CLACK.DIGITAL END-USER LICENSE AGREEMENT (EULA)
===============================================

Version 1.0.1 - 4 June 2025

PREMISES:

PLEASE READ CAREFULLY BEFORE USING THIS PRODUCT: This End-User License
Agreement (“EULA”) is a legal agreement between (a) You (or “User” -
either an individual or a single entity, even as declared to ORASTRON -
if requested - by personal data communication required on the licensing
website) and (b) Orastron srl unipersonale (“ORASTRON”), located in
Italy (registered office in Via Pasquale Voso, 20/D - 84043 Agropoli
(SA) - Italy - VAT ID IT05975760652, e-mail: info@orastron.com), that
governs your use of any Software Product, made available by ORASTRON
with this EULA attached.

BY CLICKING “I AGREE”, “ACCEPT” OR SIMILAR CLICK BUTTON / CHECK BOX
AND/OR BY TAKING ANY STEP TO INSTALL OR USE THE SOFTWARE PRODUCT
(INCLUDING DOWNLOADING), YOU (1) REPRESENT THAT YOU ARE OF THE LEGAL AGE
OF MAJORITY (18-YEAR-OLD) AND, IF APPLICABLE, YOU ARE DULY AUTHORIZED BY
YOUR EMPLOYER TO ENTER INTO THIS CONTRACT AND (2) YOU AGREE TO BE BOUND
BY THE TERMS OF THIS EULA. IF YOU DO NOT ACCEPT THE EULA TERMS, DO NOT
USE THE SOFTWARE PRODUCT.

THIS EULA SHALL ALSO FULLY APPLY TO THE ACCESS AND USE OF THE SOFTWARE
VIA WEB-BASED PLATFORMS (IF PROVIDED) - THIS INCLUDES, BUT IS NOT
LIMITED TO, ACCESSING THE SOFTWARE THROUGH ANY WEB BROWSER, WEB
INTERFACE, OR CLOUD-BASED SERVICE PROVIDED OR AUTHORIZED BY ORASTRON.
WEB ACCESS TO THE SOFTWARE VIA WEB-BASED PLATFORMS, INTERFACES, OR
SERVICES SHALL BE CONSIDERED EQUIVALENT TO THE LOCAL INSTALLATION OR
DOWNLOAD OR ACTIVATION OF THE SOFTWARE.

1.  GRANT OF LICENSE. The Software Product, which is owned by ORASTRON
    and may include associated media, and “online” or electronic
    documentation (collectively the “Software Product”) and any
    third-party software used within the Software Product (“Third-Party
    Software”), such as software libraries etc., fall within the scope
    of this EULA. ORASTRON grants You the following non-exclusive
    rights, provided You agree to and comply with all terms and
    conditions of this EULA:

    a.  Use. You may use the Software Product on your device (or devices
        if the Software Product is licensed to You for use on multiple
        devices). You may not use the Software Product on additional
        devices and do not have the right to distribute the Software
        Product. You agree to only use the Software Product as expressly
        permitted herein.

    b.  Reservation of Rights. The Software Product is licensed - not
        sold - to You by ORASTRON. ORASTRON and its suppliers own all
        rights, title and interest in and to the Software Product and
        reserve all rights not expressly granted to You in this EULA.
        You agree to refrain from any action that would diminish such
        rights or would call them into question.

    c.  Forbidden uses. You are strictly forbidden to add, change, or
        otherwise modify the Software Product and/or its features and/or
        interfaces related to the Software Product, except what is
        allowed by applicable laws.

        You may not (i) rent, sell, lease, license, sublicense, assign,
        distribute or otherwise transfer in whole or in part the
        Software Product to another party, except as set forth in
        Article 1.h; (ii) provide, disclose, divulge or make available
        to, or permit use of the Software in whole or in part by, any
        third party without ORASTRON prior written consent; or (iii)
        modify or create derivative works based upon the Software
        Product.

        If the Software Product contains or includes audio content such
        as samples, sound sets, presets, and/or audio loops (“Audio
        Content”), You may use such Audio Content to create your own
        original soundtracks for your commercial or non-commercial audio
        productions, which may be broadcasted and/or distributed to your
        discretion. However, You may not distribute the Audio Content on
        a standalone basis, nor may such Audio Content be repackaged in
        whole or in part as audio samples, sound libraries, sound
        effects, music beds, audio plugins, virtual or other music
        instruments.

    d.  Backup copies. If not specified otherwise in writing by
        ORASTRON, You may own only one copy of the Software Product for
        private back-up purposes. If it should be necessary for the
        correct use of the Software Product, You may copy the Software
        Product on a back-up device, as long as the copies are not used
        in any other way, installed on, or used on other devices and
        provided the use of the back-up device is interrupted when the
        original device or its substitute becomes operational again. You
        may copy the original Software Product up to the amount of
        copies authorized by ORASTRON. You shall not copy the Software
        Product on to a public communication network or sharing service.

    e.  Supplemental Materials. The Software Product may be accompanied
        with supplemental materials, such as software libraries or data,
        provided to You under different terms than this End-User License
        Agreement (EULA) and/or to which different copyright notices
        apply, as specified in the Software Product itself. In these
        cases, this EULA does not govern such supplemental materials,
        and ORASTRON expressly disclaims any and all liability to You or
        any third party in relation to them.

    f.  Configuration. You agree that it shall be your sole
        responsibility to ensure that any security or other settings on
        your hardware or software, including without limitation any
        routers or switches over which the Software Product may
        communicate with any equipment, are properly configured to
        enable such communication.

    g.  Support not included. ORASTRON will not provide any support
        services under this EULA, except as mandated by applicable
        (consumer or similar) law or as expressly outlined in other
        contractual terms and conditions; this EULA does not give You
        any rights to any updates or upgrades to the Software Product or
        to any extensions or enhancements to the Software developed by
        ORASTRON at any time in the future.

        ORASTRON may offer support and subscription services separately.
        If You have purchased ORASTRON support and subscription services
        with the Software Product, these services are provided to You
        under the Contract Terms and Conditions supplied by the
        authorized Seller from whom You have purchased the devices
        and/or the software. Any supplemental software code or related
        materials that ORASTRON provides to You as part of any support
        and subscription services are to be considered part of the
        Software Product and are subject to the terms and conditions of
        this EULA, unless otherwise specified.

    h.  Type of Licenses: the specific conditions of three possible
        licenses are described and governed below, and specified in the
        Software Product; the subsequent contractual articles may apply
        to the extent that they do not contradict the provisions set
        forth in this Article 1.h.

        i.  Freeware without any verification:
            a.  License Grant: The User is authorized to download and
                use the Software Product free of charge. This Software
                Product is provided as freeware, and no User
                registration is required for its use.
            b.  No Warranty: The Software Product is provided ‘as is’
                without any warranties of any kind, either express or
                implied, if admitted by the law.
            c.  No Redistribution: The User is not authorized to
                redistribute or transfer the Software Product to third
                parties.
            d.  Data Collection and Privacy: The Software Product will
                not collect User and device information.
        ii. Freeware, NFR (Not for Resale), particular conditions
            (e.g. beta tester) or Paid Software with verification - via
            Web Site (https://clack.digital/) and third-party sites
            excluding App Stores (Apple App Store, Google Play Store,
            etc.):
            a.  Registration and Activation: Depending on the version,
                the User may obtain the Software Product after
                registration or as a demo via anonymous download from
                the Web Site or third-party sites. Upon initial use, the
                Software Product might prompt for registration on the
                Web Site or require association with a Web Site user
                account. This process might involve transmitting the
                User’s explicitly provided e.g. email address, a
                non-interactive machine identifier and/or other data
                better explained in the Privacy Policy
                (https://clack.digital/eula-1.0.1#privacy-policy).

            b.  License Activation and Verification: At every startup,
                and possibly during operation, the Software Product
                might locally check for activation. If connected to the
                internet, it might also attempt to verify activation
                with the server, transmitting the same data.

            c.  License Transfer (Paid-Software only): Generally, a
                registered User may transfer a Software Product (if such
                Software Product is also registered with the User’s
                account) to another registered User. Prior to the
                transfer, the end user receiving the transferred
                Software Product must agree to all the EULA terms. This
                process may require email addresses of both parties, or
                may involve an automated system, and a transfer fee may
                be applied. If and once your license has been
                transferred to a third party, your license is
                automatically terminated, subject to Section 7(d) of
                this EULA. For further information, see here:
                https://clack.digital/faq#license-transfer.

                ORASTRON does not oversee or manage the terms, including
                any financial aspects, of transfers between users.

            d.  Data Collection and Privacy: The Software Product will
                collect certain User and device information for
                activation and verification purposes. This collection
                will be in compliance with applicable privacy laws and
                regulations. Read the attached Privacy Policy
                (https://clack.digital/eula-1.0.1#privacy-policy) for
                any information.

            e.  Scope of Use: You may install and personally use the
                Software Product associated to one account on up to 5
                devices. The Software Product may not be used on a
                network by third-party users, unless each user possesses
                a license.
        iii. Freeware, NFR (Not for Resale), particular conditions
             (e.g. beta tester) or Paid Software - via App Stores (Apple
             App Store, Google Play Store, etc.):
             a.  Acquisition Through App Store. The User obtains the
                 Software Product through an App Store, paying the
                 applicable fee, if any.
             b.  Account Linkage. While a Software Product purchased
                 through third-party App Stores is typically linked to
                 the User’s store account (e.g., Apple, Google), and
                 license transfer between accounts is not permissible,
                 the User might still need to associate the Software
                 Product with their account on ORASTRON’s servers,
                 providing similar data as in other scenarios.
             c.  License transfer. Transferring licenses acquired
                 through App Stores between users is not supported by
                 ORASTRON.
             d.  Data Collection and Privacy. As with other scenarios,
                 certain User and device information will be collected
                 in compliance with privacy laws. Read the attached
                 Privacy Policy
                 (https://clack.digital/eula-1.0.1#privacy-policy) for
                 any information.

        Non-Paid Software, including freeware, NFR (not for Resale),
        demo and beta testing copies, cannot be resold or transferred.

2.  UPGRADES. To use a Software Product identified by ORASTRON as an
    upgrade, You must first be licensed for the original Software
    Product identified by ORASTRON as eligible for the upgrade. After
    upgrading, You may no longer use the original Software Product that
    formed the basis for your upgrade eligibility and the upgraded
    software shall be deemed the “Software Product”.

3.  ADDITIONAL SOFTWARE. This EULA applies to updates or supplements to
    the original Software Product provided by ORASTRON unless ORASTRON
    provides other terms along with the update or supplement. In case of
    a conflict between such terms, the other terms will prevail.

4.  PROPRIETARY RIGHTS. All intellectual property rights in the Software
    Product and user documentation (including titles and data bases) are
    owned by ORASTRON or its suppliers and are protected by law,
    including but not limited to copyright, trade secret, and trademark
    law, as well as other applicable laws and international treaty
    provisions. The structure, organization and code of the Software
    Product are valuable trade secrets and confidential information of
    ORASTRON and its suppliers. You shall not remove, alter, or obscure
    any product identification, copyright notices, proprietary
    restrictions, or other legal notices from the Software Product.

5.  LIMITATION ON REVERSE ENGINEERING. Except to the extent that such
    restriction is not permitted under applicable law, You are not
    permitted (and You agree not to) reverse engineer, decompile,
    disassemble or create derivative works of or modify the Software
    Product. Nothing contained herein shall be construed, expressly or
    implicitly, as transferring any right, license or title to You other
    than those explicitly granted under this EULA. ORASTRON reserves all
    rights in its intellectual property rights not expressly agreed to
    herein. Unauthorized copying of the Software Product, failure to
    comply with the restrictions in this EULA, or any other breach of
    the license herein, will result in automatic termination of this
    Agreement. You acknowledge and agree that such actions will cause
    immediate, irreparable harm to ORASTRON for which monetary damages
    would be an inadequate remedy, and that injunctive relief may be
    sought by ORASTRON in such cases (if deemed to be appropriate by
    ORASTRON).

6.  FEE. In case of a Paid Software version, You agree to pay the
    Software Product any license or other due fee as otherwise stated on
    the Web Site (https://clack.digital/) or other EULA exhibits or
    purchase documents. You shall pay all applicable Fees when due, and
    according to the payment terms specified in the invoice. Any failure
    to pay Fees within a period of 30 days from the due date may cause
    your access to the Software Product to terminate immediately, and
    will be deemed a material breach of this Agreement.

7.  TERM, SALE TERMS AND AGREEMENT UPDATING.

    a.  This EULA can be terminated if it is required to do so by law.
        Your license to use the Software Product under this EULA shall
        continue until it is terminated by either party. You may
        terminate this EULA at any time, by discontinuing the use of all
        or any of the Software Product and by destroying all copies of
        the Software Product in your possession and control.
    b.  This EULA will also terminate immediately and without additional
        notice in the event You breach this EULA and/or fail to comply
        with sections 1, 4, 5, 7, 9, 10, 11, 13 or 17 of this EULA. All
        terms which by their nature should survive termination of this
        EULA shall survive its termination.
    c.  If You are identified as a ‘consumer’ under the Italian Consumer
        Code (Codice del Consumo), Legislative Decree No. 206, dated
        September 6th, 2005, additional terms and conditions will apply.
        In the event of any conflict, these supplemental terms and
        conditions will take precedence over this EULA.
    d.  Upon termination, You must immediately cease all use of the
        Software Product, destroy all copies of the Software Product,
        and remove all copies of the Software Product from any and all
        computer systems, servers, storage and devices in your
        possession, custody or control. Upon request, You will certify
        in writing to ORASTRON that You have complied with these
        requirements.
    e.  ORASTRON reserves the right to periodically update the terms of
        this EULA. Any changes will be announced on the Web Site at
        https://clack.digital/ and sent to You by e-mail (if provided).
        Continued use of the Software Product following such
        notifications will be deemed as your acceptance of the revised
        terms. If the changes materially alter your rights or
        obligations, we will make reasonable efforts to notify You of
        the change. For example, we may send a message to your email
        address, if we have one on file, or generate a pop-up or similar
        notification when You access the Software Product for the first
        time after such material changes are made.

8.  PRIVACY AND DATA PROTECTION. The personal data shall be processed as
    stated in the linked Privacy Policy:
    https://clack.digital/eula-1.0.1#privacy-policy.

    You acknowledge and agree that some or all of the Software Products
    may be designed to anonymously connect to ORASTRON’s servers. This
    connection is established for the sole purpose of searching for and
    retrieving news, updates, and notifications intended for the User
    (“Updates”). These Updates may include, but are not limited to,
    software patches, bug fixes, enhanced functionalities, and other
    relevant information that ORASTRON deems necessary for the User to
    have an optimal experience with the Software.

    The Software’s ability to connect to ORASTRON’s servers and receive
    Updates require no personal identification or the submission of
    personal data from the User. The connection is established in a
    manner that ensures the anonymity of the User, adhering to
    ORASTRON’s privacy and data protection policies. By using the
    Software, You consent to this anonymous connection and the receipt
    of Updates as described above.

    The Software Product may give You the possibility to opt-out of
    receiving these Updates at any time. In such cases, You acknowledge
    that doing so may affect the functionality and security of the
    Software.

9.  DISCLAIMER OF WARRANTIES.

    a.  YOU AGREE THAT THE USE OF THE SOFTWARE PRODUCT IS AT YOUR SOLE
        RISK AS TO SATISFACTORY QUALITY PERFORMANCE, ACCURACY AND
        EFFORT. Use of the Software Product may adversely affect the
        operation of other software and devices. To the maximum extent
        permitted under applicable law, the Software Product is offered
        on an “AS-IS” basis and ORASTRON does NOT warrant that the
        functions contained in the Software Product will meet your
        requirements or that the operation of the Software Product will
        be uninterrupted or error free or that such errors will be
        corrected. Computer software is inherently subject to bugs and
        potential incompatibility with other computer software and
        hardware. You should not use the Software Product for any
        applications or scenarios in which failure could cause any
        significant damage or injury to persons or tangible or
        intangible property, and You assume responsibility for the use
        and results obtained from the Software Product.
    b.  EXCEPT AS MAY BE SET OUT IN A SPECIFIC WARRANTY ACCOMPANYING THE
        SOFTWARE PRODUCT, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE
        LAW, ORASTRON AND ITS SUPPLIERS PROVIDE THE SOFTWARE PRODUCT AND
        THIRD PARTY SOFTWARE “AS IS” AND WITH ALL FAULTS AND WITHOUT ANY
        OTHER WARRANTY OF ANY KIND, AND HEREBY DISCLAIM ALL OTHER
        WARRANTIES AND CONDITIONS, EITHER EXPRESS, IMPLIED, OR
        STATUTORY, INCLUDING, BUT NOT LIMITED TO, WARRANTIES OF TITLE
        AND NON-INFRINGEMENT, ANY IMPLIED WARRANTIES, DUTIES OR
        CONDITIONS OF MERCHANTABILITY, OF FITNESS FOR A PARTICULAR
        PURPOSE, AND OF LACK OF VIRUSES ALL WITH REGARD TO THE SOFTWARE
        PRODUCT AND THIRD PARTY SOFTWARE. NO ORAL OR WRITTEN INFORMATION
        OR ADVICE GIVEN BY ORASTRON OR AN ORASTRON AUTHORIZED
        REPRESENTATIVE SHALL CREATE A WARRANTY. Some
        states/jurisdictions do not allow exclusion of implied
        warranties or limitations on the duration of implied warranties,
        so the above disclaimer may not apply to You in its entirety (in
        particular, if You are a consumer - in this case, read the sale
        terms that may apply to the software/device purchase, also by a
        third-party). To the extent applicable law requires ORASTRON to
        provide warranties, You agree that the scope and duration of
        such warranty shall be to the minimum extent permitted under
        such applicable law.
    c.  IN NO EVENT DOES ORASTRON PROVIDE ANY WARRANTY OR
        REPRESENTATIONS WITH RESPECT TO ANY THIRD PARTY HARDWARE OR
        SOFTWARE WITH WHICH THE SOFTWARE PRODUCT IS DESIGNED TO BE USED,
        AND ORASTRON DISCLAIMS ALL LIABILITY WITH RESPECT TO ANY
        FAILURES THEREOF, UNLESS OTHERWISE STATED ON THE WEB SITE OR
        OTHER APPLICABLE TERMS OR IF MANDATORY ACCORDING TO THE LAW.
    d.  The Software Product may display, include or make available
        content, data, information, applications or materials from third
        parties or provide links to certain third party web sites. By
        using the Software Product, You acknowledge and agree that
        ORASTRON is not responsible for any aspect of such third party
        materials or web sites. To the maximum extent permitted by
        applicable law, ORASTRON does not warrant, endorse, guarantee,
        or assume responsibility for any third party materials, and will
        not be liable in any way for any damages or losses incurred from
        the use of any such materials. You agree that any third party
        materials can contain proprietary content, information and
        material that is protected by applicable intellectual property
        and other laws, including but not limited to copyright, and that
        You will not use such proprietary content, information or
        materials in any way whatsoever except for permitted use of the
        Software Product.

10. CONFIDENTIALITY. The Software Product and any other proprietary
    information, technology or know how provided to You by ORASTRON (in
    any form) in connection with your utilization of the Software
    Product is the confidential information of ORASTRON (“Confidential
    Information”). You will use the Confidential Information only as
    expressly authorized in this EULA and You will protect the
    Confidential Information from unauthorized use, dissemination, or
    publication by using the same degree of care as You would use to
    protect Your own confidential information, but no less than a
    reasonable degree of care. You are not obligated with respect to
    Confidential Information that (a) is or becomes a matter of public
    knowledge through no fault of Yours; (b) is rightfully received by
    You from a third party without a duty of confidentiality; (c) is
    independently developed by You; (d) is disclosed under operation of
    law or (d) is disclosed by You with ORASTRON’s prior written
    consent. Unauthorized use or disclosure of Confidential Information
    may cause ORASTRON irreparable harm; therefore, ORASTRON will have
    the right to enforce this EULA and any of its provisions by any
    equitable relief.

11. LIMITATION OF LIABILITY. TO THE MAXIMUM EXTENT PERMITTED BY
    APPLICABLE LAW, IN NO EVENT SHALL ORASTRON OR ITS SUPPLIERS BE
    LIABLE FOR ANY SPECIAL, INCIDENTAL, INDIRECT, OR CONSEQUENTIAL
    DAMAGES WHATSOEVER (INCLUDING, BUT NOT LIMITED TO, DAMAGES FOR LOSS
    OF PROFITS, FOR LOSS OF DATA OR OTHER INFORMATION, FOR BUSINESS
    INTERRUPTION, FOR PERSONAL INJURY, FOR LOSS OF PRIVACY ARISING OUT
    OF OR IN ANY WAY RELATED TO THE USE OF OR INABILITY TO USE THE
    SOFTWARE PRODUCT, THIRD PARTY SOFTWARE AND/OR THIRD PARTY HARDWARE
    USED WITH THE SOFTWARE PRODUCT, OR OTHERWISE IN CONNECTION WITH ANY
    PROVISION OF THIS EULA), EVEN IF ORASTRON OR ANY SUPPLIER HAS BEEN
    ADVISED OF THE POSSIBILITY OF SUCH DAMAGES AND EVEN IF THE REMEDY
    FAILS OF ITS ESSENTIAL PURPOSE. Some states/jurisdictions do not
    allow the exclusion or limitation of incidental or consequential
    damages, so the above limitation or exclusion may not apply to You
    in part of whole.

    ORASTRON is not obligated to maintain or support the Software
    Product, or to provide You with updates, fixes, or services related
    thereto. Nevertheless, You agree to use the Software Product at your
    own risk and that ORASTRON shall not have any liability to You with
    respect to such content.

    In no event shall ORASTRON’s total liability to you for all damages,
    other than as may be required by applicable law (e.g. in cases
    involving personal injury), exceed the amount actually paid by you
    for the Software Product.

    Other applicable terms (e.g. sale terms) or laws may supersede this
    provision.

12. INDEMNITY. You agree to indemnify and hold ORASTRON and its
    officers, directors, employees and licensors harmless from any claim
    or demand (including but not limited to reasonable legal fees) made
    by a third party due to or arising out of or related to your
    violation of the terms and conditions of this Agreement, your
    violation of any laws, regulations or third party rights or your
    negligent act, omission or willful misconduct.

13. ASSIGNMENT. You expressly recognize to ORASTRON the power to
    transfer to third party, in whole or in part, for the entire world
    or single countries, temporarily or permanently, all the rights
    granted with this Agreement or some of them; in this event, ORASTRON
    will be released from all responsibilities and obligations deriving
    from the Agreement, which will be fully and solely assumed by the
    applicable assignee.

    Transfers and assignments signed by ORASTRON according to the
    previous section, are approved by You since now and ORASTRON does
    not need Your permission every time it decides to transfer the
    rights. A notice will be sent to your last known email address on
    file with ORASTRON at the time of the assignment, if any was
    provided.

14. COMPLIANCE WITH LAWS. You shall comply with all applicable laws and
    regulations, in particular of the Italian State and European Union.
    You further agree that You will not use the Software Product for any
    purpose prohibited under applicable laws.

15. APPLICABLE LAW. This EULA is governed by the laws of the Italian
    State, without regard to its conflict of laws principles, with
    respect to any proceedings arising from this EULA. The parties
    hereby agree that this Agreement is not governed by the United
    Nations Convention on Contracts for the International Sale of Goods.

16. ODR. If a dispute arises in connection with this Agreement, the
    parties will try in good faith to settle it through mediation
    conducted by the European Online Dispute Resolution Service
    (https://ec.europa.eu/consumers/odr/main/?event=main.adr.show2) and
    resolved in accordance with its Rules. The parties will share the
    costs of the mediator equally. Each party will cooperate fully and
    fairly with the mediator and will attempt to reach a mutually
    satisfactory compromise to the dispute. Costs of arbitration,
    including lawyers’ fees, will be allocated by the ODR or the
    applicable law.

17. GENERAL.

    a.  Entire agreement and Third-party Store terms. This EULA and any
        other ORASTRON’s applicable agreement are the entire agreement
        between You and ORASTRON relating to the Software Product and it
        supersedes all prior or contemporaneous verbal or written
        communications, proposals and representations with respect to
        the Software Product or any other subject matter covered by this
        EULA.

        Notwithstanding any provisions to the contrary within this
        Agreement, in the event that the Software is downloaded from an
        authorized third-party digital distribution platform or store
        (“Store”), the terms and conditions, as agreed to by ORASTRON,
        applicable to such Store may supersede the terms of this
        agreement. Specifically, in the cases of Apple App Store
        (https://www.apple.com/legal/internet-services/itunes/dev/minterms)
        and Google Play Store
        (https://play.google.com/about/developer-distribution-agreement.html)
        the terms and conditions of the Store, as linked, will prevail
        and be deemed overriding, to the extent that they differ from
        the terms set forth in this agreement. This provision is
        intended to acknowledge and accommodate the specific
        requirements and regulations that may be imposed by the Store
        from which the Software is obtained.

    b.  Headings. Headings under this EULA are intended only for
        convenience and shall not affect the interpretation of this
        EULA.

    c.  Representation. If You are a business entity, then the
        individual accepting on behalf of the entity, represents and
        warrants that You have the authority to act on behalf, that You
        represent that You are duly authorized to do business in the
        country or countries where You operate, and that your employees,
        officers, representatives, and other agents accessing the
        Software Product are duly authorized to legally bind to this
        EULA.

    d.  Waiver and Modification. No failure of either party to exercise
        or enforce any of its rights under this EULA will act as a
        waiver of those rights. This EULA may only be modified, or any
        rights under it waived, by a written document executed by the
        party against which it is asserted.

    e.  Severability. If any provision of this EULA is found illegal or
        unenforceable, it will be enforced to the maximum extent
        permissible, and the legality and enforceability of the other
        provisions of this EULA will not be affected.

    f.  Governing Law. This EULA will be exclusively governed by Italian
        law and the European Union laws, without regard to its choice of
        law principles. The United Nations Convention for the
        International Sale of Goods shall not apply.

    g.  Forum Choice. You agree to submit to the exclusive jurisdiction
        and venue of Court of Milan (Italy) and waive any
        jurisdictional, venue or inconvenient forum objections to such
        court.

    h.  Acknowledgement. You declare and guarantee that this agreement
        has been read and examined by a legal expert, hence You have
        total acknowledgement of the juridical effects of the Agreement
        itself, including any usage of the English language.

    i.  Contact Information. If You have any questions about this EULA,
        or if You want to contact ORASTRON for any reason, please direct
        all queries to: info@orastron.com.

CLACK.DIGITAL EULA PRIVACY POLICY
---------------------------------

Privacy Notice for Orastron srl unipersonale Software Product Under the
GDPR

This privacy notice elaborates on Orastron’s data processing activities
related to our Software Product as defined in the STANDARD END-USER
LICENSE AGREEMENT (EULA), under General Data Protection Regulation
2016/679.

Under the General Data Protection Regulation (GDPR), a “Data Controller”
refers to the entity (such as a company, organization, or individual)
that determines the purposes and means of processing personal data. In
the context of a privacy notice, the Data Controller is the entity
responsible for collecting, using, storing, and safeguarding the
personal data provided by the data subjects (users, customers, etc.),
and ensuring that all data processing activities comply with the GDPR
and other relevant data protection laws. The Data Controller must be
transparent about how it processes personal data and must uphold the
data protection rights of data subjects whose data it processes.

1.  Data Controller:

    -   Company: Orastron srl unipersonale
    -   Address: Via Pasquale Voso, 20/D — 84043 Agropoli (SA), Italy
    -   Email: info@orastron.com

2.  Purposes of Data Processing and Data Retention Periods:

    a.  Activation and Verification:
        -   Purpose: Ensuring software legality and preventing
            unauthorized use.
        -   Data: Machine identifiers, user credentials.
        -   Retention: Until license expiry.
        -   Legal Basis: Contract performance (Art. 6(1)(b) GDPR);
            legitimate interest in protecting intellectual property
            (Art. 6(1)(f) GDPR).
    b.  Support:
        -   Purpose: Providing user assistance and technical support.
        -   Data: Contact information, feedback, technical data.
        -   Retention: Duration of support request.
        -   Legal Basis: Contract performance (Art. 6(1)(b) GDPR).
    c.  Software Improvement:
        -   Purpose: Enhancing software functionality.
        -   Data: Usage patterns, feedback (anonymized/aggregated).
        -   Retention: As needed for improvement purposes (up to a
            maximum of 6 months).
        -   Legal Basis: Legitimate interest in improving and optimizing
            the product (Art. 6(1)(f) GDPR).
    d.  Legal Obligation Compliance:
        -   Purpose: Adhering to legal requirements (tax laws,
            regulatory compliance).
        -   Data: Transaction records, user identifiers.
        -   Retention: As mandated by relevant laws (e.g. 10 years for
            Italian Civil Code).
        -   Legal Basis: Compliance with legal obligations (Art. 6(1)(c)
            GDPR).
    e.  Legal Defense:
        -   Purpose: Protecting Orastron’s interests in legal
            proceedings.
        -   Data: Relevant user data, transaction history.
        -   Retention: Until the conclusion of legal action, plus
            necessary post-trial period.
        -   Legal Basis: Legitimate interest in defending legal claims
            (Art. 6(1)(f) GDPR).
    f.  Information Security:
        -   Purpose: Protecting against cyber threats, unauthorized
            access.
        -   Data: Access logs, security incident reports.
        -   Retention: As long as necessary for security analysis and
            improvement (up to a maximum of 6 months).
        -   Legal Basis: Legitimate interest in ensuring network and
            information security (Art. 6(1)(f) GDPR).

3.  Data Recipients: in the context of GDPR, “Data Recipients” are
    entities or individuals that receive personal data from the Data
    Controller. These recipients can include third-party service
    providers, partners, legal authorities, or any other organization or
    person to whom the Data Controller discloses personal data as part
    of its processing activities. Data Recipients are distinct from Data
    Processors, as they may not necessarily process the data on behalf
    of the Controller, but rather receive it for their own purposes. The
    Data Controller is responsible for ensuring that any transfer of
    data to recipients adheres to GDPR requirements, including data
    protection and security standards. The identity or categories of
    Data Recipients are often disclosed in a privacy notice to maintain
    transparency with the data subjects about where and with whom their
    personal data is being shared.

    Categories:

    -   Service Providers: Entities providing IT support, hosting,
        maintenance, and cloud storage services. These providers play a
        crucial role in ensuring the functionality and availability of
        the software.
    -   Legal and Regulatory Authorities: In cases where legal
        obligations arise or for legal defense purposes, personal data
        may be disclosed to relevant authorities. This ensures
        compliance with laws and regulations, including responding to
        legal requests or court orders.
    -   Security Specialists: Professionals or firms specializing in
        cybersecurity and data protection. Their role involves analyzing
        and enhancing the security of the software and protecting
        against cyber threats.
    -   Business Consultants: This includes legal, fiscal, and other
        business advisors. These consultants may access certain data in
        the course of providing their services, such as legal advice,
        tax planning, or business strategy development.
    -   Payment Processors: For handling transactions, payment
        processors may access necessary user payment information. This
        is crucial for processing purchases, subscriptions, or other
        financial transactions related to the software.

4.  Data Subject Rights: as a user of Orastron’s Software Product, under
    the General Data Protection Regulation (GDPR), you are entitled to
    various rights regarding the processing of your personal data. These
    rights are designed to give you greater control and transparency
    over your data. It’s important to understand these rights, as they
    allow you to influence how your information is handled and protected
    by Orastron.

    Under Articles 15-22 of the GDPR, data subjects (individuals whose
    data is being processed) are granted specific rights concerning
    their personal data. Here’s a more detailed explanation:

    -   Right to Access (Art. 15 GDPR): You can request confirmation
        whether your data is being processed and, if so, access to the
        personal data. This includes information about the purposes of
        processing, the categories of data concerned, and the recipients
        or categories of recipients.
    -   Right to Rectification (Art. 16 GDPR): You have the right to
        have inaccurate personal data corrected. This also includes the
        right to have incomplete personal data completed, such as by
        providing a supplementary statement.
    -   Right to Erasure (‘Right to be Forgotten’, Art. 17 GDPR): Under
        certain conditions, you can request the deletion of your
        personal data. This is applicable particularly when the data is
        no longer necessary for the purposes it was collected or
        processed, or if you withdraw consent on which the processing is
        based.
    -   Right to Restrict Processing (Art. 18 GDPR): You have the right
        to request a restriction on the processing of your personal data
        under certain circumstances, such as if you contest the accuracy
        of the data or if the processing is unlawful.
    -   Right to Data Portability (Art. 20 GDPR): This right allows you
        to receive your personal data in a structured, commonly used,
        and machine-readable format and transmit it to another
        controller, where technically feasible. This applies when the
        processing is based on consent or a contract and is carried out
        by automated means.
    -   Right to Object (Art. 21 GDPR): You have the right to object to
        the processing of your personal data based on legitimate
        interests pursued by the controller or a third party. Upon
        objection, the controller must no longer process the personal
        data unless they demonstrate compelling legitimate grounds for
        the processing which override your interests, rights, and
        freedoms, or for the establishment, exercise, or defense of
        legal claims. This right is particularly relevant in direct
        marketing contexts, where you can object to processing for such
        purposes at any time.
    -   Right to Lodge a Complaint: You have the right to lodge a
        complaint with a supervisory authority, particularly in the
        member state of your habitual residence, place of work, or place
        of the alleged infringement, if you consider that the processing
        of your personal data infringes the GDPR. E.g. in Italy You can
        file a complain to the Garante per la protezione dei dati
        personali.

5.  Additional Information:

    -   International Data Transfers: Data may be transferred outside
        the EU under GDPR Chapter V provisions, including adequacy
        decisions like the Data Privacy Framework for the USA, ensuring
        equivalent data protection.
    -   Contact: For inquiries or requests regarding your data, contact
        Orastron srl unipersonale.
