POLITICA GENERALE DI PRIVACY PER GLI UTENTI Powersoft S.p.A.

Privacy Policy of Powersoft S.p.A.

Powersoft S.p.A. collects some Personal Data from its Users.

Owner and Data Controller

Powersoft SpA, Via Enrico Conti n.5 - 50188 Scandicci (FI), Italy

Owner contact email: [email protected]

Types of Data collected

Among the types of Personal Data that Powersoft S.p.A. collects, by itself or through third parties, there are: Trackers; number of Users; city; device information; session statistics; latitude (of city); longitude (of city); browser information; Usage Data; email

address; Data communicated while using the service; first name; last name; profession; country; state; field of activity; User ID; answers to questions; name; language; user content; contact info.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Powersoft S.p.A.

Unless specified otherwise, all Data requested by Powersoft S.p.A. is mandatory and failure to provide this Data may make it impossible for Powersoft S.p.A. to provide its services. In cases where Powersoft S.p.A. specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools — by Powersoft S.p.A. or by the owners of third-party services used by Powersoft S.p.A. serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through Powersoft S.p.A.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes

strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Powersoft S.p.A. (administration, sales, marketing, legal, system

administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent

activity, as well as the following: Analytics, Displaying content from external platforms, Tag Management, User database management, Advertising, Hosting and backend infrastructure, Contacting the User, Managing data collection and online surveys, Interaction with external social networks and platforms and Information collection.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Advertising

This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on Powersoft S.p.A, possibly based on User interests.

This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.

Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside Powersoft S.p.A. For more information, please check the privacy policies of the relevant services.

Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

Salesforce (Salesforce.com, Inc.)

Salesforce is an advertising service provided by Salesforce.com, Inc. Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics 4 (Google Ireland Limited)

Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of Powersoft S.p.A, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.

Personal Data processed: browser information; city; device information; latitude (of city); longitude (of city); number of Users; session statistics; Trackers.

Place of processing: Ireland – Privacy Policy – Opt Out.

Contacting the User

Contact form (Powersoft S.p.A.)

By filling in the contact form with their Data, the User authorizes Powersoft S.p.A. to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data processed: city; country; email address; field of activity; first name; last name; profession; state; User ID.

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of Powersoft S.p.A. and interact with them.

This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Google Fonts (Google Ireland Limited)

Google Fonts is a typeface visualization service provided by Google Ireland Limited that allows Powersoft S.p.A. to incorporate content of this kind on its pages.

Personal Data processed: Trackers; Usage Data. Place of processing: Ireland – Privacy Policy.

Google Maps widget (Google Ireland Limited)

Google Maps is a maps visualization service provided by Google Ireland Limited that allows Powersoft S.p.A. to incorporate content of this kind on its pages.

Personal Data processed: Trackers; Usage Data. Place of processing: Ireland – Privacy Policy.

Hosting and backend infrastructure

This type of service has the purpose of hosting Data and files that enable Powersoft S.p.A. to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Powersoft S.p.A.

Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

ArubaCloud (Aruba S.p.A.)

ArubaCloud is a hosting service provided by Aruba S.p.A.

Personal Data processed: various types of Data as specified in the privacy policy of the service. Place of processing: Italy – Privacy Policy.

Microsoft Azure (Microsoft Corporation)

Microsoft Azure is a hosting service provided by Microsoft Corporation.

Personal Data processed: various types of Data as specified in the privacy policy of the service. Place of processing: United Kingdom – Privacy Policy.

Information collection

Pendo.io, Inc.

Pendo.io is a product analytics and user engagement platform provided by Pendo.io Inc. It enables businesses to track and analyze the usage of their digital products, gain insights into user behavior, and improve the overall user experience.

Pendo.io collects data to understand how users interact with the digital products and services offered by Powersoft S.p.A. This data is used to generate reports and provide valuable insights to Powersoft S.p.A. It helps them to make data-driven decisions, optimize their product offerings, and enhance user satisfaction.

Additionally, Pendo.io may utilize the collected data to personalize and contextualize advertisements within its own advertising network. This allows Powersoft S.p.A. to tailor ads and promotions based on user's preferences and behavior.

For more detailed information about Pendo.io's data handling practices and privacy policies, refer to these pages: Privacy Policy/

Terms of Use/ RETENTION:

By default, Pendo retains Personal Data about you for 7 years as long as you have an open account with them or as otherwise necessary to provide you with our Services. In some cases they retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. They may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Data Retention Policy

Interaction with external social networks and platforms

This type of service allows interaction with social networks or other external platforms directly from the pages of Powersoft S.p.A.

The interaction and information obtained through Powersoft S.p.A. are always subject to the User’s privacy settings for each social network.

This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

It is recommended to log out from the respective services in order to make sure that the processed data on Powersoft S.p.A. isn’t being connected back to the User’s profile.

Facebook Like button and social widgets (Meta Platforms Ireland Limited)

The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Meta Platforms Ireland Limited

Personal Data processed: Trackers; Usage Data. Place of processing: Ireland – Privacy Policy.

Managing data collection and online surveys

This type of service allows Powersoft S.p.A. to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.

The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.

These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.

Data provided via online forms, managed directly (Powersoft S.p.A.)

Powersoft S.p.A. makes use of online forms that can be used to collect Data about Users.

Personal Data processed: answers to questions; city; contact info; country; email address; first name; language; last name; name; profession; Trackers; Usage Data; user content.

Tag Management

This type of service helps the Owner to manage the tags or scripts needed on Powersoft S.p.A. in a centralized fashion. This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

Google Tag Manager (Google Ireland Limited)

Google Tag Manager is a tag management service provided by Google Ireland Limited. Personal Data processed: Trackers; Usage Data.

Place of processing: Ireland – Privacy Policy.

User database management

This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to Powersoft S.p.A, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving Powersoft S.p.A.

Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on Powersoft S.p.A.

Pardot (Salesforce.com, Inc.)

Pardot is a User database management service provided by Salesforce.com, Inc. Pardot may use Trackers to recognize and track Users behavior, as well as, to help deliver personalized ads and content. Users may opt out of Pardot’s use of Trackers for

advertising purposes by visiting the Salesforce Audience Studio Opt-Out page or following the instructions provided by YourOnlineChoices and AdChoices.

Personal Data processed: Data communicated while using the service; device information; email address; Trackers; Usage Data. Place of processing: United States – Privacy Policy – Opt out.

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Cookie Policy

Powersoft S.p.A. uses Trackers. To learn more, Users may consult the Cookie Policy.

Further Information for Users

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies: Users have given their consent for one or more specific purposes.

provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;

processing is necessary for compliance with a legal obligation to which the Owner is subject;

processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;

processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Further information about retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.

Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period

whenever required to fulfil a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The rights of Users based on the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following, to the extent permitted by law:

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.

Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.

Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.

Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.

Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.

Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a

structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another

controller without any hindrance.

Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be

communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Powersoft S.p.A. or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, Powersoft S.p.A. may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, Powersoft S.p.A. and any third-party services may collect files that record interaction with Powersoft S.p.A. (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Powersoft S.p.A. and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number

— allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through Powersoft S.p.A. (or third-party services employed in Powersoft S.p.A.), which can include: the IP addresses or domain names of the computers utilized by the Users who use Powersoft S.p.A, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT

environment.

User

The individual using Powersoft S.p.A. who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Powersoft

S.p.A. The Data Controller, unless otherwise specified, is the Owner of Powersoft S.p.A.

Powersoft S.p.A. (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by Powersoft S.p.A. as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Legal information

This privacy policy relates solely to Powersoft S.p.A, if not stated otherwise within this document. Latest update: July 06, 2023