To enable full understanding and acceptance of these terms and conditions, the following terms, in the singular and plural, shall have the meanings set forth below:

Owner: 399 Srls, with registered office in Via Bronte 140 Rome (RM) 00133, VAT number and tax code 15997121007, REA RM - 1628254 with fully paid-up share capital € 1500.00, PEC address 399srls@pec.it

User Partner: the natural person of legal age who concludes a contract for purposes unrelated to his or her entrepreneurial, commercial, craft or professional activity, if any, and who does not in any way provide personalised investment recommendations, investment advice, related tax advice or other related financial advice of any kind for information purposes only.

Website: www.mysignalslab.com

Application: MySignalsLab

Products: MyStart, MyBusiness, MyPlus

User: any subject who accesses and uses the Application and/or the Website.

Consumer User: the natural person of legal age who concludes a contract for purposes unrelated to his or her entrepreneurial, commercial, craft or professional activity, if any, and who uses the information collected on our Website and/or Application as a starting point for independent research and investment decisions and who, however, makes decisions without exclusive and unknowing use of the information offered.

General Conditions: this contract governing the relationship between the Owner and the Partners and Users for the information offered through the Application and/or Website.

399 Srls (from now on as "Owner" in the rest of the document) makes available on this Website and on the Application information, news, documents, comments, articles, reviews etc. (in general, "Material") and various services managed in total exclusivity by our Partners, subject to the terms and conditions set out in this document ("General Conditions").

By accessing or using this Website and/or the Application, including accessing and using the services, you accept these Conditions. The Owner reserves the right to change the Conditions at any time at its absolute discretion. The use of the Website and/or the Application will be governed by the most recent version of the General Conditions published on the Website and/or the Application at the time of use.
In addition, by using particular Services or Materials on the Website and/or Application, you will be subject to the guidelines and rules applicable to such Services or Materials. These may contain additional terms and conditions to the Terms of Use. All guidelines and rules refer to the Terms of Use. If you breach any of the Terms of Use, your right to access the Website and/or Application will automatically terminate and any downloaded or printed Materials must be immediately destroyed.
The information contained herein, including the Materials and Services, are protected by intellectual property laws. Any unauthorized use of Materials and Services is a violation of such laws.

The aforementioned products provide Users with a platform with personalized access through personal and private password-protected access data that allows access to the services purchased from our Partners on the Website www.mysignalslab.com or on the MySignalsLab Application. The User is responsible for the safekeeping of his access credentials, which must be used exclusively by the User and cannot be transferred to third parties. The User agrees to keep them secret and to ensure that no third party has access to them and to inform the Owner immediately if he suspects or becomes aware of any misuse or improper disclosure of the same.
The User guarantees that the personal information provided during the registration procedure is complete and true and agrees to hold the Owner harmless and indemnified from any damage, obligation to pay compensation and/or sanctions arising from and/or in any way related to the violation by the User of the rules on registration with the Application or the storage of registration credentials.

The registered User may stop using the Application and/or the Website at any time and deactivate his account or request its cancellation through the interface of the Application, if possible, or by sending a written communication to the e-mail address info@mysignalslab.com.

In the event of a breach by the User of the Terms or applicable legal provisions, the Owner reserves the right to suspend or terminate the User's account at any time and without notice.

All materials and information services contained in this Web Site and/or on the Application are provided "as is" without any other guarantees or conditions, express or implied.

The Owner assumes no responsibility for errors or omissions in the information contained herein or in other documents and/or materials that are referenced by or linked to this Website or provided on the Application by our Partners.

Although the information content published and any resources contained therein are the result of technical lucubrations or editorial development of information sources deemed reliable by our Partners, they may sometimes not be correct and accurate, either due to possible technical problems or due to the possibility of errors committed unknowingly and in good faith by the Partners themselves. Although it is our goal to ensure the continuity of such services, the Owner does not intend to guarantee such continuity, as any problems (technical or otherwise) could cause their temporary interruption.
All references to companies, their services and products are provided "as is", without warranty of any kind, express or implied. In no event shall the Owner be liable for any special, incidental, indirect or consequential damages of any kind or damages of any kind, including, among others, those resulting from loss of use, data or profits, whether or not the Owner has been advised of the possibility of such damages, nor shall the Owner be liable in any way for damages arising out of or in connection with the use or application of this information provided by third party partners.

This Website and/or the Application may contain technical or other errors, inaccuracies or typographical errors. The Owner may make changes to the material and services on this Website, including prices and product descriptions listed at any time without notice. In no event shall the Owner or its Partners have any obligation to you or any third party for any special, punitive, incidental, indirect or consequential damages or any other damages whatsoever, including, without limitation, those resulting from loss of data or profits, and for any liability arising out of or in connection with the use of this Website and/or Application or any website linked or connected to this site.
The use of the services or the downloading or acquisition of material through our platforms is at your own discretion and risk and you are solely responsible for any damage to your computer system or loss of data that may be caused by such actions. No advice or information obtained by you through the Site shall constitute a warranty not expressly stated in the Terms of Use.

Our platforms may contain links to third party sites provided by our Partners that are not under the control of the Owner. When you access a different platform you do so at your own risk and the Owner is not responsible for the accuracy or reliability of the information, data, opinions, advice and statements found on such sites and does not guarantee the quality of any product or service available on such sites. The Owner by utility and inclusion of such sites does not imply that it endorses or accepts responsibility for the content and uses of such websites and/or external platforms.

Any information, opinion, advice, indication emerged from any published material will not be configured in any way as an activity of financial promotion or financial advice, and none of the authors Partners can be held in any way responsible for damages of any kind accrued as a result of such opinions, advice, indications, information. The service offered does not intend in any way to constitute solicitation to public savings or to promote any form of investment, but has an exclusively didactic and/or informative value.

Without prejudice to the best efforts and accuracy possible in the acquisition of data and the provision of content, the user of such content and services (User consumer) declares himself aware of the fact that:

• the analyses and indications provided in the services attributable to the Owner and/or the Partners have an educational/informative character and whoever uses them for purposes other than those for which they are intended, investing their savings taking inspiration from them, does so in full decision-making autonomy and at their own risk;
• the analyses and indications provided in the services are not necessarily a valid indicator of the future prospects of the securities analysed;
• it is possible that the writer is directly and/or indirectly interested as a private investor in the performance of the securities analysed.

The reader hereby relieves the Owner and all his Partners and/or collaborators, direct and indirect, from any responsibility for any damage, direct or indirect, that may arise from improper use and for purposes other than those indicated, of the information and indications provided, from any inaccuracy, inaccuracy, limitation, untimeliness or delay, omission, interruption or suspension of the same.

It should also be noted that the Owner and/or the Partners are not able to make in any way certain forecasts on the future trend of the financial markets and users are informed that there is no guarantee of future or constant maintenance of the results or performance currently found in the analyses, portfolio, newsletters, or in all other contents of the Website and/or the Application. Finally, it should be noted that the speculative activity linked to the purchase and sale of securities, shares and derivatives is a high-risk activity governed by current national, international and European Union regulations and subject to strict rules of control and registration in registers for operators in the sector.

For each Product the price including VAT, if due, is indicated. If the nature of the Product means that it is impossible to calculate it in advance, the methods for calculating the price are indicated. Furthermore, all eventual taxes and additional charges that may vary in relation to the payment method used will be indicated.

Where such items of expense cannot reasonably be calculated in advance, there will be an indication of what expenses will be charged to the User. The Owner reserves the right to change, at any time, the price of the Products and any additional costs. It is understood that any price changes will not in any case affect contracts already concluded before the change. The User undertakes to pay the price of the Product in the times and ways indicated in the Application and/or Website and to communicate all the necessary data that may be required.
The Application and/or Website uses third party tools to process payments and does not in any way come into contact with the payment data provided (by way of example but not limited to: credit card number, name of the holder, password, etc.). If these third party instruments should deny authorization for payment, the Owner will not be able to supply the Products and will not be held responsible in any way.

For each Partner, at the time of registration, all prices and additional information regarding the use of the Owner's platforms are provided in order to make an informed use of the same, in accordance with the current laws on regulatory and fiscal matters. Considering the Products used by the consumer user, the Owner reserves the right to generate courtesy receipts for consumers who make use of the Partner's services and/or products in order to facilitate the maximum clarity of information in this point and the generation of documents capable of identifying the reality. It remains the responsibility of the Partner to use the information provided by the Owner for a correct tax treatment of any fees due to the latter from end consumers according to the laws in force and/or special laws.
It is also recalled that the services offered by the Partners are incompatible with any positions considered at risk for the Anti-Money Laundering legislation in force, politically exposed people and / or convicted under current legislation in national criminal matters and not, the acceptance of this constitutes self-certification by the Partner of the minimum requirements of integrity required.

The Partner who does not comply with the agreements privately made between himself, the Holder of the conditions of sale, and the consumer/User with particular reference to the following situation - "cancellation of the Partner" - "death of the Partner" - "momentary absence of the Partner" will follow the following operational discipline:

• The Consumer/User will receive a corresponding credit, equal to the difference in days for which he/she did not enjoy the services with the right to enjoy this credit through another Partner of his/her choice. There is no provision for refunds in any way if not in derogation according to the situations of classic withdrawal governed by law;
• In the event that the credit resulting from the absence/withdrawal of the Partner already subscribed to is not sufficient to use the digital services of another Partner, the Consumer/User will eventually have to cover the difference through a fee or choose another Partner;
• The absent Partner, in the process of cancellation, has the right (within a period of 5 days from the moment of manifestation of will) to reconsider maintaining the status quo of the consistency and relevance of its intermediary/partner profile, including the number of consumers/users present at the moment of absence and/or cancellation;
• The absent Partner, in the process of cancellation, who does not exercise the right of reconsideration within the 5 days indicated in the previous point, maintains the status quo of the consistencies and relevance of its intermediary/partner profile, EXCLUDING the number of consumer users/users present at the moment of absence and/or cancellation.

It is recalled that, as subsequently exposed, any behavior of malice and / or damage to consumers / Users by the Partners is persecutable under the terms and conditions accepted at the time of registration. The eventual responsibility of the Owner must be ascertained following irrefutable objective elements corroborated by evidence against the damaged party.
Please also note that if the Partner, as indicated in paragraph 3 of this, includes services and / or sponsorship by third parties unrelated to the Owner, the credit accrued in NO WAY can be used for such digital services outside the platform, nor put in pledge and/or guarantee.

The Owner will provide the digital Products and/or services to the User, in the manner and within the term indicated on the Application and/or Website and reported in the order confirmation.
In the event that it is not possible to supply the digital Products and services requested within this term, the User will be promptly notified by e-mail, indicating when it is expected to be able to supply them or the reasons that make supply impossible.
If the User does not intend to accept the new deadline or the provision has become impossible, he may request a refund of the amount paid, which will be promptly credited in the same mode of payment used by the User for the purchase within a maximum of 14 days from the date on which the Owner became aware of the request for refund. If the information and educational services are provided directly by partners, the owner disclaims any responsibility for the work of the above, leaving the latter with the responsibility and the duty to agree with consumers in order to ensure the rights governed by this point.
In the event that the Partner finds itself in the condition of seeing Consumers/Users use its digital services as a result of MIGRATION from another Partner (as governed by point 6) nothing can claim either from Consumers/Users or from the Owner, benefiting to this end an enlarged audience that, hypothetically, will sign with the Partner in question a subsequent fee for the digital services offered.

The Owner declares that he is the owner and/or licensee of all the intellectual property rights relating to and/or pertaining to the Application and/or Web Site. Therefore, all the trademarks, figurative or nominative and all the other signs, commercial names, service marks, denominative marks, commercial names, illustrations, images, logos and contents relating to the Application are and remain the property of the Owner or of its licensees and are protected by the current national and Community laws on trademarks and by the relevant international treaties. The Conditions do not grant the User any license to use the Application and/or the single contents and/or materials available therein, unless otherwise regulated. Any reproduction in any form of the explanatory texts and Contents of the Application, if not authorized, shall be considered an infringement of the intellectual and industrial property rights of the Owner.

The Partners remain the only responsible and owners of the information and content of an informative nature that the consumer user uses. Likewise, they are not in any way the owners of trademarks and/or other distinctive signs of the Application and/or the Website.

The Application is provided on an "as is" and "as available" basis and the Owner does not provide any explicit or implicit guarantee in relation to the Application, nor does it provide any guarantee that the Application will be able to meet Users' needs or that it will never be interrupted or be error-free or that it will be free of viruses or bugs. The Owner will make every effort to ensure that the Application is available 24 hours a day, but shall not in any way be held responsible if, for any reason, the Application is not accessible and/or operational at any time or for any period. Access to the Application may be suspended temporarily without notice in the event of system failure, maintenance, repairs or for reasons completely beyond the control of the Owner or for events of force majeure. The Owner cannot be held responsible to the User, except in the case of malice or serious fault, for inefficiencies or malfunctions related to the use of the Internet outside of its control or that of its suppliers, in accordance with what has already been read and signed in point 6 of this letter.

The Owner will not be responsible for damages, losses and costs incurred by the user as a result of failure to execute the contract for reasons not attributable to him, the user is only entitled to a full refund of the price paid and any additional charges incurred, net of all actions put in place by the Owner for the protection (as much as possible) of the User/Consumer. The Holder assumes no responsibility for any fraudulent or illegal use that may be made by third parties of credit cards and other means of payment, as it does not come into contact in any way with the payment data used (credit card number, name of the holder, password, etc.). The Owner will not be responsible for: any loss of business opportunity and any other loss, even indirect, that the User may suffer that is not a direct consequence of the violation of the contract by the Owner incorrect or unsuitable use of the Application by Users or third parties the issuance of incorrect documents or tax data due to errors in the data provided by the User, the latter being solely responsible for correct entry. In no case can the Owner be held responsible for a sum greater than twice the cost paid by the User. The Owner cannot be held responsible for the failure or delay in the fulfillment of its obligations, for circumstances beyond the reasonable control of the Owner due to force majeure events or, however, unforeseen and unforeseeable events and, in any case, independent of his will. The fulfilment of the obligations by the Holder shall be considered suspended for the period in which force majeure events occur. The owner will take any action in its power in order to find solutions that allow the proper fulfillment of its obligations despite the persistence of force majeure events, this in order to protect the User within the possible objective sphere of action.

The Application may contain links to third party sites/applications. The Owner does not exercise any control over them and, therefore, is in no way responsible for the contents of these sites/applications. Some of these links may refer to third party sites/applications that provide services through the Application. In these cases, the general conditions for the use of the site/application and for the use of the service provided by the third parties will apply to the individual services, for which the Owner accepts no responsibility.

Pursuant to European Regulation No. 679/2016 (hereinafter "Regulation") and the national legislation on the protection of personal data (hereinafter collectively "Privacy Policy"), 399 Srls invites you to carefully read this Privacy Policy which contains important information on the protection of your Personal Data.

The processing of your Personal Data will be based on the principles of correctness, lawfulness, transparency, purpose limitation and storage, minimization and accuracy, integrity and confidentiality, in accordance with the provisions of the Regulation.

Owner of the processing of Personal Data is Sorace Andrea.

In compliance with the provisions of the Regulation, the Data Controller has identified and appointed a Data Protection Officer (DPO), with the task of monitoring compliance with the Regulation and acting as a point of contact with the parties involved in the processing as well as with the Guarantor for the protection of personal data. The DPO can be contacted at the e-mail address info@mysignalslab.com.

• Personal data (such as name, surname, date of birth, age, sex, etc.);
• Contact data (e-mail, address, phone number);
• Geo-location and/or internet browsing data (including "IP" addresses) collected through cookies installed on your computer or mobile device (for more information see Cookie Policy);
• Bank data useful for the management of the commercial relationship, photographic images and/or video recordings, collected during participation in promotions, contests and institutional events, shows, exhibitions, museum contexts and installations in general;
• Data relating to your interactions with our websites, App, data relating to your device following the download of our App and the use of notifications about the publication of new content, initiatives and updates.

In addition to the aforementioned categories of Personal Data, additional data may be processed that you provide directly (the so-called "Contributions") and shared on the pages of dedicated social networks (Facebook, Twitter, Instagram, etc..), for the management of which please refer to third parties that provide such services. Among the data collected through social networks there are, for example, the likes, comments, images and in general any content and information that you may have published on the pages of social networks.

According to the requirements related to the access to the various sections of the Website (and except for single initiatives involving the conferment of specific Personal Data, for which specific information will be published from time to time), the purposes of the processing of Personal Data and the related legal bases are indicated below:

• Registration via website/APP: the registration procedure, through the creation of an account or the use of an existing social network account, is aimed at allowing the use of the portal as a "Registered User" and access to a series of exclusive services offered through the same applications. The provision of data is optional. The legal basis for the processing is the execution of pre-contractual measures to which the data subject is a party.
  In the event of registration through the APP, authorization will be requested to receive notifications regarding the publication of new content, initiatives, events, promotions, etc. The legal basis for the processing is the consent of the data subject. You can always change your mind and modify the settings regarding the receipt of such notifications directly from your device in the "Settings" and "Notifications" section.
  In case of registration or access through your social account, we may have access to some additional personal data compared to those provided during the registration to the portal, on the basis of the authorizations provided by you to the social network itself and to which we refer for the policies on the management of your privacy;
• Purchase of products: You may purchase products through our Website/APP as a Registered User (in which case You will not have to re-enter all Your Personal Data for each purchase).
  Your Personal Data will be processed in order to manage orders and payments and to carry out the consequent administrative-accounting fulfilments as well as to contact you for any communications concerning the purchases themselves. The conferment of data is necessary to complete the purchase order. The legal basis of these treatments is the execution of the Contract of which the person concerned is part;
• Management of requests: Personal Data will be collected in order to respond to requests sent to us via email, via website, App, and/or via social networks.
  These services may also be provided through the activity of video chat/call. In this case the support via video chat/call will be activated at the discretion of the user, will take place exclusively in live mode and there will be no recording of their content.

Additional Purposes:

• Marketing: subject to your express consent, we may process your Personal Data in order to send you commercial communications as well as to invite you to take part in our promotional initiatives, participate in our events, subscribe to our newsletter. The legal basis for such processing is the consent of the data subject, which may be revoked at any time;
• Profiling: subject to your express consent, we may process your Personal Data for profiling purposes, i.e. to analyse or predict your habits, potential habits and consumption choices in order to offer you products, services, promotions and personalised commercial communications. The legal basis for such processing is the consent of the data subject, which may be revoked at any time.
  Profiling activity may also be carried out through the use of proprietary and third-party cookies. We therefore invite you to read our Cookie Policy. Such processing may be carried out on condition that you provide further specific and optional consent.

Outside of the above assumptions:

• Purpose of analysis: the Personal Data you provide when interacting with the Website and/or Application and the information relating to the interaction will be included in our database and will be used anonymously to analyse and improve the services offered, to assess the effectiveness of the activities and initiatives promoted and to conduct statistical analyses on the composition of the database itself. The legal basis for the processing is the legitimate interest of the data controller.;
• Any further purposes in relation to which you have expressly given your consent, which may be revoked at any time.

The provision of your Personal Data is optional. However, failure to provide them could affect the possibility of using certain services (e.g. to place orders and purchases, to participate in competitions and prize operations, to receive newsletters, etc.).

The compulsory or optional nature of the conferment will be indicated from time to time through the use of symbols (e.g. "*") placed next to the information whose conferment is required to pursue the respective purpose.

Your Personal Data will be processed in compliance with the provisions of the Privacy Law in force, both with the aid of electronic and automated means and manually, with logic strictly related to the purposes of treatment, through databases, electronic platforms managed by the Owner or third parties (appointed Data Processors), integrated computer systems.

Your data will be processed in such a way as to ensure maximum security and confidentiality and only by persons trained and authorized to their treatment. The Owner adopts technical and organizational measures to ensure a level of security appropriate to the risk of treatment.

Personal Data are processed mainly at the Data Controller's premises and at the locations of the Data Processors.

Your Personal Data may be made accessible, for the above purposes, to employees and collaborators of 399 Srls.

The Data Controller adopts suitable guarantees to provide an adequate level of protection equal to that used in the EU/EEA and has drawn up a list of Data Processors, which is constantly updated, and which it makes available to you by contacting the addresses indicated in point 11 of this Information Notice.

Finally, your data may be transmitted to the judicial authorities where necessary and in the cases provided for by law.

In order to ensure compliance with the principles of necessity and proportionality of processing, different retention periods for Personal Data have been identified in relation to the individual purposes pursued:

• Website/APP Registration: The Personal Data provided by you for making the Website/APP Registration will be kept for the duration of your registration with the said portal. In case of inactivity for 24 months your Account will be deleted;
• Invoicing data will be kept for a period of time sufficient to guarantee the correct execution of the contract and in any case for a further 10 years for the purpose of fulfilling the related administrative and fiscal obligations;
• The data collected for the management of competitions and prize operations, will be kept for the entire period of the duration of the prize operation and for a period of time necessary to ensure its proper execution. This is without prejudice to the fulfilment of administrative and fiscal obligations in relation to which the period of data retention is that provided for by law;
• The data collected for profiling and marketing purposes, for which you have given your consent to the processing, will be kept for a period of time not exceeding 12 months (profiling) and 24 months (marketing) respectively, or such other period as may be indicated by the supervisory authorities. Where you have not provided the aforementioned consents, your personal data will be anonymised and used for statistical analysis activities.

You may at any time exercise the rights provided for by articles 15 and following of the Regulations with regard to the Data Controller, including:

• the right to obtain confirmation of the existence or not of personal data concerning him/her, even if not yet recorded, and their communication in intelligible form;
• the right to revoke at any time the consent given by you in relation to the purposes of the processing;
• the right to obtain access, rectification, cancellation, restriction of processing and portability of personal data;
• the right to object to the processing at any time you wish;
• the right to appeal to the competent supervisory authority, if you believe that the processing of your data is contrary to the legislation in force.

If you wish to exercise the above-mentioned rights, or if you wish to receive further clarifications regarding the processing of your personal data, you can write to the following e-mail address: info@mysignalslab.com.

The Conditions are subject to Italian law. For the Consumer Users any dispute relating to the application, execution and interpretation of these Conditions shall be devolved to the court of the place in which the User Consumer resides or has elected domicile, if located in the territory of the Italian State, without prejudice to the right of the User Consumer to refer to a judge other than the "consumer court" pursuant to art. 66 bis of the Consumer Code, with territorial jurisdiction according to one of the criteria referred to in Articles. 18, 19 and 20 of the Civil Procedural Code.

This is without prejudice to the application to Consumer Users who do not have their habitual residence in Italy of the provisions that may be more favourable and mandatory provided for by the law of the country in which they have their habitual residence, in particular in relation to the term for the exercise of the right to withdraw, the term for the return of the Products, in the event of the exercise of such right, the methods and formalities for the communication of the same and the legal guarantee of conformity. The User Consumer residing in Europe should be aware that the European Commission has set up an online platform that provides an alternative dispute resolution tool. Such tool can be used by the User Consumer to resolve in a non-judicial way any dispute relating to and/or deriving from contracts of sale of goods and supply of services stipulated on the web. Consequently, the User Consumer can use this platform for the resolution of any dispute arising from the contract stipulated online. The platform is available at the following address: ec.europa.eu/consumers/odr/

Please find below our contact details for any further information:

• E-mail address: info@mysignalslab.com