Privacy Policy and cookies

PRIVACY AND COOKIES POLICY

LEGAL INFORMATION AND ACCEPTANCE OF THE PRIVACY AND COOKIES POLICY

We wish to inform you by means of this Privacy and Cookie Policy of the processing of data that will take place in the course of your use of the Website www.sabait.it (hereinafter, the

"Website") and the SABA application (hereinafter, the "App"), of those that you will transmit to us in the process of registering with the Website and the App, and of those that will be used in the process of purchasing and providing services or products.

Use of the Web Site/App implies acceptance of this Privacy and cookie policy. SABA reserves

the right to modify or update this Privacy and cookie policy at any time, notifying the registered Users; the notice will be effective from the date indicated in the notice.

PRIVACY POLICY

1. BASIC INFORMATION ON DATA PROTECTION

DATA CONTROLLER

Saba Italia S.p.A.

The data controller may also be any other company in the Saba group, which will provide you with appropriate information on the protection of personal data when you purchase a product or service.

PURPOSE

• Manage User registration on the Website/App;
• Point you to the nearest car parks to your location;
• Managing the purchase of products or services through the Website/App;
• Manage and perform the performance of purchased products or services;
• Fulfilling obligations under current legislation;

-Where  you have given us consent to do so, to send you information about products or services of other companies in the mobility and automotive sector with which we cooperate and which may be of interest to you.

LEGITIMATION

-To manage User registration on the Website/App: User consent;

-To present you with the nearest car parks: User consent;

-To purchase services or products and to present them to you: execution of the contract;

- Processing necessary for the fulfilment of SABA's legal obligations;

-To inform you about other products or services of SABA or third parties and to send you personalised promotions: consent of the person concerned.

RECIPIENTS OF PERSONAL DATA

The personal data provided will not be passed on to third parties, except in the case of legal obligations or assignment

necessary for the execution of the contract.

Third party companies to which SABA entrusts services may have access to personal data, appointing them as data processors; these companies must act in accordance with SABA's operating instructions.

RIGHTS

You may exercise your rights of access, rectification, objection, cancellation, restriction of processing and portability of data in the cases and within the scope established by current

legislation by writing to dpo.saba.it@sabagroup.com. Consent given for the purposes set out above may be withdrawn at any time.

FURTHER INFORMATION

In the following paragraphs of the Data Protection Policy and Cookies Policy.

2. WHO IS THE CONTROLLER OF YOUR DATA?

Saba Italia S.p.A., with Tax Identification Number 08593300588, registered office in Via Abruzzi, 25, Rome is the Data Controller of the personal data that you submit to us for registration, that may be generated using the Website/App, as well as that processed in the process of

purchasing and providing services or products.

In the course of the procedure for the purchase of a product or service, the company with

which the contracting takes place will be identified, depending on the location of the car park, and will also be the Data Controller, which, in any case, will be carried out in accordance with this Privacy Policy.

SABA has appointed a Data Protection Officer (DPO) to whom, if you have any questions regarding the processing of your data, you can send an email at any time to

dpo.saba.it@sabagroup.com or write to the postal address above.

3. FOR WHAT PURPOSES DO WE PROCESS YOUR DATA? Registration as a user of the Website/App

If you register as a User on the Website/App, your data will be processed for the purpose of managing your registration as a User of the SABA Website/App and to manage the services

available to you as a User of the Website/App and which you can access through the private area of the Website/App.

If you wish, you can use your user profiles already created on social networks to register as a

User on the Website/App. In this case, the third-party social networks will share your data with SABA. In order to allow access and import of your data, you will have to identify and authenticate yourself on the social network from which your data will be extracted. We recommend that you review the Terms of Use and Privacy Policy of the social networks from which your data will be imported. Once the data has been imported and incorporated into your registered account, your data will be processed by SABA for the purposes described in this Privacy Policy.

Registering as a user implies that we may send you contractual, operational and informative communications.

The legal basis inherent in these processing operations is your consent, given in the registration process at the time of acceptance of the Privacy and Cookies Policy, or, where applicable, at the time of authorising the use of your third-party access data for registration to the Website and App.

Presenting the nearest car parks to your location

If you authorise us, through the Website and the App, we may use your location data to recommend the

nearest car park; we will always ask you for permission to use your location.

For the correct use of the App, it is recommended that you activate geolocalisation, so that the App will suggest the nearest car park. The data used in this case are geographical coordinates.

The legal basis for this data processing is your consent, which you provide when allowing the Website and App to access your location. You can change the configuration and revoke your consent to the use of your location at any time.

Purchase and provision of services or products

If you purchase services or products through the Website/App, your data will be processed to manage your purchase,

provide the services or products, process the payment and, where appropriate, issue the invoice or receipt.

The purchase and provision of services or products will presuppose that we will be able to send you contractual, managerial and informative communications, as well as handle your questions and requests through our support channels.

In order to initiate the payment process, it will be necessary to enter your credit card number; the payment will, however, take place via a third-party payment platform to which SABA will not have access.

Refusal to provide your personal data, as well as the transmission of inaccurate or incomplete data, may make it impossible for us to provide you with the services you have requested. In

this regard, we remind you that, as a User, you are responsible for the veracity of the data you have transmitted to us and for informing SABA of any change in them.

After you have purchased a service or product, your data will be processed to actually provide it to you:

-If the service requires the signing of a contract, it includes information on the processing of your personal data for the purpose of providing the service;

-If the product or service does not require the formalisation of a contract, you can find information on the processing of your personal data directly at each of our facilities.

In general, the processing of data necessary for the provision of products or services are:

-Contractual relationship management: your data will be processed for the conclusion of the contract, for related administrative, economic and fiscal management, including credit recovery;

-Video-surveillance system: the car parks are equipped with a video-surveillance system

evidenced by the signalling of video cameras and aimed at ensuring the security of property and buildings, it being understood that SABA has no obligation to guard parked property and vehicles;

-Car number plate reading system: the number plate will be detected by the relevant reading system in order to control access and manage the service or product purchased. Similarly, in some cases, the system will also allow exit from the car park;

-Telepass device reading system: you can access car parks using your Telepass device as a means of payment. Similarly, if you are a subscriber, you can also use your Telepass as a means of accessing the car park. If you do not wish to use your Telepass, you can remove it or ask SABA to include it in the list of disabled devices;

• Any other processing of data that may be related to the provision of the product or service, such as, handling of complaints, claims...

The legal basis for the processing of data is the contractual relationship, which, in order to be executed, requires the processing of your data.

Sending commercial communications concerning products or services of interest to you

If you expressly consent, your data may be processed for the purpose of sending you, by any means, selected information regarding offers and promotions of products and services of companies belonging to the SABA group, as well as of third party companies providing services connected to the mobility, automotive or parking sectors. In the latter case, your data will not be disclosed to third parties, as any communication will come directly from SABA.

Similarly, if you provide your consent during the process of purchasing a subscription, your personal data may be used to compile individual profiles in order to send you, by whatever means, personalised information regarding offers and promotions of services or products offered by the companies of the SABA group or by third-party companies providing services related to the automotive sector or specific to the parking sector.

Where available, the following detailed data may be incorporated into these profiles, whether provided directly by you or generated through your use of products and services of SABA, other SABA Group companies, or third parties: contact data (such as name, address, email);

additional information (such as hobbies); customer history (such as purchase data); vehicle data (such as number plate, or data generated during use of the SABA App); apps data; web data.

The legal basis for processing for commercial purposes is your consent, given during the registration process or, if applicable, by ticking the corresponding box in the contractual documentation.

Sending out popularity surveys

Your data may be processed for the purpose of contacting you to find out your opinion about the products or services you have purchased. The legal basis for data processing is the legitimate interest of SABA.

You may object to this data processing at any time by exercising your right to object by sending an e-mail to dpo.saba.it@sabagroup.com.

4. TO WHOM WILL WE DISCLOSE YOUR PERSONAL DATA?

If you do not purchase any products or services, your data will not be disclosed to third parties. Otherwise, your data may be disclosed:

- To the payment platform  operator, for the purpose of processing the latter; in this case, the legal basis is the proper development of the contractual relationship;

-Public administrations and police forces, if provided for by the applicable regulations;

-Ad Insurance, in the event of a claim within SABA's facilities (or, if applicable, third parties) and if provided for in the contractual relationship or type of claim;

• to the SABA group company that, depending on the location of the car park, is to provide the service or supply the purchased product; this company will be identified at the time of purchase, for the purpose of providing the product or service;
• If the service or product purchased so requires, to other companies in the SABA group for the purpose of applying loyalty policies specific to the service (this aspect will be detailed in the specific contract to be formalised);
• In any other case authorised by law or necessary for the proper performance of the contractual relationship.

In any case, service providers of the SABA group who are (or may be) appointed by SABA and who have the title of "Data Processor" may have access to your personal data. These service providers will process your personal data in accordance with SABA's instructions and will be obliged, in any case and expressly, to comply with the regulations in force, as well as to implement any technical measures necessary to guarantee the confidentiality of the information. The third parties in question collaborate with SABA in the provision of services relating to information systems, debt collection, marketing and professional services.

5. HOW LONG WILL WE KEEP YOUR DATA?

The data you provide when registering on the Website or the app will be retained for as long as you maintain your registration. You can unsubscribe via the Website by accessing your private area, i.e. by sending an email to dpo.saba.it@sabagroup.com.

If you decide to unsubscribe, if you have purchased services or products, or even if there are legitimate reasons, we will retain your data in blocked form until the applicable statute of limitations has expired. Thereafter, they will be deleted.

6. HOW DO WE PROTECT YOUR DATA?

SABA is committed to information security and has taken the necessary technical and organisational protective measures, depending on the level of technology available, to prevent the alteration, loss, misuse, unauthorised processing and access or theft of data.

7. WHAT RIGHTS DO YOU HAVE WITH RESPECT TO YOUR PERSONAL DATA?

You may exercise your rights at any time, as well as revoke your consent, where appropriate and in accordance with the terms of applicable law.

• Right of access: allows you to confirm whether we are processing your personal data and, if so, which ones;
• Right of rectification: allows you to help us correct errors and amend data that may be inaccurate or incomplete;
• Right of deletion: allows you to request the deletion of your data; in this case, SABA will stop processing them, unless other legitimate reasons prevail that allow processing or the law does not provide for their retention. In the latter case, they will remain duly blocked;

• Limitation of processing: allows, in the presence of the conditions provided for by the regulations, the processing of your data to be interrupted. In this case, the data may, however, be kept duly blocked for the purpose of handling complaints or your defence in the event of administrative activities or legal action;
• Right to object: allows you to ask us to stop processing your personal data in relation to which we believe we have a legitimate interest in processing it, for example as in the case of offers of products or services. We will stop processing your data, unless there are compelling legitimate grounds, or it is necessary to deal with complaints or our own defence in case of administrative or judicial actions. In these cases, the data will remain duly blocked;

• Portability: allows you to receive your personal data in a structured, commonly used and machine-readable format, so that you can pass it on to another data controller;
• Withdraw consent: this allows you to stop processing that you had previously authorised, e.g. in the case of commercial communications from third-party companies with which we cooperate.

To exercise your rights, you can contact SABA at the postal address given in paragraph 1 or at by e-mail (email: dpo.saba.it@sabagroup.com) to the Data Protection Officer.

In any case, if you consider that a breach of data protection legislation has been committed in the processing of your data, you may lodge a complaint with the Garante per la protezione dei dati personali.

COOKIES POLICY

This website employs its own and third-party cookies, which help us understand how you use it and show you content based on your browsing history. You can accept them, reject them or configure your preferences.

In the management tool, accessible from the bottom of the website, you can find detailed information about the cookies that may be installed, as well as the purpose of each one.

If the use of cookies is refused, you will still be able to access the content, although the quality of the site's operation may be reduced.WHAT ARE COOKIES?

Cookies are small data files generated on the device (computer, smartphone or tablet) from which a website is accessed and in which certain information is stored.

2. WHAT KIND OF COOKIES CAN THIS WEBSITE USE? There are different types of cookies:

-Depends on the entity managing the device or domain from which cookies are sent to the user's device and processes the data obtained:

• Own Cookies: These are those that are sent to the User's device from a domain or device managed by SABA and from which the service requested by the User is provided;
• Third-party cookies: these are those that are sent to the User's device from a device

or from a domain that is not managed by SABA, but by another entity that processes the data obtained via cookies.

-Depending on the length of time that activity remains in the terminal device:

o Session cookies: these are those designed to collect and store data while the user accesses a website and remain on the user's device during the visit (for example, until the user closes the browser and ends the visit);

• Persistent cookies: these are those that are stored on the User's device and can be accessed and processed for a period that can vary from a few minutes to several years.

- Depending on the purpose for which data obtained through cookies is processed:

oTechnical cookies: these are those necessary for the proper functioning of the website and for the use of the different options and services it offers, e.g. identifying the User's session,

personalising the page interface, allowing video content to be played or displaying the banner warning of the use of cookies, etc;

o Customisation/preference cookies: these are those that allow the user to access the service with certain predefined general characteristics depending on a number of criteria in the user's device, such as, for example, the language, the type of browser through which the website is accessed, the regional configuration from where the website is accessed, etc;

o Analysis/statistical cookies: these are those which, processed by the owner of the website or by third parties, make it possible to follow and analyse the behaviour of the User of the website, quantify the number of Users, carry out a statistical measurement and analysis of its use, by means of aggregate or statistical information;

o Advertising/marketing cookies: these are those that enable the management, in the most effective form possible, of the advertising spaces that, where appropriate, the owner has placed on the website based on criteria such as the content published or the frequency with which the ads are shown. This category also includes those called social cookies: these are necessary for external social networks (Facebook, Google, Twitter, Pinterest, Instagram, etc.) and their function is to control interaction with social widgets within the website.

3. HOW CAN YOU MANAGE COOKIES?

You can allow, block or delete cookies installed on your device at any time by accessing your browser settings. However, disabling cookies may affect the proper functioning of some sections of the Website.

Via the links below you can find information on how to deactivate cookies by changing your browser settings:

-Chrome:            https://support.google.com/chrome/answer/95647?hl=it

-Explorer:https://support.microsoft.com/it-it/help/17442/windows-internet-explorer- delete- manage-cookies