IMPORTANT NOTE

This is a translation into English for reference purposes only.

The original Italian text of this document can be read here (hyperlink).

In the event of any discrepancy between the original Italian version and this English translation, the original Italian version shall always prevail.

1. LEGAL INFORMATION

Date of last update of this Privacy Policy: December 20, 2023

Date of publication on the website and entry into force December 21, 2023

1.1 The protection of your personal data is of paramount importance to us. This privacy policy (hereinafter

the Privacy Policy) was created to help you understand how we process the information we collect about

you, when you interact with us, or that you provide to us through our website and our web application

dedicated to the PIRELLI Care™ offer (the Website and the App respectively).

1.2 Pirelli Tire S.p.A., with registered office in Viale Piero and Alberto Pirelli 25, 20126 Milan, Tax Code, VAT

and registration number in the Milan Companies Register 07211330159 (hereinafter Pirelli, we, or our,

as the case may be) will act as Controller of the processing of your personal data, for the purposes better

specified in Article 3.

2. COLLECTION OF INFORMATION

2.1 In order to provide the services provided by the Website and the App, we collect personal data that

according to the current legislation on the protection of personal data and in particular, the EU Regulation

679/2016 of the European Parliament and of the Council of 27 April 2016, on the protection of natural

persons with regard to the processing of personal data and the free circulation of such data (hereinafter

GDPR), includes information that can be used to identify you, including: name and surname, date of birth,

tax code, address, zip code, city, country, telephone number, e-mail address, the license plate of the

car/cars that you want to register on the Website and the App (including the license plate indicated on the

vehicle registration document - in case of voluntary upload of an image of the latter) and further

information relating to you, acquired from the mobile device on which you downloaded and use the App

(specifically: the GPS location). Furthermore, for the sole purpose of allowing us to formulate the most

suitable offer for you, we will process the data that you provide to us through the Site and/or the App

related to your car's license plate and driving style (hereinafter Personal Data).

Technical Information

2.2 When you browse our Website and when you use the App, we may also collect information that can be

used to identify your computer and the browser it uses or any mobile device you use to browse the internet

or interact with the App. This information is collected by installing small text files called cookies and other

similar technologies (hereinafter jointly defined as Cookies).

2.3 For all the information on how we use cookies, you can refer to our Cookie Policy.

3. USE OF PERSONAL DATA

3.1 We will use your Personal Data for the following purposes:

(i) while browsing our Website and when using the App, without the need to create an account, in order

to allow us to make the most suitable offer for you; in this phase, we will process data relating to the

license plate of your car (including images of the vehicle registration document which you may voluntarily

upload) and your driving style, as described in art. 2.1, with the explicit exclusion of any other use;

(ii) for the creation of an account on the Site or on the App, either with the sole indication of a valid e-

mail address in order to take advantage of the free feature "YOUR DRIVING STYLE" and to access

editorial content, or in the case of adding additional personal data referring to the same account, necessary

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for the purposes of the purchase of a PIRELLI Care™ Package and the possible subsequent purchase of

Additional Services, as defined in the General Terms and Conditions of Sale and described on the Website

and on the App;

(iii) to respond to your requests for assistance addressed to Customer Care;

(iv) to manage any tire inspection requests from you, by filling in the appropriate form, including

communicating the outcome of the inspection;

(v) to allow us to improve the services offered as part of PIRELLI Care™, following receipt of the

evaluations provided by you on the services you have received;

(vi) to provide the services provided by the App, including those that involve the processing of your GPS

location data and tracking of your car movements, for which your prior authorization is required, as will

be required by the mobile device on which you downloaded and use the App.

The processing of your Personal Data for the purposes of Article 3.1 herewith is based on Pirelli's

legitimate interest in satisfying your requests and therefore does not require your prior consent.

3.2 Pirelli may also use your Personal Data for marketing purposes, as described in the following Article 7,

with your prior consent.

4. SHARING OF PERSONAL DATA

4.1 We may share your Personal Data, if authorized by law or as follows:

(a) Payment Service Provider. In order to allow you to make online payments by credit card, the Personal

Data you provide will be processed by the payment service providers identified by PIRELLI, who will

each act as an independent Data Controller, in accordance with their own privacy policy, in a secure

website managed by each company.

(b) Pirelli Group Companies. Your Personal Data may be shared with Pirelli & C. S.p.A. and/or with any

company of the group based in Europe for the pursuit of legitimate interests related to the performance

of organizational and technical activities related to the purposes referred to in Article 3.

including, by way of example, the Dealers listed on the Website and on the App and any companies

engaged to perform Customer Care services. These third parties will act, unless otherwise specified, as

data controllers. We specify that third parties are subject to confidentiality ties with us and to other legal

restrictions that prohibit the use of the information we provide them for purposes other than to carry out

the related outsourcing activity unless it has been expressly agreed or your permission has been granted

for additional purposes.

(d) Tire Inspection. The Personal Data provided by you in the appropriate form or in any case, for the purpose

of inspecting the tires will be processed exclusively by the personnel specifically appointed by Pirelli; it is

in no way communicated or disseminated externally, without prejudice to the execution of any orders from

the judicial authorities or judicial police or for defensive purposes.

(e) As permitted or required by law. In some cases, we may be required to provide Personal Data in response

to a court order, subpoena, government investigation or as otherwise required by law. We also reserve the

right to communicate to the competent authorities all activities that, in good faith, we deem illegal or in

violation of applicable laws. We may disclose some Personal Data if we believe that such activity is

reasonably necessary to protect our rights, our assets, our safety, or that of others or to detect, prevent or

identify fraud, security, or technical problems.

(f) Commercial Transaction. In the event that we intend to sell or transfer ownership or control of any or all

of our businesses, or services to third parties, it may be necessary to disclose your Personal Data to the

prospective purchaser both before and after the purchase. We will do this in accordance with applicable

data protection laws. In any case, should the commercial transaction take place, we will ask that the

purchaser agree to be bound similarly to the provisions of this Privacy Policy, and to use and disclose your

Personal Data similarly to the provisions of this Privacy Policy. If, on the other hand, the commercial

transaction does not take place, we will ask the potential purchaser not to use or disclose your Personal

Data in any way and to completely delete it.

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5. YOUR RIGHTS PRIVACY

5.1 You are entitled to various privacy rights in accordance with the current regulations on the protection of

personal data. According to the provisions of the GDPR, you have the right to access your data processed

by us, request the correction and elimination (for legitimate reasons) thereof, limit or circumscribe the

processing we perform and be entitled to the portability of your Personal Data as well as be notified of

any security breach that could jeopardize your rights to the privacy and protection of your Personal Data.

To exercise your rights, you can contact us at the following e-mail address: privacy.europe@pirelli.com.

You can also use your personal area on the App to directly carry out the operations permitted therein.

You can also file a complaint with the competent supervisory authority in your country regarding data

protection, in accordance with current regulations. We may not be able to accommodate every request

relating to certain information if we believe it violates any law, other legal requirement, or other data

subject rights.

6. RETENTION OF PERSONAL DATA

6.1 We will retain your Personal Data:

(i) for the purposes set forth in art. 3.1 paragraph (i), if you do not create an account, for a period of thirty

(30) days;

(ii) in case you have addressed requests to Customer Care without creating an account, for a period of 1

(one) year from our last communication;

(iii) if you have created an account, we will keep your personal data for a period of 3 (three) years from

the date of collection of such data;

(iv) for marketing purposes, for a period of 3 (three) years from the date of collection of your consent,

unless otherwise requested by you.

Furthermore, if within the period mentioned in paragraphs (iii) and (iv) you perform any action on your

account or on any Pirelli website or app (such as but not limited to registering for any promotions or

events, requesting new services or replying to surveys), which shows that you are interested in maintaining

your account or relationship and contacts with Pirelli in relation to Pirelli’s and/or Pirelli group companies’

products and/or services, we will keep your Personal Data for a further 3 years from the date of the

recording of such actions, but we will not send marketing communications without your specific consent.

After the data retention periods for the purposes set out above, your Personal Data will be archived and

retained where necessary (e.g. in connection with the products and/or services purchased or used by you

or in the case of your participation in prize competitions), for the period of time mandatorily required by

applicable laws concerning the retention of data and documents for administrative, accounting, tax and

defense purposes (in accordance with the applicable statutes of limitations).

We will delete your Personal Data at your request, where the conditions are met, in accordance with the

data protection regulations applicable to you.

7. COMMERCIAL COMMUNICATIONS IN ELECTRONIC FORMAT

7.1 Based on your specific consent to marketing activities, Pirelli will be authorized to send you promotional

e-mails (including newsletters) and other commercial communications in electronic format relating to

products and/or services of Pirelli or other companies of the Pirelli group. You can limit the

communications that Pirelli sends you at any time. In order not to receive commercial e-mails in the future,

simply click on the link at the bottom of each e-mail that Pirelli sends you.

7.2 Keep in mind that even if you have decided to opt out of receiving future promotional e-mails, it may still

be necessary for you to be contacted by us for important information about your account, in compliance

with applicable laws on data protection. If you require information or assistance with how to unsubscribe,

please contact us by e-mail at the following address: privacy.europe@pirelli.com.

8. WHERE WE STORE YOUR PERSONAL DATA

8.1 Pirelli will process your Personal Data within the European Union.

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9. PRIVACY POLICY OF THIRD PARTIES

9.1 This Privacy Policy concerns only the use and disclosure of information by Pirelli. We are not responsible

for the privacy policies of other websites or applications, and we encourage you to read all the terms,

conditions and privacy policies provided by third parties before providing them with your information.

10. LIMITATIONS FOR DATA OF MINORS

10.1 If you are a minor, pursuant to Italian law, do not provide us with any Personal Data without the consent

of the person exercising parental authority over you. If we become aware that we have collected Personal

Data from a minor, without the consent of the person exercising parental authority over him/her, we will

promptly delete said information. Should you believe that we have collected Personal Data from a minor,

please contact us at the following address: privacy.europe@pirelli.com.

11. SECURITY OF PERSONAL DATA

11.1 We use security measures to protect your Personal Data from unauthorized access, improper use or

disclosure, unauthorized modification, unlawful destruction or accidental loss. We allow access to our

databases only when necessary, and based on strict guidelines on what use may be made of such data.

11.2 It will be your responsibility to protect your login credentials, and to this end, we recommend that you use

a unique password for our Website that is different from the password used for any other website or app.

12. CHANGES TO THE PRIVACY POLICY

12.1 Our Privacy Policy may change over time. The date on which the last version of the Privacy Policy was

changed is located at the top of this document.

13. HOW TO CONTACT US

13.1 If you have any questions regarding the Privacy Policy, or wish to examine, modify your Personal Data or

request to delete the Personal Data stored in the databases we actively use, please contact:

privacy.europe@pirelli.com.

You can also contact the Data Protection Officer (DPO) of Pirelli Tyre S.p.A. at the Company’s registered

office – e-mail DPO_Ptyre@pirelli.com.