Guideline on the processing of personal data pursuant to art. 13-14 EU Reg. 2016/679

The Parties involved: Internet site browsers.

Real Diamond Invest S.r.l. as Data Controller of personal data processing, pursuant to and in accordance with EU Reg. 2016/679 hereafter ‘GDPR’, hereby informs you that the aforementioned regulation includes the protection of data of the parties involved regarding the processing of personal data and that this processing will be based on principles of correctness, lawfulness, transparency and protection of Your privacy and Your rights.

Your personal data will be processed in accordance with the legislative provisions of the aforementioned regulation and the confidentiality obligations therein.

Purposes of processing: your data will be particularly processed for the following purposes related to the fulfillmentof legislative or contractual obligations:

• Technical and functional access to the site no data will be kept after the closing the of Browser;
• Statistics and analysis purposes of navigation and users;

Your personal data may also, prior your consent, be used for the following purposes:

• Marketing and Advertising purposes;
• To possibly satisfy market surveys, statistics and promotional activities regarding also the shipping of promotional and advertising material;
• To inform you about our or/and other societies/commercial partners’ future commercial initiatives and new products, services and offers;

Data supply regarding the aforementioned purposes is optional for you and your refusal to data processing does not enable the onward of the relationship or the adequacy of the processing.

Method of processing data. Your personal data may be processed in the following ways:

• By electronic calculators using third party software systems;
• By electronic calculators using software systems managed or programmed directly;
• Processing of data collected by other parties;
• Processing by electronic calculators;
• “Blind” temporary processing.

Each data processing takes place in accordance with the articles. 6, 32 of the GDPR and through the proper security measures.

Communication: your data may be communicated to external persons aiming to manage the relationship and to third parties duly appoointed as Responsible for Data Processing particularly to:

• Linkedin: Advertising Coverage, Analytics/Measurement, Content Customization;
• Circulation: Your personal data will not be disclosed in any way.

Your personal data may also be transferred, in accordance with the purposes indicated above and with the guarantees requested from time to time, in the

following states:

• EU countries;
• UK;
• United States.

Storage term. Please note that, in accordance with the principles of lawfulness, purpose limitation and data minimization, pursuant to art. 5 of the GDPR, the storage term of your personal data is:

• Established for a period of time not exceeding the achievement of the purposes for which they are collected and processed for the execution and fulfillment of the contractual purposes;
• Established for a period of time not exceeding the fulfillment of the services provided;
• Established for a period of time not exceeding the achievement of the purposes for which they are collected and processed and in accordance with the mandatory time provided by the law.

Data Controller: the Data Controller, pursuant to the Law, is Real Diamond Invest S.r.l. (Piazza IV Novembre, 4, 20124 Milano (MI): e-mail: segreteria@realdiamondinvest.it; tel. +390272080749; P.Iva: 08398010960) in the person of the legal representative pro tempore.

You have the right to obtain from the Data Controller the cancellation (right to be forgotten), limitation, updating, correction, portability, opposition to the processing of personal data concerning You, as well as the possibility to exercise all the rights provided in articles 15, 16, 17, 18, 19, 20, 21, 22 of the GDPR.

EU Reg. 2016/679: Articles 15, 16, 17, 18, 19, 20, 21, 22 – Rights of the interested party

1.The interested party has the right to obtain confirmation of the existence or not of personal data concerning him / her, even if not recorded yet, and their communication in comprehensible form.

2. The interested party has the right to be supplied with:

a. The origin of personal data;

b. The purposes and methods of processing data;

c. The method applied in case of processing data with the aid of electronic instruments;

d. The identifying details of the Data Controller, of the manager and of the designated representative in accordance with article 5, paragraph 2; the parties or license;

e. To whom personal data may be communicated or that can gain knowledge as appointed representative of the Country, managers or assistants.

3. The interested party has the right to be supplied with:

a. Updating, correctionor, when needed, addition to the data;

b. Cancellation,” blind” conversion or data block processed in breachingof law, including data whose storage is not necessary for the purposes the data were collected for or subsequently processed;

c. Certification that the operations as per in letters a) and b) have been brought to the attention of, also regarding their content, of those to whom the data have been communicated or circulated, except in case this fulfillment is impossible or involves a use of means manifestly disproportionedto the protected right;

d. Data portability.

4. The interested party has the right to resist, wholly or in part:

a. To the processing of personal data, by legitimate reasons, concerning him, even if relevant to the purpose of the data collection;

b. To the processing of personal data related to him for the purpose of sending advertising or direct sale material or for market researchers or commercial communication.