Annex A

PRIVACY POLICY

The data controller of users' personal data is Cramaro Holding S.p.a., with registered office Via Quari Destra 71/G I – 37044 Cologna Veneta (VR), registered at the Companies' Register of Verona, tax code and VAT number 04079350239 ("Cramaro", "Controller", "we" or "our").

This Privacy Policy describes how Cramaro collects, uses, stores, and protects the personal information of users ("User" or "you") who interact with our Cramaro tarpaulin system using the software application for Apple and Android smartphones ("App"). [cite: 13] We are committed to respecting and protecting your privacy. [cite: 14]

This document refers only to the processing of personal data associated with the functionalities of the App in connection with a Cramaro tarpauling system and has been prepared in compliance with the European Regulation (EU) 2016/679 (“GDPR”). [cite: 17, 18]

Data We Collect

We collect personal data communicated directly by the User at the time of authentication and received by Cramaro through the App, including: [cite: 20, 21]

Identification information: Name, surname, e-mail, and company. [cite: 23]
Usage data: Information concerning the use of Cramaro tarpaulin systems, maintenance, interventions, and User comments. [cite: 24]

Smartphone Functionalities & Location Services

The App may access certain smartphone functionalities exclusively to ensure its proper operation: [cite: 25]

Bluetooth Low Energy (BLE): Used for connection to the devices provided by the Data Controller. [cite: 25]
GPS Location Services: Access to location data is used solely at a local level on the device to enable BLE operation and to display the smartphone's position on a map to show the nearest service centers. [cite: 26]

Note: Location data are not collected, stored, transmitted or shared in any way by the Data Controller, nor are they associated with the user’s identity. [cite: 27]

Processing Purposes and Legal Basis

We use the personal information for the following purposes: [cite: 28, 29]

Providing App services upon authentication (Legal basis: Art. 6 (1) (b) GDPR - Execution of contract). [cite: 30, 36]
Support and troubleshooting. [cite: 31]
Diagnostics and diagnostics cycles (Legal basis: Art. 6 (1) (f) GDPR - Legitimate interest). [cite: 32, 37]
Displaying nearby Cramaro service points via geolocation. [cite: 33]
Compliance with legal obligations (Legal basis: Art. 6 (1) (c) GDPR). [cite: 34, 38]
Direct marketing activities by Cramaro Group companies (Legal basis: Art. 6 (1) (a) GDPR - Consent). [cite: 35, 40]

Data Recipients and Transfers

Users’ personal data may be disclosed to employees, Cramaro Group companies, IT providers, App developers, and legal/tax consultants. [cite: 51, 52, 53, 54, 55, 56] Data may be transferred to EU or non-EU countries with the guarantees set forth in Articles 45 and 46 of the GDPR. [cite: 61, 62]

Data Retention

Personal data will be stored for the duration of the applicable statutory limitation periods. [cite: 63, 64] For marketing purposes, data will be retained until the App is discontinued or until the User withdraws consent. [cite: 65]

User's Rights

Under articles 15-22 of the GDPR, the User is entitled to: [cite: 66, 67]

Confirm existence of data and obtain access. [cite: 69]
Request correction, integration, or erasure of data. [cite: 78, 80]
Request limitation of processing or data portability. [cite: 78, 79]
Object to processing on legitimate grounds or for marketing purposes. [cite: 81, 82]
Withdraw consent at any time. [cite: 87]
Lodge a complaint with the data protection authority. [cite: 83]

Controller’s Contacts

To exercise your rights or withdraw consent, you may contact the Controller at:

Cramaro Tarpaulin Systems S.r.l. A.S.U.
Via Quari Destra 71/G I – 37044 Cologna Veneta (VR), Italy
Email: privacy@cramaro.com

Consent withdrawal can also be exercised by deleting the account directly within the App. [cite: 88]