The following Privacy Policy (the "Policy") – pursuant to Article 13 of the European General Regulation on the Protection of Individuals in Relation to the Processing of Personal Data and the Free Movement of Such Data and repealing Directive 95/46/EC (hereinafter referred to as "GDPR") m– pursuant to Article 13 of the European General Regulation on the Protection of Individuals in Relation to the Processing of Personal Data and the Free Movement of Such Data and repealing Directive 95/46/EC (hereinafter referred to as "Site").

SPlease read this Policy carefully before using this Site because it explains how we will process your personal data (the "Data").

Free2move eSolutions S.p.A. (hereinafter "F2MeS" or the "Company") with registered office in Milan, Piazzale Lodi, 3 – 20137 Milan, is the Controller of the Data collected during the navigation activity on the Site and the provision of our services. Regarding the information collected through cookies, please refer to our cookie policy.

1. Information on the processing of personal data

The Data will be processed to administer and fulfil user requests and for general administration purposes by the Company as data controller under relevant data protection legislation, as follows:

Purposes	Data categories/data (mandatory data are marked with a *)	Legal basis and consequences of failure to provide data
A. To register the user's account, use the services offered by the Company, manage the products purchased by the user and manage the user's account. To send the user communications relating to the services (e.g. order confirmation, invoices, any other information relating to the management of the service contract)	Name*, surname *, e-mail*, residential address*, telephone number*, country of residence, company tax code or VAT number*, credit card details*, payment options*	The data processing is necessary for the registration of the user account and to provide the user with the requested service/product. Failure to provide such data will make it impossible for us to create the user account and subsequently enter into any service agreements with you.
B. General administration	Name*, surname*, e-mail*, telephone number*, e-mail address*, Country of residence*	This data processing is carried out in our legitimate interest in managing our business and services, and we do not believe that your interests or fundamental rights override (or outweigh) our legitimate interests. Failure to provide such data will make it impossible for us to provide you with any service. You may exercise your right to object within the limits established by law.
C. To manage users’ enquiries and requests and enable them to request technical support	Contact details*, order/subscription information	This data processing is in our legitimate interest to respond to your enquiries and we do not believe that your interests or fundamental rights override (or outweigh) our legitimate interests. Failure to supply such data will make it impossible for us to provide you with the requested assistance. The user is authorized to exercise his/her right to object within the limits established by law.
D. To manage requests for installation/technical support	Installation address and location of the product purchased by the user	This data processing is in our legitimate interest to respond to requests for installation and/or technical support on the product purchased and we do not believe that the interests or fundamental rights of users override (or outweigh) our legitimate interests. Failure to provide such data will make it impossible for us to provide you with the assistance requested. You may exercise your right to object within the limits established by law.
E. To take on, exercise or defend legal claims (e.g. debt collection)	The information depends on the relevant exercise of rights (e.g. information about the sums we need to collect and the debtor concerned)	This data processing is in our legitimate interest in order to establish, exercise or defend our rights and we do not believe that your interests or fundamental rights limit (or outweigh) our legitimate interests. Failure to provide such data will make it impossible for us to provide you with any service. The user is authorized to exercise his/her right to object within the limits established by law.
F. To improve services	Aggregated data that does not identify you as to your use of the services	This data processing is in our legitimate interest to improve our products/services and we do not believe that your interests or fundamental rights limit (or outweigh) our legitimate interests. Failure to provide such data will make it impossible for us to improve our services. The user is authorized to exercise his/her right to object within the limits established by law.
G. Website Maintenance and Troubleshooting	Navigation data such as IP address, location - country, information about the pages visited within the Website, access time on the Website, browsing time on each page, clickstream analysis	This data processing is in our legitimate interest for the maintenance of the website and when you report a problem with our website. We do not believe that your interests or fundamental rights limit (or outweigh) our legitimate interests. Failure to provide such data will make it impossible for us to solve your problem. The user is authorized to exercise his/her right to object within the limits established by law. It is information we need.
H. To send newsletters from the Company	Name, Surname, Email address	This data processing will take place only with your consent. Failure to provide such data will make it impossible to send our newsletter. This will in no way affect the provision of the services purchased by you. You may unsubscribe whenever you wish, using the unsubscribe link included in our emails.
I. To send you marketing emails about the Company's products/services similar to those purchased and/or products/services of the Company's subsidiaries and/or affiliates, as well as its partner companies belonging to the automotive sector.	Email address	This data processing is in our legitimate interest and is permitted by law only with reference to the e-mail contact data provided in the context of the sale of a product or service, on condition that the products / services are similar to those that have been the subject of the sale, and the interested party, after being adequately informed, does not oppose such use either initially or in relation to subsequent communications. You may unsubscribe whenever you wish, using the unsubscribe link included in our emails.
J. To send commercial and/or promotional communications about the Company's products and services, as well as to conduct market research. The processing of Data for these marketing purposes will be carried out through traditional methods (phone calls with an agent) and automatic ones (e-mail, automated calls, SMS, MMS, fax and any other IT channel such as websites, mobile apps).	Contact details (email address, address, telephone number)	This data processing will take place only with your consent. Failure to provide such data will make it impossible to send marketing communications. This will in no way affect the provision of the services purchased by you.
K. To analyse behaviour patterns, habits and propensity to consume, in order to customize our direct marketing activities as indicated above (profiling for marketing purposes)	Information relating to the use of the services (time, value and place of the charge), contact details	This data processing will take place only with your consent. Failure to provide such data will make it impossible for us to personalize our marketing communications for you. This will in no way affect the provision of the services purchased by you.
L. To communicate the Data to subsidiaries or associated companies of the Company, and to partner companies belonging to the automotive sector, which may process them in order to send commercial and / or promotional communications about their products and services, as well as to conduct market research	Contact details	This data processing will take place only with your consent. Failure to provide such data will prevent us from sending information about you to third parties for their own marketing purposes. This will in no way affect the provision of the services purchased by you.
M. To measure customer satisfaction with our products/services through a targeted survey	Contact details	This data processing is in our legitimate interest to evaluate your satisfaction with a service provided by the Company at your request. Failure to provide such data will make it impossible for us to send customer satisfaction surveys. You may exercise the right to object within the limits established by law.

The Data may be processed by automatic or electronic means.

2. How we process personal data

The data processing is carried out with an information system and with organizational and logical methods strictly related to the purposes indicated; the Company has implemented all technical and organizational security measures to ensure the confidentiality, integrity, availability and resilience of data processing, in compliance with Article 32 of the GDPR.

3. Data retention

Your Data will be kept in compliance with relevant legislation, for a period not exceeding that necessary to achieve the purposes for which they are processed. The criteria for determining the data retention period take into account the legal processing period and applicable laws (e.g. tax or anti-money-laundering laws), the statute of limitation periods and the nature of legitimate interests where they are the legal basis of the processing.

Your Data may be kept for a longer period than originally planned, in the event of disputes or requests by the relevant authorities.

The Data processed for the provision of the newsletter service and for the other marketing purposes described above will be kept until consent is withdrawn.

Given that your Data is only held for as long as necessary, it will be deleted, aggregated or made safely anonymous once it is no longer needed.

4- Communication of personal data

The Data will be communicated to the persons authorized to process it within the Company's staff.

The Data may be communicated by the Company exclusively for the purposes indicated and, where necessary, to the following categories of subjects:

• Companies belonging to the same group and/or members of F2MeS
• Technical service providers
• Provider in hosting
• Installation Service Providers
• Customer Support Service Providers
• Service providers for marketing activities
• Service providers for marketing activities
• Accounting, administrative, legal, tax and financial consultants
• Debt collection service providers
• Where necessary, the competent judicial authorities
• Where necessary, public administrations and supervisory and supervisory authorities

Your Data will not be publicly disclosed.

The entities belonging to the categories listed above may act, as appropriate, as data processors (and in this case will receive the appropriate instructions from the Company) or as independent data controllers. In the latter case, the Data will be communicated only with the express consent of the parties concerned, except in cases where the communication is mandatory or necessary pursuant to applicable law or for purposes for which the consent of the party concerned is not required.

5. Transfer of data outside the EEA

If it is instrumental to the pursuit of the purposes indicated above, your Data may also be transferred abroad to companies located either inside or outside the European Economic Area (EEA). Some of these jurisdictions may not guarantee the same level of data protection as European laws. In this case, the Company undertakes to ensure that the data is treated with the utmost confidentiality, if necessary entering into agreements that guarantee an adequate level of protection and / or adopting the standard contractual clauses provided by the European Commission.

To receive information about our guarantees mentioned above and to obtain a copy of the respective guarantees, please contact us by email privacy@f2m-esolutions.com.

6. Rights of the interested parties

You will have the right at any time to exercise the following rights and therefore:

• To obtain confirmation about the processing of your Data and, in this case, about access to the Data, pursuant to Article 15 of the GDPR (Right of access);
• To obtain the correction of inaccurate Data concerning you or, taking into account the purposes of the processing, the supplement of incomplete Data (Right to rectification);
• To obtain the deletion of your Data where one of the reasons applies pursuant to Article 17 of the GDPR (Right to be forgotten);
• To obtain the limitation of the processing of your Data, when one or more cases apply pursuant to Article 18 of the GDPR (Right to restriction);
• To object to the processing of your Data on grounds relating to your particular position, where applicable (Right to object);
• To receive your Data in a structured, commonly used and machine-readable format, and to transmit such data to another controller in the cases and within the limits set out in Article 20 of the GDPR, where applicable (Right to data portability)

In addition, where provided, the user has the right to withdraw his/her consent to the processing of his/her Data, at any time, without prejudice to the lawfulness of the processing based on the consent given before the withdrawal.

According to the GDPR, the Company may not charge for compliance with any of the requests mentioned in this paragraph, unless they are clearly unfounded or excessive and repetitive. In the event that you request more than one copy of your Data or in the event of excessive or unfounded requests, the Company may: (i) charge a reasonable fee, considering the administrative costs incurred to fulfil the request; or (ii) refuse to comply with the request. In such cases the Company will inform you of the costs before fulfilling the request.

The Company may request additional information before fulfilling requests if it needs to verify the identity of the person who made them.

To exercise your rights, you may send an e-mail stating "PRIVACY" as the subject, to privacy@f2m-esolutions.com. Remember that you can use the unsubscribe link included in our newsletters and marketing emails.

Without prejudice to any administrative or legal remedy, you also have the right to lodge a complaint with the relevant Supervisory Authority (the Guarantor for the protection of personal data), if you believe that the processing of your Data is in violation of the GDPR. More information is available on the https://www.garanteprivacy.it/.

In any case, the Company is interested in knowing the reasons for the complaint and asks to use the aforementioned contact methods before contacting the authorities, in order to anticipate and resolve any disputes amicably and promptly.

7. Link to third party websites

The third-party websites accessible from this website are under the responsibility of third parties. The Company declines all responsibility for requests and / or the provision of Data to third-party websites.

This website may also contain iFrames with third-party content. The Company is not responsible for third-party content presented in iFrames. This information is the sole responsibility of the owners of such websites.

The Company has no control or responsibility for the content of independent websites and provides this external content to its visitors for their convenience. As a result, when you visit a page containing such content, you may be presented with cookies by these third-party websites.

The Company does not control the distribution of these cookies.

Please check the third-party cookie policy and privacy policy for more information.

8. Link to social networks

Our website includes links to social networks.

In order to protect your data when visiting our website we do not use social plug-ins. Instead, HTML links are embedded in the website, allowing for easy sharing on social media platforms. Embedding the link prevents a direct connection with various social media network servers when you open a page from our website. When you click on one of the buttons, a browser window will open, directing the user to the respective website of the service provider on which (after logging in) for example, you can use the "Like" or "Share" button".

For more information on the purpose and scope of data processing and the further use of data by the provider and their websites, as well as on the user's rights and possible settings to protect the user's privacy, please refer to the data protection information of the respective service provider.

9. Changes

The Company reserves the right to partially or completely change the Privacy Policy, or simply to update its content (for example as a result of changes in current legislation). We will post any updates on this website. You should therefore review them periodically for changes to our Privacy Policy.

10. Contacts

Free2move eSolutions S.p.A. – Piazzale Lodi, 3 – 20137, Milan – Italy.

You can contact the Company by writing to the following e-mail address privacy@f2m-esolutions.com.

4 March 2022