PIAZZA NAVONA EXPERIENCE

PRIVACY POLICY

The purpose of this document is to inform the natural person (hereinafter “Data Subject”) about the processing of his/her personal data

(hereinafter “Personal Data”) collected by the data controller, Aita Pea Pea S.R.L., with registered o􀀣ce in Via Giuseppe Sacconi 4/b, Tax

Code/VAT No. 16146721002, Aita Pea Pea SRL, e-mail address info@ciaovr.it, (hereinafter “Data Controller”), via and C!ao - Piazza Navona

experience (hereinafter “Application”).

Changes and updates will be e􀀴ective as soon as they are published on the Application. In case of non-acceptance of the changes made

to the Privacy Policy, the Data Subject shall stop using this Application and may ask the Data Controller to delete his/her Personal Data.

1. Categories of Personal Data processed

The Data Controller processes the following types of Personal Data voluntarily provided by the Data Subject:

The Data Controller processes the following types of Personal Data collected automatically:

Usage Data: such as, for example, pages visited, number of clicks, actions taken, duration of sessions, etc.

If the Data Subject decides not to provide Personal Data for which there is a legal or contractual obligation, or if such data is a

necessary requirement for the conclusion of the contract with the Data Controller, it will be impossible for the Data Controller to

establish or continue any relationship with the Data Subject.

The Data Subject who communicates Personal Data of third parties to the Data Controller is directly and exclusively liable for their

origin, collection, processing, communication or divulgation.

2. Cookies and similar technologies

The Application uses cookies, web beacons, univocal identifiers and other similar technologies to collect the Data Subject's

Personal Data on visited pages and links and other actions performed during the use of the Application. This data is stored and

then used the next time the interested party browses the Application. The full Cookie Policy can be viewed at the following

address: http://www.ciaovr.it/cookie-policy

3. Legal basis and purpose of data processing

The processing of Personal Data is necessary:

a. for the performance of the contract with the Data Subject and especially:

1. fulfillment of any obligation arising from the pre-contractual or contractual relationship with the Data Subject

2. registration and authentication of the Data Subject: to allow the Data Subject to register in the Application, to access it

and to be identified in it, also via external platforms

3. support and contact with the Data Subject: to answer the Data Subject's requests

b. for legal obligations and especially:

1. the fulfilment of any obligation provided for by the applicable norms, laws and regulations, in particular, on tax and

fiscal matters

The Data Subject's Personal Data may also be used by the Data Controller to protect itself in judicial proceedings before the

competent courts.

4. Data processing methods and receivers of Personal Data

The processing of Personal Data is performed via paper-based and computer tools with methods of organization and logics strictly

related to the specified purposes and through the adoption of appropriate security measures.

Personal Data are processed exclusively by:

persons authorized by the Data Controller to process Personal Data who have committed themselves to confidentiality or have

an appropriate legal obligation of confidentiality;

subjects that operate independently as separate data controllers or by subjects designated as data processors by the Data

Controller in order to carry out all the processing activities necessary to pursue the purposes set out in this policy (for example,

business partners, consultants, IT companies, service providers, hosting providers);

subjects or bodies to whom it is mandatory to communicate Personal Data by law or by order of the authorities.

The subjects listed above are required to use appropriate measures and guarantees to protect Personal Data and may only access

data necessary to perform their duties.

Personal Data will not be indiscriminately shared in any way.

5. Place

Personal Data will not be transferred outside the territory of the European Economic Area (EEA).

6. Fully automated decision-making processes

The Data Controller uses fully automated decision-making processes that may produce legal e􀀴ects or have a signi􀀻cant impact

on the Data Subject and that operate according to these criteria: Privacy .

7. Personal Data storage period

Personal Data will be stored for the period of time that is required to fulfill the purposes for which it was collected. In particular:

for purposes related to the execution of the contract between the Data Controller and the Data Subject, will be stored for the

entire duration of the contractual relationship and, after termination, for the ordinary prescription period of 10 years. In the

event of legal disputes, for the entire duration of such disputes, until the time limit for appeals has expired

for purposes related to legitimate interests of the Data Controller, they will be stored until the fulfilment of such interest

in compliance with legal obligations, by order of an authority and for legal protection, they shall be stored according to the

relevant timeframes provided for by such obligations, regulations and, in any case, until the expiry of the prescriptive term

provided for by the rules in force

for purposes based on the consent of the Data Subject, they will be stored until the consent is revoked

At the end of the conservation period, all Personal Data will be deleted or stored in a form that does not allow the identification of

the Data Subject.

8. Rights of the Data Subject

Data Subjects may exercise specific rights regarding the Personal Data processed by the Data Controller. In particular, the Data

Subject has the right to:

be informed about the processing of their Personal Data withdraw consent at any time restrict the processing of his or her Personal Data

object to the processing of their Personal Data access their Personal Data verify and request the rectification of their Personal Data

restrict the processing of their Personal Data obtain the erasure of their Personal Data

transfer their Personal Data to another data controller

file a complaint with the Personal Data protection supervisory authority and/or take legal action.

In order to use their rights, Data Subjects may send a request to the following e-mail address info@ciaovr.it. Requests will be

immediately treated by the Data Controller and processed as soon as possible, in any case within 30 days.

Last update: 18/01/2022.

COOKIE POLICY

Our Cookie Policy is intended to describe the types of cookies used by our application http://www.ciaovr.it (hereinafter the

“Application”), the purposes, duration and methods in which the User can manage such cookies.

The data controller is AITA PEA PEA SRL Via Giuseppe Sacconi 4/b, 00196 ROMA info@ciaovr.it (hereinafter the “Owner”).

1. WHAT ARE COOKIES

Cookies are small text strings that are stored on the User's device when browsing the internet. Cookies are intended to collect and

store User’s information in order to make the Application more simple, faster and more responsive to his requests.

The word Cookie indicates both to cookies as well as to all similar technologies.

The User can block, delete or disable cookies in the device or browser settings as indicated below in the paragraph referred to

"Cookie management”.

2. TYPES OF COOKIES USED BY THIS APPLICATION

This Application uses the following cookies:

First-party technical cookies: these cookies belong to the Application’s Owner and collect User data accessible only to the

Owner. The Application uses these cookies to perform activities that are strictly necessary for the functioning of the Application

the provision of the service or to collect information, in aggregate and anonymous form, for statistical purposes. These cookies

do not profile the User. User's consent is not required for the use of these cookies.

No third party cookies are used.

3. COOKIES DURATION

Cookies have a duration determined by the expiration date or a speci􀀼c action such as closing the browser set up at the time of

installation. Cookies may be:

Temporary or session: used to store temporary information, allowing the User to link actions that are executed during a

specific session, and are removed from the User's device when the browser is turned off;

Persistent cookies: used to store information, such as the login name and password of the User, in order to prevent the same

User from typing them again each time he visits a speci􀀼c website. These remain stored on the User's device even once the

browser is closed.

4. COOKIE MANAGEMENT

The User can manage preferences relating to cookies directly in his browser and prevent third parties from installing cookies.

Further, it is also possible to delete cookies that have been installed in the past, including the cookie in which the expression of

consent to the installation of cookies has been saved by this Application. By disabling all cookies, the operation of this Application

may be compromised.

The User can delete all cookies on his device by simply selecting, on his browser, the settings that allow you to refuse them. Each

browser has specific configuration instructions which can be found on the browser provider's website at the following links:

Apple Safari: https://support.apple.com/it-it/guide/safari/manage-cookies-and-website-data-sfri11471/

Google Chrome: https://support.google.com/chrome/answer/95647

Mozilla Firefox: https://support.mozilla.org/kb/enable-and-disable-cookies-website-preferences

Internet Explorer: http://windows.microsoft.com/internet-explorer/delete-manage-cookies

Microsoft Edge https://support.microsoft.com/it-it/help/4027947/microsoft-edge-delete-cookies

Opera: https://www.opera.com/help/tutorials/security/privacy/

Furthermore, third-party cookies may be deleted by requesting the opt-outs directly from third parties or via the website

http://www.youronlinechoices.com, where the User can manage the tracking preferences of most of the advertising tools.

In order to modify the settings related to Flash cookies, it is possible to click on the following link:

https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

5. Rights of the User

The Users may exercise specific rights with respect to personal data processed by the Owner. In particular, the User has the right

to:

withdraw its consent at any time;

object the Processing of its personal data;

access its personal data;

monitor and request the rectification of personal data;

obtain a restriction of Processing;

obtain the erasure or remotion of its personal data;

receive its personal data or obtain the transfer to a different data controller;

lodge a complaint before the supervisory authority for the protection of personal data or start legal proceedings.

In order to exercise these rights, write to the Owner: info@ciaovr.it

Requests are made free of charge and processed by the Owner as soon as possible, in any case within 30 days.

Further information regarding the processing of personal data can be found in the privacy policy at the following link http://www.ciaovr.it.

Latest update: 18/01/2022

TERMS AND CONDITIONS



This document contains the general terms and conditions on the basis of which the use of the web site and of the application C!ao -

Piazza Navona Experience that provides Guided and free tour - Day and night mode - Completely rebuilt in CGI - Relive myths and

legends of the square - English audio and subtitles is offered to the users.

1. Definitions

To allow a complete understanding and acceptance of these terms and conditions, the following terms, in the singular and in the

plural, shall have the meaning indicated below:

Owner: Aita Pea Pea S.R.L, with registered address in Via Giuseppe Sacconi 4/b, VAT number/Tax code 16146721002, REA: RM

- 1637805, fully paid-up share capital of 50.000,00 €, , certified e-mail address (PEC) aitapeapea@pec-legal.it

Application: the web site and the application C!ao - Piazza Navona Experience

User: any person who accesses and uses the Application

Conditions: this contract which governs the relationship between the Owner and the Users.

2. Scope of the Conditions

The use of the Application implies full acceptance of the Conditions by the User. Should the User not accept the Conditions and /

or any other note, legal notice, information published or referred to therein, the User shall not use the Application or the services

related.

The Owner may amend the Conditions at any time. The changes shall be e􀁀ective from the time they are published in the

Application.

Before using the Application, the User is required to read the Conditions carefully save or print them for future reference.

The Owner reserves the right to change, at his own discretion and at any time, the graphic interface of the Application, the

Contents and their organisation, as well as any other feature that characterises the functionality and management of the

Application, communicating to the User the relative instructions, when necessary.

3. Content sent by the Users

The User can upload Content on the Application, provided that it is not illegal (e.g. obscene, intimidating, defamatory,

pornographic, abusive or for any reason illegal or in violation of privacy, the intellectual and / or industrial property rights of the

Owner and / or third parties), misleading, or is not otherwise harmful to the Owner and / or third parties or contains viruses,

political propaganda, commercial solicitation, mass e-mail or any other form of spamming. In the event of a dispute by a third

party regarding any announcement or conduct related to it, the User assumes full liability and undertakes to hold the Holder

harmless from any damage, loss or expense.

The User guarantees that the Contents are sent to the Application through his account from a natural person of legal age. For

natural persons under legal age, the sending of Contents must be examined and authorised by the parents or by those exercising

parental authority.

The User is the sole and exclusive responsible for the use of the Application with regard to the publication, consultation,

management of the Content and contact between Users and is therefore the sole guarantor and responsible for the correctness,

completeness and lawfulness of the Contents and its own behaviour.

It is forbidden to use an e-mail address that is not owned by the User, to use the personal data and credentials of another User in

order to use his identity, or in any other way to declare false information about the origin of the Contents.

The Owner is unable to ensure timely control over the Content received and reserves the right at any time to cancel, move or

modify the Content, which, at its discretion, appears to be illegal, abusive, defamatory, obscene or prejudicial to the right to author

and trademarks or in any case unacceptable.

Users grant the Owner a non-exclusive right of use on the Content sent, without limitations of geographical areas. The Owner may

therefore, directly or through trusted third ies, use, modify, copy, transmit, extract, publish, distribute, publicly perform,

disseminate, create derivative works, host, index, store, note, encode, modify and adapt (including without limitation the right to

adapt for transmission in any form of communication) in any form, any Content (including images, messages, including audio and

video) that should be sent by the User, including through third parties.

The Content sent will not be returned and the Owner will not be liable towards Users for the loss, modi􀀼cation or destruction of

the transmitted Content.It is expressly forbidden, unless explicitly authorised by the Owner: i) the use of automatic announcement

uploading systems, except those expressly authorised, ii) serial publication and / or management of advertisements for third

parties by any means ormethod, iii) resell the Owner's services to third parties.

4. Industrial and intellectual property rights

The Owner declares to be the owner and / or licensee of all intellectual property rights relating to and / or relating to the

Application and / or the Content available on the Application. Therefore, all the trademarks, 􀀼gurative or word and all other signs,

commercial names, service marks, word marks, commercial names, illustrations, images, logos, contents relating to the Application

are and remain the property of the Owner or its licensees and are protected by the laws in force on the trademarks and by the

relative international treaties.

The Conditions do not grant the User any license for use relating to individual contents and / or materials available therein, unless

otherwise regulated.

Any reproductions in any form of the explanatory texts and the Contents of the Application, if not authorised, will be considered

violations of the intellectual and industrial property right of the Owner.

5. Exclusion of warranty

The Application is provided "as is" and "as available" and the Owner does not provide any explicit or implicit guarantee in relation

to the Application, nor does it provide any guarantee that the Application will satisfy the needs of the Users or that it will not have

never interrupt or be error-free or free of viruses or bugs.

The Owner will endeavour to ensure that the Application is available continuously 24 hours a day, but cannot in any way be held

responsible if, for any reason, the Application is not accessible and / or operational at any time or for any period . Access to the

Application may be suspended temporarily and without notice in the event of system failure, maintenance, repairs or for reasons

wholly unrelated to the owner's will or due to force majeure events.

6. Limitation of liability

The Owner shall not be held liable towards the User, except in the case of wilful misconduct or gross negligence, for disservices or

malfunctions connected to the use of the internet outside of its own control or that of its suppliers.

Furthermore, the Owner will not be liable for damages, losses and costs incurred by the User as a result of failure to execute the

contract for reasons not attributable to him.

The Owner assumes no responsibility for any fraudulent or illegal use that may be made by third parties of credit cards and other

means of payment,

The Owner shall not be held liable for:

any loss of business opportunities and any other loss, even indirect, possibly su􀁀ered by the User that is not a direct result of

the breach of contract by the Owner

incorrect or unsuitable use of the Application by Users or third parties

In no case the Owner shall be held liable for a sum greater than twice the cost paid by the User.

7. Force majeure

The Owner shall not be held responsible for the failure or late ful􀀼lment of its obligations, due to circumstances beyond its

reasonable control due to events of force majeure or, in any case, to unforeseen and unforeseeable events and, in any case,

independent of its will.

The ful􀀼lment of the obligations by the Owner shall be considered suspended for the period in which events of force majeure

occur.

The Owner will perform any act in his power in order to identify solutions that allow the correct ful􀀼lment of his obligations

despite the persistence of events due to force majeure.

8. Links to third-party web sites

The Application may contain links to third-party web sites / applications. The Owner has no control over them and, therefore, is in

no way responsible for the contents of these sites / applications.

Some of these links may link to third-party sites / applications that provide services through the Application. In these cases, the

general conditions for the use of the site / application and for the use of the service prepared by the third parties will be applied to

the individual services, with respect to which the Owner assumes no responsibility.

9. Privacy

The protection and processing of personal data will be in accordance with the Privacy Policy which can be consulted on the page http://www.ciaovr.it/privacy

10. Applicable law and jurisdiction

The Conditions are subject to Italian law.

For Consumer Users, any dispute concerning the application, execution and interpretation of these Conditions shall be referred to

courts where the Consumer User resides or has elected domicile, if located in the territory of the Italian Republic, without

prejudice to the right of the User Consumer of going to court other than the "consumer court" pursuant to Section 66 bis of the

Italian Consumer Code, competent for the territory according to one of the criteria of the Sections 18, 19 and 20 of the civil

procedural code.

The application to Consumer Users who do not have their residence or domicile in Italy of any more favourable and mandatory

provisions established by the law of the country in which they have their residence or domicile is reserved, in particular in relation

to the term for the exercise of the right of withdrawal, after the return of the Products, in case of exercise of this right, the

formalities of the communication and the legal guarantee of conformity.

For Users who are not Consumers, any dispute concerning the application, execution and interpretation of these Conditions will

be referred to the forum of the place where the Owner is based.

11. Online dispute resolution for Consumer Users

The consumer user residing in Europe shall be aware of the fact that the European Commission has established an online

platform that provides an alternative dispute resolution tool. This tool can be used by the Consumer User to resolve any dispute

relating to and / or deriving from contracts for the sale of goods and the provision of services concluded online. Consequently, the

Consumer User can use this platform for the resolution of any dispute arising from the contract entered into online. The platform

is available at the following address: ec.europa.eu/consumers/odr/

Date 21/01/2022