Cookie Policy — dAirect Connect

Cookies are small text strings that the websites visited by the user send to the user's device, where they are stored and then transmitted back to the same sites on subsequent visits.

Alongside cookies, the Platform may use technically similar tools, such as pixels, tags, scripts, local storage, session identifiers, SDKs, or other tools suitable for collecting information on the device, session, navigation, or user interactions. For the purposes of this Cookie Policy, these tools are collectively referred to as “cookies”, unless otherwise specified.

Cookies can be installed directly by the Company (first-party cookies) or by third parties (third-party cookies). They can also be session cookies, which are deleted when the browser is closed, or persistent cookies, which are stored until their natural expiration or deletion by the user.

The Company uses cookies and similar tools for different purposes, depending on their nature and function.

In particular, cookies may be used to:

• allow the correct technical functioning of the Platform
• keep the authenticated user's session active
• ensure security, integrity, and operational continuity
• remember user preferences or settings
• measure traffic, usage, and performance of the Platform
• improve the user experience
• manage requests, forms, logins, and access to the management system
• support analysis, measurement, assistance, or marketing activities, where applicable and subject to consent, if required

3.1 Strictly necessary cookies

The Platform uses strictly necessary cookies to enable the proper technical functioning of the site and the services requested by the user.

Such cookies may include, by way of example:

• session cookies
• authentication cookies
• cookies necessary for logging in and remaining in the Account
• security cookies
• cookies necessary to store the choice regarding cookies
• functional cookies for accessing and using the management system
• cookies necessary for handling requests expressly activated by the user, such as specific support or interaction features

These cookies do not require the user's prior consent, as they are necessary for the functioning of the Platform or the provision of the service expressly requested.

3.2 Analytics and measurement cookies

The Platform may use cookies or analytics and measurement tools to collect information on site usage, pages visited, user interactions, Platform performance, the effectiveness of specific features, and, more generally, for service improvement.

Depending on the configuration in use, this category may include tools such as Google Analytics, Hotjar, and analysis components linked to CRM or support tools.

The Company treats these tools taking into account that analytics cookies cannot automatically be classified as technical. They can be assimilated to technical cookies only in the cases and under the conditions permitted by applicable laws and provisions. In all other cases, these tools are activated only with the user's prior consent.

3.3 Marketing, profiling, and advertising measurement cookies

The Platform may use, directly or through third parties, cookies or other tracking tools to measure campaign effectiveness, associate conversions, personalize promotional content, or support advertising and remarketing activities.

This category may include, by way of example, tools or pixels from Meta, Google Ads, TikTok, LinkedIn, and other advertising or attribution platforms.

These tools are activated only with the user's prior consent, where required by applicable law.

The use of strictly necessary cookies is based on the Data Controller's legitimate interest in ensuring the correct functioning, security, and operational continuity of the Platform, as well as, where applicable, the need to provide the service expressly requested by the user.

The use of analytics, marketing, or other non-necessary tracking tools is based, where required by applicable law, on the user's consent, freely given via the banner or the consent management panel.

The user can withdraw or modify their choices at any time using the tools made available by the Platform.

Upon first accessing the Platform, the user may see a specific banner or other consent management tool through which they can:

• accept all cookies
• reject all non-necessary cookies
• granularly select categories or, where available, individual tools or providers

Except for strictly necessary cookies, cookies and other non-necessary tracking tools are activated only based on the preferences expressed by the user via the banner or the consent management panel, where required by applicable law.

The preferences expressed by the user can be subsequently modified via the consent management panel or other tools made available by the Platform.

Consent management is entrusted to a Consent Management Platform (CMP) compliant with the Privacy Guarantor's Guidelines. The user's preferences are recorded and stored for the duration required by applicable law.

Where available, the consent management panel may distinguish cookies into at least the following categories:

• Necessary
• Analytics / Measurement
• Marketing / Profiling

Where technically possible and appropriate, the panel may also allow a more analytical selection of individual providers or groups of providers.

Where the same provider offers tools with different purposes, the Company reserves the right to classify the related components separately, distinguishing, for example, between strictly necessary elements and tracking, analytics, or marketing components.

The Platform may use tools provided by third-party suppliers. The updated list of providers actually in use, their purposes, and their category is made available in the consent management panel and/or in a specific information area linked to this Cookie Policy.

The providers and tools indicated in the following sections include those currently integrated into the Platform, as well as tools that may be integrated in the future. The updated list of actually active providers is available in the consent management panel.

7.1 Strictly necessary providers and tools

Technical tools used for the following may fall into this category:

• login and authentication
• security
• session
• saving consent
• functioning of the Account and management system
• loading features expressly requested by the user

Depending on the actual configuration of the Platform, this category may include the Company's proprietary tools or technical support tools integrated into the Platform.

7.2 Analytics / measurement providers and tools

The Platform may use analytics and measurement tools from providers such as:

• Google Analytics / Google Tag / Google Tag Manager, for collecting statistical and usage data
• Hotjar, for behavior analysis, heatmaps, session insights, or similar tools
• HubSpot, to the extent that analytics, traffic tracking, interaction measurement, or similar components are used
• additional technical analysis or traffic measurement tools that may be integrated

These tools are processed according to the category and consent logic actually applicable to their configuration.

7.3 Marketing / profiling providers and tools

The Platform may use marketing, advertising, or advertising measurement tools from providers such as:

• Meta / Facebook Pixel
• Google Ads / Conversion Tracking / Conversion Linker
• TikTok Pixel
• LinkedIn Insight Tag
• any marketing or advertising components of HubSpot
• additional remarketing, conversion tracking, or attribution tools that may be integrated

These tools are activated only with the user's prior consent, where required by applicable law.

The Platform may use customer communication or CRM tools, including chat services or contact forms.

Where such tools are used exclusively to make available a feature requested by the user, such as opening a chat session or managing a specific interaction activated by the user, the components strictly necessary for the operation of this service may be treated as necessary.

It is understood that any tracking, behavior analysis, user recognition, marketing attribution, or profile enrichment components linked to such tools will not be considered strictly necessary if the conditions required by applicable law are not met and, in that case, will be activated only with prior consent, if required.

The Platform may incorporate or use services, features, scripts, tags, pixels, or tools provided by third parties. In such cases, the relevant third parties may install cookies or collect data according to their own privacy and cookie policies.

The Company does not fully control the ways in which these third parties process the data collected through their respective cookies, nor can it guarantee the persistence of their settings or policies over time.

The user is therefore invited to also consult the information provided by the respective third-party providers, where applicable.

Depending on the category and configuration of the tools used, information such as the following may be collected via cookies and similar tools:

• IP address
• device or browser identifiers
• information on the browser and operating system
• session identifiers
• date and time of the visit
• pages visited
• interactions carried out on the Platform
• login outcome or session status
• user preferences
• aggregated statistical data or data relating to site usage

Such data may be processed by the Company within the limits and for the purposes indicated in this Cookie Policy and the Privacy Policy.

The duration of cookies may vary depending on their nature and purpose.

In particular:

• session cookies remain active until the browser is closed
• persistent cookies remain stored until their expiration or deletion
• consent preferences may be kept for the period necessary to document the user's choice and to avoid re-presenting the banner too frequently, barring new technical or regulatory conditions

The Company adopts retention criteria that are proportionate and consistent with the purpose of the cookie used.

The user can manage, limit, or disable cookies via:

• the consent management panel made available by the Platform, if any
• browser or device settings
• tools potentially made available by third parties

Disabling strictly necessary cookies may compromise or prevent the proper functioning of the Platform, the login, the Account, or the management system.

For any further information regarding the processing of personal data carried out by the Company, including the rights of the data subject, data recipients, retention times, and Data Controller contacts, please refer to the Company's Privacy Policy.

The data subject may exercise, within the limits and conditions established by applicable law, the rights recognized by Articles 15–22 of the GDPR, including the right of access, rectification, erasure, restriction of processing, objection, and, where applicable, data portability.

The data subject also has the right to withdraw at any time any consent given for the use of non-necessary cookies, without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise these rights, the data subject can contact the Company at the details indicated in the Privacy Policy or on the Platform.

The Company reserves the right to modify, integrate, or update this Cookie Policy at any time for legal, regulatory, technical, or organizational reasons.

The updated version will be made available on the Platform indicating the date of the last update and will become effective upon publication, unless otherwise indicated.

Any versions of this Cookie Policy translated into other languages are provided for informational purposes only. In the event of a dispute or misalignment, the Italian version strictly prevails. Translations are carried out automatically using artificial intelligence tools.