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Privacy Notice on the Processing of Personal Data

pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR)

Effective as of 22 December 2025

Preamble

This Privacy Notice has been drafted in accordance with the GDPR and the Italian Privacy Code (Legislative Decree No. 196 of 30 June 2003), as amended. It has also been prepared in compliance with the Guidelines issued by the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali), in particular the Guidelines on combating spam dated 4 July 2013.

Data Controller:
Antropika S.r.l.s., Via Giorgio Scalia, 10B – 00136 Rome (RM), Italy

VAT No.: 17361751005

Email: info@antropika.com

App covered by this Privacy Notice: Antropika (the "App").

Within the App, the Data Controller processes personal data relating to different categories of data subjects, in particular:

• end users ("tourists"), who use the App to browse, book and purchase tours and experiences; and
• tour guides, selected and authorised by the Data Controller, who collaborate in the creation and delivery of the tours published on the App.

The processing of personal data may vary depending on the category of the data subject and the features used within the App.

General Information

This document describes how the Data Controller processes your personal data provided through the App.

Below you will find a description of the main processing activities concerning your personal data. For each processing activity, we explain the legal basis, whether the provision of data is mandatory, and the consequences of failing to provide such data. Where necessary to better describe your rights, we also specify if and when a particular processing activity is not carried out.

Within the App, you may enter personal data relating to third parties. In such cases, you warrant that you have obtained the consent of those third parties to provide their personal data. You therefore agree to indemnify and hold the Data Controller harmless from any liability arising in this regard.

Registration on the App – End Users (Tourists)

The personal information and data requested during registration as an end user (tourist) are processed in order to allow you to access the restricted area of the App and to use the online services offered by the Data Controller, including browsing, booking and purchasing tours and experiences.

The legal basis for this processing is the need to perform pre-contractual measures taken at your request and, once a booking or purchase has been made, the performance of a contract to which you are a party.

The provision of data is optional; however, failure to provide the requested data will make it impossible to complete the registration process and to use the services of the App reserved for registered users.

Registration on the App – Tour Guides

The personal information and data requested during registration as a tour guide are processed in order to verify compliance with the professional requirements established by applicable law (including professional qualification and registration with the National Register of Tour Guides), as well as to establish and manage the collaboration relationship with the Data Controller and to publish tours on the App.

The legal basis for this processing is the performance of pre-contractual and contractual measures to which you are a party. The provision of data is optional; however, failure to provide such data will make it impossible to complete the registration as a tour guide and to collaborate with the Data Controller through the App.

Purchases via the App

Your personal data are processed to allow you to make purchases through the App. When you place a purchase order, your personal data are processed in order to conclude the purchase contract and to correctly perform the related operations, as well as—where required by applicable law—to fulfil tax and accounting obligations.

The legal basis for this processing is the performance of a contract to which you are a party and/or compliance with legal obligations.

Regardless of the above and without requiring your consent, the Data Controller may process your data for so-called "soft spam" purposes, as provided for by Article 130 of the Italian Privacy Code. This means that, limited to the email address you provided in the context of a purchase via the App, the Data Controller may use such email address to send direct offers relating to similar products or services, unless you object to such processing in the manner described in this Privacy Notice. The legal basis for this processing is the legitimate interest of the Data Controller, which is considered equivalent to your interest in receiving such communications.

The Data Controller may also send emails reminding you to complete a pending purchase. The legal basis for this processing is the legitimate interest of the Data Controller in sending such communications.

Responding to Your Requests

Your personal data are processed in order to respond to your requests for information. The provision of data is optional; however, failure to provide such data will make it impossible for the Data Controller to respond to your requests.

The legal basis for this processing is the legitimate interest of the Data Controller in responding to user requests, which corresponds to your interest in receiving a reply to communications sent to the Data Controller.

Internal Chat Between End Users and Guides

The App provides an internal chat feature for users and guides, intended exclusively to enable organisational and operational communications related to the booking and execution of tours (e.g. logistical information, schedules, meeting points).

The provision of data through the use of the chat is optional; however, failure to use this feature may result in the inability to receive or send operational communications relevant to the proper organisation and execution of the tour.

Personal data processed through the chat are used to ensure the correct organisation and delivery of booked services, as well as for user support, platform security and moderation purposes. The legal basis for this processing is the performance of a contract to which the data subject is a party.

For these purposes, the Data Controller may access the content of chat communications exclusively where necessary to provide support, ensure proper platform functionality, prevent or manage behaviour that violates the terms of use, or protect its rights in the event of disputes.

Chat messages are encrypted both in transit and at rest, but they are not protected by end-to-end encryption.

Generic Marketing

Subject to your consent, the Data Controller may process your personal data to send you promotional material and/or newsletters relating to its own products or services or those of third parties.

The legal basis for this processing is your consent. The provision of data for this purpose is entirely optional. Failure to provide consent will prevent you from receiving promotional material and newsletters and will prevent the Data Controller from conducting market research, including surveys aimed at assessing user satisfaction.

Such communications will be sent to the email address you provided through the App.

Profiling

Subject to your consent, the Data Controller may process your personal data for profiling purposes, namely to analyse your purchasing choices by identifying the type and frequency of your purchases, in order to send you promotional material and/or newsletters relating to products or services of specific interest to you.

The legal basis for this processing is your consent. The provision of data for this purpose is optional. Failure to provide consent will prevent the Data Controller from creating your commercial profile and from sending targeted promotional communications. Such communications will be sent to the email address you provided via the App.

Data Disclosure

The Data Controller does not sell or transfer your personal data to third parties.

Geolocation

The App may offer an optional geolocation feature, activated solely at the user's discretion, intended to enhance the user experience in specific situations, such as facilitating meetings between guides and participants or providing contextual information related to the tour location.

Geolocation is not essential for the functioning of the App, is not continuous, and is limited to situations in which the user chooses to activate it. In the absence of consent, the App remains fully usable without substantial limitations.

You may grant or deny permission for geolocation directly through your device settings and may revoke consent at any time. The processing of geolocation data is based on your consent.

Revocation of consent does not affect the lawfulness of processing carried out prior to such revocation and does not negatively affect ordinary use of the App.

Communication of Personal Data

In the course of its ordinary activities, the Data Controller may communicate your personal data to certain categories of recipients, as described in Article 2 below. For the protection of your rights, Article 2 may also specify cases in which your data are not communicated to third parties.

Communication of data differs from data transfer: in the former case, recipients may use the data only for the purposes defined in their relationship with the Data Controller. In the case of a transfer, the recipient becomes an independent data controller, which always requires your consent.

In any case, the Data Controller may process your personal data to comply with applicable legal obligations.

Specific Privacy Notice

Art. 1 – Methods of Processing and Categories of Data

Personal data are primarily processed using electronic and automated means, in compliance with the GDPR and appropriate security measures. Data processing is relevant, proportionate and limited to what is necessary. Secure IT environments and encrypted backups are used.

Processed data include:

• End users: identification data, email address, phone number, booking and purchase data, App usage data;
• Tour guides: identification and contact details, VAT number, professional credentials, registration details, and data related to tours offered through the App.

Service communications and push notifications related exclusively to App functionality are sent on a contractual basis.

Art. 2 – Communication of Personal Data

Personal data may be communicated to:

• public authorities where required by law;
• legal, administrative and tax consultants;
• employees and collaborators involved in App management;
• authorised tour guides, solely for tour organisation purposes;
• payment service providers (Stripe), which independently process payment data;
• IT service providers, CRM platforms and Firebase services (Google LLC) for App functionality and notifications.

No external customer care providers are used.

Art. 3 – Data Retention

Personal data are retained only for as long as necessary, including:

• account data: duration of the relationship and up to 24 months of inactivity;
• customer care data: up to 3 months;
• chat data: up to 3 months after tour completion;
• contractual and accounting data: up to 10 years;
• marketing data: until consent withdrawal;
• profiling data: up to 12 months.

Art. 4 – Data Transfers

The Data Controller is established in the EU and uses EU-based servers. Transfers outside the EU may occur only in compliance with GDPR provisions.

Art. 5 – Data Subject Rights

You have the right to access, rectify, erase, restrict or object to processing, request data portability, withdraw consent at any time, and lodge a complaint with a supervisory authority.

Art. 6 – Amendments

The Data Controller reserves the right to amend this Privacy Notice at any time. Users are encouraged to review it regularly. Material changes may be notified by email.