Disclosure on the use of Artificial Intelligence tools.

Data controller: Beneggi S.r.l.

Registered office: Meda (MB) Via Consorziale dei Boschi 7
VAT number and tax code: 08743220967

Dear Customer,

Pursuant to Article 13 of Law September 23, 2025, no. 132, as well as in accordance with Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR), I inform you that, in the performance of the professional assignment, the Firm may use artificial intelligence (AI)-based tools to support the entrusted activities.

1) In the performance of the assignment, the professional:

☑ makes use of and may make use of Artificial Intelligence (henceforth “AI”) systems of the type:

• Generative: assisted creation and reworking of texts, communication templates, document drafts and descriptive analysis.
• Conversational: language interfaces that understand and answer questions, useful for consulting and organizing data and documents.
• Agenting: systems that automate planning and execution of specific operational and management tasks, useful for streamlining workflows, classifying data, and activating internal processes under constant supervision of the professional.
• Predictive: use of statistical and machine learning functions to analyze accounting, tax, or management information to support professional evaluations.

These systems are used solely for technical and organizational support purposes, without replacing the intellectual, evaluative and decision-making activity of the professional, who remains fully responsible for the content and outcomes of the services rendered.

2) Characteristics and origin of AI systems

☑ Online: tools based on cloud platforms with database controlled and verified by the practitioner.
☑ Produced in the EU and, for specific functions, in non-EU countries (e.g., the U.S.), with standard data protection contractual clauses in accordance with Reg. EU 2016/679.

All technology providers used are selected on the basis of compliance with data protection and information security regulations, and if necessary appointed as Data Processors pursuant to Art. 28 GDPR.

3) Purpose of processing

The use of AI systems is confidential:

• To the analysis and management of the data provided by the Client;
• to the processing of drafts, outlines, consistency checks and automatic summaries;
• to optimizing internal workflows and improving service efficiency.

The use of AI does not change the original purpose of the assignment, but is an ancillary tool to benefit the quality and timeliness of performance.

4) Verification, accountability and human control

The practitioner verifies and validates each result produced by the IA tools before it is used or communicated to the Client.
Any margin of error or incompleteness is subject to manual review.
The use of IA in no way replaces professional judgment nor does it transfer to the IA provider any part of the responsibility associated with the performance of the work.
The final decision and evaluation remains entirely with the practitioner.

5) Data protection and security

Beneggi S.r.l. guarantees full compliance with the legislation on the protection of personal data (EU Reg. 2016/679, Legislative Decree 196/2003 and subsequent amendments).
The data processed through IA systems are limited, relevant and not excessive in relation to the purposes of the assignment.
Appropriate security measures are taken (encryption, authentication, pseudonymization, access control, logging of activities).
The information is not disseminated and is kept for the duration of the assignment and within the terms of the law.

6) Customer Rights

The Client may exercise the rights under Articles 15 – 22 of the GDPR (access, rectification, cancellation, restriction, opposition, portability) by written communication to the Firm’s office or by official PEC indicated on this website.

7) Updates and preservation

This policy may be updated in connection with regulatory, technological or organizational changes.
The most recent version will always be available on the Firm’s website or attached to the professional mandate.

Location: Meda (MB)
Date: October 09, 2025

Beneggi S.r.l.

Certified Public Accountants and Auditors
(pursuant to Art. 13 L. 132/2025 and EU Reg. 2016/679)