PRIVACY POLICY
Digital platform winbooking.com
Pursuant to Article 13 of Regulation (EU) 2016/679 (“GDPR”)

This policy describes how personal data are processed through the digital platform winbooking.com managed by: WINBOOKING.COM S.r.l., with registered office in Via Valpolicella n. 24/A – 37124 Verona (VR) – Italy (hereinafter “WinBooking” or the “Data Controller”).

1. DATA SUBJECT CATEGORIES

The winbooking.com platform involves different categories of subjects:

1. End users (guests) making bookings
2. Registered accommodation facilities
3. Event organizers
4. Intermediaries (entities acting between Organizers and accommodation facilities)
5. Website visitors

The processing methods vary depending on the role involved.

2. DATA PROCESSED

The following categories of data may be processed:

• Identification data (name, surname, company name)
• Contact details (email, telephone)
• Administrative and tax data
• Booking-related data
• Navigation data and technical logs
• Data relating to the use of the platform
• IP address and derived geolocation data

WinBooking does not process special categories of data pursuant to Article 9 GDPR.

3. PROCESSING OF USER DATA (GUESTS)

3.1. Roles of the parties
For bookings made through the platform:

• The Event Organizer acts as Data Controller for purposes related to the management of the event.
• The Accommodation Facility acts as Data Controller for purposes related to providing the hospitality service.
• The Intermediary acts as Data Processor in order to facilitate/organize, based on partial data provided by the Organizer, the relationship between the Organizer and the Accommodation Facility.
• WinBooking acts as Data Processor for the technical management of bookings.

WinBooking may also act as an independent Data Controller for specific purposes indicated in section 6.

3.2. Purpose of processing (Users)

User data are processed for:

• technical management of the booking
• sending service communications
• administrative and accounting management
• technical support
• fraud prevention

Legal basis:

• performance of a contract
• legal obligations
• legitimate interest

4. PROCESSING OF DATA OF ACCOMMODATION FACILITIES, INTERMEDIARIES AND ORGANIZERS

WinBooking processes the data of Facilities and Organizers as:

• Independent Data Controller, for:
  • management of the contractual relationship
  • billing
  • tax compliance
  • access management
  • IT security
• Data Controller for data intelligence purposes (see section 6)

Legal basis:

• performance of a contract
• legal obligations
• legitimate interest in the development of the platform

5. NAVIGATION DATA

Information systems automatically collect:

• IP addresses
• access logs
• device and browser information
• statistical usage data

Such data are used for:

• security
• maintenance
• aggregate analysis

For cookies, please refer to the Cookie Policy.

6. DATA INTELLIGENCE AND MARKET ANALYSIS

WinBooking develops and manages a digital infrastructure aimed at analyzing booking flows and generating market metrics.

For this purpose, WinBooking may process data as an independent Data Controller for:

• aggregate statistical analysis
• development of industry benchmarks
• processing of predictive models
• service improvement
• algorithmic development

Data processing is carried out in:

• aggregated form
• anonymized form
• pseudonymized form

Such processing does not allow the direct identification of individual users, Facilities or Organizers, unless explicit consent is provided or required by law.

Aggregated data may also be used after the termination of the contractual relationship.

7. COMMUNICATIONS RELATED TO SIMILAR EVENTS

Subject to the data subject’s consent or applicable legitimate interest, WinBooking may send communications relating to events similar or related to those for which a booking has been made.

You may object at any time.

8. DATA RETENTION

Data are retained:

• for the duration of the contractual relationship
• for the statutory periods required by tax and civil law
• for marketing purposes: maximum 24 months
• for profiling purposes: maximum 36 months
• for statistical purposes: in anonymized form

9. DATA RECIPIENTS

Data may be communicated to:

• authorized employees and collaborators
• IT service providers
• hosting providers
• tax and legal consultants
• competent authorities

Data are not disclosed.

10. TRANSFER OUTSIDE THE EU

Data are not transferred outside the European Economic Area.

Any transfers will take place in compliance with Articles 44 et seq. GDPR.

11. RIGHTS OF THE DATA SUBJECT

The data subject may exercise the rights provided for in Articles 15–22 GDPR:

• access
• rectification
• erasure
• restriction
• data portability
• objection
• withdrawal of consent

A complaint may be lodged with the Italian Data Protection Authority.

12. DATA CONTROLLER

WINBOOKING.COM S.r.l.
Via Valpolicella 24/A – 37124 Verona (VR)
PEC: winbooking@lamiapec.it

13. CHANGES TO THIS PRIVACY POLICY

This policy may be subject to changes or updates, including due to regulatory developments or functional updates of the winbooking.com platform.

In the event of significant changes, appropriate notice will be provided through the website or by communication to registered users.

The updated version of the policy is always available at:

www.winbooking.com/it/privacy.

Verona, 23/02/2026
WinBooking.com Srl
Enrico Ghinato

TERMS OF USE OF THE PLATFORM
WINBOOKING.COM - ACCOMMODATION FACILITIES

1. Subject
These Terms govern the use of the web platform winbooking.com (hereinafter the “Platform”), managed by WinBooking.com Srl, with registered office in VIA VALPOLICELLA 20/A - 37124 Parona VR, VAT no. 05173960237, PEC winbooking.com@lamiapec.it (hereinafter “WinBooking”), by accommodation facilities.

The Platform allows the Facility to:

• receive invitations to participate in events;
• upload or make available rates and availability;
• receive and manage bookings;
• consult reports and booking statements.

2. Nature of the service
The Platform facilitates the interaction between:

• event organizers,
• accommodation facilities,
• end users.

WinBooking:

• is not a party to the contract between the Facility and the guest;
• is not a party to the relationship between the Facility and the organizer;
• does not directly provide accommodation services.

The Facility remains the sole entity responsible for the service provided to guests.
WinBooking does not guarantee minimum booking volumes or economic results.

3. Registration and access
To use the Platform, the Facility must:

• complete the registration;
• provide accurate and up-to-date data;
• accept these Terms.

The account is personal and may not be transferred.
Acceptance of these Terms has general validity for the use of the Platform and is not required for each individual event, unless the Terms are updated.

4. Obligations of the Facility
The Facility undertakes to:

• provide truthful and updated information, rates and availability;
• comply with the published booking conditions;
• honor bookings received through the Platform;
• not bypass the Platform by directly contacting users to divert bookings;
• not manipulate data, availability or economic conditions;
• comply with all applicable regulations to its business.

5. Event management
Participation in events is optional.

Depending on the type of event:

• CUSTOM Events: economic conditions are defined by the organizer and managed outside the Platform;
• SMART Events: require acceptance of a separate commercial agreement with WinBooking.

Acceptance of these Terms does not automatically imply adherence to economic conditions or fees.
WinBooking does not intervene in economic relationships between the Facility and the Organizer in CUSTOM events.

6. Data and analysis
WinBooking may use data generated from the use of the Platform for:

• statistical analysis;
• creation of market benchmarks;
• development of functionalities and services.

Data will be processed in aggregated and non-identifiable form, unless otherwise consented. Such data will not be used to identify or profile the individual Facility for commercial purposes without consent.

7. Intellectual property and know-how
The Platform, its functionalities, logic and technologies are the exclusive property of WinBooking.

It is prohibited to:

• copy, replicate or analyze the functioning of the Platform;
• develop similar solutions based on information learned through its use.

8. Personal data protection
The Facility acts as Data Controller of guests’ personal data.

WinBooking:

• processes data for technical purposes related to Platform management;
• may process data for administrative, statistical and development purposes.

Processing is carried out in compliance with applicable regulations (GDPR).

9. Amendments to the Terms
WinBooking may update these Terms for technical, regulatory or evolutionary reasons.

The amendments:

• will be communicated via the Platform or other appropriate channels;
• may require a new acceptance in order to continue using the service.

10. Duration and termination
These Terms apply for the entire duration of use of the Platform.

The Facility may cease use at any time by deleting its account.

Termination does not exempt from the management of already confirmed bookings.

11. Applicable law – exclusive jurisdiction
These Terms are governed by Italian law.

For any disputes, the Court of Verona shall have exclusive jurisdiction.

WINBOOKING SERVICE AGREEMENT - SMART MODE

between
WinBooking.com Srl, with registered office in VIA VALPOLICELLA 20/A - 37124 Parona VR, VAT no. 05173960237, PEC winbooking.com@lamiapec.it (hereinafter “WinBooking”), operator of the web platform winbooking.com (hereinafter the “Platform”)

and

[Struttura_Ragione_Sociale], with registered office in [Struttura_Indirizzo] – [Struttura_CAP_Comune_PR], VAT no. [Struttura_PIVA], owner or operator of the accommodation business “[Struttura_Nome]” (hereinafter the “Facility”)

it is agreed as follows

1. SUBJECT OF THE AGREEMENT
1.1. This agreement governs the activation of the Facility to the SMART mode of the winbooking.com Platform.

The SMART mode allows the Facility to:

• be bookable within events managed through WinBooking;
• receive bookings generated through the Platform.

1.2. For all matters not expressly provided for in this agreement, the Terms of use of the Platform already accepted by the Facility shall apply.

2. FEES
2.1. For bookings generated through the Platform in SMART mode, the Facility shall pay WinBooking a fee equal to:
9.00% of the total amount of confirmed bookings

The fee applies to bookings:

• registered on the Platform;
• not cancelled within the deadlines set out in the applicable cancellation policy.

3. BASIS OF CALCULATION
3.1. For the purposes of calculating the fees:

• only the data recorded in the winbooking.com Platform shall be considered;
• any subsequent changes between the Facility and the guest (refunds, no-shows, early departures or variations) shall not affect the calculation of the fees.

4. INVOICING AND PAYMENT TERMS
4.1. WinBooking shall invoice the fees on a monthly basis, based on the bookings recorded in the relevant period.

Invoices issued are payable end of month from invoice date.

5. DURATION AND TERMINATION
5.1. This agreement shall be effective from the date of acceptance and shall remain valid until termination by either party.

The Facility may at any time:

• deactivate the SMART mode;
• continue to use the Platform under the conditions set out in the Terms of use.

Termination shall not affect:

• bookings already recorded;
• fees already accrued.

6. FINAL PROVISIONS
6.1. This agreement is governed by Italian law.
6.2. For all disputes relating to the interpretation, execution and validity of this agreement, the Court of Verona (Italy) shall have exclusive jurisdiction.

Acceptance
The Facility declares that it has read and accepted this agreement.

☑ I accept the WinBooking service agreement – SMART mode

Verona (Italia), 02/04/2026

☑ Pursuant to Articles 1341 and 1342 of the Italian Civil Code, the Facility declares that it expressly approves the clauses relating to fees, exclusive jurisdiction and service conditions

Verona (Italia), 02/04/2026