IRCA S.p.A. Investor Portal

Welcome to the investor relations website of IRCA S.p.A.

This Website is used to communicate information to bona fide existing and prospective bondholders and other eligible persons in connection with the reporting requirements under our financing arrangements. This Website may not be used for any other purpose.

For access to the restricted investor area, you need to login. To apply for login details, please follow the instructions in the section “Apply for login details” below.

By applying for log in details and accessing this Website, you confirm and agree that you continue to satisfy the foregoing eligibility requirements.

Apply for log in details

Fill out the form below to register your account. You will receive an email notification as soon as your registration has been approved. After approval, you will be granted access to the secured part of our Investor Portal, which can be accessed here.

Information captured in this form will be used to determine whether you will be granted access to the restricted area. Your personal data will be processed in accordance with our Privacy Policy, which sets out what personal data we process about you, for what purpose, on what legal basis, with whom we will share your personal data and your rights to such data, amongst others. It is important that you read our Privacy Policy carefully, which can be accessed here.

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PRIVACY STATEMENT PURSUANT TO ARTICLE 13 OF EU REGULATION 2016/679

Sammontana Italia S.p.A. (hereinafter also referred to as “ Sammontana Italia ” or the “ Company ”) has always been committed to protecting your privacy. Sammontana Italia invites you to carefully read this privacy statement (hereinafter the “ Privacy Policy ”), drawn up in accordance with Article 13 of EU Regulation 2016/679 (hereinafter also referred to as the “ Regulation ” or “ GDPR ”), which outlines Sammontana Italias policy with regard to the processing of personal data collected for the purposes of your registration to the "Investor Relations” Restricted Area of the website www.sammontanaitalia.com (hereinafter referred to as the “ Website ”).

We inform you in advance that your personal data will be processed in accordance with the national and European data protection legislation currently in force and in accordance with the principles of fairness, lawfulness, transparency and protection of your privacy and rights.

Table of contents

1. Data Controller
2. Types of personal data processed
3. Purposes and methods of data processing
4. Legal basis for processing personal data
5. Recipients/categories of recipients of personal data
6. Data collection and consequences of withholding data
7. Data retention period
8. Rights of data subjects
9. Filing a complaint with the Italian Data Protection Authority
10. Personal data of minors
11. Updates and amendments
12. Links to other websites

1. Data Controller
Data Controller is Sammontana Italia S.p.A. (hereinafter also referred to as “ Sammontana Italia ” or the “ Company ”), Via Tosco Romagnola n. 56, 50053 Empoli (FI), telephone: 0571 7076, Fax: 0571 707447, certified e-mail: [email protected] .

2. Types of personal data processed
Sammontana Italia collects and processes personal data (hereinafter collectively referred to as “ Personal Data ” or simply “ Data ”) regarding the user (hereinafter the “ User ” or “ Users ”) and, more specifically, the Data provided voluntarily by the User when filling out the online form required to complete the registration to the “Investor Relations” Restricted Area, namely personal identification data and contact details, for example first name, last name, address, telephone number, e-mail address, country of origin, title.

3. Purposes and methods of data processing
The Personal Data voluntarily provided by the User by filling out the “ Register ” form on the Websites “Investor Relations” page are collected and processed for the following purposes:
to allow the User to register with the “Investor Relations” Restricted Area of the Website and have access to the Companys financial documents and information; to use data in anonymised and/or pseudonymised form to conduct research and analysis regarding the country of origin of Users who request to be registered with the “Investor Relations” Restricted Area and who are therefore interested in having access to the Companys financial documents and information.
Personal Data will be processed by Data Controller, Data Processors and persons in charge of processing (“ Authorized Persons ” or “ Persons in Charge ”); they shall adopt all appropriate measures to ensure their security and confidentiality, by means of paper-based or computer-based tools, in accordance with the principles of the law, protecting the confidentiality of the data subjects and their rights by adopting appropriate technical and organizational measures to ensure a level of security commensurate with the risk.

4. Legal basis for processing personal data
The legal basis for processing personal data for the purposes set out in section 3,
letter A) is the performance of pre-contractual and contractual terms, pursuant to Article 6, paragraph 1, letter b) of the Regulation.
The legal basis for processing personal data for the purposes set out in section 3, letter B)
is the pursuance of the legitimate interests of the Data Controller pursuant to article 6, paragraph 1, letter f) of the Regulation.

5. Recipients/categories of recipients of personal data
Your Personal Data may be disclosed, exclusively for the above-mentioned purposes, to the following categories of recipients:
individuals, companies, associations or professional firms which provide assistance and consulting services to our Company, typically, but not exclusively, in the areas of accounting, administration, legal, tax and financial matters; Internet service providers, providers of cloud or IT services, Website administrators, who need to access your Data for purposes related to your request to be contacted by Sammontana Italia, and all attendant activities, to the extent strictly necessary for the performance of their duties;
subsidiary companies, entities within the same Corporate Group to which our Company belongs;
individuals whose right to access your Personal Data is recognized under applicable laws and secondary regulations;
public or private entities that manage ordinary and commercial mail delivery services;
other individuals who may become aware of your Personal Data, such as members of our staff involved in the activities performed to fulfil your contact requests.
These individuals/entities shall act as Authorized Persons, Independent Data Controllers or Data Processors within the meaning of Article 28 of the EU Regulation. These individuals or entities, which Sammontana Italia relies upon to carry out its activities, provide suitable guarantees of compliance with the personal data processing regulations in force. Your Personal Data will not be transferred to Countries outside the EU. Your Personal Data will in no case be disclosed.

6. Data collection and consequences of withholding data
The input of your Personal Data marked with an asterisk (*) on the “Register” form is not mandatory but necessary to fulfil the purposes stated in section 3. The sole consequence of withholding any of these data is the inability to register and, therefore, to access the “Investor Relations” Restricted Area. The input of your Personal Data not marked with an asterisk (*) on the "Register" form is optional. If you choose not to provide such Data, there will be no consequences.

7. Data retention period
The Data referred to herein shall be retained for as long as is strictly necessary to achieve the purposes stated in section 3, and, therefore, for managing your registration with the Website and, in any case, for as long as your profile will remain active, for the purposes stated in section 3, letter A.

8. Rights of Data Subjects
You are entitled at any time to exercise your rights against the Data Controller pursuant to Articles 15 and following of the Regulation, which are reported below for your convenience:
Right of access and rectification (Articles 15 and 16 of the Regulation): you are entitled to obtain confirmation of whether or not your Personal Data is being processed and, if so, to access your data. You also have the right to request the rectification of incorrect data and the integration of incomplete data. If you wish, we may provide you with a copy of your Data in our possession.
Right to erasure (Article 17 of the Regulation): in the cases provided for by applicable legislation (for example, personal data is no longer necessary for the purposes for which it was collected or processed, withdrawal of consensus, unlawful processing, etc.) you may request that your Personal Data be deleted, which Sammontana Italia will do without delay.
Right to restriction of processing (Article 18 of the Regulation): in the cases provided for by applicable legislation (inaccurate personal data, unlawful processing of data, etc.), you are entitled to obtain a restriction of your Personal Data processing.
Right to data portability (Article 20 of the Regulation): you are entitled to receive your Data in a structured, commonly used and machine-readable format, in order to transmit it to another data controller. Alternatively, if requested, we will directly transmit your Data to another data controller.
Right to object (Article 21 of the Regulation): you have the right, at any time, to object to the processing of your personal data on grounds relating to your particular situation pursuant to Article 6, paragraph 1, letters e) or f) of the Regulation, including profiling based on those provisions (legitimate interest of the Data Controller).
You may exercise these rights by contacting the Data Controller via registered letter, fax or email to the addresses and contact information reported in section 1, possibly using the forms made available on the website of the Italian Data Protection Authority ( Autorità Garante per la Protezione dei dati personali )( www.garanteprivacy.it ).
Upon receipt of your request, Sammontana Italia shall have one month time to take all necessary actions. The one-month deadline may be extended by two months in case of a complex request or a large number of requests.

9. Filing a complaint with the Italian Data Protection Authority
If you believe that there has been a violation of your rights to personal data protection, you can file a complaint with the Italian Data Protection Authority ( Garante per la protezione dei dati personali) in the manner and within the terms specified on the website of the Italian Data Protection Authority ( http://www.garanteprivacy.it ).

10. Personal data of minors
The services of this Website are intended for a general audience and are not targeted to individuals under the age of 18. We will not knowingly collect personal information from Users below this age limit. Should we become aware that we have collected personal data belonging to a person under the age of 18, the Data Controller will promptly delete such data.

11. Updates and amendments
The Data Controller may modify, supplement, or simply update, in whole or in part, this Privacy Policy, also to reflect changes in regulations or following the introduction of new sector-specific standards.
Any such updates or amendments will be notified through publication on the "Investor Relations" page of the Website. We recommend, therefore, that you regularly access this page to check the publication of the most recent and updated Privacy Policy.

12. Links to other websites
This Privacy Policy is provided for the Restricted Area of the Website and is not applicable to other external websites that may be accessed through links.

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