Information obligations pursuant to Articles 13 and 14 of GDPR 679/2016

Privacy policy pursuant to Article 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

In accordance with the EU General Data Protection Regulation (Regulation 2016/679 of the European Parliament and of the Council), we hereby inform you of the

following.

1. Name and contact details of the data controller and data protection officer

This data protection policy applies to data processing by:

ROC.TRAAM GmbH SRL

Seilbahnstrasse 6C

39031 Riscone/Brunico

2. Collection and storage of personal data, as well as the type and purpose of its use

a) When you visit our website www.roctraam.com, the browser on your device automatically sends information to our website server. This information is temporarily

stored in a log file. The following information is automatically collected and stored until it is automatically deleted:

- IP address of the requesting computer,

- date and time of access,

- name and URL of the requested file,

- website of origin (referrer URL),

- browser used and, if applicable, the operating system of your computer and the name of your access provider.

This data is processed for the following purposes:

- to ensure a smooth connection to the site,

- to ensure comfortable use of our website,

- to evaluate system security and stability,

- for further administrative purposes.

The legal basis for data processing is Article 6(1)(f) of the GDPR. Our legitimate interest arises from the purposes listed above. Under no circumstances do we use the data collected to draw conclusions about you personally. Cookies and analysis services are also used when you visit our website. Further details can be found in

sections 4 and 5 of this policy.

3. Data communication

Your personal data will not be disclosed to third parties for purposes other than those listed below. We only disclose your personal data to third parties if:

- you have given your express consent in accordance with Art. 6(1)(a) GDPR,

- the disclosure is necessary pursuant to Art. 6(1)(f) GDPR for the protection of legal rights and there is no reason to believe that you have an overriding interest in not

disclosing your data,

- the disclosure is necessary for legal reasons pursuant to Art. 6(1)(c) GDPR,

- it is permitted by law and necessary pursuant to Art. 6(1)(b) GDPR for the performance of contractual relationships with you.

4. Cookie

We use cookies on our website. These are small files that your browser automatically creates and that are stored on your device when you visit our website. Cookies do not cause any damage and do not contain viruses, Trojans, or other malicious software. Information about the specific device used is stored in the cookie. However, this does not mean that we directly learn your identity. The use of cookies serves, on the one hand, to make the use of our website more pleasant. For example, we use so- called session cookies to recognize that you have already visited individual pages on our website. These are automatically deleted at the end of the session. In addition, we use temporary cookies to improve usability, which remain stored on your device for a certain period of time. If you visit our website again, it will automatically recognize that you have already visited the website and what settings you have made. We also use cookies to statistically analyze the use of our website and to optimize our offering (see point 5). These cookies are also deleted after a specified period. The data processed via cookies is necessary for the purposes stated and for the protection of our legitimate interests pursuant to Art. 6 (1) (f) GDPR. Most browsers automatically accept cookies. You can configure your browser so that no cookies are stored or so that a warning always appears before a new cookie is created. However, completely disabling cookies may limit the use of certain features of the website.

5. Analysis tools

a) Tracking tools: The tracking measures listed below and used by us are carried out on the basis of Art. 6 (1) lit. f GDPR. With the tracking measures used, we want to

ensure a needs-based design and the ongoing optimization of our website. We also use tracking measures to statistically record the use of our website and to evaluate it for the purpose of optimizing our offer for you. These interests are to be regarded as legitimate within the meaning of the aforementioned provision. The respective data processing purposes and data categories can be found in the corresponding tracking tools.

i) Google Analytics: For the purpose of designing our website in line with user needs and continuously optimizing it, we use Google Analytics, a web analytics service

provided by Google Inc. (https://www.google.de/intl/en/about/) (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter referred to as “Google”). In this context, pseudonymized usage profiles are created and cookies (see section 4, (please check the data processing agreement at static.googleusercontent.com/media/www.google.com/de//analytics/terms/de.pdf)) are used. The information generated by the cookies about your use of this website, such as Browser type/version, operating system used, referrer URL (the previously visited page), host name of the accessing computer (IP address), time of the server request, are transmitted to a Google server in the USA and stored there. The information is used to evaluate the use of the website, to compile reports on website activity, and to provide other services related to website activity and internet usage for the purposes of market research and the design of this website in line with user needs. This information may also be transferred to third parties if this is required by law or if third parties process this data on behalf of Google. Under no circumstances will your IP address be merged with other Google data. The IP addresses are anonymized so that they cannot be assigned (IP masking). You can prevent the installation of cookies by adjusting your browser software settings accordingly; however, we would like to point out that in this case you may not be able to use all the functions of this website to their full extent. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing a browser add-on (https:// tools.google.com/dlpage/gaoptout?hl=en).

As an alternative to the browser add-on, especially for browsers on mobile devices, you can also prevent Google Analytics from collecting data by clicking on this link. An opt-out cookie will be set to prevent future collection of your data when you visit this website. The opt-out cookie is only valid in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you must set the opt-out cookie again. Further information on data protection in connection with Google Analytics can be found in the Google Analytics Help Center (https://support.google.com/analytics).

ii) Google Adwords Conversion Tracking: We also use Google Conversion Tracking to statistically record the use of our website and evaluate it for the purpose of

optimizing our website for you. Google Adwords sets a cookie (see section 4) on your computer if you have accessed our website via a Google ad. These cookies expire after 30 days and are not used for personal identification. If the user visits certain pages of the Adwords customer's website and the cookie has not yet expired, Google and the customer can recognize that the user clicked on the ad and was redirected to this page. Each Adwords customer receives a different cookie. Cookies cannot therefore be tracked across the websites of Adwords customers. The information collected using the conversion cookie is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers see the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that can be used to personally identify users. If you do not wish to participate in the tracking process, you can also refuse the setting of a cookie required for this purpose, for example by setting your browser to generally disable the automatic setting of cookies. You can also disable cookies for conversion tracking by setting your browser to block cookies from the domain “www.googleadservices.com”.

Google's privacy policy on conversion tracking can be found here (services.google.com/sitestats/en.html).

6. Social Media Plug-in

We use social plug-ins from the social networks Facebook, Twitter, and Instagram on our website on the basis of Art. 6 (1) lit. f GDPR in order to increase our visibility. The underlying advertising purpose is to be regarded as a legitimate interest within the meaning of the GDPR. Responsibility for data protection-compliant operation must be ensured by the respective providers. We integrate these plug-ins using the so-called two-click method in order to protect visitors to our website as best as possible.

) Facebook: Our website uses social media plugins from Facebook to make its use more personal. For this purpose, we use the “LIKE” or “SHARE” button. This is a service offered by Facebook. When you visit a page on our website that contains such a plugin, your browser establishes a direct connection to Facebook's servers. The content of the plugin is transmitted directly from Facebook to your browser and integrated into the website. By integrating the plugins, Facebook receives the information that your browser has accessed the corresponding page of our website, even if you do not have a Facebook account or are not currently logged in to Facebook.

This information (including your IP address) is transmitted directly from your browser to a Facebook server in the USA and stored there. If you are logged in to Facebook, Facebook can directly associate your visit to our website with your Facebook account. If you interact with the plugins, for example by clicking the “LIKE” or “SHARE” button, the corresponding information is also transmitted directly to a Facebook server and stored there. The information is also published on Facebook and displayed to your Facebook friends. Facebook may use this information for advertising, market research, and the needs-based design of Facebook pages. To this end, Facebook creates usage, interest, and relationship profiles, e.g., to evaluate your use of our website with regard to the advertisements displayed to you on Facebook, to inform other Facebook users about your activities on our website, and to provide other services related to the use of Facebook. If you do not want Facebook to assign the data collected via our website to your Facebook account, you must log out of Facebook before visiting our website. For the purpose and scope of data collection and the further processing and use of the data by Facebook, as well as your rights in this regard and setting options for protecting your privacy, please refer to Facebook's privacy policy (https://www.facebook.com/about/privacy/).

7. Rights of data subjects You have the right:

pursuant to Art. 15 GDPR to request information about your personal data processed by us. In particular, you can request information about the purposes of processing,the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing, or objection, the existence of a right to lodge a complaint, the origin of your data if it was not collected by us, and the existence of automated decision-making, including profiling and, where applicable, meaningful information about its details;

to request the immediate correction of inaccurate or incomplete personal data stored by us in accordance with Art. 16 GDPR;

to request the erasure of your personal data stored by us in accordance with Art. 17 GDPR, unless the processing is necessary for exercising the right of freedom of

expression and information, for compliance with a legal obligation, for reasons of public interest, or for the establishment, exercise, or defense of legal claims;

pursuant to Art. 18 GDPR, to request the restriction of the processing of your personal data if you dispute the accuracy of the data, the processing is unlawful, but you oppose its erasure and we no longer need the data, but you need it for the establishment, exercise, or defense of legal claims, or you have objected to the processing pursuant to Art. 21 GDPR; pursuant to Art. 20 GDPR, to receive your personal data that you have provided to us in a structured, commonly used, and machine-readable format or to request its transfer to another controller; and pursuant to Art. 77 GDPR, to lodge a complaint with a supervisory authority. As a rule, you can contact the supervisory authority of your usual place of residence or workplace or our law firm's registered office for this purpose.

8. Right to object

If your personal data is processed on the basis of legitimate interests pursuant to Art. 6 (1) lit. f GDPR, you have the right to object to the processing of your personal

data pursuant to Art. 21 GDPR, provided that there are reasons for this arising from your particular situation.

If you wish to exercise your right to object, simply send an email to info@roctraam.com.

9. Data security

When you visit our website, we use the widely used SSL (Secure Socket Layer) procedure in conjunction with the highest level of encryption supported by your browser. This is usually 256-bit encryption. If your browser does not support 256-bit encryption, we use 128-bit v3 technology instead. You can tell whether an individual page of our website is being transmitted in encrypted form by the closed display of the key or lock symbol in the lower status bar of your browser. We also use appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction, or unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.

10. Current status and changes to this privacy policy

This privacy policy is currently valid. Due to the further development of our website and offers on it, or due to changes in legal or regulatory requirements, it may

become necessary to change this privacy policy. You can access and print out the current privacy policy at any time on the website at www.roctraam.com/privacy.