Cookie Policy

Information on data processing

This Cookie Policy applies to the website https://www.alps.it (hereinafter, the "Website") and forms an integral part of the Privacy Policy.

DATA CONTROLLER AND CONTACT DETAILS The Data Controller is Alps Blockchain S.p.A., with registered office at Vicolo Liceo 1, 38122 Trento (TN), Italy, Italian tax code and VAT number 02515120224, Trento Economic and Administrative Index (REA) no. TN-230317 (hereinafter also the “Data Controller” or simply the “Controller”). For any clarification or information, or to exercise the rights set out in this Cookie Policy, the Data Controller may be contacted at the following details: tel. +39 333 2663836, email: amministrazione@alpsblockchain.com, certified email (PEC): info@pec.alpsblockchain.com.

COOKIES USED BY THE WEBSITE, PURPOSES AND LEGAL BASIS Cookies are small text files that the websites visited by the user (so-called “publishers” or “first parties”), or other websites or web servers (so-called “third parties”), place and store on the user’s computer or mobile device—directly in the case of publishers and indirectly, through them, in the case of third parties—so that they can be sent back to the same websites on the user’s next visit.

Cookies allow a website to remember the user’s actions and preferences (such as login details, selected language, font size and other display settings), so that the user does not have to enter them again when returning to the website or moving from one page to another. Cookies are therefore generally used to perform electronic authentication, monitor sessions and store information about the activities of users who access a website. They may also contain a unique identification code that makes it possible to track the user’s browsing activity within the website for statistical or advertising purposes.

More specifically, the Data Controller informs users that the Website uses the types of cookies described below, classified in accordance with the applicable personal data protection legislation (Regulation (EU) 2016/679 and Italian Legislative Decree No. 196/2003, as amended by Legislative Decree No. 101/2018) and the guidance issued by the competent authorities, including the Italian Data Protection Authority (the “Authority”), with particular reference to the “Guidelines on cookies and other tracking tools” adopted by Decision No. 231 of 10 June 2021. 2.1 TECHNICAL COOKIES These cookies are essential to enable the transmission of a communication over an electronic communications network or are strictly necessary to provide an information society service expressly requested by the user. Without these cookies, browsing the Website and carrying out certain operations requested by the user would be impossible or less secure. These cookies enable essential functions such as managing a browsing session, customising the browsing experience (e.g. selecting the language and/or currency) and detecting and preventing fraud.

In view of the purposes for which technical cookies are used, storing them on the device does not require the user’s prior consent under Article 122 of Italian Legislative Decree No. 196/2003 (the “Privacy Code”) and Article 5 of Directive 2002/58/EC, as subsequently amended and supplemented. Disabling these cookies will prevent the user from browsing the Website correctly and/or from using the services, pages, functions or content available on it.

2.2 ANALYTICS COOKIES These cookies are used to assess a website’s effectiveness and help measure its “traffic”, i.e. the number of visitors, which may be broken down by geographical area, connection time or other characteristics. They are therefore used to produce aggregate statistics for internal research into the number of users and how they visit the website.

As specified by the Authority in the “Guidelines on cookies and other tracking tools” (Decision No. 231 of 10 June 2021, published in Official Gazette No. 163 of 9 July 2021), analytics cookies are treated in the same way as technical cookies and may therefore be used without the user’s prior consent if:

They are used by the publisher (so-called first-party analytics cookies) to process purely statistical data, even where the data relate to multiple domains, websites or apps, provided that they are attributable to the same publisher.

Analytics cookies are used by third parties that provide web measurement services to the publisher, subject to the following conditions: they are used solely to produce aggregate statistics and in relation to a single website or mobile application; at least the fourth component of the IP address is masked; and those third parties refrain from combining analytics cookies, even where minimised in this manner, with other processing activities (for example, customer files or statistics on visits to other websites) and/or from disclosing them to further third parties, except where the statistics produced by those further third parties from the minimised data concern multiple domains, websites or apps attributable to the same publisher or corporate group.

Conversely, if analytics cookies do not meet all the above conditions, they may be used only after the website has obtained the user’s consent. The Website does not, however, use analytics cookies.

2.3 PROFILING COOKIES In general, these cookies are used to associate specific actions or recurring behavioural patterns in the use of a website’s functions with identified or identifiable individuals. Their purpose is to group profiles into homogeneous clusters of varying sizes so that, among other things, the service can be delivered in an increasingly personalised manner beyond what is strictly necessary to provide it, and targeted advertising communications can be sent in line with the preferences expressed by the user while browsing online.

By their nature, these cookies may be installed on the device only with the user’s prior consent, as required by Article 122 of the Privacy Code and Article 5 of Directive 2002/58/EC, as subsequently amended and supplemented. The user gives consent through the banner displayed upon first accessing the Website, in accordance with the Authority’s Guidelines No. 231/2021. Profiling cookies may be selected or deselected directly through the banner shown upon first access to the Website or, subsequently and at any time, through the dedicated link in the footer of every page of the Website. Through the banner, the user may manage these cookies individually and withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

The profiling cookies installed by this Website are of the type described above and are not managed directly by the Data Controller, but by other entities—namely third parties—acting as independent data controllers. A complete list of the cookies used by the Website, including their purposes and retention periods, is always available at the end of this Privacy Policy and within the cookie banner.

MANAGING AND DELETING COOKIES THROUGH BROWSER SETTINGS The Data Controller informs users that they may also express or change their cookie preferences through the settings of the browser used on their device. Disabling cookies through the browser does not replace the granular controls offered by the Website’s banner under applicable law, but provides an additional and complementary option. In relation to the Website, preferences expressed through the browser will take effect only from the user’s first connection following the change. For further information on changing cookie preferences, please refer to the following links: Firefox: https://support.mozilla.org/it/kb/protezione-antitracciamento-avanzata-firefox-desktop — Microsoft Edge: https://support.microsoft.com/it-it/microsoft-edge/eliminare-i-cookie-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09 — Safari: https://support.apple.com/it-it/HT201265 — Chrome: https://support.google.com/chrome/answer/95647?hl=it — Opera: https://help.opera.com/en/latest/web-preferences/#cookies

If the user uses more than one browser, the procedure must be carried out for each browser. If other devices are used (such as smartphones or tablets), the relevant device instructions should be consulted to remove cookies. Choosing to block all cookies may impair or prevent the Website from functioning correctly, as some cookies are strictly necessary for browsing.

DISPLAYING CONTENT FROM EXTERNAL PLATFORMS YouTube provides a service that enables videos uploaded to its platform to be displayed on other websites, allowing the Website to embed YouTube content within its pages. For further information: https://www.youtube.com/intl/ALL_it/howyoutubeworks/our-commitments/protecting-user-data/ — Google Fonts is a font-display service operated by Google LLC. For further information: https://policies.google.com/privacy?hl=en — Font Awesome is a font-display service operated by Fonticons, Inc. For further information: https://fontawesome.com/privacy

“SOCIAL” BUTTONS The Website contains “social buttons/widgets” displaying the icons of social networks (YouTube, LinkedIn, Instagram and Facebook), which allow users to be redirected to the Data Controller’s social media profiles. By clicking the relevant button, the user voluntarily chooses to share browsing data with the selected social network. Outside these circumstances, the Website will not share any browsing information or personal data with the social networks accessible through the social buttons. For further information on the cookies used by each platform, please consult the respective privacy and cookie policies.

TRANSFERS TO THIRD COUNTRIES OR INTERNATIONAL ORGANISATIONS The Data Controller informs users that personal data may also be transferred to countries outside the European Union. The user’s personal data may be transferred to the United States of America as a result of the use of Google Inc. products. The Data Controller informs users that such transfers are carried out in compliance with Articles 44 et seq. of the GDPR. In particular, where US providers are certified under Commission Implementing Decision (EU) 2023/1795 of 10 July 2023 (the “EU-U.S. Data Privacy Framework”), the transfer is based on that adequacy decision. In the absence of certification, the transfer is based on the Standard Contractual Clauses adopted by Commission Implementing Decision (EU) 2021/914 of 4 June 2021, supplemented, where appropriate, by suitable additional safeguards.

For further information: https://policies.google.com/privacy/frameworks?hl=it

PERSONAL DATA RETENTION PERIOD The retention period for each cookie is indicated in the table below and in the cookie banner.

RIGHTS OF THE DATA SUBJECT The GDPR grants data subjects specific rights, including the rights of access, rectification, erasure, restriction of processing and data portability, as well as the right to object to processing and the right not to be subject to a decision based solely on automated processing under Article 22 of the GDPR. Users may withdraw at any time the consent given to the storage of profiling cookies, using the methods described in the relevant section of this Cookie Policy or, alternatively, by contacting the Data Controller using the details provided in the Website’s Privacy Policy. Withdrawal of consent will apply only to subsequent processing and will not affect the lawfulness of processing based on consent before its withdrawal. Data subjects also have the right to lodge a complaint with the Italian Data Protection Authority under Article 77 of the GDPR (www.garanteprivacy.it) and to seek a judicial remedy under Articles 78 and 79 of the GDPR.

HOW TO EXERCISE DATA SUBJECT RIGHTS As a data subject, the user may exercise the rights specified above and in the Website’s Privacy Policy at any time. The Data Controller will respond to the request without undue delay and, in any event, within one month of receipt. This period may be extended by a further two months where necessary due to particular complexity, in accordance with Article 12(3) of the GDPR. Rights may be exercised free of charge unless the request is manifestly unfounded or excessive, pursuant to Article 12(5) of the GDPR. To lodge a complaint with the Authority, users may use the forms available on the Authority’s website (www.garanteprivacy.it).

UPDATES TO THE COOKIE POLICY This Cookie Policy may be updated from time to time. Users are therefore advised to review it regularly to remain properly informed about the cookies used by the Website.

ALPS BLOCKCHAIN SPA

Head Office: Vicolo del Liceo, 1 - 38122 Trento (TN), Italy
Head Quarters: Via del Brennero, 111 - 38121 Trento (TN), Italy
VAT No. - Tax Code: 02515120224 | Business Register TN 230317
Share Capital: €1,404,466.66
PEC: info@pec.alpsblockchain.com