MILA-Y PRIVACY POLICY

This Privacy Policy explains how Mila-Y and the applicable Prowinch entity ("Prowinch," "Mila-Y," "we," "us," or "our") collect, use, disclose, retain, and protect personal information when individuals visit our websites, configure or purchase Mila-Y hardware, create or use an account, use our mobile or web applications, connect equipment, request support, or otherwise interact with Mila-Y (collectively, the "Services").

The data controller for a particular interaction will normally be the Prowinch entity identified in the applicable quotation, order, subscription, account registration, or regional website:

• United States: Prowinch LLC, 2901 NW 21st Terr Miami 33140 Florida United States.
• European Economic Area/United Kingdom: Prowinch Europe S.r.l., Via Palmiro Togliatti 30/32, Senago (MI) 20030, Italy.

Where more than one Prowinch entity jointly determines the purposes and means of processing, the entities may act as joint controllers. Their respective responsibilities and a contact point for privacy requests must be confirmed before publication.

When a business customer uses Mila-Y to process personal information about its employees, contractors, operators, technicians, or other authorized users, that customer may be the controller or business and Prowinch may act as its processor or service provider. In those circumstances, the customer's privacy notice and the applicable data processing agreement also apply.

We collect information directly from users and customers; automatically from websites, apps, Mila-Y hardware and connected equipment; from authorized installers, distributors, service providers, and customer administrators; and from lawful public or commercial sources.

Where processing is based on consent, consent may be withdrawn at any time without affecting processing already performed. Where processing is based on legitimate interests, information about the balancing assessment may be requested, subject to lawful limitations.

We may use strictly necessary technologies to provide security, authentication, preferences, shopping-cart functions, and core website or app operation. With consent where required, we may also use analytics, functionality, and advertising technologies. Non-essential cookies should not be activated for EEA/UK visitors until the required consent is obtained.

A cookie-preference tool should identify the actual technologies in use, their providers, purposes, durations, and categories. Users may change their choices through [INSERT COOKIE SETTINGS LINK]. Browser controls may also limit cookies, although blocking necessary technologies may impair the Services.

We may disclose relevant information to:

• Prowinch affiliates supporting product development, sales, installation, service, security, administration, and customer support;
• hosting, cloud, communications, analytics, identity, payment, shipping, customer-support, cybersecurity, and professional service providers operating under appropriate contractual restrictions;
• the customer's account administrators, authorized users, installers, distributors, and service organizations according to permissions and instructions;
• government authorities, courts, regulators, law enforcement, or other parties when required by law or reasonably necessary to protect rights, safety, security, or property;
• a buyer, investor, lender, adviser, or successor in connection with a merger, financing, restructuring, sale, or transfer, subject to appropriate confidentiality and legal requirements; and
• other parties at the user's or customer's direction or with valid consent.

Prowinch will not characterize its practices as not involving a 'sale' or 'sharing' under U.S. state privacy laws until all advertising, analytics, and cross-context behavioral advertising practices are confirmed. If applicable, a 'Your Privacy Choices' mechanism and legally required opt-out signals must be implemented.

Mila-Y is developed and supported across the United States and Italy, and information may be processed in countries other than the country where it was collected. Where EEA, Swiss, or UK personal data are transferred internationally, we will use a valid transfer mechanism as applicable, such as an adequacy decision, the EU Standard Contractual Clauses, the UK Addendum or International Data Transfer Agreement, and supplementary safeguards. The specific mechanism and participating entities must be documented before launch.

We retain personal information only for as long as reasonably necessary for the purposes described above, including contractual, safety, warranty, product-liability, cybersecurity, accounting, tax, and legal requirements. Retention periods vary by record and jurisdiction.

Information may be retained longer when necessary to preserve evidence, resolve disputes, enforce agreements, comply with a legal hold, or protect safety. We may retain properly aggregated or de-identified information where it cannot reasonably be linked back to an individual.

We use administrative, technical, and physical safeguards designed to protect personal information, including access controls, authentication, logging, secure development practices, and vendor oversight appropriate to the risk. No system, wireless connection, cloud service, or transmission method can be guaranteed completely secure. Customers are responsible for protecting credentials, managing user permissions, securing local networks and devices, and promptly reporting suspected compromise.

Depending on location and applicable law, individuals may have rights to request access, correction, deletion, restriction, portability, objection, withdrawal of consent, and information about processing; to opt out of certain sales, sharing, targeted advertising, or profiling; and to appeal a denied request. Individuals may also lodge a complaint with a competent privacy or data protection authority.

Requests may be submitted to [INSERT PRIVACY EMAIL] or through [INSERT REQUEST FORM/LINK]. We may verify identity and authority before acting. Authorized agents may submit requests where permitted by law. We will not unlawfully discriminate against a person for exercising privacy rights.

If Prowinch processes information solely on behalf of a business customer, we may direct the requester to that customer or assist the customer as required by contract and law.

Users may unsubscribe from promotional email through the link in the message or by contacting us. Service, transactional, safety, security, warranty, or account communications may still be sent when necessary.

Mila-Y is an industrial business service and is not directed to children. Accounts and equipment-control permissions must not be issued to anyone who lacks the legal capacity, training, authorization, or minimum age required for the applicable workplace and equipment.

The Services may link to or interoperate with third-party websites, applications, networks, devices, or services. Their privacy practices are governed by their own notices. Customers should review and approve integrations before enabling them.

We may update this Policy to reflect changes in the Services, technology, law, or our practices. We will post the revised version with a new effective date and provide additional notice where required. Material changes will not be applied retroactively where prohibited.

Privacy inquiries and rights requests:

• Email: [INSERT PRIVACY EMAIL]
• United States address: 2901 NW 21st Terr Miami 33140 Florida United States
• European address: Via Palmiro Togliatti 30/32, Senago (MI) 20030, Italy.
• EU/UK representative or Data Protection Officer, if applicable: joan.carrillo@prowinch.eu