Privacy Policy

PURSUANT TO EUROPEAN REGULATION NO. 2016/679 (“GDPR”)

WEBSITE

ESSENTIAL INFORMATION ON PROCESSING OF PERSONAL DATA

Set out below are the main points regarding the processing of your personal data by the company Quadrivio Group Sarl, the Data Controller, through this website (hereinafter, the “Website”).

The company Quadrivio Group Sarl (the “Company”) has its registered office at no. 26, Boulevard Royal, L - 2449 Luxembourg.

For any clarification, questions or needs connected with your privacy and your personal data, you may contact us by writing at any time to info@quadriviogroup.com, by telephoning +39 02 89093758 or by sending a fax to +39 02 8900067.

Which data we use and why.

We process the personal data you provide when you communicate with us using the contact methods listed on our Website; this data comprises your personal and contact details contained in the communication, as well as any information that you include in or attach to the communication addressed to us.

Your personal data is processed for the following purposes:

a) To respond to your specific requests for information;

in this case, processing your data is for legitimate reasons since it is necessary to satisfying your specific request.

b) To evaluate any job application or work proposal you have made and to carry out selection with a view to a possible employment relationship with you;

in this case, processing your data is for legitimate reasons since it is necessary to conducting the pre-contractual procedures to satisfy your request.

c) To undertake pre-investment activities (e.g. determining your suitability for investments, ascertaining your investment preferences);

in this case, processing your data is for legitimate reasons since it is necessary to implementing the pre-contractual procedures to satisfy your request.

d)To undertake business development and marketing activities related to providing suggestions and recommendations regarding services that may be of interest to you. This may include direct electronic marketing.

in this case, processing your data is for legitimate reasons since it is based on your explicit consent or on the Data Controller's legitimate interest.

e) To provide updates and information through our newsletter available on the Website;

in this case, processing your data is for legitimate reasons since it is based on your explicit consent.

Who we share your data with.

Your data may be disclosed to:

- the Company's partners, shareholders, collaborators and employees specifically authorized to process this data;

- third parties based in Italy and belonging to the following categories ‒ Internet and telecommunications operators, technical support centres;

- other entities within our group as part of our routine business performance reporting activities, in the context of corporate reorganization or group restructuring, or to provide assistance regarding marketing or business development;

- regulatory, law enforcement and judiciary authorities, in order to comply with the law;

- cloud service providers;

- third-party service providers appointed as data processors where such information is pertinent to performing their services.

Under no circumstance will your data be disclosed to countries outside of the European Union, except when specified in the Cookies Policy, which may be consulted on this Website.

How long we store your data.

We store your personal data for a limited period of time, which is established by the purpose it has been collected for; when this period expires, the data is deleted, or in any case made irreversibly anonymous.

More specifically, the data we collect when you send us a request for information and the data processed in undertaking pre-investment activities are deleted 3 months after we have satisfied your request. The data processed in relation to the newsletter is deleted within 30 days of your request for deletion, while the data processed when you send us a job application and/or your CV is deleted 12 months after receipt of your application/CV.

Your personal data rights.

- You may at any time learn which elements of your personal data we hold and how these are used; you may ask for this data to be updated, supplemented or corrected, and you may also request a copy of it.

- In those cases provided for by the regulations in force, you may ask for your data in our possession to be deleted or may restrict the processing operations involving your data.

- Should you so wish, you may ask to receive any of the personal data we hold, in a form readable by electronic devices and, where technically possible, you may ask us to transfer this data directly to a third party designated by you.

To exercise the above-listed rights, you may contact us using the email address or telephone numbers indicated above. We will then send you an email to confirm receipt of your request and we will respond as soon as possible.

Should you believe that your personal data has been processed unlawfully, you may lodge a complaint with a competent supervisory authority for ensuring compliance with personal data protection regulations. In Italy, this complaint may be submitted to the Italian Data Protection Authority (www.garanteprivacy.it).

This Privacy Policy was updated in November 2025 and may undergo changes or supplementation over time. We therefore recommend periodically checking its contents.

For further information on the collection and processing of your personal data, please read our full privacy policy, included here below.

For more detailed information on cookies or similar technologies, please consult our Cookies Policy.

FULL PRIVACY POLICY ON PERSONAL DATA PROCESSING

pursuant to Article 13 of EU Regulation 2016/679

1. General information.

Who is the Data Controller?

2. Which personal data do we collect?

3. How do we use the collected personal data?

4. What are the legal grounds to our processing your data?

5. Who is this data disclosed to?

6. How long do we store this data?

7. Your rights and how to exercise them.

8. Security measures.

9. Complaints

10. Changes to this Privacy Policy.

11. Legal references and useful links.

1. General information.

Who is the Data Controller?

The company Quadrivio Group Sarl is the data controller (hereinafter, the “Data Controller”), meaning the entity that decides how and why to process your personal data through this website (hereinafter, the “Website”).

The following is the information you need in order to know who we are and how to contact us:

Quadrivio Group Italy S.r.l.

Address: 26, Boulevard Royal, L - 2449 Luxembourg

Telephone: +39 02 89093758

Email: info@quadriviogroup.com

2. Which personal data do we collect?

The following are the categories of personal data that we process.

We collect the data you provide us with when you communicate using the contact addresses and numbers on our Website, and also through its dedicated newsletter box.

Besides your personal and contact details contained in the communication we receive, we will also process any information that you include or attach to a communication addressed to us, such as the data present on a CV.

By way of example, but not limited to, we may collect your name, residential address, workplace details, email address, other contact details, business contact information, signature, employment and career history, legal status, correspondence records, and details relating to your investment activities or preferences.

For information on the use of the Website cookies, please consult the specific Cookies Policy.

3. How do we use the collected personal data?

We use your personal data only to the extent strictly necessary to satisfy the following purposes:

a) To respond to your specific requests for information.

We use the data you provide when you communicate with us (by letter, email, telephone or fax) through the contact details shown on the Website, in order to respond to your specific requests.

Depending on the type of request, provision of your personal data for this purpose may be a necessary requirement in order to complete any resulting contract with the Data Controller.

You are free to provide or withhold your personal data. However, should you withhold it, we will be unable to respond to your request, which means we will be unable to supply you with the requested information.

b) To evaluate any job application or work proposal you have made, and to carry out selection with a view to a possible employment relationship with you.

We use the data you provide to us when you, of your own initiative, apply for a position with us (by letter, email, telephone or fax); this is for evaluation of your application and to carry out selection with a view to a possible employment relationship with you.

Provision of your personal data for this purpose is a necessary requirement for (possible) stipulation of a contract with the Data Controller.

You are free to provide or withhold your personal data. However, should you withhold it, we will be unable to evaluate your application, which means we will be unable to select you to begin a work relationship with us.

c) To undertake pre-investment activities (e.g. determining your suitability for investments, ascertaining your investment preferences).

We use the data you provide when you communicate with us (by letter, email, telephone or fax) through the contact details shown on the Website, in order to respond to your specific requests.

Depending on the type of request, provision of your personal data for this purpose may be a necessary requirement in order to implement the pre-contractual procedures regarding your requested.

You are free to provide or withhold your personal data. However, should you withhold it, we will be unable to satisfy your request, which means we will be unable to implement the pre-contractual procedures regarding your request.

d) To undertake business development and marketing activities related to providing suggestions and recommendations for services that may be of interest to you. This may include direct electronic marketing.

We use the data you provide when you communicate with us (by letter, email, telephone or fax) through the contact details shown on the Website or by filling out the dedicated newsletter box solely in the case of explicit consent or the Data Controller's legitimate interest (as in the case of direct marketing).

You are free to provide or withhold your personal data. However, should you withhold it, we will be unable to satisfy your request, which means we will be unable to implement the measures you have requested.

e)To provide updates and information through our newsletter available on the Website.

We use the data you provide when you communicate with us (by letter, email, telephone or fax) through the contact details shown on the Website or by filling out its dedicated newsletter box solely in the case of explicit consent.

You are free to provide or withhold your personal data. However, should you withhold it, we will be unable to satisfy your request, which means we will be unable to provide you with the requested updates and information.

Lastly, the laws regulating personal data protection oblige us to use your contact details in certain circumstances in order to provide you with specific information on the processing of your data (for instance, to inform you of a security breach concerning your data and the measures we have adopted to deal with this).

With regards to all the aforementioned activities, we shall process your personal data primarily using electronic and computing devices; the devices we deploy ensure high security standards and fully respect current regulations.

4. What are the legal grounds to our processing your data?

We process your personal data only if one or more of the following conditions provided for by law are satisfied:

- The processing is necessary in order to execute a contract that you are party to or to implement pre-contractual procedures adopted upon your request (to respond to your information request sent to our contact details shown on the Website, or to evaluate a job application or work proposal you have made and to carry out selection with a view to a possible employment relationship with you, or regarding pre-investment activities).

- You have given explicit consent (to receive the newsletter, or for data processing for marketing purposes).

- The Data Controller's legitimate interest exists (direct marketing).

5. Who is this data disclosed to?

Your personal data may be disclosed to:

a) the Company's partners, shareholders, collaborators and employees specifically authorized to process this data;

b) third parties based in Italy and belonging to the following categories ‒ Internet and telecommunications operators, technical support centres;

c) other entities within our group as part of our routine business performance reporting activities, in the context of corporate reorganization or group restructuring, or to provide assistance regarding marketing or business development;

d) regulatory, law enforcement and judiciary authorities, in order to comply with the law;

e) cloud service providers;

f) third-party service providers appointed as data processors where such information is pertinent to performing their services.

The data is generally stored within the EU. In the event of transfer outside of the European Economic Area, we ensure that any personal data processing is conducted in compliance with the applicable legislation and with appropriate safeguards, such as adequacy decisions, standard contractual clauses approved by the European Commission and other safeguards deemed adequate under current regulations.

6. How long do we store this data?

We store your personal data for a limited period of time, which varies according to the type of activity dictating the data processing.

Once this period has expired, your data is permanently deleted or in any case made irreversibly anonymous.

Your personal data is stored respecting the following expiry dates and criteria:

a) the data we collect when you send us an information request is deleted 3 months after we have satisfied your request;

b) the data we collect when you send us a job application and/or your CV is deleted 12 months after receipt of your application/CV;

c) the data we collect in undertaking pre-investment activities is deleted 3 months after we have fulfilled your request;

d) the data we collect in undertaking business development and marketing activities and for sending the newsletter are deleted when you withdraw your consent (after 12 months in the case of direct marketing).

In any case, due to technical reasons, cessation of processing and the subsequent permanent deletion or irreversible anonymization of the data are completed within 30 days of the above-specified expiry dates.

7. Your rights and how to exercise them.

With regards to our processing of your personal data, you may exercise the following rights:

a) Access, modify or supplement your data, and obtain a full or partial copy of it.

You have the right to access your personal data and to obtain specific information on the nature of the processing carried out by us.

You may ask for your personal data to be corrected, modified or supplemented with additional information.

We will not accept requests to supplement your personal data with information that we do not need for the purposes of the above-described processing, in accordance with the applicable personal data protection laws.

Should you so wish, we will provide you with a copy of the data we hold.

b) Delete your data.

In the cases provided for by current legislation, you may request deletion of your personal data.

Once your request has been received and reviewed, if it is deemed legitimate, we shall promptly cease processing your personal data, with the exception of the data needed to continue processing in order to comply with any legal obligations.

c) Request temporary restrictions regarding the processing of your data.

You may ask for restrictions on the processing of your data. In this case, we will continue to store your personal data but will not use it, with the exception of any specific request made by you or requirements to comply with the law.

You may restrict the processing of your data:

- when you dispute the accuracy of your personal data;

- when its processing is unlawful but you object to deletion of your data;

- when we no longer require your data but you need to exercise your rights during legal proceedings.

d) Request transfer of your data to another party (the “right to data portability”). In certain cases, you may ask to receive, in a commonly used electronic format readable by computing devices, the data we have collected and processed in relation to a concluded contract with you.

Should you so wish and where technically feasible, we will transfer your data, upon your request, directly to a third party designated by you.

To exercise the above-listed rights, you can:

- email a request to info@quadriviogroup.com;

- contact us at the phone numbers specified in Paragraph 1 of this Privacy Policy.

We will then send you an email to confirm receipt of your request and we will respond as soon as possible, and in any case within 30 days of receiving your request.

To ensure that your personal data is not subject to breaches or unlawful use by third parties, before granting your request to exercise any of the above rights, we may need to ask you for further information to confirm your identity.

8. Security measures.

We protect your personal data with specific technical and organizational security measures designed to prevent your data from being used fraudulently or unlawfully.

9. Complaints.

In Italy, this complaint may be submitted to the Italian Data Protection Authority.

Further information on how to make a complaint is available on the website of the Italian Data Protection Authority, at the address www.garanteprivacy.it.

Complaints may also be lodged with other authorities besides the Italian one, if that supervisory authority belongs to the EU country where you normally work or live, or is where the claimed infringement has taken place.

10. Changes to this Privacy Policy.

This Privacy Policy was updated in November 2025.

This Privacy Policy may undergo changes or supplementation over time; these may be necessary as a consequence of modifications in the nature of the personal data processing described above, or as a result of new legislation regarding personal data protection. In the case of changes affecting the processing in progress, we undertake to inform all interested parties of these changes before they become applicable.

The updated version of this Privacy Policy will be published on this webpage, stating the date of its latest update. Regarding this matter, we suggest you consult this page when you access the Website.

11. Legal references and useful links.

We process your personal data in full compliance with the relevant regulations set out in EU Regulation 2016/679 (General Data Protection Regulation or "GDPR") of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data, which superseded EC Directive 95/46/EC; we also fully comply with the relative Italian regulations governing the processing of personal data, and with the measures issued by the Italian supervisory body (Italian Data Protection Authority) and by the European Data Protection Board (EDPB).

More specifically, this Privacy Policy has been drafted in compliance with Article 13 of EU Regulation 2016/679 and respecting the other aforementioned sources.

Should you wish to consult the text of EU Regulation 2016/679 and the other sector provisions in force in Italy, or the measures introduced by the Italian supervisory authority, please consult the website www.garanteprivacy.it.