Privacy policy and information for the use of cookies pursuant to Arts. 122, paragraph 1 and 154, paragraph
1, lett. h], of the Personal Data Protection Code and pursuant to Art. 13 of Regulation (EU) 2016/679
Industrie Cartarie Tronchetti S.p.A. pays the utmost attention to the respect and protection of your privacy.
Below, we provide the information relating to the processing of personal data of Users [hereinafter, the “Users”] who interact with the Internet website www.foxy.eu [hereinafter, the “Site”] of Industrie Cartarie Tronchetti S.p.A, with particular reference to the processing of cookies collected through browsing.
This information, therefore, relates exclusively to the possible processing of Users’ personal data processed by Industrie Cartarie Tronchetti S.p.A. while browsing the Site.

1. Data Controller. The Data Controller of the personal data relating to Users of the Site is Industrie Cartarie Tronchetti S.p.A, with registered office in Piano della Rocca, 55023 Borgo a Mozzano [LU] Italy.

2. Purposes of data processing User data is collected and used to allow browsing the Site, to improve the browsing experience, and to respond to any requests and communications from Users through the “Contact Form”; on the web page www.foxy.eu.

3. Types of data processed

Browsing Data: The computer systems and software procedures used to operate this Site acquire, during their normal performance, some personal data whose transmission is implicit in the communication protocols of the Internet. This information is not collected with the intention of associating it with identified data subjects. However, by its nature, it could allow Users to be identified through processing and association with data held by third parties. This category of data includes the IP addresses or domain names of the computers used by the Users who connect to the Site, the URI [Uniform Resource Identifier] addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response given by the server [e.g. successful, error, etc.], and other parameters relating to the operating system and the IT environment of the User. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site, to check its correct functioning and to improve the browsing experience of Users, and are deleted immediately after processing. The data may be used to ascertain responsibility in case of hypothetical computer crimes against the Site.

Data provided voluntarily by Users: the optional, explicit and voluntary sending of data in the “Contact
Form” present on the Site entails the subsequent acquisition of the sender’s name, surname and email
address, necessary to respond to requests, as well as any other personal data included in the
communication. For the processing of data for these purposes, your consent is not required since the
processing is necessary for the execution of a contract of which you are a party or for the execution of
pre-contractual measures adopted at your request [Art. 6, paragraph 1, lett. b of the Regulation], as well
as, where applicable, to fulfill a legal obligation [Art. 6, paragraph 1, lett. c of the Regulation].

4. Faculty of providing data. Apart from what is specified for browsing data and for cookies, the User is free to provide his/her personal data in order to request the sending of informative material or other
communications.

5. Data processing. The processing is carried out through automated tools [e.g. using electronic procedures andmedia] for the time strictly necessary to achieve the purposes for which the data were collected and, inany case, in compliance with the relevant regulations in force. Specific security measures are observed to prevent the loss of data, the illicit or incorrect use thereof, and unauthorized access. The data are processed by employees authorized by the Data Controller and by any appointed data processors.

6. Security of personal data. Industrie Cartarie Tronchetti S.p.A. adopts security measures to protect the confidentiality, integrity, completeness and availability of personal data.

7. Processing of cookies. Cookies are small text strings that a website, when visited by a User, sends to the browser of the User’s terminal, where they are stored to then be re-transmitted to the same websites the next time the User visits them. While browsing a site, the User can also receive cookies on his/her terminal that are sent from different sites or web servers [so-called “third parties”], on which some elements may reside [such as, for example, images, maps, sounds, specific links to pages of other
domains] present on the site that the User is visiting. Cookies can have different functions:

◦ technical cookies allow the User to be remembered during his/her browsing of the website. The data
from these cookies do not require consent, as the processing is necessary for the execution of a contract
to which the data subject is a party.

◦ analytical cookies collect aggregate information relating to the parts of the Site visited most frequently,
and monitor the promotional messages conveyed by the Site itself, in order to improve the contents and
facilitate consultation. The data from these cookies are processed on the basis of your unique and
informed consent. Consent is provided by continuing on the Site following the closure of the
information banner on cookies. Pursuant to Art. 7 of Regulation (EU) 2016/679, consent can be
revoked at any time and in the same manner in which it is provided.

◦ profiling cookies are designed to create User profiles based on the browsing experience, not only on the
individual Site, but in general on the web as a whole, and are used to send advertising messages in line
with the preferences expressed by the User in the context of browsing the Internet. The data from these
cookies are processed on the basis of your unique and informed consent. Consent is provided by
continuing on the Site following the closure of the information banner on cookies. Pursuant to Art. 7
of Regulation (EU) 2016/679, consent can be revoked at any time and in the same manner in which it
is provided.

8. The cookies installed by the Site:

• Technical cookies: they can be divided into browsing or session cookies, which guarantee normal
browsing and use of the Site; analytics cookies, similar to technical cookies when used directly by the
Site manager to collect information, in aggregate form, on the number of Users and how they visit the
Site; functionality cookies, which allow the User to browse according to a series of selected criteria [for
example, the language] in order to improve the service provided. Prior consent from Users is not required to install these cookies.

• Third-party profiling cookies: these cookies allow the creation of an anonymous profile of Users based
on their browsing experience on this and all other Sites. In this way it is possible to provide you, during
your browsing activity, advertising targeted on your interests instead of generic advertising. These
cookies are not managed by our company and are called third-party cookies.

• Social network plug-in cookie links: Industrie Cartarie Tronchetti S.p.A. informs you that Social Network cookies are not present on the Sites owned by Industrie Cartarie Tronchetti S.p.A. and are not sent by the latter to the User’s terminal. These cookies, which are absolutely not essential for browsing purposes, are activated only when the relative web page is accessed, by clicking on the related icons, or by entering the respective social websites. For more details and to disable their being stored on the User’s terminal, please refer to the following:
– Facebook, LinkedIn, Twitter, YouTube, Instagram

However, please note that if you disable cookies, you will not have access to many features that make
this Site more efficient.
You can find below the details of the individual cookies sent by the Site and further information useful for understanding their use.

9. Communication of data to third parties.

Without prejudice to any processing carried out by third parties
acting on behalf of the Controller for the management of the Site, duly appointed as responsible for the
external processing, no data collected during browsing of the Site by Users shall be communicated or
disclosed to third parties.

10. Your rights.

Pursuant to Articles 15-22 of Regulation (EU) 2016/679, you have the right at any time to: [I] obtain confirmation of the existence or not of personal data concerning you; [II] know the purposes of
the processing and the methods, the recipients of such data, the retention period; [III] obtain the
rectification or cancellation, and where applicable, the limitation of the processing; [IV] oppose the
processing; [V] where applicable, receive in a structured format, commonly used and readable by an
automatic device, the personal data concerning you provided to the Company and transmit such data to
another Data Controller without impediments from the Company; [VI] to lodge a complaint with the
Italian Data Protection Authority. Requests should be addressed to the Controller, by e-mail at the
following address: privacy@ictit.eu.

11. Links to third party websites.

This privacy statement refers exclusively to the Site. The Site contains links to
third-party websites, over which the Controller has no form of control. The Controller will therefore not
be in any way responsible for the processing of any personal data performed by such third parties.