1. Data Controller

Marco Cerulli Consulting, CHE - 207.456.046, Via Ferrera 46, 6612 Ascona, Switzerland.

1.2 Types of Data Collected

The Personal Data collected through the online and offline services, documents, software, platform, and websites (collectively, "Services") provided by A4ManagementTools, M arco Cerulli Consulting, and any of our affiliates/partners, either independently or through third parties, include: Cookies, Usag e Data, first name, last name, email, IP address, browser information, and device information. For more details, please refer to the dedicated sections of this privacy policy. Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed prior to the data collection. Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this Appli cation. Unless otherwise specified, all Data requested by this Application is mandatory. If the User refuses to provide it, it may be impossible for this Application to provide the Service. In cases where this Application specifically states that some Data is optional, Users are free to refrain from communicating such Data without any consequence on the availability or functioning of the Service. Users who have doubts about which Data is mandatory are encouraged to contact the Data Controller. The use of Cookies – or other tracking tools – by this Application or the owners of third - party services used by this Application, unless stated otherwise, serves to provide the Service requested by the User, in addition to the other purposes described in this document and the Cookie Policy, if available. The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through this Applicatio n and declares to have the right to communicate or broadcast them, thus relieving the Data Controller of all responsibility towards third parties. Privacy Policy of A4ManagementTools

2. Methods and Place of Data Processing

The Data Controller adopts appropriate security measures to prevent unauthorized access, disclosure, modification, or destruc tion of Personal Data. These measures include encryption, access controls, firewalls, and regular audits. Data is processed at the operational offices of the Data Controller and any other locations where the parties involved in the processing are located. For further information, please contact the Data Controller. Data processing is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the indicated purposes. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of individuals involved in the organization of this Application (administrative, sales, marketing, legal, system administrators) or external parties (such as third - party technical service providers, mail carriers, hosting providers, IT companies, communication agencies) appointed, if necessary, as Data Processors by the Data Controller. An updated list of Data Processors can always be requested from the Data Controller.

3. Legal Basis of Data Processing

The Data Controller processes Personal Data related to the User if one of the following conditions applies:

• The User has given consent for one or more specific purposes; Note: In some jurisdictions, the Data Controller may be allowed to process Personal Data without the User's consent or any of the legal bases specified below, as long as the User does not obje ct (“opt - out”) to such processing. However, this is not applicable when the processing of Personal Data is governed by European data protection legislation;

• The processing is necessary for the performance of a contract with the User and/or for any pre - contractual obligations thereof;

• The processing is necessary to comply with a legal obligation to which the Data Controller is subject;

• The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official a uthority vested in the Data Controller;

• The processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party.

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

It is always possible to ask the Data Controller to clarify the specific legal basis that applies to each processing operatio n and to specify whether the processing is based on the law, required by a contract, or necessary to enter into a contract.

4. Place of Data Processing

Data is processed at the operational offices of the Data Controller and any other places where the parties involved in the processing are located. For more information, please contact the Data Controller. The User's Personal Data may be transferred to a country other than their own. To obtain further information about the place of processing, the User can refer to the section detailing the processing of Personal Data. The User has the right to obtain information regarding the legal basis for transferring Data outside the European Union or to an international organization governed by public international law or established by two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to safeguard their Data. If any such transfer takes place, the User can find more information by checking the relevant sections of this document or by inquiring with the Data Controller using the contact details provided at the beginning.

5. Retention Period

Data is processed and stored for as long as required by the purposes for which it was collected. Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the contract has been fully executed.

• Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained as long as needed to fulfill such purposes. The User can obtain further information regarding the legitimate interests pursued by the Data Controller in the relevant sections of this document.

When processing is based on the User's consent, the Data Controller may retain Personal Data longer until such consent is rev oked. Furthermore, the Data Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obliga tion or by order of an authority. Once the retention period expires, Personal Data will be deleted. Therefore, the right to access, the right to erasure, the r ight to rectification, and the right to data portability cannot be enforced after the retention period expires.

6. Purposes of Data Processing

The User's Data is collected to allow the Data Controller to provide its Services, as well as for the following purposes: Statistics and Contacting the User. To obtain detailed information about the purposes of processing and the Personal Data relevant to each purpose, the User may refer to the relevant sections of this document.

6.1 Details on the Processing of Personal Data

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

• Service Provision as user account management, execution of the main functions of the software and user access and use of the platform.

• Support and Customer Service such as responding to service requests and technical support, managing support tickets.

• Billing and Payment Management how to issue invoices, process payments, manage subscriptions and renewals.

• Communications with Users, such as sending notifications regarding service or platform updates, maintenance notices and security alerts, responding to requests for information.

• Marketing and Promotions, such as sending newsletters and consensual promotions, customising offers according to their needs and analysing users' preferences in order to improve the services offered to them.

• Analysis and Service Improvement such as collecting needs from users, analysing usage data to improve platform functionality and monitoring service performance.

• Security and Fraud Prevention as monitoring suspicious activity, implementing security measures to protect user data, and fra ud prevention and detection.

• Compliance and Legal Compliance as compliance with applicable laws and regulations, responding to requests from competent aut horities, and retaining data as required by law.

• Customisation of the User Experience, as adaptation of software functionality to the needs expressed by users and personalise d suggestions.

• Customer Relationship Management (CRM) as maintaining customer relationships, managing customer information to improve intera ction.

• Research and Development as use of data to develop new functionalities and improve existing ones, analysis of usage trends to innovate the service in contact with real needs.

• Integration with Third Party Services as to ensure the functioning and synchronisation of data with other platforms used by users and the sharing of selected data with selected partners to provide additional functionality specifically requested.

• Backup and Data Recovery such as performing regular data backups, data recovery in case of loss or damage.

7. User Rights

Users may exercise certain rights regarding their Data processed by the Data Controller. In particular, Users have the right to:

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

• Object to data processing. 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. Further details are provided in the specific section below.

• Access their Data. Users have the right to learn if Data is being processed by the Data Controller, obtain disclosure regardi ng 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, under certain circumstances, to restrict the processing of their Data. In this case, the Data Controller will not process their Data for any purpose other than storing it.

• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Data Controller.

• 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 an y hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract to which the User is a party, or on pre - contractual obligations thereof.

• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority or take legal action.

7.1 Details on the Right to Object

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Data Controller, or for the purposes of the legitimate interests pursued by the Data Controller, 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 without providing any justification. To learn whether the Data Controller is processing Personal Data for direct marketing purposes, Users can refer to the relevant sections of this document.

8. How to Exercise User Rights

To exercise their rights, Users can direct a request to the contact details of the Data Controller provided in this document. Requests are processed free of charge and will be addressed by the Data Controller as early as possible and always within one month.

9. Additional Information About Data Processing

• Defense in court. The User's Personal Data may be used for legal purposes by the Data Controller in court or in the stages leading to possible legal action arising from improper use of this Application or the related Services. The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

• Specific information. At the User's request, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data.

10. System Logs and Maintenance

For operation and maintenance purposes, this Application and any third - party services it uses may collect system logs, which are files that record interactions and may also contain Personal Data, such as the User IP address.

11. Information Not Contained in This Policy

More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time.

12. Response to "Do Not Track" Requests

This Application does not support “Do Not Track” requests. To determine whether any of the third - party services utilized support them, Users are encouraged to review the respective privacy policies of those services.

13. Changes to this Privacy Policy

The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users on this page and, if possible, through a notification sent via one of the contact details held by the Data Controller, where technically and legally feasible. Therefore, please regularly check this page, referring to the date of the last modification indicated at the bottom. Should the changes affect processing activities whose legal basis is consent, the Data Controller will collect the User's consent again, if necessary. The Italian version of this document is authoritative. The English version is provided solely for ease of reading.