Terms and Conditions of Sale

Version 1.0 — In force from 24/04/2026

RECITALS

These Sales Terms and Conditions (hereinafter the “Sales Terms” or the “Conditions”) govern the provision of paid Experiences offered by Hosts through the digital platform Stravagando (hereinafter the “Platform”), operated by Horizon Servizi Integrati S.r.l.s. (hereinafter “Stravagando” or the “Company”), with reference to the search, booking and attendance of such Experiences.

Access to the Platform for non-transactional purposes — including use of the social, gamification and User-Generated Content (UGC) components — is governed by the separate General Terms and Conditions of Use of Stravagando (hereinafter “General T&C”), which form an integral part of the relationship with the User for such purposes. These Sales Terms apply on a supplementary and prevailing basis over the General T&C, limited to the matters governed herein.

Access to and use of the Platform for booking Experiences is conditional on full acceptance of these Sales Terms. By making a Booking, the User declares to have read, understood and accepted them. The Platform stores acceptance with date, time, IP address, user-agent and document version for evidentiary purposes, in compliance with EU Regulation 910/2014 (eIDAS), Italian Legislative Decree 82/2005 (Digital Administration Code) and Italian Legislative Decree 70/2003 (E-Commerce Decree).

These Sales Terms apply only to Users who use the Platform as a Guest/Customer. Users acting as Hosts are subject to the Host Conditions; Users joining the Referral Program are subject to the Referral Conditions. In the event of conflict between these Sales Terms, the Host Conditions and/or the Referral Conditions, the special conditions prevail, limited to their respective scope of application.

Capitalised terms have the meanings set out in Art. 1, whether used in the singular or plural. For definitions concerning the non-transactional components (Profile, Places/Atlas, POI, Achievements, etc.), reference is made to Section 2 of the General T&C.

The Appendices A and B applicable based on the User’s country of residence, the Privacy Policy, the Cookie Policy, the Cancellation Policies specific to each Listing, the operational Guidelines published on the Platform, and the General T&C for non-transactional matters all form an integral part of this Agreement. In the event of conflict, the following order of precedence applies: the applicable Appendices, these Sales Terms, the Cancellation Policies, the Privacy Policy and Cookie Policy, the General T&C (limited to the matters they govern), the operational Guidelines.

ART. 1 — DEFINITIONS

For the purposes of these Sales Terms, the following terms have the meanings indicated below.

1.1 “Platform”: the website accessible at the main address stravagando.com and its subdomains, the mobile application for iOS and Android, the APIs exposed to authorised partners and any other digital medium operated by Stravagando through which the Services are provided.

1.2 “Stravagando” or “Company”: Horizon Servizi Integrati S.r.l.s., owner and operator of the Platform, with registered office at Via L’Aquila 22, 65122 Pescara (PE), Italy.

1.3 “User”: any natural person who accesses the Platform, with or without registration.

1.4 “Account”: the personal account created by the User on the Platform in accordance with the procedures set out in Section 4 of the General T&C, identified by unique credentials.

1.5 “Guest” or “Customer”: the User registered on the Platform who uses the Services to search, book and/or attend Experiences offered by Hosts. The Customer must be of full legal age and have full legal capacity to act pursuant to art. 2 of the Italian Civil Code.

1.6 “Participant”: the natural person who actually attends the booked Experience. The Participant may or may not coincide with the Customer who made the Booking.

1.7 “Beneficiary”: the person, other than the Customer, who will use the Experience or Voucher purchased by the Customer (e.g. in the case of a gift Experience).

1.8 “Parent or Legal Guardian”: the person holding parental responsibility or legal guardianship over a minor Participant, pursuant to arts. 316 et seq. of the Italian Civil Code.

1.9 “Host”: the natural or legal person registered on the Platform who publishes and offers Experiences to Guests, pursuant to the Host Conditions.

1.10 “Experience”: any experiential activity (tour, laboratory, workshop, tasting, excursion, indoor or outdoor experience, cultural, sporting or recreational event, activity with or for animals, food and wine experience, educational activity) offered by the Host to Guests through the Platform.

1.11 “Listing” or “Experience Detail Page”: the page published by the Host on the Platform containing the description of the Experience, the participation conditions, the Price, availability dates, images, the Cancellation Policy and any other relevant information.

1.12 “Booking”: a Direct Booking or a Request Booking as defined in Art. 7.

1.13 “Direct Booking”: a Booking made by the Customer with immediate confirmation, without the need for prior approval by the Host.

1.14 “Request Booking” or “Booking Request”: a Booking request made by the Customer to a Host, requiring the latter’s explicit acceptance within a maximum of 48 hours from receipt, after which the request automatically lapses.

1.15 “Confirmed Booking”: a finalised Booking, whether by Direct Booking or Request Booking accepted by the Host, communicated to the Customer through the Booking Notification.

1.16 “Booking Notification”: the email communication containing the summary of the Confirmed Booking, sent to the Customer at the registered email address.

1.17 “Alternative Proposal”: the proposal for an Experience on alternative date, time or place made by the Host or by Stravagando to the Customer in the event of supervening unavailability or force majeure (Art. 9).

1.18 “Cancellation Policy”: the set of rules governing the cancellation of Bookings and any refunds, chosen by the Host from the available options (Art. 9.1) and indicated in the Listing.

1.19 “No-Show”: the failure of the Customer or Participant to attend the meeting point on the agreed day and time for the Experience, without prior cancellation notice, with a delay exceeding 15 minutes from the agreed time (unless otherwise specified in the Listing for Experiences with fixed departure times).

1.20 “Price”: the amount payable for participation in the Experience, set by the Host and indicated in the Listing, inclusive of VAT where applicable.

1.21 “Service Fee”: the amount, if any, charged by Stravagando to the Customer for the intermediation Services provided by the Platform, calculated as a percentage of the Price or as a fixed amount and indicated separately before confirmation of the Booking.

1.22 “Tourist Tax”: the local accommodation tax possibly due for Experiences that include overnight stays, collected by the Platform on behalf of the Host and paid by the Host to the competent Municipality.

1.23 “Total Amount”: the sum of the Price of the Experience, any Service Fee and any Tourist Tax, corresponding to the total amount charged to the Customer at the time of Booking.

1.24 “Gift Card”: a token of legitimacy pursuant to art. 2002 of the Italian Civil Code, of the multi-use type, with free or pre-defined face value, redeemable by the Customer or the Beneficiary for the purchase of one or more Experiences of their choice on the Platform. Governed by Art. 8.D.1.

1.25 “Gift Voucher”: a token of legitimacy of the single-use type, tied to a specific Experience (e.g. gift of a particular cooking class), possibly with an “open date” within the validity window but bound to the Experience identified at the time of purchase. Governed by Art. 8.D.2.

1.26 “Voucher”: a generic term encompassing both Gift Cards and Gift Vouchers as defined above. Governed by Art. 8.D.

1.27 “Promotional Code” or “Discount Code”: the alphanumeric code distributed by Stravagando granting the Customer a discount on the Price or on the Total Amount, according to the specific terms communicated upon distribution. This also includes discount codes assigned as Level Perks by the gamification system described in Section 9 of the General T&C.

1.28 “Referral Code”: the unique alphanumeric code usable by the User during registration as part of the Referral Program, governed by the Referral Conditions.

1.29 “Services”: the set of services provided by Stravagando to Users, including provision of the Platform, search and consultation of Listings, the Booking system, payment processing, management of refunds and cancellations on behalf of Hosts, the Experience review system and Customer Service.

1.30 “Stripe”: Stripe Payments Europe Ltd and its affiliates, the provider of payment processing services used by the Platform in Stripe Connect mode (destination charges configuration with application fee and on_behalf_of for payments linked to Experiences and Experience-specific Gift Vouchers; platform charge configuration for multi-use Gift Cards, with subsequent transfer to the Host upon redeem).

1.31 “Content”: text, photographs, videos, reviews, ratings, comments and any other material posted by Users on the Platform in connection with the marketplace sales relationship. For UGC Content related to the social components, gamification and Places (POI) catalogue, reference is made to Section 6 of the General T&C.

1.32 “Force Majeure”: unforeseeable, unavoidable events independent of the parties’ will that prevent or render significantly more burdensome the performance of contractual obligations, as detailed in Art. 17.A.

1.33 “Mandatory Provisions”: provisions of the Italian Consumer Code (Italian Legislative Decree 206/2005), the Italian Civil Code and other mandatory consumer protection laws that cannot be derogated from by agreement between the parties.

1.34 “National Identification Code (CIN)”: the unique identification code introduced by the Italian Ministry of Tourism for accommodation facilities and short-term rentals pursuant to Italian Law 191/2023, applicable to Experiences that include overnight stays in accommodation facilities or tourist rentals managed by the Host.

1.35 “Safety”: the set of organisational, procedural and material measures adopted for the prevention and management of risks related to the provision of Experiences, in compliance with applicable law (including Italian Legislative Decree 81/2008 on occupational health and safety where applicable to the Host’s activity).

1.36 “Chargeback”: the procedure initiated by the Customer with its payment institution to dispute a charge on the card used for the Booking, pursuant to the rules of the Visa, Mastercard, American Express and similar payment networks.

1.37 “Guidelines”: the operational Guidelines published by Stravagando on the Platform, detailing service standards, Customer Service operational timing, exact Cancellation Policy percentages, complaint processes and other operational parameters not forming the subject matter of these Conditions.

1.38 “POI” (Point of Interest): a term introduced in Section 2 of the General T&C, referenced here where Experiences are associated with places in the Platform’s Places catalogue.

ART. 2 — SCOPE OF APPLICATION AND ACCEPTANCE

2.A — Personal and geographic scope

2.1 Addressees. These Sales Terms apply to all Users who access or use the Platform as Guests, for the purpose of booking paid Experiences, regardless of the access channel (website, mobile app, partner link, third-party embed, API).

2.2 Capacity to act and Customer status. The use of marketplace Services is reserved to adult natural persons with full legal capacity to act pursuant to art. 2 of the Italian Civil Code. Full legal age is a requirement for the qualification of Customer and for assuming the payment obligations arising from the Booking.

Access to the Platform for non-transactional purposes (registration, profile, social, gamification, contribution to the Places catalogue) is governed by the General T&C, which set a minimum age of 14 years (or the digital consent age set by the national law of residence in other EU/EEA Member States). A User aged between 14 and 18 may therefore hold a Stravagando Account but may not make Bookings of paid Experiences.

Minors may attend Experiences exclusively as Participants accompanied by at least one responsible adult, who assumes the qualification of Customer and is responsible for all related effects pursuant to Art. 7.6.

2.3 Geographic scope. The Platform is available in all countries where applicable law does not prohibit its provision. Users residing in States subject to international sanctions (UN, EU, OFAC) or in countries subject to total embargo (North Korea, Iran, Syria, Crimea, Donetsk, Luhansk, save for specific exemptions) may not use the Platform. Stravagando reserves the right to restrict access to the Services in certain countries for regulatory, technical or commercial reasons.

As of today, Stravagando’s commercial activity is concentrated in EU/EEA territory. The clauses specific to U.S. residents set out in Appendix B are designed in view of a future formal opening to the U.S. market.

2.4 Exclusion of professional use. Use of the Services as a Guest is reserved to non-professional purposes, unless the Customer is a legal entity or professional acquiring the Experience for purposes related to its activity (e.g. corporate team building, corporate events). In such cases, the consumer protections under Arts. 11 and A.5 do not apply.

2.B — Acceptance and conclusion

2.5 Click-through acceptance. Acceptance of these Sales Terms takes place by clicking the relevant checkbox (“I accept the Sales Terms”) at the time of Booking. For registered Users, acceptance of the General T&C and the Privacy Policy has already been obtained upon registration. Acceptance is stored with date, time, document version, IP address, user-agent and technical snapshot and is enforceable in court pursuant to EU Regulation 910/2014 (eIDAS) and art. 20 of Italian Legislative Decree 82/2005 (Digital Administration Code).

2.6 Versioned re-acceptance. Upon each substantial update of the Sales Terms, the registered User is required to re-accept the updated version. Failure to accept within 30 days from notice of a new version entails the suspension of certain features (in particular the ability to make new Bookings) until acceptance, without prejudice to the validity of already-confirmed Bookings.

2.7 Language of acceptance. The Sales Terms are presented to the User in Italian. The Platform may provide translations into other languages for informational purposes; in the event of interpretation discrepancies, the Italian text prevails, save as provided in Appendix B for U.S. residents.

2.8 Confirmation of acceptance. Following acceptance, the User receives at the registered email address a copy of the accepted Sales Terms and accompanying documents (Privacy Policy, Cookie Policy), pursuant to art. 51, paragraph 7, of the Italian Consumer Code.

ART. 3 — ROLE OF STRAVAGANDO AND NATURE OF THE SERVICE

3.A — Digital intermediary

3.1 Mere intermediation. Stravagando operates exclusively as a digital intermediation platform between Hosts and Guests. The Platform facilitates the matching of Guests’ demand for Experiences with Hosts’ supply of Experiences, providing the necessary technological tools (search engine, Booking system, payment management, communications, reviews, Customer Service).

3.2 Direct Host-Customer contract. The contract for the provision of the Experience is concluded directly between the Host and the Customer and is finalised upon the Customer’s receipt of the Booking Notification. Stravagando is a third party to such contractual relationship and, as such, extraneous to it, with consequent exclusion of liability for the Host’s breach in the provision of the Experience, without prejudice to any mediation intervention pursuant to Art. 12.

3.3 Beneficiaries of the contract. The Host-Customer contract may provide for the designation of Beneficiaries (persons other than the Customer who will enjoy the Experience). Contracts in favour of third parties are governed by arts. 1411-1413 of the Italian Civil Code; refusal by the Beneficiary or designation of a new Beneficiary follow the rules of Art. 7.D.

3.B — Qualifying exclusions

3.4 Stravagando is not. Stravagando is in no case the supplier, organiser or provider of the Experiences; it is not a travel agency, tour operator or organiser of travel packages pursuant to Italian Legislative Decree 79/2011 (Tourism Code) as amended by Italian Legislative Decree 62/2018 implementing Directive (EU) 2015/2302; it is not the employer, principal (outside of the collection mandate referred to in 3.7), client or person responsible for the Hosts; it is not the guarantor of the quality, safety, lawfulness or conformity of the Experiences; it is not a payment institution under Italian Legislative Decree 11/2010 (cashier activity is entirely delegated to Stripe Payments Europe Ltd, a regulated entity).

3.5 Exclusion of “travel package” qualification. Individual Experiences booked through the Platform constitute single tourist services pursuant to Italian Legislative Decree 79/2011 and do not constitute travel packages, as the Platform does not automatically combine multiple types of tourist services (transport + accommodation + ancillary tourist services) for the same trip or holiday. The single Experience, even if it includes overnight stay, does not in itself constitute a travel package unless the Platform itself assembles the combination of several distinct services for the same trip.

3.6 Exclusion of “linked travel arrangement” qualification. Nor does the Platform constitute a “linked travel arrangement” pursuant to art. 33(1)(n) of Italian Legislative Decree 79/2011, since it does not facilitate, through a linked booking process, the conclusion of separate contracts with individual suppliers of tourist services according to the modalities described in the regulation.

3.C — Collection mandate and Stripe Connect model

3.7 Collection in the name and on behalf of the Host. Stravagando intervenes in the payment collection phase from the Customer acting in the name and on behalf of the Host pursuant to art. 1705 of the Italian Civil Code (mandate without representation limited to the collection of the price). Such intervention is functional to the intermediation Service and does not alter the nature of the relationship between Customer and Host. Payment of the Price by the Customer to Stravagando has discharging effect towards the Host. Any refund of the Price, where due, is made by Stravagando in the name and on behalf of the Host. For the Service Fee, where applicable, Stravagando collects in its own name.

3.7-bis Stripe Connect technical model. Payments are processed through the Stripe Connect model with the following technical configurations:

• for Experience Bookings and for Experience-specific Gift Vouchers (Art. 8.D.2): destination charges configuration with application fee and on_behalf_of, where the Host is qualified as Merchant of Record of the transaction and Stravagando retains its Service Fee;

• for multi-use Gift Cards (Art. 8.D.1): platform charge configuration — funds are initially acquired by the Platform and subsequently transferred to the Host at the time of redeem of the Gift Card on a specific Experience, consistent with the fungible nature of the Gift Card, which cannot be immediately attributed to a specific Host.

Payouts to Hosts operate in manual mode controlled by the Platform, in order to manage any chargebacks, disputes and clawbacks without exposure to recovery risks against an already-paid Host.

3.D — Customer Service and ranking

3.8 First-line Customer Service. Stravagando provides a first-line assistance service to Customers for issues relating to the use of the Platform, Bookings and payments. For issues relating to the actual provision of the Experience (quality, safety, conformity to the Listing description), the Host remains solely liable, without prejudice to any Stravagando mediation pursuant to Art. 12.

3.9 Ranking transparency (P2B EU Reg. 2019/1150). Listings are ordered in the Platform’s search results based on an algorithm that combines geographic relevance, Listing completeness, price, review quality, Host KPIs, conversion rate, recency and other commercial factors. The description of the main ranking parameters is published in the legal section of the Platform in compliance with art. 5 of EU Reg. 2019/1150 and updated upon any substantial change to the algorithm. Stravagando undertakes not to discriminate Listings on geographic, ethnic, religious, gender, sexual orientation or political opinion grounds, without prejudice to the application of objective technical and commercial criteria.

3.10 Sponsorship and promotion. Some Listings may appear in sponsored or featured positions following payment by the Host. Such Listings are clearly identified as promotional in compliance with art. 22 of EU Reg. 2022/2065 (Digital Services Act).

ART. 4 — USER ACCOUNT AND MARKETPLACE SPECIFICITIES

4.1 Reference to the General T&C. Registration, email verification, Account security (including passwords, 2FA, re-authentication for sensitive operations), credential management, access notifications, the prohibition of multiple Accounts per person, the non-transferability of the Account and the discipline of succession mortis causa are entirely governed by Section 4 of the General T&C, which is hereby recalled.

These Sales Terms govern only the marketplace specificities set out in the following paragraphs.

4.2 Tax and billing data. At the time of Booking or thereafter, the Customer who requests electronic invoicing provides the Platform with its tax data (Tax Code, VAT number if any, SDI recipient code, billing address). The truthfulness of the data is the Customer’s responsibility. The data is transmitted to the Host for the issuance of the invoice pursuant to Art. 8.17.

4.3 Enhanced KYC in case of suspected fraud. If anti-fraud measures under Art. 18 are activated, Stravagando may request supplementary documentation from the Customer for identity verification (enhanced KYC), in particular for high-value Bookings or anomalous purchase patterns. Failure to cooperate entails the precautionary suspension of refunds and the ability to make new Bookings until clarification.

4.4 Multiple Accounts for benefit accumulation. The general prohibition on multiple Accounts under Section 3 of the General T&C remains. In the marketplace context, the creation of multiple Accounts for the following purposes constitutes an aggravated violation:

• unduly accumulating Discount Codes, Referral Codes or promotional campaign benefits;

• circumventing per-user limits on codes, coupons or loyalty programs;

• circumventing suspensions applied to an Account in connection with violations of these Conditions.

The violation entails the immediate closure of all linked Accounts and clawback of unduly received benefits, without prejudice to Stravagando’s right to retain funds present in closed Accounts to cover damages, sanctions or matured credits.

4.5 Precautionary suspension for marketplace anti-fraud reasons. Consistent with Section 13 of the General T&C, Stravagando may temporarily suspend the Account in case of suspected marketplace fraud (attempted abusive Chargebacks, card testing, suspected identity theft). The suspension is communicated to the User as soon as possible and in any case no later than 24 hours after activation of the measure, except where communication is precluded by orders of the authorities.

ART. 5 — USE OF THE PLATFORM

5.A — Personal and non-commercial use

5.1 Purpose of use. The User undertakes to use the Platform solely for personal and non-commercial purposes, unless registered as a Host pursuant to the Host Conditions or as a corporate operator for corporate Experiences according to specific agreements. Any use for the purpose of resale of Bookings, unauthorised intermediation, competition with the Platform or systematic data extraction is prohibited.

5.2 Regulatory compliance. The User undertakes to use the Platform in compliance with applicable law, public morals, third-party rights, the guidelines published by the Platform and the rules of the payment networks (Visa Core Rules, Mastercard Rules, etc.) to the extent applicable.

5.B — Specific prohibitions

5.3 Prohibited practices. The User is expressly prohibited from:

• accessing the Platform with automated tools (bots, crawlers, scrapers, spiders), save only for general-purpose search engines for standard indexing;

• systematically extracting data from the Platform, Listings or reviews through scraping or data mining techniques, including for market analysis, dynamic pricing or competitive intelligence purposes;

• performing reverse engineering, decompilation, reverse engineering of the Platform’s software or mobile apps, outside the limits permitted by art. 64-quater of Italian Law 633/1941 (Copyright Law);

• circumventing security, authentication, rate-limiting, CAPTCHA or anti-fraud systems;

• transmitting viruses, malware, ransomware, harmful code or performing actions that may compromise the stability or security of the Platform or the devices of other Users;

• impersonating other Users, the Hosts or Stravagando, including through confusable domains or profiles;

• publishing unlawful, defamatory, offensive, discriminatory content or content infringing third-party privacy or rights;

• carrying out credential stuffing, account takeover, card testing or other forms of computer fraud;

• using the Platform for money-laundering, terrorist financing or other activities prohibited by Italian Legislative Decree 231/2007 and subsequent amendments.

5.4 Disintermediation. The User shall refrain from contacting the Host outside the Platform to conclude transactions that circumvent Stravagando’s intermediation, without prejudice to direct contact after the Experience for non-commercial purposes (review, thanks, exchange of personal experiences).

5.5 Spam and unsolicited communications. The User shall not use the Platform’s communication channels (internal messaging, review system, Q&A) to send unsolicited commercial communications, spam, chain letters or promotions to persons who have not given consent.

5.C — Corrective measures

5.6 Sanctioning system. The progressive sanctioning system applicable to all T&C violations (warning, restricted, suspended, banned), the right to complaint, the procedures of automated moderation and DSA complaint are entirely governed by Sections 13 and 12-bis of the General T&C, which are hereby recalled.

The following violations, being specifically connected to the sales relationship, entail application of the above sanctioning measures with particular severity:

• abusive activation of Chargebacks (Art. 8.F);

• fraudulent use of Discount Codes, Referral Codes or promotional programs (Art. 8.9);

• creation of multiple Accounts for benefit accumulation (Art. 4.4);

• circumvention of Cancellation Policies through simulated conduct;

• disintermediation (Art. 5.4) if repeated.

In addition to the measures under the General T&C, Stravagando may:

• perform clawback of unduly received benefits;

• withhold funds on the Host’s Payout to cover matured credits against the Host (limited to the Host relationship);

• seek compensation for any damages suffered, including through judicial proceedings;

• report the User to industry-shared anti-fraud blacklists within GDPR limits.

5.7 Right to be heard. Before applying suspensions or revocations, Stravagando notifies the User of the formal contestation, assigning 15 days to submit observations or supplementary documentation, save for cases of serious violation or legal obligation requiring immediate intervention. The complete complaint procedure is the one set out in Sections 12-bis and 13 of the General T&C.

ART. 6 — SEARCH, LISTINGS AND PRICES

6.A — Search and display

6.1 Search tools. The Platform makes available to Users search tools by category, geography, date, price, duration, language of delivery, Experience characteristics (accessibility, indoor/outdoor, difficulty level, family-friendly, pet-friendly). Results are ordered according to the ranking algorithm referred to in 3.9.

6.2 Listings. Listings are published and managed by the Host under its sole responsibility. The information contained in the Listings (description, images, prices, availability, requirements, restrictions, highlights) is provided by the Host, and Stravagando does not guarantee its accuracy, completeness or currency, without prejudice to basic moderation performed at the time of publication.

6.3 Host verification. Stravagando carries out preliminary verification of the Host’s identity during onboarding (KYC via Stripe Connect, verification of tax code, VAT number and — where applicable — professional licences and CIN for Experiences with overnight stay). Such verification does not constitute a guarantee of quality, safety or conformity of the Experiences, with the Host’s sole liability remaining unchanged.

6.B — Prices, transparency and dynamic pricing

6.4 Price and Total Amount. The Price of the Experience is set by the Host and indicated in the Listing. Prior to confirmation of the Booking, the User views the Total Amount in a transparent manner, with breakdown of Price, any Service Fee, any Tourist Tax for Experiences with overnight stay and any discounts applied. The Total Amount shown at checkout is the amount actually charged.

6.5 VAT inclusiveness. The Price indicated in the Listing is inclusive of VAT where applicable, pursuant to art. 18 of the Italian Consumer Code. VAT is managed autonomously by the Host according to its own tax regime; the Customer has no direct tax relationship with Stravagando in respect of VAT on the Experience, except for the Service Fee where applicable.

6.6 Price changes and dynamic pricing. Any Price changes by the Host take effect only for Bookings concluded after the change. Confirmed Bookings remain subject to the Price in force at the date of confirmation. The Platform may apply dynamic pricing mechanisms (yield management) on the Service Fee based on seasonality, demand, Booking lead time and other commercial factors; the Fee applied to the individual Booking is the one shown at checkout and is not subject to subsequent changes.

6.7 Best Price. Stravagando undertakes to present the most updated Price communicated by the Host to the Platform; however, it does not guarantee that such Price is the lowest available in absolute terms, as the Host may sell its Experiences through other channels or directly. The Customer is invited to check independently for any different prices, without prejudice to the advantage of booking through the Platform in terms of protections, Customer Service and payment management.

6.C — Tourist Tax and CIN (Experiences with overnight stay)

6.8 Delegated collection of the Tourist Tax. For Experiences that include overnight stay, the Host may delegate to the Platform the collection of the municipal Tourist Tax, calculated based on the number of Participants, the nights of stay and the rate set by the Municipality of provision. The Tax is indicated separately in the Total Amount at checkout.

6.9 Payment to the Municipality. The Tourist Tax collected by the Platform is transferred to the Host through Payout, and the Host is solely responsible for payment to the competent Municipality within the deadlines set out in the municipal regulation. Stravagando assumes no joint liability for non-payment by the Host.

6.10 National Identification Code. For Experiences with overnight stay provided in accommodation facilities or tourist rentals subject to Italian Law 191/2023, the Host is required to possess and indicate in the Listing the National Identification Code (CIN).

Stravagando makes available in the Listing the CIN communicated by the Host and verifies only its formal compliance with the pattern established by the Italian Ministry of Tourism. In the absence of public APIs to query the central register, Stravagando does not undertake any obligation to verify the substantive validity, currency or correct ownership of the CIN. The truthfulness of the code, its ownership by the declaring Host and its correspondence with the facility actually used for the overnight stay remain the sole responsibility of the Host.

ART. 7 — BOOKING PROCESS

7.A — Booking modalities

7.1 Supported types. The Platform supports two Booking modalities, chosen by the Host at the time of Listing publication:

• Direct Booking (instant booking): immediate confirmation upon payment, without the need for prior approval by the Host;

• Request Booking: requires explicit acceptance by the Host within 48 hours, after which the request automatically lapses.

7.2 Payment pre-authorisation (Request Booking). For Request Bookings, at the time of the request Stravagando performs a pre-authorisation on the Customer’s payment method for the Total Amount. The pre-authorisation temporarily blocks the amount without charging it. The final charge occurs only upon the Host’s acceptance. In case of refusal or lapse of the request, the pre-authorisation is automatically released within the technical times of the payment institution (typically 5-7 business days for credit cards, 1-3 days for wallets).

7.3 Real-time availability. Experience availability is updated by the Host in real time or through third-party channel managers. Stravagando does not guarantee the absence of overlaps or synchronisation errors; in such cases, the provisions of Art. 7.D apply.

7.B — Contract conclusion

7.4 Time of conclusion. The contract for the provision of the Experience is concluded between Host and Customer at the moment the Customer receives the Booking Notification at the registered email address. The Notification constitutes confirmation of Confirmed Booking.

7.5 Content of the Notification. The Booking Notification contains:

• the unique booking number;

• date, time and location of the Experience, with geographic coordinates or map link;

• number and details of the Participants (anonymised where requested);

• summary of the Total Amount paid, with breakdown of Price, Service Fee, Tourist Tax and discounts applied;

• link to the Booking summary in the Account;

• Host contact details (name, contacts for emergencies in the 24 hours preceding the Experience);

• any operational instructions from the Host (detailed meeting point, required equipment, access code);

• applicable Cancellation Policy;

• form for exercising the right of withdrawal where applicable (in particular for multi-use Gift Cards, pursuant to Art. A.2.4);

• link to these Conditions and to the Privacy Policy.

7.C — Customer, Participant and Beneficiary

7.6 Distinction and responsibility. The Customer is the person who makes the Booking and the payment. The Participant is the natural person who will actually attend the Experience. The Beneficiary is the person, other than the Customer, to whom the Experience or Voucher is destined (e.g. gift).

7.7 Customer’s duties to Participants and Beneficiaries. The Customer is responsible for communicating to the Participant and/or Beneficiary the Booking conditions, the Host’s instructions, restrictions and any other relevant information. The Customer warrants that the Participant and/or Beneficiary is of full legal age or, if a minor, is accompanied by a Parent or Legal Guardian who assumes responsibility.

7.8 Experiences involving minors. For minor Participants:

• the Booking must be made by a Parent or Legal Guardian, who declares parental responsibility pursuant to arts. 316 et seq. of the Italian Civil Code;

• the Parent/Legal Guardian gives informed consent to the minor’s participation in the Experience, assessing suitability in light of age, maturity and the characteristics of the activity;

• for Experiences with medium or high risk level (sports, mountain hikes, water activities), the Parent/Guardian may be required to sign a specific release (parental waiver) prepared by the Host, without prejudice to the inderogability of minor protection rules;

• the presence of the Parent/Guardian or a delegated adult reference person is mandatory during the Experience, unless otherwise indicated in the Listing for Experiences explicitly designed for kids with qualified Host personnel;

• the personal data of the minor are processed in compliance with art. 8 GDPR and the guidelines of the Italian Data Protection Authority.

7.9 Transferability. Unless otherwise indicated in the Listing or with the Host’s consent, Bookings are nominative and the transfer of the Participant to another person requires the Host’s consent, obtainable through the Platform’s messaging with at least 48 hours notice before the start of the Experience. For Vouchers, Art. 8.D applies.

7.D — Errors, unavailability and Alternative Proposal

7.10 Manifest publication errors. In case of manifest publication errors of the Listing (e.g. obviously incorrect price due to typo or malfunction, description that does not correspond to the Experience actually offered, manifestly unrelated photos), Stravagando reserves the right, in the name and on behalf of the Host, to cancel the Booking and fully refund the Customer, without prejudice to the Customer’s right to request confirmation under the actual conditions if the Host agrees. A “manifest error” is considered a price deviation greater than 30% compared to the average of comparable Experiences, save proof to the contrary.

7.11 Supervening unavailability. If, after confirmation of the Booking, supervening unavailability of the Experience occurs on the booked date and place (Force Majeure, Host unavailability, incompatible weather conditions, unavailability of the location, overbooking due to channel manager mismatch), the Host or Stravagando may propose to the Customer an Alternative Proposal on different date, time or place, or a full refund. The Customer is free to accept the Alternative Proposal or opt for a refund, communicating the choice within 48 hours from receipt of the proposal; in the absence of a reply, full refund is presumed.

7.12 Change of meeting point. The Host may change the meeting point up to 24 hours before the start of the Experience, provided that the new point is reachable from the original meeting point within 15 minutes on foot or by public transport. Changes beyond this threshold trigger the application of the Alternative Proposal discipline.

7.13 Re-booking after cancellation. A Customer who has been subject to a cancellation by the Host (Art. 9.6) may make a new Booking of a similar Experience on the Platform benefiting — where available — from a compensation voucher of equal amount or a discount on the Total Amount, according to the conditions published in the Guidelines.

ART. 8 — PAYMENTS, FEES AND VOUCHERS

8.A — Payment methods

8.1 Supported instruments. Payments are processed exclusively through Stripe Connect. The main methods supported by Stripe are accepted:

• credit/debit cards Visa, Mastercard, American Express, Discover, JCB;

• digital wallets Apple Pay, Google Pay;

• SEPA Direct Debit for EU residents;

• Bancontact, iDEAL, Giropay, Sofort and other local methods where available;

• SEPA Instant transfer for amounts above certain thresholds.

The up-to-date list of available methods is visible at checkout based on the Customer’s residence and the amount of the Booking.

8.2 PCI-DSS security. Stravagando does not store the User’s payment card data, which is processed directly by Stripe in compliance with PCI-DSS Level 1 standards. The Platform receives only a technical token for subsequent processing (e.g. refunds). Payments are subject to Strong Customer Authentication (SCA) pursuant to EU Directive 2015/2366 (PSD2), via 3D Secure 2.0.

8.3 Anti-fraud checks. Stripe applies automatic anti-fraud filters on payments (Stripe Radar). Stravagando integrates further security checks based on detected risk (documentary verification, cardholder verification, velocity checks). Payments rejected for security reasons do not finalise the Booking and do not result in a charge; the Customer may attempt a new payment with an alternative method.

8.B — Service Fee

8.4 Service Fee. The Service Fee, where applied, is transparently indicated at checkout before confirmation of the Booking. The Fee covers the Services rendered to the Customer (search engine, secure Booking system, payment management, Customer Service, mediation, escrow for refunds). Promotional campaigns may provide for the zeroing or reduction of the Service Fee for categories of Experiences, periods or users.

8.5 Non-refundable nature of the Fee. Unless otherwise indicated and without prejudice to mandatory consumer protections (in particular for cancellation by the Host or Force Majeure), the Service Fee is non-refundable in case of cancellation by the Customer not falling within the cases of full refund.

8.C — Discount codes, promotions and referral

8.6 Promotional Codes. Discount Codes distributed by Stravagando may be applied at checkout according to the specific terms of the Code (temporal validity, minimum amount, Experience category, per-user limits, geographic exclusions). The discount is applied to the Total Amount or to the Price, as specified. Codes are nominative, not cumulable with each other unless otherwise indicated and non-monetisable.

Codes from Level Perks (gamification). Discount codes assigned as Level Perks by the gamification system described in Section 9 of the General T&C are subject to these provisions on Discount Codes, in addition to the specific assignment and duration rules indicated in the Technical Service Specifications. Their availability is conditioned on the activation of the corresponding perk by Stravagando, which may be modified or suspended in accordance with paragraph 9.3 of the General T&C.

8.7 Referral Codes (welcome discount). Users may benefit from welcome discounts applied through another User’s Referral Code. The use of the Referral Code is governed by the Referral Conditions and entails the recognition of a commission to the Referrer pursuant to the rules of such program, at no additional cost to the Customer.

8.8 Loyalty discounts. Stravagando may grant the Client, at its own discretion and at its own expense, promotional discounts («Loyalty Discounts») in the form of Discount Codes applicable to Bookings of Experiences on the marketplace. Unlocking is subject to meeting combined conditions tied to the Client’s activity on the platform — by way of example, reaching a given Level of the gamification system described in the General T&C Sec. 9 and/or having attended a minimum number of Experiences with a check-in validated by the Host — according to the parameters published from time to time in the Service Technical Specifications or in the help section. Unlocking is definitive: once earned, the Loyalty Discount remains valid according to its own terms even if the unlocking conditions are no longer met. Monetary cashback, accruable points, user wallet or points→cash conversion systems are not currently operational and remain indicated as features that the platform may introduce in the future, whose conditions will be communicated upon any activation by means of an update to these Conditions.

8.8-bis Conditions of use of Loyalty Discounts. Unless otherwise stated in the individual discount, Loyalty Discounts: (a) are personal, registered and non-transferable, and may be used only once; (b) have an expiry indicated at the time of unlocking, after which they can no longer be used; (c) cannot be combined with other Discount Codes on the same Booking (the discount most favourable to the Client applies); (d) have no monetary value and are not convertible into cash nor refundable; (e) reduce solely the amount payable by the Client and are borne entirely by Stravagando, which absorbs them from its own Service Fee: the amount due to the Host for the Experience is not reduced in any way. In the event of cancellation or refund of the Booking, the applied discount does not entitle the Client to any cash credit; Stravagando may, at its discretion, restore the availability of the unused discount. Stravagando may modify, suspend or discontinue the Loyalty Discounts programme at any time, without prejudice to discounts already unlocked and not yet expired. Fraudulent or abusive use of Loyalty Discounts is subject to the measures set out in paragraph 8.9.

8.9 Prohibition of abuse. Fraudulent or abusive use of Promotional Codes, Referral Codes or Level Perks programs (e.g. multiple accounts to accumulate benefits, third-party kickback, simulation of subsequently cancelled Bookings, cookie stuffing) constitutes a violation and entitles Stravagando to clawback the benefits, apply the corrective measures referred to in Art. 5.6 and seek compensation for damages.

8.D — Vouchers and Gift Cards

The Platform sells two distinct types of tokens of legitimacy pursuant to art. 2002 of the Italian Civil Code, with differentiated regimes.

8.D.1 Multi-use Gift Cards

8.10 Legal nature and operation. Gift Cards are tokens of legitimacy of the multi-use type with free or pre-defined face value (presets of amounts from which the Customer chooses upon purchase). They are not linked to a specific Experience, to a specific Host or to a fixed date: the Beneficiary is free to spend them, even in several transactions, for the purchase of any Experience available on the Platform, until the face value is exhausted.

From a Stripe Connect technical perspective, Gift Cards follow the platform charge model (Art. 3.7-bis): the amount is acquired by the Platform upon purchase and subsequently transferred to the individual Host at the time of redeem of the Gift Card on one of its Experiences.

8.11 Validity. Gift Cards have a pre-defined validity communicated at the time of purchase, in any case no less than 24 months from the date of issuance, save for different conditions of specific campaigns and without prejudice to applicable mandatory protections. Once the term has elapsed, the unused residual value is extinguished, save for mandatory protections provided by applicable law.

8.12 Transferability and gift function. Gift Cards are transferable to the Beneficiary indicated by the Customer at the time of purchase, or transferable by the Customer to third parties without need for prior authorisation. The Platform offers a digital gift function that allows the Customer to personalise the Gift Card with message, image and to schedule its delivery on a chosen date. The Platform is not liable for loss, theft or unauthorised use of the Gift Card code communicated to third parties by the Customer, except where theft is reported before use and within the limits of the law.

8.13 Right of withdrawal (14 days). Gift Cards, being multi-use tokens of legitimacy not linked to a specific Experience with a fixed date, are subject to the consumer right of withdrawal of 14 days pursuant to art. 52 of the Italian Consumer Code. The withdrawal may be exercised within 14 days from the date of purchase, provided that the Gift Card has not been used in whole or in part. The refund is made on the same payment method, within 14 days of receipt of the withdrawal notice. Reference is made to Art. A.2.4 for the model withdrawal form and procedural requirements.

8.D.2 Experience-specific Gift Vouchers

8.14 Legal nature and operation. Gift Vouchers are tokens of legitimacy of the single-use type, linked to a specific Experience identified by the Customer at the time of purchase. They may include an “open date”, allowing the Beneficiary to autonomously choose the date of use within the validity window of the Voucher, but they remain bound to the Experience selected at purchase. They include a contractual snapshot of the Experience (description, conditions, Cancellation Policy) at the time of their generation.

From a Stripe Connect technical perspective, Gift Vouchers follow the destination charge model with application fee and on_behalf_of (Art. 3.7-bis), with immediate transfer of the net amount to the Host of the specific booked Experience, consistent with the qualification of the Host as Merchant of Record of the transaction.

8.15 Applicable discipline. The Gift Voucher, as it is linked to a specific Experience, is subject to the Cancellation Policy of the chosen Experience (Art. 9.1) and does not benefit from the 14-day right of withdrawal pursuant to art. 59, paragraph 1, letter n) of the Italian Consumer Code (exclusion for leisure services with specific date or period of performance), without prejudice to the Beneficiary’s right of cancellation according to the percentages provided for in the applicable Cancellation Policy.

Any changes to the Experience by the Host (variation of the Price, the Cancellation Policy, the conditions) subsequent to the issuance of the Gift Voucher do not affect the Voucher already purchased, consistent with the contractual snapshot referred to above.

8.D.3 Provisions common to Gift Cards and Gift Vouchers

8.16 Use modalities. Both Gift Cards and Gift Vouchers are used at checkout (or at date selection for Gift Vouchers) by entering the unique code of the token. For Gift Cards, the amount is deducted from the Total Amount of the Experience chosen by the Beneficiary; any positive differences are paid with standard payment method, any residuals remain available on the Gift Card until the validity term.

8.17 Cancellation of Booking made with Voucher. In case of cancellation of a Booking that has involved the use (in whole or in part) of a Gift Card, the corresponding share returns to the Gift Card balance with the original expiry date unchanged or, if requested and where technically feasible, with the expiry date extended by 12 months. For Gift Vouchers, cancellation follows the Cancellation Policy of the Experience, with possible refund of the Voucher price to the original Customer on the same payment method used.

8.18 Cancellation of the program by Stravagando. If Stravagando discontinues the Gift Card or Gift Voucher program, holders of Vouchers not yet used will be granted a full refund of the residual value within 30 days of cessation, save for a different more favourable agreement.

8.19 Loss and theft. In case of loss or theft of the Voucher code, the Customer promptly communicates the event to Customer Service. For nominative Vouchers (associated with a specific account), Stravagando may block the code and issue a new code of equal residual value. For bearer Vouchers, the block is possible only if the Voucher has not yet been used; portions already used by third parties are non-refundable.

8.E — Receipts, invoices and tax data

8.20 Payment receipt. For each Booking, the Customer receives via email a payment receipt containing the transaction details and the Total Amount charged. The receipt is downloadable at any time from the Account. The receipt does not constitute a tax document.

8.21 Invoice for the Customer. Upon the Customer’s request made at checkout or within the legal deadline, the Host issues to the Customer the electronic invoice or telematic receipt for the Experience. The invoice is issued by the Host (not by Stravagando) for the amount of the Price, based on the personal and billing data provided by the Customer. Stravagando does not intervene in the issuance of the invoice for the Experience but facilitates the transmission of billing data to the Host.

8.22 Invoice for the Service Fee. For the Service Fee, where applied, Stravagando issues to the Customer a specific receipt or invoice, according to the applicable tax regime, with transmission via Italian Interchange System (SDI) for Italian business Customers.

8.F — Chargeback

8.23 Definition and procedure. A Customer who believes to have suffered an unjust charge may activate the Chargeback procedure with its payment institution, pursuant to the rules of the card networks (Visa Core Rules, Mastercard Rules), within the terms and modalities provided for in its banking contract. The Customer is required to first attempt resolution through Stravagando’s Customer Service (Art. 12) before activating the Chargeback, consistent with the principle of contractual good faith.

8.24 Effects. The opening of a Chargeback entails the withholding of the disputed amount on the Host’s Payout until the dispute is resolved. Stravagando provides the payment institution with the evidentiary documentation (Booking Notification, attendance log, review, Customer-Host communications) for the defence of the transaction.

8.25 Chargeback abuse. Activation of Chargebacks for Bookings actually performed or for facts not falling within the cases provided for by the card networks (so-called friendly fraud or first-party fraud) constitutes abuse and entitles Stravagando to:

• suspend or revoke the User’s Account;

• request payment of the original amount, the Chargeback fees charged by Stripe and management costs;

• report the User to industry-shared anti-fraud blacklists within GDPR limits;

• initiate legal actions for the recovery of damages.

ART. 9 — CHANGES, CANCELLATIONS AND REFUNDS

9.A — Cancellation Policy

9.1 Available policies. The Host chooses, for each Experience, one of the six Cancellation Policies available on the Platform, clearly indicated in the Listing before Booking. The available types, with the related refund percentages applied to the Price of the Experience, are the following:

PolicyRefund 100%Refund 50%Refund 0%last_minuteup to 24 hours before—less than 24 hours beforevery_flexibleup to 48 hours before—less than 48 hours beforeflexiblemore than 5 days beforefrom 3 to 4 days beforeless than 3 days beforemoderatemore than 8 days beforefrom 5 to 7 days beforeless than 5 days beforestrictmore than 15 days beforefrom 8 to 14 days beforeless than 8 days beforevery_strictmore than 31 days beforefrom 15 to 30 days beforeless than 15 days before

Times are calculated with reference to the Experience start time indicated in the Booking Notification. In the absence of contrary indication, the time zone of the place of provision of the Experience applies.

The full description of the Policies, the cases of full refund, the Customer protection clauses and any operational conditions are detailed in the Cancellation Policy published on the Platform, which forms an integral part of these Sales Terms and prevails, in case of conflict, over the provisions of this article limited to the description of the individual Policies.

9.2 Mandatory indication. The applicable Cancellation Policy is clearly indicated in the Listing before Booking, in the checkout screen, in the Booking Notification and in the Booking summary in the Account. Explicit acceptance of the Policy is recorded at checkout before payment.

9.B — Cancellation by the Customer

9.3 Modalities. The Customer may request cancellation directly from the Account, through the “My Bookings” section, or by contacting Customer Service. The cancellation is effective from the system confirmation. The refund, where due according to the applicable Cancellation Policy, is processed automatically.

9.4 Calculation of refund. The refund percentage provided for by the applicable Cancellation Policy is calculated on the Total Amount paid by the Customer, including:

• the Price of the Experience;

• any Tourist Tax;

and excluding:

• Stravagando’s Service Fee, save for the cases of full refund referred to in 9.5;

• any non-refundable charges declared in the Listing (e.g. deposits for customised materials, non-refundable third-party tickets).

9.5 Right to full refund. Regardless of the applicable Cancellation Policy, the Customer always has the right to a full refund of the Total Amount (including Service Fee and Tourist Tax) in case of:

• cancellation by the Host (Art. 9.6);

• impossibility of provision due to Force Majeure (Art. 17.A);

• serious breaches by the Host that prevent enjoyment of the Experience under the published terms;

• violation of mandatory consumer protection rules;

• manifest publication errors (Art. 7.10);

• exercise of the consumer’s right of withdrawal where applicable (Art. A.2);

• documented impossibility of attendance for serious health reasons of the Customer or Participant arising between Booking and date of the Experience, attested by medical certificate (so-called “medical force majeure” protection), within the limits of the Guidelines.

9.C — Cancellation by the Host

9.6 Permitted cases. The Host may cancel the Booking only for objective and documentable reasons, including:

• supervening unavailability of the Host (illness, accident, serious family reasons);

• Force Majeure;

• failure to reach the minimum number of participants declared in the Listing;

• unavailability of the location for reasons not attributable to the Host;

• meteorological events incompatible with safe provision of the Experience;

• orders of public authorities (health restrictions, temporary prohibitions).

In all cases of cancellation by the Host, the Customer is entitled to a full refund of the Total Amount.

9.7 Prompt communication. Cancellation by the Host is communicated to the Customer with the greatest possible notice and in any case no later than 24 hours before the start of the Experience, save for Force Majeure events occurring in the last hours. For repeated serious disservices, Stravagando adopts progressive measures against the Host according to the Host Conditions (reduction of visibility, suspension, account revocation).

9.8 Additional compensation. In case of cancellation by the Host communicated with less than 48 hours notice, the Customer is entitled, in addition to the full refund, to a compensation voucher equal to 20% of the Total Amount, usable on future Bookings within 12 months, save for cases of documented Force Majeure.

9.D — No-Show

9.9 Definition. A No-Show is the failure of the Customer or Participant to attend the meeting point on the agreed day and time for the Experience, without prior cancellation notice through the Platform and with a delay exceeding 15 minutes from the agreed time. For Experiences with fixed departure times (e.g. boat tour, escape room with other participants), the waiting time may be reduced to 5 minutes, with explicit indication in the Listing.

9.10 Effects. In case of No-Show, the Customer is not entitled to refund and the Host retains the entire Total Amount (net of the Platform’s Service Fee), unless the applicable Cancellation Policy provides otherwise or the Customer proves Force Majeure causes promptly communicated.

9.11 Prompt communication by the Customer. A Customer who anticipates being unable to attend or being late is required to communicate this promptly to the Host through the Platform’s messaging or the emergency contacts provided in the preceding 24 hours. Prompt communication enables evaluation of alternatives (rescheduling, ride-share with other Participants) and mitigates the consequences of delay.

9.E — Changes to the Booking

9.12 Customer requests. The Customer may request changes to the Booking (date change, number of Participants, additional options, language of provision where available) through the Platform. The change is finalised only upon the Host’s acceptance within the times indicated and, where applicable, after settlement of the Total Amount.

9.13 Settlements. In case of increase of the Total Amount, the Customer must complete the supplementary payment within 24 hours from acceptance of the change, on pain of lapse of the change itself. In case of reduction, the difference is refunded according to the rules of the applicable Cancellation Policy, or returned in full if the change is due to a cause attributable to the Host.

9.14 Limit on changes. Substantial changes (date change of more than 30 days, significant change of location) may be refused by the Host and treated as cancellation and new Booking, with application of the Cancellation Policy in force.

9.F — Partial or reduced provision of the Experience

9.15 Interruption of Experience in progress. If the Experience is interrupted halfway due to causes attributable to the Host (e.g. inadequacy of the guide, equipment malfunction, inappropriate conduct of the Host), the Customer is entitled to a proportional refund of the unused part, save for a substantiated request for full refund for serious ascertained disservices. Interruption due to supervening Force Majeure during the Experience gives the right to proportional refund or Alternative Proposal.

9.16 Reduced-mode provision. If the Experience is provided in a reduced mode compared to that described in the Listing (e.g. excluded stage, reduced duration, substitute activity), the Customer who recognises a reduction in value may request a proportional refund through Customer Service within 7 days of the date of performance.

9.17 Partial attendance of Participants. If fewer Participants than booked are present at check-in, the Experience is provided regularly without change of Price, unless the applicable Cancellation Policy provides otherwise or the Host accepts a voluntary reduction.

9.G — Refund modalities

9.18 Times and channel. Refunds are processed by Stravagando through Stripe on the same payment method used by the Customer, pursuant to the PSD2. The credit times depend on the Customer’s payment institution:

• credit/debit cards: typically 5-10 business days;

• digital wallets: typically 1-3 business days;

• SEPA Direct Debit: typically 3-7 business days;

• bank transfer: typically 2-5 business days.

The times indicated are indicative and are not within Stravagando’s control. For used multi-use Gift Cards, the refund is made through credit back to the Gift Card balance with the original expiry date unchanged or, upon request and where technically feasible, with the expiry date extended by 12 months.

9.19 Mediation. In case of dispute between Customer and Host regarding cancellation or refund, Stravagando may offer a mediation service, facilitating dialogue between the parties without assuming the role of arbitrator or responsibility for the final decision (Art. 12). Stravagando reserves the right to process a unilateral refund in favour of the Customer in cases of clear non-performance of the Host ascertained on the basis of the available documentation.

ART. 10 — ATTENDANCE OF THE EXPERIENCE

10.A — Duties of Customer and Participant

10.1 Physical and mental fitness. The Customer warrants that the Participant is in physical and mental condition fit for participation in the booked Experience, with particular reference to Experiences requiring physical effort, mountain activities, diving, extreme sports, activities with animals or presenting specific risks. It is the Customer’s responsibility to verify before Booking that the Participant is fit, including through medical evaluation where appropriate, and to report to the Host any medical conditions relevant to safety (heart disease, asthma, severe allergies, pregnancy, claustrophobia, vertigo).

10.2 Allergies and special needs. The Customer is required to communicate to the Host, at the time of Booking or promptly before performance, any:

• food allergies (nuts, gluten, lactose, shellfish, etc.) and intolerances;

• dietary restrictions of religious or ethical choice (vegan, vegetarian, halal, kosher);

• accessibility needs (reduced mobility, sensory disabilities, support for guide dog);

• relevant pathologies for the safety of the activity (asthma, epilepsy, severe allergies to insect bites);

• specific phobias relevant to the Experience (acrophobia for mountain activities, aquaphobia for water activities).

The Platform makes available a specific field in the Booking form. Failure to communicate in advance exempts the Host from liability for events connected to such conditions.

10.3 Identity documents. The Host may request the Participant to present a valid identity document for the check-in of the Experience, in particular for:

• Experiences with nominative reservation;

• Experiences with age restrictions (e.g. food and wine experiences with alcohol service to adults);

• Experiences with sector-specific regulations (diving with licence, fishing activities with licence);

• Experiences with overnight stay (mandatory registration pursuant to the Italian Public Security Consolidated Law — TULPS).

A Participant who refuses to show the document may be excluded from participation without the right to refund.

10.4 Liability release. For Experiences with medium or high risk level, the Host may request the signing of a liability release (waiver) before the start of the Experience. The release covers the risks inherent in the activity and cannot exclude the Host’s liability for wilful misconduct, gross negligence or personal injury (arts. 1229, 1681 of the Italian Civil Code for transport). Refusal to sign the release excludes participation, save for cases in which the release contains unfair or invalid clauses.

10.B — Conduct during the Experience

10.5 Compliance with instructions. The Participant is required to comply with:

• the safety instructions of the Host and the personnel of the location;

• the conduct rules communicated (dress code, photo restrictions, no-smoking, no-touch policy for artworks);

• the agreed schedules and stages of the program;

• the environmental protection rules in case of activities in protected natural areas (EC Reg. 338/97 on protected species, Parks regulations, EU Habitats and Birds Directives);

• any other indication necessary for the correct and safe performance of the Experience.

10.6 Suitable conduct. The Participant shall refrain from conduct that may compromise the safety of itself or others, damage property or environments, disturb other Participants, constitute a violation of legal rules or harm the dignity of other persons (verbal harassment, sexual harassment, discriminatory conduct). The Host reserves the right to interrupt participation in case of seriously inadequate conduct, without the right to refund, and to report the fact to the competent authorities where it constitutes a crime.

10.7 State of intoxication. Participation in a state of drunkenness, under the effect of narcotic substances or in other conditions that compromise safety or orderly performance is prohibited. The Host may refuse the Participant’s participation in such conditions without the right to refund. For Experiences with alcohol service, consumption is subject to compliance with the legal limit for the activity (e.g. prohibition of driving) and to the Host’s discretion in evaluating fitness to continue.

10.8 Photographs and image rights. Unless otherwise indicated, personal photography of the Participant during the Experience is generally permitted for private use. Publication on social media or commercial use of photographs depicting other Participants, the Host or its premises requires the consent of the persons concerned pursuant to art. 96 of Italian Law 633/1941 and the GDPR. The Host may in turn take photographs/videos during the Experience, subject to the Customer’s explicit consent to processing.

10.C — Delays and management

10.9 Customer delay. In case of delay of the Customer or Participant at the meeting point, the Host waits a reasonable time — typically 15 minutes — before proceeding without the latecomer or considering the Booking as No-Show (Art. 9.9). For Experiences with fixed departure times (e.g. tours with other participants, experiences with external reservations, boat trips, escape rooms), the waiting time may be reduced to 5 minutes as indicated in the Listing.

10.10 Host delay. In case of significant delay by the Host without justified communicated reason:

• over 30 minutes for Experiences up to 4 hours in duration;

• over 60 minutes for longer Experiences;

the Customer is entitled to a full refund, save where the delay is due to documented Force Majeure. Smaller delays do not give rise to refund but entail continuation of the Experience with respect of the planned duration, where possible.

10.D — Materials, equipment and devices

10.11 Participant equipment. The Participant is required to present itself with the personal equipment indicated in the Listing (e.g. adequate clothing, footwear, personal protective equipment, swimwear, specific technical equipment). The Host is not required to provide personal equipment unless explicitly indicated.

10.12 Materials provided by the Host. Any materials, tools or equipment made available by the Host (e.g. sports equipment, ingredients for workshops, audio-guides, bicycles, kayaks) remain the property of the Host. The Participant is required to:

• use them with the diligence of a good family man pursuant to art. 1176 of the Italian Civil Code;

• return them at the end of the Experience in adequate condition, save normal wear and tear from use;

• promptly report any malfunctions or defects detected;

• compensate for any damage due to improper use, negligence or wilful misconduct, according to the rates published by the Host or, failing that, according to market value.

The Host may request a security deposit at the start of the Experience, returned at the end in case of absence of damage; the deposit is managed directly between Host and Participant and does not transit through the Platform, save for different technical configuration.

10.13 Loss or damage to personal property. Neither the Host nor Stravagando is liable for the loss or damage of the Participant’s personal property during the Experience, save in cases of wilful misconduct or gross negligence by the Host that is ascertained. The Participant is invited not to bring unnecessary valuables and to take care of them.

10.E — Experiences with food and beverage service

10.14 HACCP and traceability. For Experiences that include the service of food or beverages, the Host guarantees compliance with the HACCP regulation (EC Reg. 852/2004) and provides information on allergens pursuant to EU Reg. 1169/2011, based on what was communicated by the Customer at the time of Booking.

10.15 Labelling. The Host is responsible for the labelling, origin and traceability of the food used, in compliance with EU Reg. 1169/2011 and the relevant Italian and regional sector regulations (PDO, PGI, Organic, wine regulations of the Italian Ministry of Agriculture).

10.16 Alcohol service. The service of alcoholic beverages is reserved for adult Participants and within the limits provided for by Italian Law 125/2001 on alcohol and local regulations. The Host may refuse service to Participants showing signs of intoxication.

10.F — Experiences with animals

10.17 “Pet-friendly” Experiences. For Experiences where the presence of the Participant’s pets is allowed, the Customer warrants that the animal is up to date with the compulsory vaccinations, microchipped pursuant to Italian Presidential Decree 320/1954 and subsequent amendments, accompanied by muzzle and leash where required, and kept in such a way as not to pose a danger to other Participants.

10.18 Experiences with the Host’s animals. For Experiences involving interaction with the Host’s animals (horses, educational farms, whale watching, dog experiences), the Host guarantees compliance with the regulations on animal welfare (Italian Law 281/1991 and regional regulations; for equestrian activities, EC Reg. 882/2004) and the availability of adequate insurance coverage. The Participant follows the Host’s instructions for safe interaction with the animals.

10.G — Experiences with transport of persons

10.19 Sector protections. For Experiences that include transport of persons, the specific protections of the following EU Regulations apply where applicable:

• EU Reg. 1177/2010 on the rights of passengers travelling by sea and inland waterway;

• EU Reg. 181/2011 on the rights of passengers in bus and coach transport;

• EC Reg. 261/2004 on the rights of air passengers in case of cancellation or long delay;

• EC Reg. 1371/2007 on the rights of rail passengers.

A Host operating transport services is required to hold the legal authorisations and provide the Customer with the pre-contractual information required by the applicable regulations.

ART. 11 — EXPERIENCE REVIEWS

11.0 Scope of application. These provisions govern only the reviews of Experiences booked on the marketplace, as a transparency tool between Customer and Host in the sales relationship. The reviews and UGC Content of the social, gamification components and the Places catalogue (posts, photos, POI suggestions, place reviews) are governed by Sections 6, 11 and 12 of the General T&C (AI automated moderation system, DSA notice & action, future right of reply).

11.A — Experience Reviews

11.1 Right to review. Only Customers who have actually attended an Experience (status completed of the Booking) may post a review and rating on the Listing. The Platform verifies the actual attendance through internal logs (check-in confirmed by the Host, time elapsed from the start time, any automatic failsafes).

11.2 Time window. The review may be published within 30 days from the date of performance of the Experience. After this term, the possibility to leave a review lapses. The 30-day window is considered appropriate to allow the maturation of a thoughtful judgement and prevent merely impulsive or late reviews.

11.3 Review structure. The review includes:

• a summary rating on a scale of 1 to 5 stars;

• detail ratings on specific parameters (organisation, communication of the Host, value for money, accuracy of description);

• an optional text comment with minimum and maximum length published in the Guidelines;

• optionally, photographs taken during the Experience, within the limits of respect for third-party privacy.

11.4 Visibility. Reviews are public and visible on the Host’s Listing, on the Host’s profile and, in aggregate form, in the search results. The Customer’s name is shown in anonymised format (name + initial of surname) or according to the privacy preferences expressible in the Account. The date of the Experience is shown to allow verification of temporal relevance.

11.B — Moderation

11.5 Principle of non-interference. Stravagando does not modify the content of reviews and does not alter their sentiment, ensuring the authenticity of feedback in compliance with art. 26-bis of the Italian Consumer Code (introduced by Italian Legislative Decree 26/2023 implementing EU Directive 2019/2161 — Omnibus). Stravagando adopts proportionate and effective procedures to ensure the authenticity of reviews.

11.6 Cases of removal. Stravagando may remove or hide a review only in the following exhaustive cases:

• unlawful content: offensive, defamatory, discriminatory, threatening or inciting hatred (Italian Legislative Decrees 215/2003, 216/2003, Italian Law 645/1952);

• manifestly false content: review of an Experience never delivered, of a different Host, manifestly irrelevant review;

• non-pertinent sensitive personal data (health information, sexual orientation, third-party political opinions);

• spam, advertising content or unauthorised external links;

• third-party intellectual property violations (photos of other Users without consent, copyrighted material);

• paid reviews or sale of reviews — practices prohibited by EU Directive 2019/2161 (Omnibus) and Italian Legislative Decree 26/2023;

• reviews coming from fake accounts or suspected of manipulation (coordinated review bombing, multiple reviews from the same IP/device);

• review-for-benefit exchanges not disclosed (review in exchange for undisclosed discount).

11.7 Moderation procedure. Reviews are subject to preliminary automated moderation (filters for offensive language, spam, sensitive data) and manual moderation upon report, consistent with the AI moderation system described in Section 12 of the General T&C. The Customer whose review is removed receives a reasoned notification and may file an appeal within 15 days according to the procedure set out in Art. 12 of these Sales Terms and Section 12-bis of the General T&C (DSA notice & action system).

11.8 DSA notice & action procedure. In compliance with EU Regulation 2022/2065 (Digital Services Act), the Platform makes available a “notice and action” procedure for reporting unlawful content, accessible from the footer of each review and Listing. Reports are processed within the times and modalities provided by the DSA. For the details of the unified notice & action mechanism applicable to all Content of the Platform, reference is made to Section 12-bis of the General T&C.

11.9 Algorithmic transparency of reviews. The algorithm for ordering and displaying reviews (chronological, by relevance, by rating) is described in the legal section of the Platform. Any “Verified Purchase” reviews are distinctly identified to allow the Customer to evaluate reliability.

11.C — Host’s right of reply

11.10 Public reply. The Host may publicly reply to each review received, only once per review, within 90 days from publication, subject to the same moderation rules as 11.6. The reply is published immediately below the Customer’s review. The reply is subject to technical validation of length (minimum 10 characters, maximum 2,000 characters) and automatic strip of HTML markers.

11.11 Customer’s rejoinder. The Customer may in turn reply to the Host’s response only once, within 30 days of publication of the Host’s response. The rejoinder must maintain respectful tones and may not introduce new elements or unfounded accusations; in case of abuse, it may be removed.

11.D — User-uploaded content

11.12 Licence over content uploaded as part of Experience reviews. By uploading content on the Platform in connection with an Experience review (photos, comments), the User grants to Stravagando a non-exclusive, free, worldwide, sub-licensable to technical and promotional partners of the Service, and revocable (with effects pro futuro upon deletion of the content) licence to:

• host, reproduce, distribute the content on the Platform and its applications;

• modify for technical purposes (compression, resizing, translation);

• use the content for purposes of promotion of the Platform and Listings, including on social channels and in advertising material;

• create derivative works for analysis and improvement purposes of the Services.

For Content uploaded in the context of UGC components (storytelling posts, Places catalogue photos, POI suggestions), the licence is governed in a unified manner by Section 6.2 of the General T&C.

11.13 User’s warranties. The User warrants:

• to hold all the necessary rights over the uploaded content;

• not to infringe third-party rights (intellectual property, image, privacy);

• not to include unlawful, offensive or discriminatory material;

• to have obtained the consent of the persons portrayed in photographs or videos (arts. 96 of Italian Law 633/1941 and GDPR).

The User indemnifies Stravagando from third-party claims arising from violation of the foregoing warranties.

11.14 Licence revocation. The User may revoke the licence at any time by deleting the content from the Platform, with effects pro futuro. Deletion does not affect uses already legitimately made during the licence (e.g. content already published in promotional material).

11.E — Q&A system

11.15 Public questions. Users may ask public questions about the Listing before Booking. The Host’s replies (or those of other Customers who have attended) are published under the Q&A section of the Listing. The Q&A system is subject to the same moderation rules as reviews.

ART. 12 — CUSTOMER SERVICE AND COMPLAINTS MANAGEMENT

12.A — Channels

12.1 First-line Customer Service. Stravagando provides assistance to Customers for issues relating to the use of the Platform, Bookings, payments and refunds. Customer Service is accessible through:

• online help center with FAQ section;

• contact form in the Account;

• email to support@stravagando.com;

• where available, live chat in app and on web;

• dedicated phone number for emergencies during the Experience.

12.2 Response times. Stravagando undertakes to provide responses to assistance requests within reasonable times and in any case no later than 30 days from receipt, giving priority to requests relating to Experiences already booked and in progress, or to emergency situations reported during the performance of the Experience. The updated operational modalities, including any standard times by category of request and escalation procedures, are published in the Guidelines and in the Technical Service Specifications, according to the update regime referred to in Section 19.1 of the General T&C.

12.3 Supported languages. Customer Service is available in Italian and English; additional languages (French, Spanish, German) may be available depending on the volume of requests and as published in the Guidelines.

12.B — Management of complaints about the Experience

12.4 Preliminary communication to the Host. For issues relating to the actual provision of the Experience (quality, safety, conformity to the Listing, conduct of the Host), the Customer is invited to first contact the Host through the Platform’s messaging system, giving the Host the opportunity to resolve or offer a remedy.

12.5 Escalation to Stravagando. If direct communication with the Host is not resolutive within a reasonable time or in serious cases (safety, non-performance, serious breaches), the Customer may open a formal complaint through the dedicated form in the Account or via email to support@stravagando.com. The complaint must contain:

• Booking number;

• detailed description of the problem;

• date and time of the event;

• any evidence (photos, videos, screenshots, testimonies);

• requested remedy (full or partial refund, compensation voucher, alternative Experience).

12.6 Management procedure. Stravagando takes charge of the complaint, conducts the investigation by requesting clarifications or supplementary documentation from the Customer and the Host, and communicates to the Customer the proposed solution within the times referred to in paragraph 12.2. The application of the solution, in case of acceptance by the Customer, takes place promptly compatibly with the technical times of the payment institutions (Art. 9.18).

12.7 Mediation. In case of dispute between Customer and Host, Stravagando offers a mediation service, facilitating dialogue between the parties without assuming the role of arbitrator or responsibility for the final decision. The final decision rests exclusively with the parties or, failing agreement, with the competent authority pursuant to Art. 17.E and Appendix A.

12.8 Reservation of intervention. Stravagando reserves the right to unilaterally process a refund in favour of the Customer where, on the basis of the available documentation, a serious breach by the Host is clearly ascertained. This power does not entail acknowledgement of liability by Stravagando and does not prejudice the relationships between the parties, without prejudice to Stravagando’s right of recourse against the Host pursuant to the Host Conditions.

12.C — Escalation

12.9 Lack of resolution. In case of dissatisfaction with the outcome of the complaint, the Customer may request a review of the case by the higher Customer Service channels. The operational escalation modalities are published in the Guidelines.

12.10 Formal complaint to the owner. For complaints that do not find a solution through Customer Service, the Customer may submit a formal complaint to the owner of the Platform at the PEC address horizonserviziintegrati@pec.it or by registered letter with return receipt to the registered office, with response within the times referred to in paragraph 12.2.

ART. 13 — INTELLECTUAL PROPERTY

13.A — Stravagando’s rights

13.1 Ownership. All intellectual property rights related to the Platform, its original content (texts, graphics, layout, software, source code, UI/UX design, trademarks, logos, slogans), aggregated databases, technical and contractual documents (including these Conditions and their translations) are the exclusive property of Stravagando or its licensors.

13.2 Protection. Stravagando’s rights are protected by:

• Italian Law 633/1941 on copyright;

• Italian Legislative Decree 30/2005 (Industrial Property Code) for trademarks, patents, designs;

• Italian Legislative Decree 169/1999 on databases;

• EU Reg. 2017/1001 on the European Union trademark for Stravagando’s EU trademarks.

13.3 Limited licence to the User. The User receives a personal, non-exclusive, non-transferable, non-sub-licensable, free and revocable licence for the use of the Platform exclusively within the limits of these Terms and for Service purposes. The licence terminates automatically upon cessation of the contractual relationship.

13.4 Prohibitions. The User is expressly prohibited from:

• reproducing, copying, modifying, distributing, selling, sub-licensing Platform materials outside authorised personal use;

• using the trademarks, logos or distinctive signs of Stravagando in violation of industrial property rights, including through meta tags, abusive keyword advertising or confusable domains;

• creating derivative works based on Platform content;

• removing or altering copyright notices, trademarks or proprietary indications;

• performing deep linking or framing of the Platform in modes that alter its original presentation or unduly exploit its reputation.

13.B — Third-party content

13.5 Host content. Content published by Hosts (descriptive texts of Listings, photographs, videos) remains the property of the Hosts themselves, who grant Stravagando a licence for publication, distribution and promotion on the Platform, pursuant to the Host Conditions. Such content may be used by the User exclusively for the purposes of search, evaluation and Booking of the Experience.

13.6 User content. Content uploaded by the User (Experience reviews, related photographs) remains the property of the User, who grants Stravagando the limited licence referred to in Art. 11.D of these Sales Terms.

13.C — Trademarks, partners and APIs

13.7 Stravagando trademarks. “Stravagando”, the logo, the official slogans and any other distinctive sign are trademarks of Stravagando, registered or in the course of registration. Their use is reserved to Stravagando and partners authorised in writing. Any unauthorised use will be pursued in the competent legal venues.

13.8 Third-party trademarks. Third-party trademarks, logos and trade names (payment cards, wallets, social networks, mobile operating systems, commercial partners) are the property of their respective owners and used on the Platform exclusively for identification and interoperability purposes.

13.9 APIs and plugins. The use of Stravagando’s APIs and SDKs, where available to authorised partners, is subject to specific licence agreements and technical rate limits. Unauthorised use of the APIs, mass data extraction or circumvention of technical limitations constitutes a violation of these Terms and of Stravagando’s rights.

13.D — DMCA and notice & action protection

13.10 Unified reporting procedure. For the reporting of content alleged to infringe third-party intellectual property rights, reference is made to the unified notice and action procedure described in Section 12-bis of the General T&C, which integrates the protections of EU Reg. 2022/2065 (DSA), Italian Legislative Decree 70/2003 (E-Commerce Decree) and — for U.S. residents or holders of U.S. copyright — the Digital Millennium Copyright Act (DMCA) pursuant to Appendix B.

Reports may be sent to:

• email: support@stravagando.com;

• PEC: horizonserviziintegrati@pec.it;

• for U.S. claimants: DMCA Designated Agent indicated in the legal section of the Platform, in compliance with 17 U.S.C. §512(c)(2).

ART. 14 — LIABILITY AND INDEMNITY

14.A — Stravagando’s liability

14.1 Liability limits. Stravagando is liable exclusively for:

• the proper provision of the intermediation Services described herein, according to the obligation of means typical of an information society service provider;

• the accuracy of transaction data (amounts, dates, identification of the parties);

• the technical security of the Platform according to industry standards and best practices;

• the informational transparency on the Services provided;

• the regulatory compliance of its intermediation activity.

Stravagando is not liable, under any circumstances and on any ground:

• for the quality, safety, conformity or actual provision of the Experiences, which are the sole responsibility of the Hosts;

• for the conduct of the Users on the Platform and during the Experiences;

• for the content posted by Users, save the limits set out in Italian Legislative Decree 70/2003 and the DSA;

• for Force Majeure events preventing the provision of the Platform or the Experiences (Art. 17.A);

• for the functioning of third-party services integrated (cloud providers, Stripe payment gateway, map providers, social login, SMS providers).

14.2 Liability cap. Save in cases of wilful misconduct, gross negligence, infringement of inderogable consumer rights or personal injury, Stravagando’s overall liability to the Customer for each event or series of connected events does not exceed the greater of:

• the Total Amount of the Booking to which the event refers;

• € 500.

For Users who have not made Bookings, the cap is set at € 100.

This limitation applies within the limits permitted by applicable law. The mandatory consumer protections set out in the Italian Consumer Code and EU regulations remain in any case unaffected.

14.3 Exclusion of indirect damages. Save the inderogable limits referred to above, Stravagando is not liable for indirect, consequential, punitive damages, loss of opportunity, loss of profit, loss of data, reputational damage or other non-pecuniary damages, unless they are a direct consequence of wilful misconduct or gross negligence by Stravagando.

14.B — User’s liability

14.4 Direct liability. The User is directly liable for:

• the truthfulness of the information provided upon registration and Booking;

• the compliance with these Conditions and the safety instructions during the Experience;

• the compensation of damages caused to Stravagando, Hosts, other Users or third parties during or in connection with the use of the Platform and Experiences;

• the legitimacy of content uploaded on the Platform (Art. 11.D);

• the security of its Account according to the procedures set out in Section 4 of the General T&C;

• the conduct of Participants for whom the Customer has made the Booking, in particular minors and Beneficiaries.

14.5 Indemnity. The User indemnifies and holds harmless Stravagando, its affiliates, employees, directors and partners from claims, actions, costs, charges and expenses (including reasonable legal fees) arising from:

• violation of these Sales Terms or of law by the User;

• content uploaded by the User in violation of third-party rights (intellectual property, image, privacy);

• conduct of the User or of Participants causing damages during the Experience;

• activation of abusive Chargebacks (Art. 8.F);

• fraudulent use of codes, Vouchers, promotional programs.

14.C — Insurance coverage

14.6 Stravagando’s insurance. Stravagando holds professional civil liability insurance coverage for the Services provided, with limits adequate to the volume of transactions intermediated.

14.7 Hosts’ insurance. Professional Hosts are required to take out third-party and worker liability (RCT/RCO) policies adequate to the type of Experience offered, pursuant to the Host Conditions. Stravagando may require proof of coverage before publication of the Listing for high-risk Experiences.

14.8 Customers’ insurance. The Customer is recommended to take out independent supplementary insurance coverage for travel, accidents, Booking cancellation, in particular for long-duration, high-risk or foreign-destination Experiences.

ART. 15 — PERSONAL DATA PROTECTION

15.1 Full reference. The processing of Users’ personal data is governed in full by the Privacy Policy published on the Platform and by Section 16 of the General T&C, in compliance with EU Regulation 2016/679 (GDPR), Italian Legislative Decree 196/2003 (Privacy Code) as amended by Italian Legislative Decree 101/2018, ePrivacy Directive 2002/58/EC and the guidelines of the Italian Data Protection Authority.

The Privacy Policy describes the purposes of processing, legal bases, recipients, retention periods, extra-EU/EEA transfers and the rights of the data subject (arts. 12-22 GDPR), together with the modalities for their exercise.

15.2 Marketplace specificities. Limited to the sales relationship governed by these Terms, the following specificities are noted:

• Stripe Payments Europe Ltd acts as autonomous Controller of processing for payment management, anti-fraud security and financial compliance activities. The User’s payment data are transmitted directly to Stripe in compliance with its PCI-DSS Level 1 standards and are not stored by Stravagando;

• Tax retention. Booking data relevant for tax and accounting purposes (amounts, counterparties, invoices, receipts) are kept by Stravagando for the ten-year term referred to in art. 2220 of the Italian Civil Code and art. 22 of Italian Presidential Decree 600/1973, even after any deletion of the Account;

• Anti-money laundering. For anti-money laundering prevention purposes referred to in Italian Legislative Decree 231/2007 (Art. 18 of these Terms), Stravagando may keep identification and operational data for the periods provided by AML regulations, regardless of Account deletion;

• DAC7. Stravagando complies with the tax reporting obligations to the Italian Revenue Agency pursuant to EU Directive 2021/514 (DAC7) and Italian Legislative Decree 32/2023, annually communicating data on Host sellers enabled on the Platform. The data thus transmitted are kept within the terms provided by the Directive.

15.3 Data subject rights. The rights of access, rectification, deletion, restriction, portability and objection may be exercised according to the modalities described in the Privacy Policy and Section 16 of the General T&C, subject to the limitations deriving from the tax and AML obligations referred to in paragraph 15.2.

15.4 Contact of the Controller and DPO. The Data Controller is Horizon Servizi Integrati S.r.l.s., with registered office at Via L’Aquila 22, 65122 Pescara (PE), Italy. The Data Protection Officer (DPO), where appointed, and the contact points are indicated in the Privacy Policy.

ART. 16 — CHANGES, DURATION AND WITHDRAWAL

16.A — Changes to the Conditions

16.1 Right to modify. Stravagando may modify these Sales Terms to:

• adapt them to regulatory developments or orders of competent authorities;

• adapt them to technological developments or new Platform features;

• adapt them to market developments or business model changes;

• correct errors, interpretative ambiguities or gaps in the Conditions;

• improve the clarity of the clauses or the user experience of the acceptance process.

16.2 Prior notice. Substantial changes are communicated to registered Users with notice of no less than 30 days before entry into force, through:

• email to the registered address;

• notice upon login to the Platform;

• publication in the legal section of the website.

For non-substantial changes or formal adjustments, publication on the Platform is sufficient. Changes imposed by law or by orders of authorities may enter into force without notice.

16.3 Re-acceptance. The User is required to re-accept the modified Conditions upon the first login after entry into force. Continued use of the Platform constitutes implied acceptance.

16.4 Right of withdrawal for non-acceptance. A User who does not intend to accept the changes has the right to withdraw from the relationship and close the Account within 30 days from the notice, without charges, retaining the right to the regular performance of already-confirmed Bookings and to any refunds due, as well as GDPR rights (data deletion/export) referred to in Section 16 of the General T&C.

16.B — Duration and User withdrawal

16.5 Duration. The contractual relationship between User and Stravagando has indefinite duration and continues until withdrawal by one of the parties.

16.6 User withdrawal. The User may withdraw at any time and without need for justification, by closing the Account according to the self-service procedures set out in Section 21 of the General T&C.

16.7 Effects of withdrawal. Withdrawal entails the termination of the contractual relationship with immediate effect, without prejudice to:

• the validity of already-confirmed Bookings, which remain governed by these Sales Terms;

• the retention of tax, accounting and AML obligations for the legal periods (paragraph 15.2);

• the survival of clauses by their nature destined to operate beyond cessation (liability, indemnity, intellectual property, applicable law and jurisdiction);

• the GDPR rights of the data subject, according to the Privacy Policy.

16.C — Withdrawal and suspension by Stravagando

16.8 Cases of suspension/revocation. Stravagando may suspend or revoke the User’s access to the Platform in the cases provided for in Section 13 of the General T&C (progressive sanctioning system) and in Art. 5.6 of these Sales Terms for the specific violations of the sales relationship.

16.9 Procedure. Suspension or revocation is preceded by formal contestation and the right to be heard referred to in Art. 5.7, save in cases of severity requiring immediate precautionary measures. The User may file an appeal according to the DSA procedure provided for in Section 12-bis of the General T&C.

16.10 Effects on Bookings in progress. In case of suspension/revocation, Confirmed Bookings in progress are managed according to the following rules:

• future Bookings for Experiences yet to be performed: the User retains the right to attend them, unless the suspension/revocation is connected to serious violations preventing the safety of the performance;

• refunds due: processed according to the ordinary rules;

• credits accrued in favour of the User: settled according to the ordinary rules, save for cases of withholding for clawback of undue benefits (Art. 5.6).

ART. 17 — GENERAL PROVISIONS

17.A — Force Majeure

17.1 Definition. Force Majeure consists of unforeseeable, unavoidable events independent of the parties’ will that prevent or render significantly more burdensome the performance, including — by way of example and not exhaustive:

• natural events: earthquakes, floods, volcanic eruptions, tsunamis, landslides, fires not caused by negligence;

• extreme weather events: hurricanes, storms, exceptional snowfalls, heat or cold waves, where they objectively render impossible or dangerous the provision of the Experience;

• health events: pandemics, epidemics, mandatory quarantines ordered by health authorities;

• political/social events: wars, terrorist acts, revolutions, coups d’état, general strikes, riots;

• orders of authorities: closure orders, restrictions on movement, supervening international sanctions;

• technological events: prolonged electrical blackouts, serious malfunctions of public infrastructure (telephone network, internet), cyber attacks of systemic scale.

Circumstances reasonably foreseeable and manageable with the diligence of the industry operator (e.g. normal seasonal weather conditions, announced local strikes, staff holidays) do not constitute Force Majeure.

17.2 Effects. The Force Majeure event suspends the obligations of the parties for the duration of the impediment, without prejudice to the Customer’s right to a full refund for any supervening impossibility of the Experience (Art. 9.5 letter b) and to the Alternative Proposal (Art. 7.11).

17.3 Communication. The party invoking Force Majeure shall promptly communicate to the other party the event and its presumable duration, providing adequate documentation.

17.B — Assignment of the contract

17.4 Prohibition for the User. The User may not assign to third parties the rights and obligations under these Sales Terms or individual Bookings, save as permitted under Art. 7.9 for the transfer of the Booking to another Participant with the Host’s consent.

17.5 Stravagando’s right of assignment. Stravagando may assign this contract to third parties as part of corporate restructuring, merger, demerger, transfer of business or affiliate operations, with 30 days notice to the User. The assignment may not result in a worsening of the User’s rights; otherwise, the User has the right to withdraw pursuant to Art. 16.4.

17.C — Communications

17.6 Modalities. Unless otherwise indicated, communications between the parties take place through:

• email: at the User’s registered address and at support@stravagando.com or at another address indicated on the Platform;

• notifications within the Account or via mobile app;

• official communications from Stravagando: through publication on the Platform with email notification to registered Users.

For communications of legal content (withdrawal, formal contestations, complaints), the use of registered letter with return receipt or PEC to Stravagando’s registered office is recommended.

17.7 Update of contacts. The User undertakes to keep its contact details up to date. Communications sent to the registered addresses are presumed received, save proof to the contrary.

17.D — Interpretation and miscellaneous clauses

17.8 Entire agreement. These Sales Terms, together with the Appendices, the accompanying documents referenced and the General T&C for non-transactional matters, constitute the entire agreement between the parties, superseding any prior oral or written understanding.

17.9 Document retention. Stravagando retains a copy of the version of the Conditions accepted by the User for the entire duration of the contractual relationship and for the subsequent legal periods, according to the Privacy Policy. The User may request a copy of the accepted version via email.

17.10 Severability clause. Should one or more clauses of these Conditions be declared null, invalid or ineffective by a competent judicial or regulatory authority, the remaining clauses retain full effect. The parties undertake to replace the invalid clause with a valid clause pursuing the same economic-legal purpose.

17.11 Non-waiver. Failure or delay by Stravagando in exercising a right does not constitute a waiver of the right itself. Any waivers must be in writing.

17.12 Titles. The titles of articles and paragraphs are merely explanatory and do not constitute a substantive part of the contractual content.

17.13 Language. The Italian version of the Conditions is the reference version. Translations into other languages are provided for informational purposes; in case of discrepancies, the Italian text prevails, save for the special provisions of Appendix B for U.S. residents.

17.E — Applicable law and jurisdiction

17.14 Applicable law. These Sales Terms are governed by Italian law. For consumers residing in other EU/EEA States, the more favourable inderogable provisions of the law of the consumer’s country of residence pursuant to EU Reg. 593/2008 (Rome I), art. 6, remain applicable.

17.15 Jurisdiction. For disputes with consumers, the forum of the consumer’s residence or elected domicile shall have exclusive jurisdiction pursuant to art. 66-bis of the Italian Consumer Code and EU Reg. 1215/2012 (Brussels I-bis) for consumers residing in other EU States.

For disputes with non-consumer Users (professionals, businesses), the Court of Pescara (Italy) shall have exclusive jurisdiction, save for different written agreement.

17.16 ODR. For consumers residing in the European Union, the European Commission’s ODR platform (Online Dispute Resolution) is available at https://ec.europa.eu/consumers/odr. Stravagando’s ODR contact email is support@stravagando.com.

17.17 ADR and mediation. Stravagando adheres, where applicable, to alternative dispute resolution (ADR) procedures provided for by sector-specific regulations and the Italian Consumer Code, without prejudice to the Customer’s right to refer the matter to the competent judicial authority. For Italian consumers, the mandatory mediation pursuant to Italian Legislative Decree 28/2010 is also available for the matters listed in art. 5 of the same decree.

ART. 18 — ANTI-FRAUD AND ANTI-MONEY LAUNDERING MEASURES

18.A — Anti-fraud

18.1 Technical measures. Stravagando implements technical and organisational measures for the prevention and combating of fraud, including:

• Stripe Radar for risk scoring on payments;

• velocity checks on Bookings, registrations and payments from the same source;

• detection of multiple-Account patterns of the same user (device fingerprint, IP, behavioral analytics);

• content moderation to identify suspicious activity (fake Accounts, false reviews, phishing);

• blacklists of IPs, devices and identities flagged in past fraud.

18.2 Checks on request. In case of suspected fraud, Stravagando may request from the User:

• documentary verification of identity (enhanced KYC);

• verification of the cardholder of the payment card used;

• certifications or self-declarations on the source of funds for significant amounts;

• clarifications on usage patterns.

Failure to cooperate entails the precautionary suspension of the Account and of pending refunds/payments until clarification.

18.3 Consequences of fraud. In case of ascertained fraud, Stravagando may:

• immediately close the Account and all linked Accounts;

• withhold funds present in the Accounts to cover damages, sanctions or matured credits;

• report the User to industry-shared blacklists within GDPR limits;

• report the User to the competent authorities for applicable legal offences;

• initiate legal actions for the recovery of damages.

18.B — Anti-Money Laundering (AML)

18.4 Regulatory framework. Stravagando, as an intermediation service provider, is required to comply, to the extent applicable, with the provisions of Italian Legislative Decree 231/2007 (implementing EU anti-money laundering directives) and FIU orders, as well as EU Regulation 2024/1624 on anti-money laundering when in force. The payment management activity is largely outsourced to Stripe, a qualified regulated entity.

18.5 AML measures. The measures adopted in implementation of the AML legislation include:

• customer due diligence (CDD) of the customer and Hosts;

• enhanced due diligence (EDD) for transactions of significant amount or suspicious patterns;

• constant transaction monitoring to identify anomalous operations;

• reporting of suspicious transactions to the Italian Financial Intelligence Unit (UIF/FIU);

• data retention for AML purposes for the periods provided (10 years from the cessation of the relationship).

18.6 Cooperation with authorities. Stravagando cooperates with the competent authorities (Bank of Italy, UIF, Italian Financial Police, Italian Revenue Agency) by providing information and documentation upon reasoned request. The User acknowledges that, in such cases, communication to the User of ongoing investigations may be precluded for investigative secrecy pursuant to art. 329 of the Italian Code of Criminal Procedure and AML confidentiality obligations.

18.C — DAC7

18.7 Tax reporting Host. Stravagando, as a “platform operator” pursuant to EU Directive 2021/514 (DAC7) and Italian Legislative Decree 32/2023, collects and annually communicates to the Italian Revenue Agency the identification and operational data of Host sellers enabled on the Platform, according to the technical specifications of the Italian Ministry of Economy. This obligation does not concern purchasing Customers, without prejudice to their respective personal tax obligations.

APPENDIX A — SPECIFIC CONDITIONS FOR EU/EEA CONSUMERS

A.1 — Scope of application

These Specific Conditions apply to Customers who qualify as consumers pursuant to art. 3, paragraph 1, letter a) of Italian Legislative Decree 206/2005 (Consumer Code) and art. 2 of EU Directive 2011/83/EU on consumer rights, namely natural persons acting for purposes outside any business, commercial, craft or professional activity carried on, residing in a Member State of the European Union or the European Economic Area (Norway, Iceland, Liechtenstein).

These Specific Conditions prevail over the General Conditions in case of conflict, limited to the matters governed herein and within the limits of the inderogable provisions for consumer protection.

A.2 — Right of withdrawal

A.2.1 General discipline. The consumer benefits from the right of withdrawal of 14 days under arts. 52 et seq. of the Italian Consumer Code for distance contracts, exercisable without need for justification and without penalty.

A.2.2 Exclusions applicable to Experiences. The right of withdrawal does not apply to Experiences booked for a specific date or period of performance, pursuant to art. 59, paragraph 1, lett. n) of the Italian Consumer Code. This includes:

• Experiences booked for a specific date indicated at the time of Booking;

• Experience-specific Gift Vouchers (Art. 8.D.2), as they are linked to a specific Experience identified at the time of purchase.

For such Experiences and Gift Vouchers, the Cancellation Policies chosen by the Host (Art. 9) apply, which represent the contractual cancellation regime of the Customer.

A.2.3 Further exclusions. The right of withdrawal also does not apply to contracts for:

• services fully performed before the 14-day deadline, with the consumer’s express agreement (art. 59 lett. a);

• leisure activities at specific dates already referred to (art. 59 lett. n).

A.2.4 Cases of applicability of the right of withdrawal. The right of withdrawal applies:

• to multi-use Gift Cards (Art. 8.D.1), provided they have not been used in whole or in part and subject to the 14-day term from the date of purchase;

• to any subscription-based ancillary Platform services (e.g. future premium subscriptions), save the exemption of art. 59 lett. a for services already fully performed.

A.2.5 Exercise of the right. The consumer exercises withdrawal by communicating it via email to support@stravagando.com or by using the model withdrawal form attached to the pre-contractual information, containing:

• name, address, contact details;

• reference to the contract from which withdrawing (Booking number, Gift Card code);

• date of the communication.

A.2.6 Effects. A consumer who validly exercises withdrawal is entitled to a full refund of the Total Amount, made within 14 days of receipt of the communication using the same payment method used for the transaction.

A.3 — Consumer Code protections

A.3.1 Pre-contractual information. Prior to confirmation of the Booking, the consumer receives all the pre-contractual information provided for by art. 49 of the Italian Consumer Code: essential characteristics, identity of the professional, total price inclusive of taxes and charges, payment methods, duration, withdrawal conditions, applicable warranties and competent forum.

A.3.2 Written confirmation. Immediately after confirmation of the Booking, the consumer receives via email confirmation of the contract on durable medium with all the elements referred to in art. 51 of the Italian Consumer Code.

A.3.3 Unfair terms. Clauses possibly qualifying as unfair pursuant to arts. 33 et seq. of the Italian Consumer Code are null, unless individually negotiated. The nullity of individual clauses does not entail the nullity of the entire contract.

A.3.4 Conformity guarantees. The conformity guarantees provided by arts. 128 et seq. of the Italian Consumer Code apply to Experiences, as reformed by Italian Legislative Decree 170/2021 (implementing EU Directive 2019/770 on contracts for the supply of digital content and services and EU Directive 2019/771 on the sale of goods). The consumer has the right to remedies such as repair, re-performance of the service, price reduction or termination of the contract, in the terms and modalities provided by the regulation.

A.4 — Mediation and ODR

A.4.1 ODR. For disputes arising from contracts concluded online, the consumer may resort to the European Commission’s ODR platform (https://ec.europa.eu/consumers/odr) pursuant to EU Reg. 524/2013. Stravagando’s ODR contact point is reachable at email support@stravagando.com.

A.4.2 ADR. Stravagando adheres, where applicable, to the alternative resolution procedures provided for by EU Directive 2013/11/EU (ADR) as implemented in the individual Member States. For Italy, the mandatory mediation procedures referred to in Italian Legislative Decree 28/2010 are accessible through mediation bodies registered with the Italian Ministry of Justice.

A.5 — Consumer forum

A.5.1 Forum. For consumers, the forum of the place of residence or elected domicile shall have exclusive jurisdiction pursuant to art. 66-bis of the Italian Consumer Code, derogating any different contractual clause. For consumers residing in other EU States, the forum provided by EU Reg. 1215/2012 (Brussels I-bis), art. 18, applies.

A.5.2 Class action. The right of the consumer to participate in representative actions for redress pursuant to Italian Legislative Decree 28/2023 (implementing EU Directive 2020/1828 on representative actions) is reserved.

APPENDIX B — SPECIFIC CONDITIONS FOR U.S. RESIDENTS

B.1 — Scope of application

These Specific Conditions for U.S. Residents apply to Customers residing in the United States of America, including its territories and possessions, without prejudice to the different qualification of “consumer” applicable based on the law of the State of residence.

As of today, Stravagando operates predominantly in EU/EEA territory. These provisions are set out in view of a future formal opening to the U.S. market; some sections — in particular those relating to tax reporting (B.6) and further U.S. compliance obligations — will be operationally activated at the time of such opening, through update of these Conditions.

In case of conflict with the main body of the Conditions, these Specific Conditions prevail, limited to the matters governed herein.

B.2 — Applicable law, binding arbitration and forum

B.2.1 Applicable law. Save the mandatory federal and state provisions applicable to the resident consumer, these Sales Terms continue to be governed by Italian law for the matters not covered by applicable U.S. law, consistent with the Company’s seat.

B.2.2 Preliminary amicable resolution. Before initiating arbitration or judicial action, the U.S. resident Customer shall send to Stravagando a written Notice of Dispute containing: (a) name and contact details; (b) description of the claim; (c) requested remedy. The Notice of Dispute is sent to the PEC address horizonserviziintegrati@pec.it or to the postal address Via L’Aquila 22, 65122 Pescara (PE), Italy. The parties shall make good-faith efforts to resolve the dispute within 60 days of receipt of the Notice; after such term without agreement, either party may activate arbitration or other remedies referred to in the following paragraphs.

B.2.3 Binding individual arbitration. Save as provided in the following B.2.4, disputes between Stravagando and the U.S. resident Customer that are not resolved in the amicable phase shall be referred to binding individual arbitration pursuant to the Federal Arbitration Act (9 U.S.C. §1 et seq.), administered by the American Arbitration Association (AAA) in accordance with the AAA Consumer Arbitration Rules and the Consumer Due Process Protocol. The arbitrator applies the substantive law pursuant to B.2.1 and renders a reasoned written award.

For disputes with a value not exceeding $25,000, the seat of arbitration is set in the Customer’s city of residence (alternatively, upon Customer’s request, it may be conducted entirely on a documentary and telephone/video conference basis without in-person hearing). For disputes with a value exceeding $25,000, the seat is New York, New York, save for different written agreement between the parties.

B.2.4 “Small claims court” exception. Nothing in B.2.3 prevents either party from bringing an individual action before the small claims court competent for the Customer’s residence, where the dispute falls within the value and subject-matter limits of such court. Filing an action in small claims court does not constitute waiver of the arbitration clause for further disputes between the parties.

B.2.5 Class action waiver. The U.S. resident Customer agrees that disputes will be resolved exclusively on an individual basis, waiving participation in class action, class arbitration, coordinated mass arbitration or other representative actions, to the maximum extent permitted by applicable law. The arbitrator may not consolidate the claims of multiple Customers or preside over collective or representative proceedings. Severability: should the class action waiver of this paragraph be held invalid or unenforceable by a competent authority with reference to a specific dispute, the specific dispute will be referred to the competent judicial authority, while the remaining provisions of B.2 (and in particular individual arbitration for further disputes) retain full effect.

B.2.6 Arbitration costs. The arbitration costs (filing fees, administrative fees, arbitrator’s fees) are governed by the AAA Consumer Arbitration Rules. For disputes initiated by the Customer with a value not exceeding $10,000, Stravagando will bear the AAA filing costs exceeding $250 and the arbitrator’s fees, unless the arbitrator qualifies the claim as frivolous pursuant to Rule 11 of the Federal Rules of Civil Procedure. Each party bears its own legal costs, save for a different decision of the arbitrator within the limits of applicable law.

B.2.7 Opt-out. The Customer may opt out of the clauses set out in B.2.3 (binding arbitration) and B.2.5 (class action waiver) by communicating it in writing to Horizon Servizi Integrati S.r.l.s. within 30 days of first acceptance of these Conditions, at the PEC address horizonserviziintegrati@pec.it or at the postal address Via L’Aquila 22, 65122 Pescara (PE), Italy, indicating: User’s name, Account email, date of first acceptance and express opt-out declaration. The exercise of the opt-out does not prejudice the other provisions of these Conditions and Appendix B. In case of timely opt-out, the competent courts of the Customer’s State of residence or, failing that, of the State of New York, have exclusive jurisdiction for disputes.

B.2.8 Survival. The provisions of this B.2 survive the cessation of the contractual relationship with reference to disputes accrued during its validity.

B.3 — DMCA — Copyright protection

B.3.1 DMCA procedure. U.S. copyright holders may request the removal of content alleged to infringe their rights through the procedure provided for by the Digital Millennium Copyright Act, 17 U.S.C. §512.

B.3.2 Designated Agent. The designated agent for the receipt of DMCA notifications is indicated in the legal section of the Platform, in compliance with 17 U.S.C. §512(c)(2). The contact point is:

• DMCA Designated Agent: Horizon Servizi Integrati S.r.l.s.

• Email: support@stravagando.com

• Postal Address: Via L’Aquila 22, 65122 Pescara (PE), Italy

B.3.3 DMCA notification requirements. The notification must contain the elements provided by 17 U.S.C. §512(c)(3):

• physical or electronic signature of the person authorised to act on behalf of the rights holder;

• identification of the copyrighted work;

• identification of the material alleged to be infringing and its URL location on the Platform;

• contact information of the complainant;

• good faith statement on the infringement;

• statement, under penalty of perjury, of authorisation to act.

B.3.4 Counter-notice. A User whose content has been removed may file a counter-notice pursuant to 17 U.S.C. §512(g) with the same formal elements. In the absence of legal action by the complainant within 10-14 business days, the content may be restored.

B.3.5 Repeat infringer policy. Stravagando adopts a Repeat Infringer Policy providing for the closure of accounts of Users who have been the subject of repeated valid DMCA notifications not subject to valid counter-notice, pursuant to 17 U.S.C. §512(i).

B.4 — Advertising disclosures — FTC

B.4.1 Compliance with FTC Endorsement Guides. U.S. resident Customers who publish reviews, UGC content or participate in the Referral Program undertake to comply with the FTC Endorsement Guides (16 CFR Part 255), providing clear and conspicuous disclosure of:

• any material relationship with Stravagando or with the Host (sponsorship, free gift, discount in exchange for review);

• any commissions received through the Referral Program;

• use of artificial intelligence in the generation of the content, if applicable.

B.4.2 Operational guidelines. Stravagando publishes operational guidelines on the application of the FTC Endorsement Guides in the Guidelines of the Referral Program and reviews. Violation of such guidelines may result in removal of the content and exclusion from the referral program.

B.5 — State consumer protections

B.5.1 Residual rights. These Specific Conditions do not prejudice the rights of the U.S. resident consumer provided by applicable state laws, including — by way of example:

• California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) for California residents;

• California Civil Code §1789.3 on electronic services to consumers;

• New York General Business Law §349 on unfair trade practices;

• Texas Deceptive Trade Practices Act and similar state laws on consumer protection.

B.5.2 CCPA/CPRA disclosure. California residents benefit from the specific rights provided by the CCPA and CPRA, detailed in the Privacy Policy under the “California Privacy Notice” section. The exercise of CCPA/CPRA rights is free and accessible through the “Do Not Sell or Share My Personal Information” procedure.

B.6 — Tax reporting (1099-K, W-9) — future feature

B.6.1 Current status. As of today, Stravagando operates predominantly in EU/EEA territory. The U.S. tax reporting obligations (including Form 1099-K and collection of Form W-9) pursuant to the Internal Revenue Code and the implementing measures of the Internal Revenue Service (IRS) are therefore not operationally activated.

B.6.2 Future opening to the U.S. market. At the time of formal opening to the U.S. market, Stravagando will activate the necessary processes of:

• collection of Form W-9 from Hosts resident in the U.S. or qualified as U.S. persons;

• issuance of Form 1099-K to Hosts who exceed the minimum thresholds of transaction volume and number of transactions set by the IRS;

• transmission of tax information to the IRS according to the times and modalities provided.

U.S. Customers will be notified of any withholdings or supplementary requirements through update of these Conditions with notice pursuant to Art. 16.

B.6.3 Exclusion of Customer obligations. The obligation of tax reporting and backup withholding refers exclusively to Hosts operating as U.S. persons; the purchasing Customer of an Experience is not subject to 1099-K obligations, without prejudice to its personal tax obligations for income tax return.

B.7 — Additional age restrictions

B.7.1 Consistency with COPPA. For U.S. residents, the use of the Platform is subject to compliance with the Children’s Online Privacy Protection Act (COPPA, 15 U.S.C. §§6501-6506). Stravagando does not knowingly collect personal data of minors under 13 years resident in the U.S. for non-transactional purposes, and of minors under 18 years for transactional purposes (Bookings). Age verification is aligned with the provisions of Section 3 of the General T&C and Art. 2.2 of these Sales Terms.

B.8 — International sanctions

B.8.1 OFAC and export controls. The Customer declares not to reside in States subject to total OFAC sanctions or to be included in the Specially Designated Nationals List (SDN) or equivalent sanction lists. The use of the Platform in violation of OFAC sanctions, EAR (Export Administration Regulations) or ITAR (International Traffic in Arms Regulations) is expressly prohibited and entails the closure of the Account.

VERSION HISTORY

Version 1.0 — In force from 24/04/2026