptions for some websites Delete one or all cookies For more information visit the dedicated page.

MOZILLA FIREFOX

Run the Mozilla Firefox Browser Click on the menu in the browser toolbar next to the URL entry window for navigation Select Options Select the Privacy panel Click on Show Advanced Settings In the “Privacy” section click on the “Content settings” button In the “Tracking” section you can change the following settings relating to cookies: Ask sites not to perform any tracking Notify sites of your willingness to be tracked Do not communicate any preference regarding the tracking of personal data From the “History” section you can: By enabling “Use custom settings” select to accept third-party cookies (always, from the most visited sites or never) and to store them for a specific period (until they expire, until Firefox is closed or to ask each time) Remove individual cookies stored For more information visit the dedicated page.

SAFARI 6

Run the Safari Browser Click on Safari, select Preferences and press on Privacy In the Block Cookies section specify how Safari should accept cookies from websites To see which sites have stored cookies click on Details For more information visit the dedicated page.

SAFARI IOS (MOBILE DEVICES)

Run the Safari iOS Browser Tap on Settings and then Safari Tap on Block Cookies and choose between the various options: “Never”, “Third-party and advertisers” or “Always” To delete all cookies stored by Safari, tap on Settings, then Safari and finally on Delete Cookies and data For more information visit the dedicated page.

OPERA

Run the Opera Browser Click on Preferences then on Advanced and finally on Cookies Select one of the following options: Accept all cookies Accept cookies only from the site you are visiting: third-party cookies and those sent from a domain other than the one you are visiting will be rejected Never accept cookies: all cookies will never be saved. For more information visit the dedicated page.

6 - WHO PROCESSES YOUR DATA

The data collected using cookies may be processed by Otiara employees and collaborators, as authorised data processors. Such data may also be processed by companies we trust that carry out technical and organisational tasks on our behalf. These companies are our direct collaborators and act as external data controllers. In particular, in the context of data processing carried out via the Sites, you may contact Otiara to find out who is responsible for processing for the management and technical maintenance of the Site. The data collected using cookies will not be disclosed.

7 - TRANSFER OF YOUR DATA OUTSIDE THE EUROPEAN UNION

The data collected using Google cookies will be transferred outside the European Union (e.g. to the United States). The applicable privacy legislation provides that your specific consent is not required for the transfer to third countries when the transfer of your data is necessary for the performance of a contract concluded between the data subject and the data controller (Article 49, paragraph 1, letter (b) of the Regulation), or for the performance of pre-contractual measures adopted at the request of the data subject; it is carried out to a country that guarantees an adequate level of protection (Article 45 of the Regulation) or on the basis of the adoption of adequate guarantees (Articles 46 and 47 of the Regulation), and in particular on the basis of the adoption of binding rules for groups of companies, the adoption of contractual clauses approved by the European Commission or adherence to the guarantees provided for by the Privacy Shield agreement with the USA. carried out towards a country that guarantees an adequate level of protection (Article 45 of the Regulation) or on the basis of the adoption of adequate guarantees (Articles 46 and 47 of the Regulation), and in particular on the basis of the adoption of binding rules for groups of companies, the adoption of contractual clauses approved by the European Commission or adherence to the guarantees provided for by the Privacy Shield agreement with the USA. The transfer of your data towards third countries will therefore take place in compliance with the guarantees, measures and rights provided for (i) by the Privacy Shield agreement for the United States; (ii). By simply making a request to the references indicated in point 10), you may receive more information on the transfer of your data and on the guarantees provided for their protection as well as on the means to obtain such data or the place where they were made available.

8 - WHAT ARE YOUR RIGHTS

By sending a communication to the addresses listed below in point 10), you may at any time exercise the rights referred to in Articles from 15 to 22 of the Regulation, including:

• obtain confirmation as to whether or not personal data concerning you are being processed.

• obtain access to your personal data and the information indicated in art. 15 of the Regulation.

• obtain the rectification of inaccurate personal data concerning you without undue delay or the integration of incomplete personal data

• obtain the erasure of personal data concerning you without undue delay.

• obtain the restriction of the processing of personal data concerning you.

• be informed of any rectification or erasure or restriction of processing carried out in relation to personal data concerning you.

• receive the personal data concerning you in a structured, commonly used and machine-readable format.

• object at any time, for reasons relating to your particular situation, to the processing of personal data concerning you.

In particular, your right to withdraw at any time any consent to processing provided and to object to our analysis activities remains unchanged.

9 - WHO CAN YOU CONTACT TO LODGE A COMPLAINT

We remind you that, if you believe that the processing of your data violates the provisions of the Regulation, you can always lodge a complaint with the Data Protection Authority ( www.garanteprivacy.it ), or with the Data Protection Authority of the country in which you habitually reside, work or where the alleged violation occurred.

10 - THE DATA CONTROLLER AND THE DATA PROTECTION OFFICER

Otiara, who can be contacted at [email protected]. For more information regarding the processing of your data carried out via the Site, we invite you to read our Privacy Policy.

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