Accessibility statement

X-Flow website and online purchase service — xflow.comestai.io

Last updated: 13 October 2026

Come Stai S.p.A. provides this information pursuant to Article 12 and Annex IV of Legislative Decree No. 82 of 27 May 2022, which transposes Directive (EU) 2019/882 ("European Accessibility Act"), and the AgID Guidelines on the accessibility of services. The technical reference is the EN 301 549 standard with the WCAG 2.1 level AA guidelines.

1. Description of the service

X-Flow is the service through which Come Stai S.p.A. sells comestai app usage packages online to consumers, directly or through partner agencies. It includes:

• the packages showcase page, available at xflow.comestai.io/shop;
• the access pages dedicated to individual partners (landing pages);
• the purchase engine: choice of package, entry of the customer's details, payment, order confirmation;
• the online withdrawal function and the legal and informational pages published in the legal documents section.

2. How the service works

The user chooses a package, enters first name, last name, mobile phone number, email address and tax code, and accepts the contractual terms, the privacy notice and the consent to immediate performance of the service. In some flows payment takes place immediately; in others the payment link is sent to the email address provided. Payment is handled by a third-party provider. At the end the user receives a QR code, shown on the confirmation page and sent by email, to be scanned with the comestai app to activate the credits. The right of withdrawal can be exercised online through a personal link on the confirmation page and in the email. This information is also available as text on this page, in the languages offered by the language selector.

3. How the service meets the accessibility requirements

For the showcase, partner access, purchase and legal pages, the following measures are adopted, with reference to the requirements of Annex I of the decree and the WCAG 2.1 AA criteria:

• semantic structure of the pages: main heading, identified content area, "Skip to content" link and declared page language;
• purchase forms with a label associated with every field, required fields indicated, and error and status messages made available to assistive technologies;
• keyboard operability and a visible focus indicator with adequate contrast;
• colour contrast ratios checked with automated tools (WCAG 2.1 A and AA scan of all public pages) and corrected where insufficient;
• text alternatives for informational images, including the confirmation QR code, which is also made available by email, with the activation address shown as a text link;
• the PDF documents of the Contractual Terms and the Privacy Notice linked on the purchase pages in a structured format, with headings, lists, and the document language and title declared;
• prices shown with the wording "VAT included" and legal texts in HTML format, readable by assistive technologies, in nine languages.

4. Verification and monitoring

The compliance of the service is verified at every substantial change to the pages and, in any case, at least once a year, with a technical analysis against the WCAG 2.1 AA criteria and automated scans. User reports (point 8) are handled as non-compliances to be corrected. The documentation of the checks is kept for as long as the service is operational and may be made available to AgID upon request.

5. Compliance status and non-accessible content

This service is partially compliant with the requirements of the EN 301 549 standard and the WCAG 2.1 level AA guidelines, due to the non-compliances listed below.

a) Non-compliance with accessibility legislation

• testing with real assistive technologies (screen readers) and with keyboard-only navigation has not yet been completed across all functional paths;
• the payment module, provided by an external processor but integrated into the purchase path, is not excluded from the assessment: its accessibility by keyboard and with screen readers, and the supplier's accessibility documentation, are being verified;
• the payment link received by email expires after 10 minutes and cannot be extended by the user; the page shows the time remaining and, once the link has expired, a new link can be requested from the point of sale;
• some informational pages generated using third-party tools (page builders) may present, in places not yet individually verified, incomplete alternative text on decorative images or markup that is not fully semantic.

b) Disproportionate burden

No exemption for disproportionate burden or for fundamental modification is currently invoked under the applicable legislation.

c) Content not falling within the scope of the applicable legislation

• third-party content neither funded nor developed by, nor under the control of, Come Stai S.p.A. (for example, the cookie banner);
• multimedia content or documents published by third parties.

6. Tracking and disability-related data

Come Stai S.p.A. does not use tracking techniques (such as cookies or browser fingerprinting) from which it would be possible to infer disability conditions of users, nor does it collect information about the tools, settings or assistive technologies that users use to access the service. The partner access, purchase and legal pages do not load third-party analytics or profiling tools and use only a technical session cookie. On the showcase page, statistical analytics tools are activated only with the express consent given through the cookie banner. The payment module is provided by a third-party payment processor.

7. Preparation and review of this statement

This statement was drawn up on 30 July 2026 and last reviewed on 13 October 2026.

The method used is a self-assessment carried out by the service provider, with a technical analysis of the service's pages against the WCAG 2.1 AA criteria and an automated scan of all public pages. The information is verified periodically and at every change to the service, as indicated in point 4.

8. Oral information, feedback and contact details

Accessibility information is available in written form on this page and orally by telephone at +39 02 668141. Anyone who wants content in an accessible format as an alternative to a non-accessible document can request it by calling the same number or by writing to marketing@comestai.io: an accessible version of the document will be provided.

If you encounter an accessibility problem when using the service, you can report it to us by filling in the form below. You will receive a reply as soon as possible. Alternatively, you can write directly to the address above, indicating the page concerned and a description of the problem encountered.

9. Enforcement and redress procedure

If the reply to the report is not satisfactory, or if there is no reply, the user may contact the Agency for Digital Italy (AgID), the authority supervising the accessibility of services, through the channels indicated on its institutional website www.agid.gov.it.

10. Information about the service provider

• Name: Come Stai S.p.A.
• Registered office: Via A. Rizzoli 4, 20132 Milan (MI), Italy
• VAT number: 13043690968
• Accessibility contact: marketing@comestai.io
• Telephone: +39 02 668141