GENERAL PRIVACY POLICY

The purpose of this General Privacy Policy (the Policy) is to describe the ways in which CMG di MARIA GIOVANNA COSTA, an Italian sole proprietorship with registered office in 95126 Catania (CT), Via Antonino Caruso n. 22, paid-up share capital Euro 2,500.00, CF/P.IVA and registration no. in the Reg. Imp. del SUD EST SICILIA CSTMGV79H67C351J, REA CT - 427221, tel: +39 347 4970853, as data controller, processes the personal data of its customers and potential customers to provide the best possible service.

MARIA GIOVANNA COSTA and/or her local company CMG di MARIA GIOVANNA COSTA responsible for you, as described in this Policy (hereinafter: "We", "Our" or "Us") collect, store, process, use and disclose personal data of the customer or potential customer relating to his/her use, in his/her country, of the websites mariagiovannacosta.com, the MGC apps, the smart products (if and when applicable), or visits to our premises or social media.

1. TYPES OF PERSONAL INFORMATION COLLECTED

CMG di MARIA GIOVANNA COSTA may collect the following categories of personal data for the purposes described in this Policy:

• a) Identifying and contact information (such as your name, address, telephone number or email address) provided by you, for example, to register for an online account or fill out a form with your information in a showroom, attend an event, make a purchase or identifying information necessary to claim a VAT refund.

• b) Payment information: such as credit card information, bank account number, PayPal account information or other payment information provided by you to receive the products or services requested by you.

• c) Demographic information such as gender and birthday.

• d) Your image at the time of your visit to the office, if video surveillance systems are installed, or your voice when you call the Customer Service of CMG di MARIA GIOVANNA COSTA (since the telephone call could be recorded).

• e) Preferences and interests that you have chosen to disclose during your contacts or privileged meetings with our client advisors (including, for example, preferences regarding our collections or other luxury brands, your size, your lifestyle or basic information about your family).

• f) Information of a medical nature, relating to the possible side effects caused by the materials used.

• g) Information disclosed or published by you in a public place, on our social pages or websites, such as for a product review.

• h) Information about online or in-store purchases. This includes the products purchased and their prices.

• i) If (potential) customers use our websites, information about the browser used or surfing behaviour.

• j) If (potential) customers use our app on a mobile device, we may collect GPS location, subject to consent where necessary. We may also check how often the app is used and where it was downloaded from. We may collect information about the browser used or browsing behavior.

• k) With regard to the use of smart products, we may collect information about your use of such products (such as information on the characteristics of the most used product or the battery level) and, where necessary to provide the service requested by you, information on geolocation;

• l) We may also collect information published on third-party sites or social platforms about CMG di MARIA GIOVANNA COSTA products and services, when necessary for the purposes defined below.

Personal data may be collected directly from you (for example, when you create an account on one of our sites/apps, or make a purchase or interact in any other way with our client advisors at the headquarters or with our Customer Service CMG di MARIA GIOVANNA COSTA), or passively from you (for example, when you use tracking tools such as browser cookies), or from third parties (such as social platforms).

If you choose not to provide personal data that is necessary for the performance of a contract or required by law, you will not be able to receive the requested products or services or register on our websites, apps and other media.

2. HOW WE USE PERSONAL INFORMATION

We use the information described above for the purposes indicated at the time of collection or further in this Policy.

Information is collected for:

• a) better understand your interests and expectations and how you use our products: we may use this information to improve our websites, apps and products/services. We use your information to personalize your experience with us and tailor our marketing activities to your needs and interests, as we believe it is also in our legitimate interest to satisfy you as much as possible and respond to your needs.

• b) provide our smart services, process orders, respond to your requests or questions and manage complaints: for example, we use your information to process an order and deliver a product. We may also use your data to send you requested information or communications about your account or our relationship: we may contact you to inform you of changes to the Site or updates to the services. We may also contact you to request feedback or in relation to this Policy or the terms of the website. In this case, the information will be processed for the performance of the contract entered into with Us.

• c) for security purposes: We may use the information to protect Our company, Our customers, Our affiliates and Our websites and apps from fraud, theft or breaches that could harm Our business, as it is our legitimate interest to ensure the security of the activities We carry out online and offline.

• d) manage the possible side effects caused by our materials in compliance with the obligations to which we are subject as manufacturers of clothing and accessories.

• e) to prevent counterfeiting and combat illegal resale channels of CMG di MARIA GIOVANNA COSTA products that violate the general terms and conditions of sale of CMG di MARIA GIOVANNA COSTA and the selective distribution network of CMG di MARIA GIOVANNA COSTA (in particular, to control the quantities or frequency of products purchased), as it is in our legitimate interest to protect ourselves from online counterfeiting and safeguard our distribution network.

• f) for marketing purposes: we may use the information to contact you, after receiving your consent (where applicable), and inform you of new products and special offers which we think may be of interest to you.

• g) for analysis purposes: we may use your information to analyse the online reputation of CMG di MARIA GIOVANNA COSTA or our products and to verify the effectiveness of our online and offline campaigns and events, as it is in our legitimate interest to protect the image of CMG di MARIA GIOVANNA COSTA and optimise our marketing campaigns.

• h) Other purposes: We may use the information to keep track of transactions and other business records, for legal, administrative and audit purposes. We may also use the information to comply with legal, insurance and processing requirements.

3. SHARING PERSONAL INFORMATION

We undertake not to disclose or otherwise share your personal data, except:

• a) With the company CMG di MARIA GIOVANNA COSTA, and only to authorized personnel with the need to access the information in order to perform an internal audit or for administrative or billing purposes, and to provide you with the same level of services throughout the world.

• b) with service providers and agents who perform services on Our behalf: For example, We share information with vendors who send emails on Our behalf. We may also share personal data with service providers who help Us operate Our websites.

• c) With your prior consent, with our business partners: for example, we share information with third parties with whom we sponsor events or promotions.

• d) with third parties in the context of corporate restructuring and reorganisation (including in the event of dissolution or liquidation), as well as total or partial mergers or in the event of transfer, assignment or sale of assets.

• e) where required by law or necessary to comply with applicable laws: for example, we may share information to respond to a court order.

4. TRACKING TOOLS AND USE OF COOKIES

We may collect certain information through cookies, web beacons and other automated means. A cookie is a text file stored in a dedicated area of ​​the hard disk of a device, for example when visiting an online service, reading an email, or installing or using a mobile app. The cookie allows its manager to identify the device on which it is stored during the period of validity of the consent, which does not exceed 13 months.

What types of cookies do we use?

• a) Some cookies may be functional to collect information that will allow us to facilitate navigation, such as language preferences, storage of login data or storage of the contents of your cart or wish list.

• b) Other cookies collect information about your behavior by collecting the reference URLs (the origin of our visitors, the banners they clicked on and those that redirected them to our website), the pages viewed, the duration of the visits. This information will allow us to improve our sites and apps, to better understand the products and services you prefer, and to offer personalized communications and/or content from our websites or our applications.

• c) We also use cookies for web analytics, in order to evaluate the activity of the websites and to identify the most visited areas of the sites, thus improving the visibility of our contents.

• d) We use cookies to ensure the security of online transactions/purchases through device fingerprinting, which allows us to identify certain aspects of the devices used to place an order.

• e) Our websites and apps may contain third-party cookies (delivered by advertising agents, analytics providers, etc.) that allow us to collect browsing information on your Devices, as well as to verify the effectiveness of our advertising campaigns on third-party sites. Third-party cookies are governed by the privacy policies of the third parties in question. In this Policy, we inform you, to the extent that we are aware of it, of the purposes of these cookies and how you can manage them.

• f) allow other parties to know that you have browsed our site. This is the case, for example, of the "Like" and "Share" functions offered by social platforms ("Facebook", "Twitter", etc.).

Social networks that offer these functions may identify you even if you have not used these functions on our website. In fact, these functions allow social network platforms to track information relating to your navigation of our website whenever your social network account is active during your visit to our website.

We do not control how these platforms collect your personal data when you visit our website. We encourage you to read the privacy policies of the social networks to learn how they use the browsing information collected (including for advertising purposes). The privacy policies should contain information on how to manage your preferences regarding a social network account.

Acceptance of cookies

Except for technical and security cookies, the use of cookies on a Device depends on the user's choices, which can be made and modified freely at any time.

You can manage cookies by setting your browser to accept or reject cookies on your Device, for all or for each individual cookie. The settings you choose may change your ability to navigate the Internet and may sometimes change your ability to access certain services that require the use of cookies.

This is the case where we or our business partners are no longer able to recognize the type of browser used by Your Device, such as language, screen settings or country of connection. We cannot be held responsible for reduced access to our services due to previous deletion or deactivation of cookies.

Managing cookies on your browser

Each browser has its own cookie management system, as indicated in the “Help” section of the browser itself, where you can find all the information on how to set your preferences.

If you share your Device with others or if your Device uses multiple browsers, we cannot guarantee that personalized services and advertising designed to respond to your personal use of the Device (where such personalized services and advertising are available) will correspond to your use and not someone else's.

5. TRACKING TOOLS AND USE OF COOKIES

The information we collect about you may be transferred to any country where a CMG di MARIA GIOVANNA COSTA branch is established, and stored and processed there, in order to provide you with the best services during your visits and for the purposes indicated in this Policy.

Additionally, we may transfer your personal data to service providers responsible for maintaining our websites, apps or social media or any other tools used to process information about our customers or potential customers.

Some recipients are located in third countries, which are not considered to be able to guarantee the same level of protection of personal data as the European Union country in which you provided your information.

We are committed to protecting your personal data, and to providing an adequate level of protection for personal data transferred to recipients established in such countries by entering into data transfer agreements with recipients based on the European Commission's standard clauses (as revised or replaced by the European Commission from time to time), or on the EU/US Privacy Shield as may be revised or replaced or on any other valid transfer mechanism available in the future.

6. RETENTION PERIOD

Your personal data are stored in such a way that you cannot be identified, and for the entire period considered by CMG di MARIA GIOVANNA COSTA reasonably necessary to achieve the purposes for which they were collected or processed, or according to the laws in force regarding data retention. The retention period of Your personal data collected by Us is established, for the purposes of data processing, based on the following criteria:

• The data collected for the specific purposes described in Article 2 will be retained only for:

• Three (3) years from your last interaction, if you are a potential customer (i.e. you have not made any purchase with us but are interested in CMG di MARIA GIOVANNA COSTA),

• For the duration of the commercial relationship with CMG di MARIA GIOVANNA COSTA and 10 years thereafter, if you are a customer (i.e. you have purchased our products or services).

• Personal data will be stored for use: in the event of a dispute for the limitation period applicable to the relevant purpose;

• In the event that legal action is initiated, personal data may be retained until its conclusion, including any appeal period, and then deleted or archived as permitted by applicable law;

Your personal data will then be made anonymous or deleted.

7. YOUR RIGHTS

You may access your personal data stored by us. If you request it, we will provide all the information, as required by law, on the purposes of the processing, the categories of data processed, the categories of recipients, the period of data storage and rights of rectification, erasure or limitation of the data to which you have access (where applicable, etc.).

Where the processing is based on your consent or the performance of a Contract between you and Us, you may request a copy of your personal data held by Us in a compatible format that allows you to exercise your right to data portability.

Furthermore, you may give general or specific instructions on how your personal data shall be processed and may be used after your death.

You may also request the correction, modification or deletion of incomplete, outdated or inaccurate information.

The deletion of personal data may be requested in cases where (i) they are no longer necessary for the purposes of data processing, (ii) you have revoked your consent to the processing of data for which such consent is necessary, (iii) you have objected to the processing of data, (iv) the processing of personal data is unlawful, (v) the personal data must be deleted to comply with a legal obligation of CMG di MARIA GIOVANNA COSTA

You may request the restriction of processing if (i) the accuracy of your personal data is contested to allow CMG di MARIA GIOVANNA COSTA to carry out the necessary checks, (ii) you intend to limit your personal data rather than erase them, despite the processing being unlawful, (iii) you wish CMG di MARIA GIOVANNA COSTA to retain the personal data as it is deemed necessary to defend itself in legal actions, (iv) you have objected to the processing but CMG di MARIA GIOVANNA COSTA needs to carry out checks to ascertain the existence of legitimate reasons for the processing that prevail over your rights.

You also have the right to lodge a complaint with the competent supervisory authority.

Our Data Protection Officer’s contact details are privacy@mariagiovannacosta.com . When the processing of information is based on your consent (for example when you agree to receive communication materials), this may be revoked at any time, without prejudice to the lawfulness of the processing based on consent carried out before the revocation.

Where personal data is processed to pursue Our legitimate interests, You may object to such processing if Your interests and freedoms prevail over Our legitimate interests.

8. PROTECTION OF PERSONAL INFORMATION

We are committed to providing an adequate level of protection of personal data and to ensuring that appropriate technical and organizational security measures are adopted to protect personal data (including by providing training to the personnel involved) from accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, as well as from any other form of unlawful processing.

However, if the internet is not completely secure, we cannot guarantee that your personal data stored or received by us is completely secure. We recommend that you use caution when using the internet to access our sites, apps or social media.

9. MINORS

Our websites and apps are not intended for children. Without the consent of a parent or guardian (except as permitted by applicable law), we will not, to the best of our knowledge, collect personally identifiable information from children.

You must be at least sixteen years old to provide us with personal information, and eighteen years old to enter into transactions on our websites and apps. By entering into transactions with us, you automatically represent that you are at least eighteen years old and have full authority to enter into such transactions and to be legally bound by them.

If we are informed (via the "Contact Us" section) or become aware that a minor has provided us with his or her personal data through our media or otherwise, we will immediately delete such personal data.

10. THIRD PARTY SITES

We may link to third-party sites or services that are not under our control and are governed by their own privacy policies. This Policy does not apply to third-party sites. We strongly recommend that you review the privacy policies of all third-party sites you visit to learn how they handle your personal data.

11. CHANGES TO THIS NOTICE

This notice may be changed from time to time to reflect changes in the processing of your personal data. Substantial changes will be communicated to you as required by law. We will also post an updated copy on this Site.

12. THIRD PARTY SITES

In case you wish to request the updating of the information in our possession or of your preferences, or for any question on the protection of your personal data, you can contact us by e-mail at privacy@mariagiovannacosta.com .