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PRIVACY AND COOKIE POLICYThis Privacy and Cookie Policy (“Policy”) applies to the processing of your personal data by
Bending Spoons S.p.A. ("Bending Spoons", "we" or "us") through “jobs.bendingspoons.com”(“Website”) in accordance with Regulation (EU) 2016/679 – General Data Protection
Regulation (“GDPR”), the Italian Legislative Decree 196/2003 (as amended), Directive
2002/58/EC – ePrivacy Directive (as amended), and other applicable local laws ("DataProtection Laws")
1.

Data Controller and Data Protection Officer

The Data Controller is Bending Spoons S.p.A., based in Corso Como 15, Milan, MI 20154(Italy), VAT 08931860962. For any requests regarding the processing of your personal data,
please email us at privacy@bendingspoons.com.
Our Data Protection Officer can be contacted for any requests relating to the processing ofyour personal data or this Policy by sending an email to dpo@bendingspoons.com.
2.

Categories of personal data that we collect, purposes and legal bases for ourprocessing

We process the following categories of personal data, for the purposes and on the legal
bases indicated below. Please note that not all the below information may be deemed
personal data in your jurisdiction in all cases.

Purposea.

To enable you to use
our Website and toprovide you withinformation about it,
and to process any
requests you send to
us when you contactus.

b.

To comply with ourlegal obligations andany other obligations
arising out of theinstructions received
from the authorities.

c.

To establish, exercise
or defend our rights
and those of ouremployees, and tocarry out corporatetransactions oroperations (forexample, in case ofbankruptcy, merger,

Legal basisCategories of processed data

Processing is necessary totake steps at your request
prior to entering into acontract or for theperformance of a contract towhich you are party (art.
6(1)(b) of the GDPR).

Identification and contact information(such as name and email address), ID
and technical information on yourdevice, your web browser details, andyour IP address, and similar
technologies, and other information
you provide us through our Website,
for example, when you submit arequest for information or when you
contact our customer support.
Any information necessary to ensure
the performance of these purposes.

Compliance with a legal
obligation to which we aresubject (art. 6(1)(c) of theGDPR).

The legal basis for theprocessing is our legitimate
interest (art. 6(1)(f) of theGDPR) to establish, exercise
or defend our rights and tocarry out corporatetransactions or operations.

Any information necessary to ensure theperformance of these purposes.

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PurposeLegal basis

Categories of processed dataacquisition,
reorganization, sale ofassets or assignments,
and due diligence
related to any suchtransactions).

d.

To create user
profiles by analyzing
preferences, behaviors,interests and choices
expressed through theuse of our products
and services, also inorder to use attribution
data to measure theeffectiveness of ourcampaign and makeour advertising more
relevant.

Identifiers and Internet and network
activity information (such as IPaddress).
The legal basis for theprocessing is your consent(art. 6(1)(a) of the GDPR
and/or, where appropriate,art. 5(3) of the e-Privacy
Directive)

To know how we process your personal data through the use of cookies and similar
technologies, see Section 8 (Cookies) below.
3.

Data Retention

We retain data collected through the use of our website for as long as necessary to carry out
the purposes indicated above and in accordance with applicable laws. To know how longyour data is stored through cookies and similar technologies, see Section 8 (Cookies) below.
4.

Your Choices

Providing navigation data is necessary if you want to navigate and interact with our Website.
Same goes for the information you share with us when you contact us to request informationor support. You can freely decide whether to accept cookies and other tracking technologies
not strictly necessary for the functioning of the Website as indicated in Section 8 (Cookies)
below.
5.

Sharing Your Personal Data

We may share or disclose your personal data to the following categories of recipients:● subjects carrying out activities that are related or instrumental to our business andoperational activities as outsourced data processors appointed in writing inaccordance with Data Protection Laws, or acting as autonomous data controllers(such as IT or storage service providers, mobile measurement partners, suppliers ofmobile marketing services, and advertising networks and platforms);● public, judicial or police authorities, within the limits established by applicable laws;● in the event that we undertake extraordinary corporate transactions or operations(e.g., in the event of bankruptcy, mergers and acquisitions, reorganizations, sale ofbusinesses or assets, and in connection with due diligence relating to such

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transactions), our advisors and potential purchasers and your personal data may
form part of the assets being transferred to a new owner.
Personal data will not be disclosed for any reason other than those stated above, unlesssuch disclosure is deemed necessary for the fulfillment of a legal obligation or if we request
your consent.
6.

Transfer Your Personal Data outside the European Economic Area

We may transfer your personal data from the European Economic Area (“EEA”) to othercountries outside the EEA (e.g. if your personal data is collected by third parties when you
accept – where appropriate – third-party cookies and/or similar technologies, who may belocated outside the EEA).
Such data transfers are based on appropriate safeguards in accordance with Data
Protection Laws, including (a) the standard contractual clauses developed by the EuropeanCommission; (b) the decisions of adequacy of the European Commission; or (c) Binding
Corporate Rules.
More information on the relevant data transfers, and appropriate warranties is available for
consultation by sending an email to privacy@bendingspoons.com.
7.

Your Rights

At any time and free of charge, you can exercise the following rights, as specified andsubject to certain limitations and exceptions under Data Protection Laws:● Right of access. You have the right to obtain information about the processing of yourpersonal data and to access it.
● Right to rectification. You have the right to ask for the updating, rectification orintegration of your personal data.
● Right to erasure. You have the right to request the deletion of your personal data.
● Right to restriction of processing. You have the right to request the restriction of theprocessing of your personal data.
● Right to data portability. You have the right to obtain a portable electronic copy ofyour personal data.
● Right to object. Where we rely on our legitimate interest to process your personaldata, you have the right to object to such processing, wholly or partly, on groundsrelated to your particular situation. In particular, you are entitled to object to theprocessing of your personal data for direct marketing purposes, including profiling.
● Right to withdraw your consent. Where we rely on your consent to process yourpersonal data, you have the right to withdraw your consent, although the processing
carried out before your withdrawal of consent will remain valid.
You also have the right to lodge a complaint before the competent national Data Protection
Authority, in particular before the Data Protection Authority of the Member State of yourhabitual residence, place of work or place of the alleged infringement.
To exercise your rights, or if you have any other questions about privacy or data protection at
Bending Spoons, you can contact us by sending an email to privacy@bendingspoons.com.
We may take reasonable steps to verify your identity prior to responding to your request.
8.

Cookies

What are cookies and tracking technologies?

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When we use the word “cookies” in this Policy, we mean any tracking technology that storesor accesses information on the user’s device, including any SDK, tracking pixel, HTML5 local
storage, local shared object, and fingerprinting technique.
Cookies are usually classified:(A) by purpose (Technical cookies, Analytics cookies, Profiling cookies);(B) by publisher (First-party cookies, Third-party cookies); and(C) by duration (Session cookies, Permanent cookies).
This classification is important because different legal requirements apply based on how thecookie is classified.
Below you will find the types of cookies and tracking technologies as classified with some
practical examples.
A. By purpose
Technical cookies
Technical cookies are used solely for the purpose of transmitting messages over anelectronic communication network, or to provide a service specifically requested by the user.
In other words, technical cookies are essential for the correct functioning of the website andto provide the service offered to and requested by the user.
For example, technical cookies can be used to monitor sessions, to store specific server
access information related to the user configuration, to facilitate the use of online content, or
to keep track of items in a shopping cart or information used to fill in a form.
Technical cookies include the functional cookies you might find mentioned while browsing
the Website.
Technical cookies do not need your consent.
Analytics cookies
Analytics cookies may be used to assess the effectiveness of an information society service
provided by a publisher, to evaluate and improve the design of a website or to help measure
its traffic.
In other words, analytics cookies may be used to track the traffic and performance of a
website, by collecting aggregate data on the number of visitors and how they interact withthe website to improve its services.
For example, analytics cookies may collect information about how users access a website,
including the number of visitors, possibly grouped by geographical area, time slot, how longvisitors stay on the site for, what parts of the site they visit or other characteristics, thenumber of pages visited or the number of users who viewed a particular section.
Please consider that if analytics cookies are properly anonymized, they can be installed
without your previous explicit consent.
Profiling cookies
Profiling cookies may be used to trace specific actions or recurring behavioral patterns in theuse of the offered functionalities back to specific, identified or identifiable individuals for thepurpose of grouping the different profiles within homogeneous, multi-sized clusters. This isaimed in turn to enable a company to provide increasingly customized services beyond what

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is strictly necessary for the delivery of the service and also send targeted advertising
messages in line with the preferences expressed by the user during their web-browsing
activities.
In other words, profiling cookies may be used to convey behavioral advertising, measure theeffectiveness of ads, or to customize the services offered in line with the user’s monitoredbehavior.
For example, profiling cookies can be used to create user profiles and offer content in linewith the user’s interests, or to send targeted ads or messages.
Profiling cookies include the performance, marketing and social media cookies you mightfind mentioned while browsing the Website.
Profiling cookies need your explicit consent.
B. By publisher
First-party cookies
Cookies are installed directly by the website that the user is browsing. In other words, thepublisher of the website installs the cookies directly without using any third-party publishers
and processes the information thereby acquired.
Third-party cookies
Third-party cookies are set by external providers other than those of the website that theuser is browsing. In other words, the publisher of the website installs the cookies indirectly,
using third-party publishers and processes the information thereby acquired.
For the purposes of this Policy, third party cookies include any tracker which, although
directly published by us, is provided by third parties which receive or otherwise process fortheir own purposes the information acquired through these cookies when you visit theWebsite. For further information, please refer to the privacy policy of such third party asindicated in the cookie table.
The data collected by these third parties is governed by their own specific privacy policies,
terms and conditions, or cookie policies to which we have no control over.
When our website hosts third-party non-anonymized analytics cookies and/or profilingcookies, you will be asked to consent to such third-party cookies when landing on ourwebsites for the first time, via a specific cookie banner.
You can manage and delete these third-party cookies at any time by accessing the privacy
policies of the third parties as indicated in the following section ("Types of cookies used bythe Website”).
C. By duration
Session cookies
Session cookies expire when the user's browsing session expires.
Permanent cookies
Permanent cookies last longer than a single browsing session.
Types of cookies used by the Website
This Website installs the following types of cookies:

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Provider (i.e.,
first party or
third-party)
MetaName

Retention
periodPurpose_fbp, fr

3 months

Campaign
attributionandoptimization

Third-party Privacy
Policy (whereappropriate)https://www.facebook.
com/about/privacy

Cookie settings
You can also disable (in whole or in part) technical cookies through the specific functions ofyour browser. Please note, however, that if you don’t allow technical cookies, you may not beable to use the Website, view its contents and take advantage of its services. Inhibiting
technical cookies may result in some services or features of the Website not being available
or not working properly and you may be required to modify or manually enter certain
information or preferences each time you visit the Website.
The choices you make with respect to the Website's cookies will be recorded in a cookie.
However, in some circumstances this cookie may not work properly: in such cases, werecommend that you delete the cookies you do not like and inhibit their use through thefeatures of your browser.
Your cookie preferences will need to be reset if you use different devices or browsers toaccess the Website.
You can find information on how to manage cookie settings on certain browsers via thefollowing links:● Chrome● Firefox● Internet Explorer● Safari
For more information about how to limit the use of third-party cookies installed in yourbrowser, please visit www.youronlinechoices.com. Once arrived on the website, byaccessing the "Your ad choices" section, you will be able to view the list of third parties that
install cookies on your browser and manage your consent granularly ("On/Off"). Moreover,by expanding the "Info" section, you will be able to access to more information about eachthird party and its privacy and cookie policies.
With regards to your rights under applicable Data Protection Laws, please refer to Section 7above.
9.

Changes

We may modify or update this Policy, also in view of future changes in applicable Data
Protection Laws or in case we implement new features or functionalities that will process
personal data.
Last updated: 25/05/2022***