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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 “bendingspoons.com” and“jobs.bendingspoons.com” (“Website”) in accordance with Regulation (EU) 2016/679 –General Data Protection Regulation (“GDPR”), the Italian Legislative Decree 196/2003 (asamended), Directive 2002/58/EC – ePrivacy Directive (as amended), and other applicable
local laws ("Data Protection Laws").
1.

Data Controller and Data Protection Officer

The Data Controller is Bending Spoons S.p.A., based in via Nino Bonnet 10, 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 our
processing

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 datain your jurisdiction in all cases.

PurposeLegal basis

Categories of processed dataa.

To enable you to use
our Website.

Processing is necessary forthe performance of a contract
to which you are party (art.
6(1)(b) of the GDPR).

ID and technical information on yourdevice, your web browser details, yourIP address, and other information you
provide us by using our Website that isnecessary to the functioning of theWebsite.

b.

To comply with ourlegal obligations andany other obligations
arising out of the
instructions 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,
acquisition,
reorganization, sale ofassets or assignments,

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.

Any information necessary to ensure theperformance of these purposes.

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PurposeLegal basis

Categories of processed data

The legal basis for theprocessing is theperformance of ourcontractual relationship (art.
6(1)(b) of GDPR).

Identification and contact information
you provide us (such as first and last
name, email address) and the content of
your communication or request.

and due diligence
related to any suchtransactions).

d.

To process andrespond to customer
supportcommunications and torequests for
information you may
raise with us.

e.

To create user profiles
by analyzing
preferences, behaviors,interests and choices
expressed through theuse of the Website,
also in order to use
attribution data tomeasure theeffectiveness of ourcampaign and makeour advertising more
relevant.

Identifiers and Internet and network
activity information (such as IP address).
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

Personal data may be processed by both automated and non-automated means and may be
stored at our premises and on our service providers’ servers. We adopt technical andorganizational measures designed to prevent the loss, improper use and alteration of yourpersonal data. In some cases, we may also adopt data encryption and pseudonymization
measures. However, transmissions over the Internet are never 100% secure, and you should
not provide any personal data if you want to avoid any risk.
Personal data processed for the purposes referred to in Section 2.a) and 2.d) will be kept fora period not exceeding the one necessary for the said purposes and, in each case, for no
more than 3 years from the date of your last interaction with the Website.
Personal data processed for the purposes referred to in Section 2.b) will be kept up to 5 years
from the date of your last interaction with the Website.
Personal data processed for the purposes referred to in 2.c) will be kept up to 10 years fromthe date of your last interaction with the Website.
Personal data processed for the purposes referred to in Section 2.e) will be kept until you
withdraw your consent.

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To know how long your 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 in accordancewith Data Protection Laws, or acting as autonomous data controllers (such as IT or
storage service providers, mobile measurement partners, suppliers of mobile
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 suchtransactions), 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, unless suchdisclosure is deemed necessary for the fulfillment of a legal obligation or if we request yourconsent.
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 European Commission;(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 and subject
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 or
integration 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.

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Right to data portability. You have the right to obtain a portable electronic copy of yourpersonal data.
Right to object. Where we rely on our legitimate interest to process your personal data,
you have the right to object to such processing, wholly or partly, on grounds related toyour particular situation. In particular, you are entitled to object to the processing ofyour 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?
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 an electronic
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 theWebsite.
Technical cookies do not need your consent.

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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 with the 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 long
visitors stay on the site for, what parts of the site they visit or other characteristics, the numberof 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 the
purpose of grouping the different profiles within homogeneous, multi-sized clusters. This is
aimed in turn to enable a company to provide increasingly customized services beyond whatis 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 monitored
behavior.
For example, profiling cookies can be used to create user profiles and offer content in line withthe user’s interests, or to send targeted ads or messages.
Profiling cookies include the performance, marketing and social media cookies you might findmentioned 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 the useris 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 for their own
purposes the information acquired through these cookies when you visit the Website. For
further information, please refer to the privacy policy of such third party as indicated in thecookie table.

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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 our websites
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 by theWebsite”).
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:
Provider (i.e., firstparty or thirdparty)

Name

Retention
periodPurposeThird-party
Privacy Policy(whereappropriate)https://www.onetru
st.com/cookiepolicy/#otnoticesection-1a0d3a9cee2c-4725-a50af715df70e55d
https://www.onetru
st.com/cookiepolicy/#otnoticesection-1a0d3a9cee2c-4725-a50af715df70e55d
N/A

OneTrust

OptanonAler
tBoxClosed

365 days

Technical

OneTrust

OptanonCon
sent

365 days

Technical

First-party

bs_last_video_index

0 daysTechnical

Vimeo__cf_bm

0 daysTechnical

https://vimeo.com/cookie_policy

Google_ga

1 yearAnalytics

https://policies.goo
gle.com/privacy

Google_ga_xxxxxxx
xxx

1 yearAnalytics

https://policies.goo
gle.com/privacy

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First-party

Role Model

Up to 3years

Analytics

Facebook_fbp

2 months

Profilinghttps://jobs.bendin
gspoons.com/docs/
06_10_2023_Bend
ing%20Spoons%2
0%20Privacy%20Po
licy%20(ENG_IT)_
Job%20Applicants.
pdf
https://www.facebook.com/privacy/policy/?entry_point=fa
cebook_page_footerCookie 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 to accessthe 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 your browser,
please visit www.youronlinechoices.com. Once arrived on the website, by accessing the "Yourad choices" section, you will be able to view the list of third parties that install cookies on yourbrowser and manage your consent granularly ("On/Off"). Moreover, by expanding the "Info"
section, you will be able to access to more information about each third party and its privacy
andcookiepolicies.
With regards to your rights under applicable Data Protection Laws, please refer to Section 7
above.
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.

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Last updated: February 28, 2024***