Privacy Policy

• 1. Who we are

We are Cantieri di Ostia (also known as Canados Yachts, Oceanic Yachts, Gladiator Yachts), an Italian Shipyard with headquarters at Via dell’Idroscalo 252, Rome 00121, Italy. For more information, please see our website under www.canados.com and www.canados-refit.com. Cantieri di Ostia - Canados is responsible for the collection and use of your personal data described in this privacy policy. For the processing of your personal data in relation with Cantieri di Ostia - Canados activity, Cantieri di Ostia - Canados is fully responsible. We have determined our responsibilities for compliance with the obligations under applicable privacy legislation for processing your personal data in relation to our activities. In summary, we have arranged that if you want to exercise your rights, such as your right to access, correct, erase, restrict, object or port personal data or to withdraw your consent, or if you have any questions or complaints about the processing of your personal data, you can either contact us in accordance with ‘your rights’ (please see below) or contact Cantieri di Ostia – Canados’ Protection Officer. Furthermore, we will inform you about the processing of your personal data in our privacy policies. You can find the privacy policy of Cantieri di Ostia - Canados on its website.

• 2. The types of personal data we process

2.1 General. We may collect and process the following categories of personal information: a. Name, type of owned yacht, will to change your boat and other identifying information For example, we may record your name, title, gender and date of birth, your nationality, country of residence, type of yacht you owned, places where you usually use your yacht and eventually expression of interest to change your actual yacht or simply buy one. b. Your contact details and personal account or registration details Your contact details may include your address, telephone number and email address. When you enter in a contractual relationship with Cantieri di Ostia - Canados, we may also record additional other information you fill out on your contract. c. Information about your expression of interest and eventual purchases of product and/or services When you sign a contract with us, we process your information . This information may include details about, prices, delivery date, work to done or detail of product to be delivered. In addition, we process information in relation to extras and eventual change order along the construction process and/or refit and products you purchase. d. Information about your contract with us When you contract us to build your new boat, to buy a stock boat or a trade-in, a product, part or a service we process information in relation to your contract. e. Our communication with you When you send us an email or contact online or via social media, we might keep track of your communication with us. We also register your preferences and focus of interest among our range of boats and/or services. For example when you unsubscribe from one of our newsletters via other channels than email (such as WhatsApp, Facebook or Instagram), our customer support will register your questions or complaints in our database. f. Information we collect when you use our websites and other digital media • When you visit our websites, or we may register your IP address, browser type, operating system, referring website and web-browsing behavior. We might also collect information via cookies and similar technologies when you visit our websites. For more information please read our cookie policy on the website or the mobile app you use. • We may receive an automatic notification when you open our emails or click on a link in such emails. • With your permission, we may also receive your location data. g. Information in relation to social media Depending on your social network settings we may receive information from your social network provider. For example, when you sign in for our services using a social network account, we may receive your social network profile including your contact details, interests and contacts. For more information on the personal data that we receive from your social network provider and how to change your settings, please check the website and privacy policy of your social network provider. h. Information you choose to share with us You may choose to share information with us, for example when you share your interests and preferences with us, leave a comment for us on Facebook or Instagram. 2.2 Cookies and similar technologies. When you use our website or we collect information via cookies and similar technologies. For more information please read our cookie policy on the website or mobile app you use. 2.3 Specific services or events. For specific services or events, we may collect other types of data and use such data for different purposes than described in this privacy policy. We will inform you about this when you register for the specific service, event or download the specific app.

• 3. How we collect your data

3.1 We collect the aforementioned categories of personal data in the following ways: a. We collect data you provide to us When you visit us on a boat show, when you visit our shipyard or any Cantieri di Ostia – Canados representative office or dealer or a yacht broker, contact us via our websites, register for one of our events, contact our customer support, subscribe to receive our emails, register or participate in one of our presentations. b. We receive your personal data from your broker, boat dealer our co-branding partners and other companies involved in introducing clients to Cantieri di Ostia – Canados. We receive your data from these parties to handle your needs for services and purchases. For example, when you buy a yacht or product through a dealer, we receive your identifying information and details from your dealer or broker. c. We receive personal data from medium we advertise in. For example, when you read an article about us in a digital media, the media can provide us with your details and your interest in our products and/or services. d. When you use our website, we collect information via cookies and similar technologies For more information please read our cookie policy on our websites. e. Depending on your social network settings, we may receive information from your social network provider Please see ‘The types of personal data we process’ above.

• 4. For which purposes we use your data

4.1 The main purposes for which we use your personal information are: a. To provide our services to you To handle your purchases, we need to process most of the information described above. For example, we need your name, and other identifying information to issue your quote or contract. To confirm all details or our relationship and to inform you about changes in your delivery time, we need your contact details. b. To provide our online services to you • For example, we use your name and details of your boat when asking us for a service quote • Some of our online services your location, for example to show you the nearest location where our after-sale service can intervene. • To ease your use of our online services, we may analyze the data we collect when you use our digital media and combine it with information collected via cookies and similar technologies (please see above). For example, to understand which digital channel (email, social media) or device (desktop, tablet or mobile) you prefer, so we can restrict our communication to that channel or device. c. For statistical research • General. We might use automatic tools to perform statistical research into general trends regarding the use of our services, products, websites and social media and the behavior and preferences of our customers and users. • Categories of data. To perform our research, we may use the categories of personal data described above, including details on your actual yacht (such as date of construction, brand name, engine hours, condition of the boat, number of cabins, power, installed options…) and personal details (gender, postal code). We combine this data with the data we collect with cookies and similar technologies when you visit our websites or use our social media. And we merge it with (aggregated) data collected by third party providers using analytical or marketing cookies or similar technologies. For more information on cookies and similar technologies, please check the cookie policy on our website. We only use aggregated data for our analysis and do not use your name or e-mail address. Without your consent, we will not use special categories of data for this statistical research. • Examples. We use details of your actual boat to improve our services and products and provide more relevant offers. For example, if our research shows that your more into fast yachts or into big volume boats, we will adapt our offer and communication to you in this direction. We also use customer surveys to measure customer satisfaction and to understand what is important for our customers so we can improve our service. And we use cookies and similar technologies to evaluate how our website visitors navigate our website so we can make it more intuitive. • Legal basis. We process your personal data for our legitimate interests to develop better services and offers for our customers, to improve our products and services, to provide more responsive customer support and to improve the design and content of our websites. • Right to object. You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data for statistical research (please see below ‘Your rights’). d. To send you updates and special offers tailored to your interests • Communication. When you contact us, we send you personalized ads and special offers for related products and services (unless you opt-out during the booking procedure). For example, before a boat show, we might send you an email to find out if you would like to visit and receive an invitation. You may also subscribe to receive emails or mobile push notifications from us with updates and special offers tailored to your interest. For example, you can subscribe to Cantieri di Ostia - Canados newsletter which keeps you informed on attractive offers, promotions, package deals and the latest news. With your consent, we may also send you emails on specific occasions, such as a special offer on your birthday or personalized offers for your next boat. We may also use other communication channels to send you personalized ads and special offers, such as postal mail or, with your consent, social channels (such as Facebook, WhatsApp or Instagram). • Categories of data. We use your contact details to communicate with you. To understand what is relevant to you, we might use automatic tools to analyze your personal data. For this purpose, we may use the categories of personal data described above, including your actual boat, information about you (gender, zip code) and the interests and preferences and point of interests you shared with us. We might combine this data with data that we collect with cookies and similar technologies when you visit our websites or social media. And we might merge it with (aggregated) data collected by third party providers using analytical or marketing cookies or similar technologies. For more information on cookies and similar technologies, please check the cookie policy on our website. Without your consent, we will not use special categories of data. • Legal basis. We process your personal data as described in this paragraph for our legitimate interest and the interests of third parties to provide you with relevant updates and offers. • Opt-in and opt-out, unsubscribe and right to object. You can opt-out from receiving commercial emails and newsletters at any given time. You can unsubscribe from these commercial emails and the emails and mobile push notifications with updates and special offers, any time by clicking the unsubscribe link in the email, by adjusting your communication preferences in your account (if available), by changing your smart phone settings (for mobile push notifications) or by contacting us (please see ‘Your Rights’ below). emails (such as your booking confirmation, e-ticket and membership welcome mail). You may object to the use of your personal data for direct marketing purposes anytime (please see below ‘Your rights’). e. For other direct marketing purposes • General. This paragraph describes specific examples of our use of your data for other direct marketing purposes. • Marketing cookies. Our websites might use marketing cookies which are typically placed by advertising networks. These networks are companies which act as intermediaries between Cantieri di Ostia - Canados and advertisers. These marketing cookies are amongst others used to show relevant, personalized advertisements or offers (based on your visit to and click behavior on our websites) when you visit those networks or connected websites. For more information on these marketing cookies and how you can withdraw your consent for these cookies, please check the cookie policy on our website or the mobile app you use. • Linked site behavior. If you log onto our websites or if you visit our websites via a link in an email, we might link your site behavior to your data on our data management platform. For example, when you look for a yacht model or specific service on our websites, marketing cookies might be used to show you relevant advertisements (see previous paragraph). f. To communicate with you We use your contact details to communicate with you in relation to our services or products, to answer your questions or to handle your complaints. g. For record keeping and to comply with statutory obligations We collect, store and use your data for internal business purposes, such as record keeping and to comply with our legal and fiscal obligations. We may be required by law to collect and share your identifying information and your acquisition information with public authorities or governmental organizations for the purpose of custom control, tax status of the boat and/or services we delivered to you or flag authorities requests. 4.2 Legal basis. We collect, use and store your personal data to provide services to you, to comply with the legal obligations we are subject to, if necessary for our legitimate interests or the interests of a third party or on the basis of your consent. You may withdraw your consent at any time by following the specific instructions in relation to the processing for which you provided your consent. For example, by clicking the unsubscribe link in the email, adjusting your communication preferences in your account (if available) or by changing your smart phone settings (for mobile push notifications and location data). You may also contact us to withdraw your consent (please see ‘Your Rights’ below). If you refuse to provide personal data that we require for the performance of the contract or compliance with a legal obligation, we may not be able to provide all or parts of the services you have requested from us. For example, we may have to cancel a sale or provision of services requested by you. If you provide incomplete or inaccurate information, we may be forced to deny delivery of the product or service under applicable Italian, European or international laws. When we process your personal data for our legitimate interests or the interests of a third party, we have balanced these interests against your legitimate interests. Where necessary we have taken appropriate measures to limit implications and prevent unwarranted harm to you. For more information on these interests, please see the ‘For which purposes we use your data’ above. Where we process your personal data for our legitimate interests or the interests of a third party, you have the right to object at any time on grounds relating to your particular situation (please see ‘Your Rights’ below).

• 5. Disclosing or sharing data with third parties

5.1 General. We may disclose or share your personal data with our group companies, co-branding partners, your broker or boat dealer, service providers or subcontractors for the following purposes. a. To facilitate your day-to-day operation of your yacht To handle support and to facilitate your purchases of products or services from Cantieri di Ostia - Canados, we might have to share your personal data with our group companies, subcontractors, suppliers, marinas and other companies involved in facilitating the use of your boat. For more information on our group companies and the suppliers and partners we work with, please see our website. When you purchase our services or products through a dealer, representative office, agent or other third party, we also share your personal information data with these parties. b. For support services We use third parties to provide our services, such as IT suppliers, electronics, engine suppliers, social network providers, marketing agencies, providers. All such third parties will be required to adequately safeguard your personal data and only process it in accordance with our instructions. Within the Cantieri di Ostia - Canados group, business activities are carried out (and business efficiencies are achieved) by processing or consolidating information (including personal data) in centralized databases and systems. These central databases and systems may be hosted or managed by one group company for other group companies. In addition, for efficiency purposes certain operational functions may be performed by one group company for other group companies. This means that our group companies may have access to your personal data for these purposes. Our group companies may only process your personal data as required for the relevant business function and in accordance with this privacy policy. c. Statistical research and direct marketing We may share your personal data with group companies and third parties for statistical research and direct marketing. Please see above ‘Statistical research’, ‘To send you updates and special offers tailored to your interests’ and ‘Other direct marketing purposes’ for more information. d. To let you benefit from the services of our partners With your consent, we may share your information with our partners to let you benefit from the services of these partners that we integrate or offer in our own services and apps. For example, we may share non-personalized information (destination, travel date and duration of the trip) with a marina booking platform so it can provide you with an offer for a berth tailored for your trip. Although we select our partners with care, these partners have their own privacy policies that apply to the way they use your personal data. f. To secure order 5.2 Public authorities. We may also be required by law to collect and share your identifying information with public authorities or governmental organizations for the purpose of border control, tax status, security. 5.3 Third party websites. Our websites and social media might contain links to third-party websites. If you follow these links, you will exit our websites or social media. This privacy policy does not apply to websites of third parties. Cantieri di Ostia - Canados cannot accept liability for the use of your personal data by these third parties. Your use of these websites is at your own risk. For more information on how these third parties treat your personal information, please check their privacy policy (if available).

• 6. Security and retention

6.1 Cantieri di Ostia - Canados will take appropriate technical and organizational measures to protect your personal data against loss or unlawful use. 6.2 Your personal data will be retained for as long as required for the purposes described in this privacy policy or in so far as such is necessary for compliance with statutory obligations and for solving any disputes.

• 7. International transfer of your data

7.1 Cantieri di Ostia - Canados may transfer your personal data to countries other than your country of residence (including countries outside the European Economic Area). This occurs in the course of providing our group companies, partners, subcontractors, suppliers or service providers who have operations in countries across the world. The laws of these countries may not afford the same level of protection to your personal data. 7.2 The transfer of personal data to countries other than your country of residence is often necessary to provide our services to you. In other cases, Cantieri di Ostia - Canados will ensure that adequate safeguards are in place to comply with the requirements for the international transfer of personal data under applicable privacy laws. For transfers of personal data outside the European Economic Area, Cantieri di Ostia - Canados may use Commission approved Standard Contractual Clauses as safeguards.

• 8. Your rights

8.1 You may contact our Privacy Office (please see below) to exercise any of the rights you are granted under applicable data protection laws, which includes (1) the right to access your data, (2) to rectify them, (3) to erase them, (4) to restrict the processing of your data, (5) the right to data portability and (6) the right to object to processing. 1. Right to access You may ask us whether or not we process any of your personal data and, if so, receive access to that data in the form of a copy. When complying with an access request, we will also provide you with additional information, such as the purposes of the processing, the categories of personal data concerned as well as any other information necessary for you to exercise the essence of this right. 2. Right to rectification You have the right to have your data rectified in case of inaccuracy or incompleteness. Upon request, we will correct inaccurate personal data about you and, taking into account the purposes of the processing, complete incomplete personal data, which may include the provision of a supplementary statement. 3. Right to erasure You also have the right to have your personal data erased, which means the deletion of your data by us and, where possible, any other controller to whom your data has previously been made public by us. Erasure of your personal data only finds place in certain cases, prescribed by law and listed under article 17 of the General Data Protection Regulation (GDPR). This includes situations where your personal data are no longer necessary in relation to the initial purposes for which they were processed as well as situations where they were processed unlawfully. Due to the way we maintain certain services, it may take some time before backup copies are erased. 4. Right to restriction of processing You have the right to obtain the restriction of the processing of your personal data, which means that we suspend the processing of your data for a certain period of time. Circumstances which may give rise to this right include situations where the accuracy of your personal data was contested but some time is needed for us to verify their (in)accuracy. This right does not prevent us from continuing to store your personal data. We will inform you before the restriction is lifted. 5. Right to data portability Your right to data portability entails that you may request us to provide you with your personal data in a structured, commonly used and machine-readable format and to have such data transmitted directly to another controller, where technically feasible. Upon request and where this is technically feasible we will transmit your personal data directly to the other controller. 6. Right to object. You also have the right to object to the processing of your personal data, which means you may request us to no longer process your personal data. This only applies in case the ‘legitimate interests’ ground (including profiling) constitutes the legal basis for processing (see ‘Legal basis’ above). At any time and free of charge you can object to direct marketing purposes in case your personal data are processed for such purposes, which includes profiling purposes to the extent that it is related to such direct marketing. In case you exercise this right, we will no longer process your personal data for such purposes. 8.2 You may withdraw your consent at any time You may withdraw your consent at any time by following the specific instructions in relation to the processing for which you provided your consent. For example, you may withdraw consent, by clicking the unsubscribe link in the email, adjusting your communication preferences in your account (if available) or by changing your smart phone settings (for mobile push notifications and location data). You may also contact the Privacy Office of Cantieri di Ostia – Canados. 8.3 For more information on how you can withdraw your consent for cookies and similar technologies we use when you visit our websites, please check the cookie policy on our websites. There may be situations where we are entitled to deny or restrict your rights as described above. In any case, we will carefully assess whether such an exemption applies and inform you accordingly. We may, for example, deny your request for access when necessary to protect the rights and freedoms of other individuals or refuse to delete your personal data in case the processing of such data is necessary for compliance with legal obligations. The right to data portability, for example, does not apply in case the personal data was not provided by you or if we process the data not on the basis of your consent or for the performance of a contract. 8.4 When you would like to exercise your rights, all you have to do is send your request to the Privacy Office of Cantieri di Ostia - Canados: Cantieri di Ostia - Canados Privacy Office Via dell’Idroscalo 252 Rome 00121 Italy Email: This email address is being protected from spambots. You need JavaScript enabled to view it. 8.5 You can also contact us at if you have any questions, remarks or complaints in relation to this privacy policy. However, if you have unresolved concerns you also have the right to complain to the Italian Data Protection Authority http://www.garanteprivacy.it/home_en located in Rome, Piazza di Monte Citorio 121, Rome 00186.

• 9. How we look after this policy

9.1 This privacy policy was most recently amended on 25 May 2018 and replaces earlier versions. We may amend this privacy policy from time to time and will notify you of any changes prior to these changes taking effect.