1. INTRODUCTION

Your privacy is important for HTA. We have therefore developed a Privacy Policy concerning the way in which we collect, use, disclose, transfer and store your data. We invite you to read this document to learn about our privacy protection criteria and to let us know if you have any questions.

With this document HTA provides you, pursuant to articles 13 and 14 of European Regulation no. 2016/679, concerning the protection of real persons and the processing of personal data (hereinafter "GDPR"), some information on the processing of your personal details that are requested whenever you come in contact with HTA with relation to the use of the HTA website https://www.hta-it.com the services offered by HTA and HTA applications (hereinafter simply "App").

Our Rules on privacy explain:

• Data collected and purpose.
• Mode of use of said information.
• The options that we offer, including the manner of accessing and updating the information.

This document is also drawn up considering the provisions of Directive 2002/58/EC, as updated by Directive 2009/136/EC, on cookies, and the provisions of the Authority for the Protection of Personal Data "Identification of simplified modes for information and the acquisition of consent for the use of cookies" of 8 May 2014.

2. PROCESSED DATA

2.1 Data necessary for using the website and for using the applications

Personal information is data that can be used to identify or contact a given person, to offer better services to all our customers/users. You might be asked to provide your data whenever you come in contact with HTA or with a company affiliated to HTA.

Access data collected anonymously: The I.T. systems and software procedures used for the operation of the website and of all HTA applications, during normal operation, collect some personal data even without the user being registered. This data category includes the IP address or domain name of the device you use, the operating system, the URI addresses of the resources requested, and other parameters related to the I.T. environment of your device.

Data supplied voluntarily by the user: If you choose to register and create your own account, we ask you to supply some personal information including your name, surname, e-mail address, tax code, user name and password, which are necessary for the management of the Users/Customers master file. The user is responsible for the exactness of the personal information supplied to HTA.

Data on position: When HTA applications and services are used, we could collect and process information on your position and on the position of your systems. However, you can decide later to deactivate the delocalization services of your appliance by accessing the settings of your device (Android or IOS).

3. PURPOSES OF PROCESSING AND LEGAL BASIS

By legal basis of processing we mean the source of processing after consent of the party concerned in accordance with art. 4 of the GDPR.

3.1 Your data will be processed:

• for the technical management of the HTA systems and of the applications;
• for the management of your registration;
• to allow you to use the functions of the applications;
• to send you news and for marketing activity;
• to fulfil the legal obligations to which the Data Controller is subject.

4. PERIOD OF STORAGE

Your data will be processed for the whole duration of the contract and/or validity of the account and for the period contemplated by the law on taxation. Personal data processed for marketing purposes will be kept until specific consent is withdrawn by the party concerned.

5. METHODS OF PROCESSING AND THEIR USE

5.1 Processing

The data will be processed respecting safety and confidentiality, with the aid of electronic and automated instruments. Suitable technical and organisational measures will be applied to guarantee safety, confidentiality, integrity and availability, avoiding the risk of loss, destruction or unauthorised access.

6. RECIPIENTS OF THE DATA

HTA shares users' personal data with companies that provide services such as data processing, storage, clearing of orders, home-delivery, and assistance. These companies are obliged to protect your data.

7. YOUR RIGHTS

You can request access to the data, correct or delete them as per art.17 of the GDPR. You can withdraw the consent given at any time. These rights may be exerted by sending an e-mail to: privacy@hta-it.com.

8. Cookie management and similar technologies

The websites managed by HTA S.r.l. use cookies and similar technologies (hereinafter "cookies") to ensure the proper functioning of the pages. Cookies are small text files sent to the user's device.

The activation methods for non-technical cookies vary based on the legislation in force in the country from which the user accesses our services:

• Where required by local regulations (as in the case of the EU territory), the installation of non-technical cookies occurs exclusively subject to express consent (Opt-in).
• In other jurisdictions, installation may occur by default, without prejudice to the user's right to withdraw consent or object to the processing (Opt-out) at any time.

For the HTA-IT.COM website, the dedicated Cookie Policy can be consulted at the following link: cookie-policy-www-hta-it-com.html

9. INFORMATION NOT CONTAINED IN THIS POLICY

Further information on the processing of Personal Data may be requested from HTA at any time using the contact information.

10. MODIFICATIONS

HTA reserves the right to make modifications to this privacy policy at any time, informing the Users on this page.

11. DATA CONTROLLER AND CONTACT DATA

The Data Controller is HTA s.r.l. - Via del Mella, 77 - 25131 Brescia - Italy / e-mail: (privacy@hta-it.com).

Latest update: April 2026