Garda Estates srl, via Porto 29, Moniga del Garda                  P.IVA 04395200985 REA 611357

Information on the protection of personal data and the use of cookies pursuant to Regulation (EU) 2016/679 ("GDPR")

Dear Customer,

Garda Estates Srl, with registered office at Via Porto 29 - 25080 Moniga Del Garda (BS) (hereinafter, the "Company"), is the Data Controller of the data you provide when registering on the site, or otherwise acquired in the course of providing the services you may access. Requests or communications to the Data Controller may be sent to the email address privacy@gardaestates.it.

Access to the site does not require entering your personal details.

To use the online 'contacts' service and to access other additional services, you will need to enter your personal data in specific sections of the site.

The data entered will be processed with security measures appropriate to current technological standards and in compliance with the obligations set out by Regulation (EU) 2016/679 on the protection of personal data ("GDPR").

According to the indicated regulations, such processing will be based on the principles of fairness, lawfulness, and transparency, and the protection of your privacy and your rights. The following information refers only to this website and does not concern other websites that may be consulted by the user through redirect links placed on the pages of our site. No data resulting from the consultation of the web service is communicated or disseminated.

Pursuant to Article 13 of the GDPR, we therefore provide you with the following information:

1. The Company collects and processes your personal data for purposes necessary or instrumental to the provision of the services you have requested and provided through this site, including by communicating the data to third-party companies referred to in art. 5 of this notice (appointed by the Company as data processors) for the technical and administrative management of the services. Your data may be processed for internal purposes such as compiling registry lists, bookkeeping, invoicing, creditor management to fulfill all obligations required by current regulations, statistical purposes, communications, and additional services explicitly requested by you.
   The legal bases for processing, depending on the case, may be your consent, the execution of a contract to which you are a party, or the fulfillment of legal obligations to which the Company is subject as Data Controller.
2. The processing of your data may also take place: (a) to send information and commercial offers for services similar to those you purchased when accessing the Site, unless you object to this processing by sending an email to privacy@gardaestates.it and, where you give your express consent, (b) to send information and commercial offers, advertising and informational material, carry out commercial communications, including interactive ones, conduct direct sales or placement activities for products or services, including those of third parties.
3. Processing will be carried out both manually and using electronic tools, in compliance with all necessary precautions to ensure the security and confidentiality of the information.
4. Your data may be processed within our Company by all those appointed in writing by the Data Controller and trained on the obligations of the Privacy Law.
5. The data may be communicated to third parties, exclusively for technical and operational needs strictly related to the above purposes and in particular to the following categories of subjects: a) Entities, professionals, companies, or other structures appointed by us for processing related to the fulfillment of administrative, accounting, commercial, and management obligations related to the ordinary conduct of our economic activity, also for credit recovery purposes; b) Public authorities and administrations for purposes related to the fulfillment of legal obligations; c) Banks, financial institutions, or other entities for whom the transfer of data is necessary for the performance of our Company's activities, particularly in relation to the fulfillment, by us, of contractual obligations undertaken towards you.
6. Your personal data will be stored on servers available to the Company located within the European Union. The Company does not transfer personal data to countries outside the European Union.
7. The personal data concerning you will be kept for the entire duration of your contractual relationship with the Company. After the termination of the contractual relationship, the Company will retain the personal data relating to the execution of the contract for the fulfillment of contractual and legal obligations, including tax obligations.
   Subsequently, the personal data relating to the execution of the contract will be kept for a period not exceeding the limitation period provided by law in order to possibly assert or defend a right in court.
8. The provision of your personal data is optional, it being understood that refusal to disclose the data or to give consent to the processing referred to in point 1 of this notice will make it impossible for us to conclude the contract and provide any requested services and to fulfill legal obligations. In case of refusal of the processing of personal data referred to in art. 2 of this notice, the processing will be limited to the full execution of the obligations arising from the provision of the services you requested, as well as the fulfillment of obligations provided for by laws, regulations, and EU legislation.
9. The Data Controller is Garda Estates Srl, with registered office at Via Porto 29 - 25080 Moniga Del Garda (BS).
   The list of any data processors is available at the Data Controller's offices and can be requested by sending an email to privacy@gardaestates.it
   
10. At any time you may exercise your rights towards the Data Controller, pursuant to Articles 15-22 GDPR, which for your convenience we summarize below. In particular, you have the right: to obtain the cessation of processing in cases where your personal data are processed for direct marketing purposes, including in relation to services identical to those already purchased from our Company (so-called right to object); to obtain information regarding the purposes for which your personal data are processed, the period of processing, and the subjects to whom the data are communicated (so-called right of access); to obtain the rectification or integration of inaccurate personal data concerning you (so-called right of rectification); to obtain the deletion of personal data concerning you in the following cases (a) the data are no longer necessary for the purposes for which they were collected; (b) you have withdrawn your consent to the processing of the data if they are processed on the basis of your consent; (c) you have objected to the processing of personal data concerning you in the event that they are processed for our legitimate interest; or (d) the processing of your personal data is not in compliance with the law. However, we point out that the retention of personal data by the Company is lawful if it is necessary to enable it to fulfill a legal obligation or to ascertain, exercise, or defend a right in court (so-called right to erasure); to obtain that the personal data concerning you are only stored without any other use being made of them in the following cases (a) you contest the accuracy of the personal data, for the period necessary to allow us to verify the accuracy of such personal data; (b) the processing is unlawful but you nevertheless object to the deletion of the personal data by us; (c) the personal data are necessary for the establishment, exercise, or defense of a right in court; (d) you have objected to the processing and are awaiting verification as to whether our legitimate reasons for processing prevail over those of the data subject (so-called right to restriction); to receive in a commonly used, machine-readable, and interoperable format the personal data concerning you processed by automated means, if they are processed by virtue of a contract or on the basis of your consent (so-called right to portability).

We also remind you that you have the right to contact the Data Protection Authority (Piazza Venezia, 11 - 00187 Rome) to assert your rights regarding the processing of your personal data.

Use of cookies

Cookies are small text strings that the websites visited by the user send to their device (usually to the browser), where they are stored to be sent back to the same websites upon the user's next visit.

While browsing a website, the user may also receive cookies on their device that are sent from sites or web servers other than the one being visited (so-called "third parties"), where certain elements (such as images, maps, sounds, specific links to pages of other domains) present on the site being visited may reside. The website https://www.gardaestates.it/ (hereinafter, the "Site") uses cookies to make its services simple and efficient for users viewing the Site's pages. Users who view the Site will have minimal amounts of information placed on the devices they use, whether computers or mobile devices, in small text files called "cookies" saved in the directories used by the User's web browser. There are various types of cookies, some to make the use of the Site more effective, others to enable certain features. By analyzing them in detail, our cookies allow us to:

store the preferences entered by the visitor;

avoid re-entering the same information multiple times during the visit, such as username and password;

The processing is carried out by the Data Controller using automated tools. With the exception of technical cookies, which are strictly necessary for normal browsing, the provision of data is left to the discretion of the visitor who decides to browse the Site after having read the brief information notice (so-called banner) and to use the services that involve the installation of cookies. The user can therefore avoid the installation of cookies, except for technical cookies,

by refraining from taking any action in correspondence with the banner or through the appropriate functions available on the various browsers, described in detail in this information notice.

Types of Cookies used by the Site

Technical Cookies (mandatory)

This type of cookie allows certain sections of the Site to function properly. They fall into two categories:

persistent and session:

persistent: once the browser is closed, they are not destroyed but remain until an expiration date

preset;

session: they are destroyed every time the browser is closed.

These cookies, always sent from our domain, are necessary to correctly display the site and in relation to the technical services offered, will therefore always be used and sent, unless the user changes the settings in their browser (thus affecting some functionalities or the display of the site's pages).

Analytical cookies

Cookies in this category are used to collect information about the use of the site. The Site will use this information for anonymous statistical analysis in order to improve the use of the Site and to make the content more interesting and relevant to users' preferences. This type of cookie collects data anonymously about user activity and how they arrived at the Site. Analytical cookies are sent by the Site itself or by third-party domains.

The Site uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). The information generated by the cookies about your use of the website (including your IP address in anonymous form) will be transmitted to and stored by Google on servers. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, but please note that this

it could compromise the ability to use certain features of this website. By using this website, you consent to the processing of your data by Google in the manner and for the purposes indicated above. It is possible to prevent Google from detecting a cookie generated by your use of this website (including your IP address) and processing such data, by downloading and installing the browser plugin available at the following web address:

http://tools.google.com/dlpage/gaoptout?hl=en

Third-party service analytics cookies

These cookies are used to collect information about users' use of the Site in anonymous form such as: pages visited, time spent, sources of traffic origin, geographic origin, age, gender, and interests for marketing campaign purposes. These cookies are sent by third-party domains external to the Site.

This type of cookie integrates functionalities developed by third parties within the pages of the Site, such as icons and preferences expressed on social networks for the purpose of sharing site content or for the use of third-party software services (such as software for generating maps and other software that offers additional services). These cookies are sent by third-party domains and partner sites that offer their functionalities among the pages of the Site.

Pixel markers

This website may use "pixel tags," which are small graphic files that allow monitoring of website usage. A pixel tag can collect information such as the IP address (Internet Protocol) of the computer that downloaded the page where the tag appears; the URL (Uniform Resource Locator) of the page where the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that retrieved the pixel tag; and the identification number of any cookie present on the computer and previously set by that server. If correspondence is exchanged with users via email messages that support the HTML format, "format detection" technology may be used, which allows pixel tags to communicate whether the recipient has received and opened the message.

Profiling cookies

These are cookies necessary to create user profiles in order to send advertising messages in line with the preferences expressed by the user within the pages of the Site.

The Site, according to current regulations, is not required to request consent for technical and analytics cookies that do not allow user identification, as they are necessary to provide the requested services. For all other types of cookies, consent can be given by the User in one or more of the following ways:

By accepting and expressly revoking consent to the use of cookies within the Site. Click here: www.gardaestates.it/pagina-di-revoca

Through specific configurations of the browser used or of the related software programs used to browse the pages that make up the Site. Click here: www.gardaestates.it/pagina-di-revoca

By modifying the settings in the use of third-party services. Click here: www.gardaestates.it/pagina-di-revoca

The aforementioned solutions may prevent the user from using certain features or viewing parts of the Site.

Websites and third-party services

The Site may contain links to other websites that have their own privacy policies which may differ from the one adopted by the Site and therefore the Site is not responsible for these sites. For example, the Site provides links to the social pages of Garda Estates Srl on Facebook, Instagram, Twitter, Google+, LinkedIn, Pinterest, and Youtube. Please note

that clicking on the links to such social networks may result in the installation of cookies by these third parties. For more information, please refer to their respective cookie policies.

Cookies used by the Site

Below is the list of all cookies used by this Site:

COOKIE NAME EXPIRATION

To disable cookies by revoking consent on the Site click here: www.gardaestates.it/pagina-di-revoca

This page is visible, via a link at the bottom of all pages of the Site pursuant to art. 13 GDPR and in compliance with the simplified procedures for the information notice and the acquisition of consent for the use of cookies published in the Official Gazette no.126 of June 3, 2014 and related register of measures no.229 of May 8, 2014

Privacy Policyand Withdrawal of consents

Garda Estates srl, via Porto 29, Moniga del Garda                  P.IVA 04395200985 REA 611357