Accessibility

Document drafted in accordance with EU Directive 2019/882
(European Accessibility Act), transposed into Italian law by Legislative Decree
no. 82 of 27 May 2022, and with the Guidelines on the accessibility of IT tools
from the Agency for Digital Italy (AgID).

Reference Standard: WCAG 2.1 (Web Content Accessibility
Guidelines) — Level AA.

Version effective from: 30/05/2026


PREMISES

NAOLULU, owner of the website www.naolulu.com (hereinafter
"NAOLULU" or "the Owner"), is committed to making its
e-commerce site accessible to people with disabilities, in compliance
with current European and Italian regulations.

This Declaration describes the accessibility status of the
Site, the initiatives undertaken to ensure an inclusive experience,
and how users can report any critical issues.


ARTICLE 1 — COMMITMENT TO ACCESSIBILITY

1.1 NAOLULU recognizes the right of every person to access
information and online services without discrimination, in accordance
with the principles established by the UN Convention on the Rights of Persons
with Disabilities (ratified by Italy with Law 18/2009).

1.2 The Owner undertakes to:

a) Adopt international best practices in digital accessibility;

b) Progressively bring the Site's content into compliance with
WCAG 2.1 AA level standards;

c) Train its staff and suppliers on the importance of accessibility;

d) Constantly monitor the Site's accessibility level and
intervene to improve it;

e) Consider accessibility as a selection criterion when choosing
new tools, technologies, and suppliers.


ARTICLE 2 — ADOPTED ACCESSIBILITY STANDARDS

2.1 The www.naolulu.com website is developed following the
international standard WCAG 2.1 (Web Content Accessibility Guidelines),
version 2.1, AA conformance level, published by the World Wide
Web Consortium (W3C).

2.2 WCAG 2.1 is structured around four fundamental principles:

a) PERCEIVABLE: Information and user interface components
must be presented to users in ways they can perceive;

b) OPERABLE: User interface components and navigation
must be operable by all;

c) UNDERSTANDABLE: Information and the operation of user
interface must be understandable;

d) ROBUST: Content must be robust enough to be reliably
interpreted by a wide range of user agents, including assistive
technologies.


ARTICLE 3 — CURRENT STATUS OF CONFORMANCE

3.1 The Site is currently in a state of PARTIAL CONFORMANCE with
WCAG 2.1 AA level.

3.2 Partial conformance is declared because some content or
functionalities may not fully comply with all success criteria
of the standard, in particular:

a) SOME PRODUCT IMAGES may not have complete or descriptive
alternative text (ALT text), particularly for content
received from third-party suppliers (BrandsGateway and other
distributors);

b) SOME THIRD-PARTY MULTIMEDIA CONTENT (social widgets,
videos, plugins) may not be fully accessible, as they are
under the control of their respective providers;

c) KEYBOARD NAVIGATION may not be optimal in
specific sections of the Site;

d) SOME INTERACTIVE ELEMENTS may not be fully
optimized for screen readers.

3.3 NAOLULU is actively working to overcome these limitations
through a continuous improvement plan, described in the following
Article 6.


ARTICLE 4 — SITE ACCESSIBILITY FEATURES

4.1 The Site has been designed to offer the following
accessibility features:

NAVIGATION
— Logical and hierarchical content structure
— Consistent navigation menu across all pages
— Breadcrumbs (navigation paths) to guide the user
— Full keyboard navigation capability
— Skip links to jump to main content

CONTRASTS AND COLORS
— Contrast ratios between text and background conforming to WCAG standards
— Information is not conveyed exclusively through color (e.g., errors indicated also by text, not just by red)
— Color palette designed to be perceivable even by users
with color blindness

READABILITY
— Legible fonts and appropriate sizes
— Ability to enlarge text up to 200% without loss of
functionality
— Optimized spacing between lines and paragraphs
— Correctly declared content language

MULTIMEDIA CONTENT
— Product images with descriptive alternative text (ALT text)
where possible
— Videos with subtitles or text transcripts, where present

FORMS AND INTERACTIONS
— Descriptive labels associated with all form fields
— Clear and contextual error messages
— Visual confirmations of completed actions
— Adequate session times with the possibility of extension

COMPATIBILITY WITH ASSISTIVE TECHNOLOGIES
— Semantic HTML code to support screen readers
— ARIA (Accessible Rich Internet Applications) attributes where necessary
— Testing with major screen readers (NVDA, JAWS, VoiceOver)


ARTICLE 5 — TECHNOLOGIES USED

5.1 The technologies used to develop the Site and on which
accessibility conformance depends are:

— HTML5 (HyperText Markup Language)
— CSS3 (Cascading Style Sheets)
— JavaScript
— ARIA (WAI-ARIA 1.1) — Web Accessibility Initiative

5.2 The Site is hosted on the Shopify platform, which complies with
the latest accessibility standards.


ARTICLE 6 — IMPROVEMENT PLAN

6.1 NAOLULU is committed to continuously improving the Site's
accessibility through the following actions:

a) PERIODIC AUDITS: semi-annual reviews of the accessibility level
with automated tools and manual tests;

b) TRAINING: continuous updating of staff and suppliers
on digital accessibility topics;

c) PROGRESSIVE CONTENT IMPROVEMENT: progressive integration
of alternative text (ALT text) for product images;

d) TECHNICAL OPTIMIZATION: gradual code refactoring to
align with WCAG 2.1 standards;

e) LISTENING TO USERS: systematic collection of feedback received
from users with disabilities to identify new areas for improvement;

f) SUPPLIER EVALUATION: preference for partners and technologies that
natively ensure accessibility.


ARTICLE 7 — BROWSER AND DEVICE COMPATIBILITY

7.1 The Site is optimized for the following browsers in their latest
versions:

— Google Chrome
— Mozilla Firefox
— Safari (Desktop and Mobile)
— Microsoft Edge

7.2 The Site is responsive and automatically adapts to:

— Desktop and laptop computers
— Tablets
— Smartphones

7.3 The Site is compatible with major assistive technology tools,
including:

— NVDA (NonVisual Desktop Access)
— JAWS (Job Access With Speech)
— VoiceOver (macOS and iOS)
— TalkBack (Android)
— Screen magnification software
— Alternative keyboards and voice command systems


ARTICLE 8 — SUGGESTIONS FOR USERS

8.1 To improve their browsing experience on the Site,
users can:

a) USE THE BROWSER'S ZOOM CONTROLS (Ctrl + / Cmd +) to
enlarge the content;

b) ACTIVATE THE HIGH-CONTRAST MODE of their operating
system or browser;

c) USE KEYBOARD NAVIGATION by using the Tab key to
move between interactive elements;

d) ENABLE THEIR DEVICE'S SCREEN READERS for
voice content reading;

e) REQUEST personalized assistance by contacting Customer
Service.


ARTICLE 9 — REPORTING ACCESSIBILITY BARRIERS

9.1 If a user encounters difficulties in accessing or using
the Site due to accessibility barriers, they are invited
to report it to the Owner at the following contacts:


Email: info@naolulu.com
Certified Email: diana.design@pec.it

9.2 The report should include:

a) The affected page of the Site www.naolulu.com

b) A detailed description of the problem encountered;

c) The device, browser, and assistive technologies potentially
used;

d) Their contact details to receive a response.

9.3 NAOLULU undertakes to:

— Provide an initial response to the report within 5 business
days;

— Indicate the estimated resolution times, where technically possible;

— Offer, where necessary, alternative ways to access the
requested information or services (phone assistance, email
with detailed descriptions, etc.).


ARTICLE 10 — PERSONALIZED ASSISTANCE

10.1 In case of difficulty placing an order or finding
information on the Site, users with disabilities can request
personalized assistance from Customer Service:

Email: naolululab@gmail.com
Hours: Monday-Friday, 9:00 AM-6:00 PM (CET)

10.2 NAOLULU staff are available to:

— Provide detailed product information via email;

— Assist by phone or email during the purchasing process;

— Send detailed text descriptions of product images;

— Manage orders by phone or through alternative channels, where
necessary.


ARTICLE 11 — ALTERNATIVE REMEDIES

11.1 If a user is unable, due to accessibility barriers,
to access content or a functionality of the Site, they can
request from Customer Service:

— The content in an alternative accessible format (text,
accessible PDF, audio file);

— The execution of operations on their behalf (e.g., completing
the order by phone);

— Detailed instructions to overcome the specific barrier.

11.2 These alternative services are provided at no additional cost
to the user.


ARTICLE 12 — COMPLAINTS AND ESCALATION PROCEDURE

12.1 If the report does not receive an adequate response or the user
believes the reported barrier has not been resolved, they can:

a) Submit a formal complaint to Certified Email: diana.design@pec.it

b) Contact the competent supervisory authorities:

AGCOM (Italian Communications Regulatory Authority)
Website: www.agcom.it

AgID (Agency for Digital Italy)
Website: www.agid.gov.it

c) Take legal action with the competent judicial authorities.


ARTICLE 13 — EVALUATION METHODOLOGY

13.1 This Declaration has been drafted based on:

a) Internal self-assessment carried out by the Owner using
automated analysis tools (for example: Google Lighthouse,
WAVE, Axe DevTools);

b) Manual navigation tests with keyboard and major
screen readers;

c) Feedback received from Site users.

13.2 NAOLULU has not, as of the date of this Declaration,
undergone a formal conformance assessment by an independent
third-party body. It reserves the right to do so in the future,
consistent with business growth and the evolution of applicable
regulations.


ARTICLE 14 — UPDATES TO THE DECLARATION

14.1 This Declaration is updated at least annually, and
whenever substantial changes to the Site occur that
affect the accessibility level.

14.2 The date of the last revision is indicated at the bottom of this
document.

14.3 Previous versions of the Declaration are archived by
the Owner and available upon request.


ARTICLE 15 — CONTACTS

15.1 For any inquiries regarding the Site's accessibility:

General Email: naolululab@gmail.com
Certified Email: diana.design@pec.it
Postal address: Via Federico Caudana, 26100, Cremona
Customer service hours: Monday-Friday, 9:00 AM-6:00 PM (CET)


NAOLULU
VAT Number 01844450195

Document updated on: 30/05/2026