PRIVACY POLICY

1. LEGAL INFORMATION

Date of last update of this Privacy Policy: 31st December 2025.

1.1 The protection of your personal data is of the utmost importance to us. This privacy policy (hereinafter the “Privacy Policy”) has been created to help you understand how we process the information we collect about you (as a Buyer or a Voucher Beneficiary) and about your Companion in the context of the sale of a P ZERO™ Experience Package or a Gift Voucher made by Pirelli (as defined in Article 1.2 below and better described in the General Terms and Conditions of Sale) for the purposes of your/your participation in the P ZERO™ Experience.

With specific reference to the collection and processing of personal data of Companions, it is your responsibility to inform these subjects of the processing of personal data referred to in this Privacy Policy, where their contact details are entered by you in the dedicated platform, made available by Pirelli.


1.2 Pirelli UK Tyres Limited, with its registered office at Derby Road, Burton on Trent, DE13 0BH (hereinafter “Pirelli”, “we”, “us”, or “our”, as the case may be) will act as “Data Controller” of the personal data provided for the purposes of participation in the P ZERO™ Experience, for the purposes better specified in art. 3.


2. COLLECTION OF INFORMATION

2.1 We collect personal data that comply with the legislation on the protection of personal data and in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data as currently amended and implemented in UK (hereinafter, “UK GDPR”), inclusive of information that can be used to identify you, including, but not limited to, your first and last name, address, zip code, city, country, telephone number, and e-mail address (hereinafter the “Personal Data”).


Information you provide to us

2.2 We may process your name, date of birth, contact details, e-mail address, home address, name, date of birth of any accompanying persons, and any other information you provide to us when you interact with us or when you contact us.


Technical information

2.3 When you browse our website(s), we may collect information that can be used to identify your computer and the browser you use or any mobile device you use to browse the internet. This information is collected through the installation of small text files called “cookies” and other similar technologies, (hereinafter jointly referred to as Cookies). In addition to other functions, when you visit our website(s) again, the previously stored cookies allow us to recognize your browser. Cookies may store unique identifiers, user preferences or other information as described in our Cookie Policy. For this specific purpose, Pirelli Tyre S.p.A., with registered offices at Viale Piero e Alberto Pirelli 25, 20126 Milan (Italy), acts as Data Controller.



3. USE OF PERSONAL DATA AND LEGAL BASIS FOR THE PROCESSING

3.1  We will use Personal Data for the following purposes:

(i) for your registration on the website dedicated to the P ZERO™ Experience (if you are a Buyer or a Voucher Beneficiary) or to fill in the online documents (if you are a Companion);

(ii) to allow you to purchase a P ZERO™ Experience Package or a Gift Voucher and for the fulfilment of obligations related to the organisation and management of the P ZERO™ Experience;

(iii) to respond to your Customer Care support requests;

(iv) to fulfil legal obligations to which Pirelli is subject;

(v) to establish, exercise or defend legal claims or protect our rights.

The processing of Personal Data for the purposes of this art. 3. is necessary to fulfil your request to participate in the P ZERO™ Experience, as well as to fulfil legal obligations and pursue our legitimate interest in exercising our rights, therefore it does not require your prior consent.

3.2  Pirelli may also use Personal Data for marketing purposes, as described in Article 7 below, with your prior consent.

3bis. USE OF ARTIFICIAL INTELLIGENCE

3bis.1. Pirelli may use artificial intelligence systems (“AI Systems”) for some of the purposes described in Section 3 above in relation to the Personal Data that you voluntarily provide.

3bis.2. In any case, Pirelli will act in accordance with applicable laws and regulations and, where required by applicable law, will notify you when you interact with an AI System.

4. SHARING OF PERSONAL DATA

We may share Personal Data, if authorized by law or as follows:


(a) Payment Service Provider. In order to allow you to make online payments by credit card or PayPal, the Personal Data you provide will be processed by payment service providers identified by Pirelli, which will act as independent Data Controllers, in accordance with their privacy policy, within a protected website managed by the same companies.


(b) Pirelli Group companies. Personal Data may be shared with Pirelli & C. S.p.A. and/or any company in the group for the pursuit of legitimate interests related to the performance of organizational and technical activities related to the purposes referred to in art. 3. Any transfer of Personal Data to third countries will be subject to appropriate safeguards (such as, for example, adequacy decisions or the adoption of standard contractual clauses).


(c) Third Parties. Personal Data may also be processed by service providers and/or insurance companies appointed by Pirelli. The insurance companies will act as independent Data Controllers. The other third parties will act, unless otherwise specified, as data processors. Please note that third parties are subject to confidentiality obligations with us and other legal restrictions that prohibit the use of the information we provide to them for any purpose other than to carry out the related outsourcing activity, unless we have expressly agreed to it or have been granted your permission for additional purposes.


(d) As permitted or required by law.. In some cases, we may be required to provide Personal Data in response to a court order, subpoena, government investigation, or as otherwise required by law. We also reserve the right to notify the relevant authorities of any activity that, in good faith, we believe to be illegal or in violation of applicable laws. We may disclose certain Personal Data if we believe that such activity is reasonably necessary to protect our rights, property, safety, or the safety of others, or to detect, prevent, or detect fraud, security, or technical issues.


(e) Commercial operation. In the event that we intend to sell or transfer ownership or control, in whole or in part, of our assets or our services to a third party, it may be necessary to disclose Personal Data to the prospective buyer both before and after the purchase. We will do so in accordance with applicable data protection laws. In any event, should the business transaction take place, we will require that the acquiring party agree to be bound in a manner similar to that provided in this Privacy Policy and that it uses and discloses Personal Data in the same manner as set forth in this Privacy Policy. If, on the other hand, the commercial transaction does not take place, we will ask the potential buyer not to use or disclose the Personal Data in any way and to delete it completely.



5. THE PRIVACY RIGHTS OF THE PARTICIPANT TO THE P ZERO™ EXPERIENCE

5.1  The participant in the P ZERO™ Experience enjoys various privacy rights in accordance with current regulations on the protection of personal data. In accordance with the provisions of the UK GDPR, you have the right to access your data processed by us, request its correction, deletion (for legitimate reasons), restrict or restrict the processing we carry out and enjoy the right to portability of your Personal Data, to withdraw your consent (where applicable), to object to the processing and the right to be notified of any breach of security that may put at risk your rights to privacy and protection of your Personal Data. To exercise your rights, you can contact us at the following e-mail address:dpo_pirelliuktyres@pirelli.com. You can also use your personal area on our website to directly carry out the operations permitted therein. You may also lodge a complaint with the competent data protection supervisory authority in your country, in accordance with applicable regulations (for UK, the Information Commissioner’s Office www.ico.org.uk). We may not be able to comply with every request for certain information if we believe that doing so violates any law, other legal requirement, or other rights of data subjects.



6. RETENTION OF PERSONAL DATA

6.1 We will retain the Personal Data of participants in the P ZERO™ Experience as follows: (i) in the event that you have submitted support requests without creating an account, for a period of 1 (one) year from our last communication; (ii) if you have created an account, for a period of 7 (seven) years from the date of collection of such data; (iii) for marketing purposes, for a period of 7 (seven) years from the date of collection of your consent, unless otherwise requested by you. In addition, if within the period indicated in paragraphs (ii) and (iii) you carry out actions on your account or on one of the Pirelli sites or apps (such as, by way of example but not limited to, registration for promotions or events, request for new services, responses to surveys), which shows your interest in maintaining your account or relationships and contacts with Pirelli in relation to the products and/or services of Pirelli and/or companies in the Pirelli Group, we will retain Personal Data for a further 7 (seven) years from the date of registration of such actions, without however sending marketing communications without your specific consent. After the data retention terms for the purposes indicated above, Personal Data will be archived and retained where necessary (for example in relation to the products and/or services purchased or used by you or in the case of your participation in prize competitions), for the period of time required by applicable laws regarding the retention of data and documents for administrative purposes, accounting, tax and defensive (in accordance with the limitation periods of the rights applicable in these areas). We will delete Personal Data upon your request, where the conditions are met, in accordance with the data protection laws applicable to you.



7. ELECTRONIC COMMERCIAL COMMUNICATIONS

7.1 On the basis of your specific consent to marketing activities, Pirelli will be authorised to send you promotional e-mails (including newsletters) and other commercial communications in electronic format relating to products and/or services of Pirelli or other companies of the Pirelli group. You can limit the communications that Pirelli sends you at any time. To opt out of receiving future marketing e-mails, simply click on the “unsubscribe” link at the bottom of every e-mail that Pirelli sends you.


7.2 Please note that even if you have opted out of receiving future promotional e-mails, we may still need to contact you with important information about your account, in accordance with applicable data protection laws. If you need information or assistance on how to unsubscribe, please contact us by e-mail at the following address: dpo_pirelliuktyres@pirelli.com.


7.3 In addition, we may send you “customer satisfaction” communications – even in the absence of specific consent – on the basis of our legitimate interest in understanding your degree of satisfaction of the P ZERO™ Experience and whether improvement actions are needed. You can oppose to such communications at any time by clicking on the “unsubscribe” link at the bottom of any e-mail that Pirelli sends to you or by contacting us directly as described in the paragraph “HOW TO CONTACT US”.



8. PRIVACY POLICIES OF THIRD PARTIES

8.1 This Privacy Policy only covers Pirelli’s use and disclosure of information. We are not responsible for the privacy policies of other websites or applications and we encourage you to read all terms, conditions and privacy policies provided by third parties before providing them with your information.



9. LIMITATIONS ON CHILDREN’S DATA

9.1 If you are a minor under Italian law, do not provide us with any Personal Data without the consent of the person exercising parental authority over you. If we become aware that we have collected Personal Data from a child without the consent of the person exercising parental authority over him/her, we will promptly delete such information. If you believe that we have collected Personal Data from a child, please contact us at the following address: dpo_pirelliuktyres@pirelli.com



10. SECURITY OF PERSONAL DATA

10.1 We use security measures to protect Personal Data from unauthorized access, improper use or disclosure, unauthorized modification, unlawful destruction or accidental loss. We allow access to our databases, only when necessary, and based on strict guidelines on what use may be made of such data.

10.2 You will be responsible for protecting your login credentials and, to this end, we recommend that you use a unique password for our website that is different from the password used for any other website.



11. CHANGES TO PRIVACY POLICY

11.1 Privacy laws and practice are constantly developing. Our policies and procedures are therefore subject to continuous review. Our Privacy Policy may be amended from time to time, but we will not reduce your rights under this Privacy Policy without your consent. The date on which the last version of the Privacy Policy was modified is located at the top of this document.



12. HOW TO CONTACT US

12.1 If you have any questions regarding the Privacy Policy, or would like to review, edit your Personal Data or request that we delete Personal Data stored in databases we actively use, or if you want to contact the Data Protection Officer (“DPO”) of Pirelli UK Tyres Limited please contact the Company’s registered office or write at the e-mail address: dpo_pirelliuktyres@pirelli.com.


12.2 With reference to the processing of personal data collected through Cookies, you can also contact the Data Protection Officer of Pirelli Tyre S.p.A. at the following e-mail address: DPO_PTyre@pirelli.com.