COOKIE POLICY

(version 1.3 of 21 March 2022)

Dear Visitor (hereinafter "You" or " User "),

This website www.incontrigarantiti.com (hereinafter the "Site") is owned by the company PROTOR INVESTMENT LIMITED, Agias Zonis & Thessalonikis, Nicolaou Pentadromos Center, Floor 10, Flat/Office 1001A BLOCK B, 3026, Limassol, Cyprus, Vat. Number CY-10400673K (hereinafter, "We" or the "Company").

Since so-called cookies are used on our Site for a range of purposes, with this policy (hereinafter "Cookie Policy") we wish to explain what cookies are and how they are used on the Site.

Some cookies (so-called first party cookies) are transmitted and controlled by us. Using these cookies, the Company collects and processes certain personal information about you. In this Cookie policy, pursuant to Article 13 of EU Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data (hereinafter, "Regulation"), we explain how we collect this data, for what purposes and what your rights are.

Other cookies (so-called third-party cookies), are, however, conveyed and controlled by third parties. In this policy you will find links to information published by these third parties, so please read this information carefully.

If you are not familiar with cookies, please read this Cookie Policy and the Site's General Privacy Policy carefully, so that you can be aware of your choices.

The Data Controller takes the utmost account of Users' right to privacy and personal data protection. For any information relating to this Cookie Policy, Users can contact the Data Controller at any time, using the following methods:

• By sending a registered letter with advice of receipt to the registered office of the Data Controller, PROTOR INVESTMENT LIMITED, Agias Zonis & Thessalonikis, Nicolaou Pentadromos Center, Floor 10, Flat/Office 1001A BLOCK B, 3026, Limassol, Cyprus;
• By sending an e-mail to privacy.it@incontrigarantiti.com.

A. What are cookies and what are they for?

Cookies are small text strings sent by the websites visited by the user to his terminal (usually the browser), where they are stored before being sent back to the same websites during the next visit by the same user (so-called first-party cookies). When browsing this Site, the user may also receive cookies from other sites or web servers (so called third-party cookies): this is because the site might include elements such as images, maps, sounds, specific links to web pages of other domains found on different servers from that on which the required page is found. In other words, these are cookies set by a website other than the website currently being visited.

Cookies can have a duration limited to a single browser session (so-called session cookies), and in this case they are automatically deactivated when the user closes the browser; or they may have a predetermined expiry date and, in this case, they will remain stored and active on your hard disk until this expiry date, continuing to collect information during different browsing sessions (so-called persistent cookies).

Cookies are used for a range of purposes. Some are necessary to allow you to browse the site and take advantage of its features (so-called technical cookies). Others are used to obtain statistical information, whether aggregated or not, on the number of users accessing the Site and on how the Website is used (so-called tracking or analytics cookies). Others are used to track your consumer profile and make you view advertisements on the site that may be of interest to you, as they are consistent with your tastes and consumption habits (so-called profiling cookies).

For more details on these different categories of cookies continue to read this policy. Learn how they work and what they are forand choose freely whether to consent to using or blocking them.

B. Technical cookies

Technical cookies are used on the Site so you can browse the Site and enjoy its features. These are always first-party cookies, as we manage them directly on the Site.

Some technical cookies are essential to offer you an optimal browsing experience or to allow you to log on to the website, for example to make a purchase on the Site or enter a reserved area (so-called browsing cookies) Browsing cookies are normally Session cookies and, therefore, are turned off automatically once you close your browser.

Other technical cookies enable you to store some of your preferences (for example, the language or country of origin) without having to reset them during subsequent visits (so-called functionality cookies). For this reason, functionality cookies are often persistent cookies, because they remain stored on your computer even after the browser is closed until their expiry date or until you decide to delete them.

On the site the following technical cookies are currently used:

As required by existing privacy legislation, your prior consent is not needed to install these cookies. You may of course block the installation of technical cookies by changing browser settings (see section E, no. 1 to see how).  Remember, however, that if you block the installation of technical cookies, or subsequently remove the same, this may affect in whole or in part your ability to access the Site, use all or part of the Site, enable or disable certain functions or receive certain services.

C. Monitoring or "analytics" cookies

Analytics cookies are used to collect statistical information about the Site, in aggregate form or not, about the number of users accessing the Site and how they visit the Site.

This Site's analytics cookies are third-party cookies, since they are not directly conveyed by us but by third parties. Therefore, they are not installed directly by the Company but by third parties.

Other third-party analytics cookies are installed on the Site only with your prior consent, because they are not anonymous, giving third parties access to disaggregated analytics data in terms of IP address (in other words, using these cookies, third parties could theoretically trace your identity through the IP address):

For this reason, when you access the Site a special banner is displayed, telling you that (i) third-party analytics cookies are used on the Site and that (ii) by clicking the relevant button, you consent to the use of cookies. If you consent to the installation of cookies in this way, We will keep track of your consent through a special technical cookie (by clicking, however, the "X" button, you refuse the installation of cookies other than technical and analytics not anonymized) In this way, we will avoid you displaying the cookies banner during your following visits of the Website. Remember that if you were to remove this technical cookie from your browser in the ways referred to in section E, no. 1), consent tracking would be lost and, therefore, on your next visit to the site the cookie banner would be displayed again.

Of course, you are free to block the installation of analytics cookies at any time, without in any way compromising the opportunity to visit the site and enjoy its contents. To learn how, read carefully the information on third party cookies via the links in the table above.

D. Profiling cookies

Profiling cookies are used to create a new user profile, based on the preferences and tastes you manifest when browsing the Internet, and to display advertisements in line with your profile. In this way you will see more interesting advertisements on our site.

As required by existing privacy legislation, your prior consent is required to install these cookies. For this reason, when you access the site a special banner is displayed, telling you that (i) profiling cookies are used on the Site and that (ii) by clicking the relevant button, you consent to the use of cookies. If you consent to the installation of cookies in this way, We will keep track of your consent through a special technical cookie (by clicking, however, the "X" button, you refuse the installation of cookies other than technical and analytics not anonymized). In this way, we will avoid you displaying the cookies banner during your following visits of the Website. Remember that if you remove this cookie from your browser, in the ways described in section E, no. 1 below, consent tracking will be lost and, therefore, on your next site visit the cookie banner will be displayed again.

Of course, you can block the installation of analytic cookies at any time, without in any way compromising the opportunity to visit the Site and enjoy its contents. If you decide to disable behavioural advertising, it does not mean you will no longer receive advertising on the Site. However, banners on the site may not reflect your interests or your current browser preferences.

Most profiling cookies are installed by third parties, which act as independent data processors (third-party cookies). Below is a list of third-party profiling cookies currently used on the site, indicating the link to the cookie policy pages created by their developers:

E. How to manage cookies and object to their use

There are several options to manage, disable and delete cookies.

(1) Change your browser settings

Follow the instructions provided by the maker of your browser to find out how to manage, disable or delete all cookies (technical, analytics and profiling cookies):

• Explorer: https://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
• Chrome:https://support.google.com/chrome/answer/95647?hl=en&p=cpn_cookies
• Firefox:https://support.mozilla.org/en-US/kb/disable-third-party-cookies
• Safari:https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
• Opera:https://help.opera.com/en/latest/web-preferences/#cookies

Make your choices carefully. Blocking all cookies indiscriminately, including technical cookies, without providing a specific exception for the Site, may mean you can no longer browse the site or use all or part of its features. Also, if you delete all cookies from the browser, even technical cookies could be removed, thus you may remove the preferences you set, and might no longer find the products or services in your shopping cart.

(2) Use our interactive tools or those provided by third parties

To disable first party profiling cookies, i.e. those installed directly by us, simply use the interactive button that is illustrated in section D of this Cookie Policy. Your choice to object to the use of these cookies will have no effect on the ability to browse the Site and use its featuresand may be revoked by you at any time using the same interactive button.

To disable third party cookies, consult the privacy policies of third parties installing analytics cookies (see section C) or profiling cookies (see section D above) to learn about the other tools at your disposal to manage, disable and delete cookies, and more generally to object to their use. Remember that, by disabling third-party cookies, (i) you object to their use not only on the Site but on all websites where these cookies are used, and (ii) the ability to surf the Site and use its features will not be affected in any way. When you disable third-party cookies you will however see the banner on the Site's home page relating to cookies; in this case, however, you will not receive any third-party cookies that you have correctly disabled.

(3) Use the Internet website Internet www.youronlinechoices.eu

Your Online Choices is an Internet website managed by the non-profit organisation European Interactive Digital Advertising Alliance (EDAA), providing information on the behavioural advertisings based on profiling cookies and allow the Internet users to oppose easily (opt-out) to the installation of the main profiling cookies installed by the marketing operators and used on Internet websites. Before using this instrument, we hereby recommend you to read carefully the general terms and conditions of the site Your Online Choices.

Please use Your Online Choices consciously. Indeed, notwithstanding that many of the most important marketing companies using cookies are members of the same, certain third parties installing cookies through the Website could not be members of Your Online Choices. Therefore, the use of Your Online Choices does not guarantee that third parties cookies will be received surfing on the Website. Please be remained that, removing all the cookies from the browser, also the technical cookies released by Your Online Choices in order to remind your choices could be removed, thus reactivating third parties cookies.

F. Processing methods and data storage periods

As noted in the introduction to this policy, the Company collects and processes certain personal information through cookies that it conveys directly to the Site (first-party cookies). The Company acts as the Data Controller, in compliance with the provisions of the Regulation. We will process your data only by electronic means, in a totally automated fashion and without human mediation. Our employees and collaborators will accordingly never access the content of your personal data obtained through cookies, which means that they will never be able to access and/or obtain direct personally identifiable information (PII).

Some of our employees and partners, appointed by us to process data, may perform maintenance work on the computer systems hosting your data, without ever being able to access their content. Personal data may be stored on servers operated by third parties (e.g. computer system suppliers),or may be managed by subjects specialising in online advertising, acting as external processing managers based on a specific appointment made in writing by the Company. We inform you that, in compliance with the conditions and guarantees established by the Regulation, your data may be transferred to countries outside the European Economic Area, which may not offer a level of privacy and personal data protection comparable to that guaranteed by European privacy laws, but as Data Controller we will take the utmost account of data security, and will proceed with the management of these transfers with all due caution and guarantees. Your personal data will not be disclosed to third party data processors or disseminated.

Your personal data will be kept for the time strictly necessary to carry out the primary purposes described in this statement, or in any case as necessary for the protection of the rights of both the interests of both Users and the Company.

G. Your rights

To exercise your rights, or obtain any further information or clarification in relation to this Cookie Policy, please contact the Data Controller in the following ways:

• By sending a registered letter with advice of receipt to the registered office of the Data Controller PROTOR INVESTMENT LIMITED, Agias Zonis & Thessalonikis, Nicolaou Pentadromos Center, Floor 10, Flat/Office 1001A BLOCK B, 3026, Limassol, Cyprus;
• By sending an e-mail message to: privacy.it@incontrigarantiti.com;

Pursuant to the Regulation, the Data Controller informs Users that they are entitled to be informed about:

(i) the origin of the personal data;

(ii) the purpose and methods of data processing;

(iii) the software applied if the data are processed electronically;

(iv) the identification details of the controller and managers;

(v) the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as managers or agents.

Furthermore, Users are entitled to:

1. access, update, rectify or, should they wish to do so, supplement their data;
2. request the deletion, transformation into anonymous form  or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
3. confirmation that those to whom the data are communicated or disclosed are notified of the actions referred to under letters (a) and (b), including their content, unless the fulfilment thereof proves to be impossible or involves using methods that are clearly disproportionate to the right being protected.

Furthermore, Users have:

1. the right to withdraw consentat any time, if the processing is based on their consent;
2. (if applicable) the right to data portability (the right to receive all personal data concerning the Data Subject in a format that is structured, commonly used and readable by automatic devices), the right to limit the processing of personal data and the right to be deleted ("right to be forgotten");
3. the right to object:
1. in whole or in part, for legitimate reasons, to the processing of personal data concerning the Data Subject, even if pertinent to the purpose of the collection;
2. in whole or in part, to the processing of his/her personal data for the purpose of sending advertising and direct marketing materials, or for carrying out market research or business communications;
3. if personal data are processed for direct marketing purposes, to object at any time to the processing of their data for this purpose, including profiling in so far as it is connected to such direct marketing;
4. if it is believed that processing of the data is in breach of the Regulation, the right to file a complaint with the Supervisory Authority (in the Member State in which the Data Subject normally resides, in which they work or in which the alleged violation has occurred).

The Data Controller is not responsible for updating all links that can be viewed in this Policy, therefore whenever a link is not working and/or up-to-date, Users acknowledge and accept that they must always refer to the document and/or section of the websites referred to by the link.