Last Update January 2019

The DIAMAN Tech S.R.L. and DIAMAN Capital Ltd undertake to protect and safeguard the privacy of its Customers: this privacy policy, given to Customers and to anyone else working in their name and on their behalf, explains how the DIAMAN Tech S.R.L. and DIAMAN Capital Ltd (hereafter "The Company"), undertakes to protect the information collected for the provision of the services offered. The technology of the Company's products and services is, in fact, constantly evolving to ensure adequate levels of privacy, security and transparency for users.

In particular, this document describes how the collected data are used and managed: we hope to explain it in a clear and understandable way, but we will provide in the following the contact details needed to contact us if the interested party wants to ask further questions.

In general, any information or personal data that will be provided to the Company in the use of the products and services offered by the Company (the "Services"), as better defined later, will be treated according to the internationally recognized principles of lawfulness, correctness, transparency, purpose limitation and retention, data minimization, accuracy, integrity and confidentiality.

This privacy policy was prepared after 24 May 2018; occasionally it may require modification, also due to changes in the applicable legislation. To stay updated, we invite the interested party to regularly visit a specific section on the web pages (https://www.ex-ante.it/privacy-policy/ or https://app.exantecrypto.com/d/indexPrivacy.ic) to get to know the most recent and updated version.

By using our Services, you consent to the use of your data pursuant to this Privacy Policy. A necessary note: if the interested party does not agree with this Privacy Policy, it is necessary to stop using our Services.

At the same time senses of the art. 13, Legislative Decree 30 June 2003 n. 196 and of EU Regulation 2016/679, we also inform you that DIAMAN Tech S.R.L. and DIAMAN Capital Ltd guarantee, within the framework of regulatory provisions, that the processing of personal data takes place in compliance with fundamental rights and freedoms, as well as the dignity of the person concerned (Article 4, paragraph 1, letter i) of the code) with particular reference to privacy, personal identity, the right and protection of personal data. This page describes how to manage the site https://login.ex-ante.it and https://app.exantecrypto.com in relation to the processing of personal data of those who interact with the web service: the information is provided pursuant to Legislative Decree 196/2003 (hereinafter the Privacy Code) only for the site in question and not for other websites that may be consulted by the user through links, of which DIAMAN Tech S.r.l. and DIAMAN Capital Ltd are in no way responsible.

HOLDER OF THE PRIVACY POLICY

Data controllers, pursuant to art. 26 of the 2016/679 EU Regulation, relative to all the data provided by the customer and in relation to the purposes described below are:

DIAMAN Tech S.r.l.
Via Riccardo Lombardi 14/4
30020 - Marcon (VE) - Italy
P. IVA IT04135450270

And:

DIAMAN Capital Ltd
29/14 Vincenti Building
Strait Street
VLT1432 - La Valletta - Malta
VAT MT25223436

DEFINITIONS

For the purpose of helping and guaranteeing a clearer and unimaginable understanding of DIAMAN Tech S.r.l. and DIAMAN Capital Ltd define the meaning of the following terms:

Personal data: means any information concerning an identified or identifiable natural person ('data subject'); an individual is identified as identifiable, either directly or indirectly, with particular reference to an identifier such as a name, an identification number, location data, an online identifier or one or more characteristic elements of his physical identity, physiological, genetic, psychological, economic, cultural or social;
Treatment: means any operation or set of operations performed with or without the aid of automated processes and applied to personal data or sets of personal data, such as the collection, registration, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, cancellation or destruction;
Data controller: the natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of processing personal data; where the purpose and means of such processing are determined by Union or Member State law, the controller or the specific criteria applicable to his designation may be established by Union or Member State law;
Co-owner: when two or more owners jointly determine the purposes and the means of processing, they are co-owners of the processing;
Controller: the natural or legal person, public authority, service or other body that processes personal data on behalf of the controller;
Recipient: means the natural or legal person, the public authority, the service or another body that receives personal data, whether it is a third party or not. However, public authorities that may receive communication of personal data in the context of a specific investigation in accordance with Union or Member State law are not considered recipients; the processing of such data by these public Authorities complies with the applicable data protection rules according to the purposes of the processing;
Third: the natural or legal person, the public authority, the service or other body other than the data subject, the data controller, the controller and the persons authorized to process personal data under the direct authority of the owner or manager;
Consent of the interested party: any manifestation of free will, specific, informed and unequivocal of the interested party, with which he expresses his assent, through a declaration or unequivocal positive action, that the personal data concerning him / her are object of treatment;
Violation of personal data: the security breach that involves accidental or unlawful destruction, loss, modification, unauthorized disclosure or access to personal data transmitted, stored or otherwise processed;
Binding corporate rules: policies on the protection of personal data applied by a controller or controller established in the territory of a Member State to the transfer or set of transfers of personal data to a controller or responsible for processing in one or more third countries, in the context of a business group or group of undertakings carrying out a common economic activity;
Supervisory Authority: means the independent public authority established by a Member State in accordance with Article 51;
Controlling authority concerned: a control authority involved in the processing of personal data because: a) the controller or processor is established in the territory of the Member State of that control authority; b) data subjects residing in the Member State of the Control Authority are or are likely to be substantially influenced by the processing; or c) a complaint has been filed with that Supervisory Authority.
Cross-border treatment: means (a) processing of personal data which takes place within the framework of the activities of establishments in more than one Member State of a controller or controller in the Union where the controller or processor is established in more than one Member State; or (b) processing of personal data which takes place within the framework of the activities of a single establishment of a controller or controller in the Union, but which affects or is likely to substantially affect data subjects in more than one Member State;

TREATMENT OPERATIONS AND RELATED PURPOSES

All personal information you provide is the result of your free choice. The information you provide us by sending an e-mail and / or completing the registration form is used exclusively to reply to your questions or to satisfy requests made by you; our organization, upon demonstration of your specific free consent, may use personal data for purposes such as sending promotional and commercial information, by post or telephone and / or by electronic communications such as e-mails, faxes, messages of the type SMS, MMS or newsletter or with automated systems, related to new offers of products or services, in order to improve the services offered or to propose commercial offers aimed in all cases to identify your needs and new opportunities for your possible interest: in this context and for the aforementioned purposes, consent to the processing of personal data is merely optional, without prejudice to the right to object, in whole or in part.

The lack of consent will not have any consequences on the relationships in being or in the process of being established for the activation of the requested service, precluding only the performance of the activities indicated above.

The Company will process the personal data provided by the Clients only in the ways established in this Privacy Notice and in compliance with the laws in force. Personal Data will be used for the following purposes:

Provision of the service / fulfillment of contractual and pre-contractual obligations: for purposes related to the execution of the obligations envisaged in the contract signed (or under negotiation).
Legitimate prevailing interest of the Company: for checks and evaluations on the results and on the progress of the relationship, as well as on the risks connected to it (such as: truthfulness of the data provided, solvency even in the course of a relationship); to transmit questionnaires and make telephone calls to improve the efficiency of products and services offered by the Company regarding the level of customer satisfaction; to draw up anonymous statistics on services rendered; to draw up statistics on participation in fairs, events, seminars and any other initiative aimed at promoting the Company's services; the provision of Personal Data for this purpose is not mandatory, otherwise it will not be possible to provide any Service.
Obligations of the law to which the Company is subject: for compliance with the law and / or provisions of public bodies, which require the Company to collect and / or further process certain types of personal data.
Sending promotional offers to its customers: the treatment for this purpose is based on the legitimate interest of the Company to transmit marketing communications via e-mail and to make telephone calls concerning products and services similar to those already purchased by Users.
Marketing: send marketing communications on products and services of the Company, to anyone who has previously given their consent, including market research and surveys, by e-mail, SMS, by phone, through banners, instant messaging, through an operator, via paper mail and through the official social pages of the Company (RSS, Linkedin and YouTube).
Entering and sending communications via a mailing list.

NATURE OF TREATMENT

The bases used by the Company to process Personal Data, according to the purposes indicated in the previous Article 2, are the following:

Provision of service / fulfillment of contractual / pre-contractual obligations: the processing for this purpose is necessary for the execution of the contract signed (or under negotiation) between the Company and the interested party and therefore, to be able to use the services contractually agreed. The provision of Personal Data for this purpose is not mandatory, but in the absence it will not be possible to provide any Service;
Legitimate prevailing interest of the Company as: treatment performed to check and evaluate the results and the progress of the contractual relationship, as well as the risks connected to it (namely: truthfulness of the data provided, solvency even in the course of a relationship). Treatment carried out to improve the quality of the services offered by the Company: to this end, it will be possible to send questionnaires and market surveys or make telephone calls or chat sessions. These market surveys / surveys in general will be studied in such a way as to minimize the use of Personal Data;
Legal obligations: the processing for this purpose is necessary for the Company to fulfill any legal obligations. The Personal Data submitted to the Company will be processed according to the applicable regulations, which could entail their conservation and communication to the competent Authorities;
Promotional communications to its Customers: the processing for this purpose is based on the legitimate interest of the Company to transmit marketing communications concerning the integration of products and services already purchased by our Customers or the promotion of similar products and services. The interested party may interrupt, at any time and for free, the receipt of these communications, writing info@ex-ante.it, and without prejudice to the lawfulness of the processing in the period of validity of the same consent;
Marketing: the processing for this purpose is based exclusively on the consent of the Customer, freely revocable at any time and without prejudice to the lawfulness of the processing in the period of validity of the same consent. In case of revocation, the Company will not proceed with any further communication.
Marketing: the processing for this purpose is based exclusively on the consent of the Customer, freely revocable at any time and without prejudice to the lawfulness of the processing in the period of validity of the same consent. In case of revocation, the Company will not proceed with any further communication.

The processing of personal data may be carried out with or without the aid of electronic means and in any case automated, and will include all the operations necessary for the processing in question provided for in art. 4 paragraph 1, letter a, D.Lgs. June 30th 2003 n. 196 and the EU Regulation 2016/679: in any case, the treatment will be carried out in compliance with all precautionary measures, which guarantee its security and confidentiality. Personal data will be processed exclusively by designated persons responsible for processing or by personnel in charge of processing, appointed by the Data Controller, DIAMAN Tech Srl, which has prepared all the minimum computer security measures necessary to minimize the risk of violation of the privacy of users by third parties, constantly updated and whenever it proves indispensable.

TREATMENT METHOD

The processing of personal data is carried out by means of the following operations: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, deletion and destruction of data.

Personal data are subjected to electronic and / or automated processing, through the use of a storage space hosted on hardware owned by the Company located in Italy and Malta.

The data will be processed in such a way as to guarantee continuous security and confidentiality and may also be carried out with the help of electronic and / or automated means.

In accordance with European regulations and national data protection laws, the Company has put in place specific procedures to prevent unauthorized access to data, in addition to their improper or illegal use, as well as to prevent destruction or loss, even accidental of the data themselves.

Only personnel duly authorized by the owner can access the data during the course of their work. Both DIAMAN Tech S.R.L. and DIAMAN Capital Ltd draw on the same database that is being processed.

NAVIGATION DATA

The Personal Data of the interested party may be shared with the subjects indicated below ("Recipients"):

Subjects that typically act as data controllers, ie: individuals, companies or professional firms that collaborate and / or provide assistance and advice to the Company in accounting, administrative, tax, legal, tax, financial, labor, debt collection, with regard to the provision of services, mailing of advertising material or contractual communications, companies that perform market analysis and research; a complete list of all managers can be requested by contacting the e-mail address: info@ex-ante.it;
Subjects with whom it is necessary to interact for the provision of the Services (platforms for the management of e-mail services, online questionnaires, webinars, which specifically are also in charge of following up any requests for cancellation forwarded by the Customers);
Subjects with whom it is necessary to interact for the provision of communication services, events and seminars, even online;
Subjects delegated to perform technical maintenance activities (including maintenance of network equipment and electronic communications networks);
Persons authorized by the Company to process Personal Data, necessary to perform activities strictly related to the provision of the Services; towards such persons, it operates a legal obligation of confidentiality;
Factoring companies, credit institutions, credit insurance companies;
Professional orders or training bodies accredited with these Orders;
Subjects, bodies or competent authorities to whom it is mandatory to communicate personal data to comply with legal obligations, to prevent abuse or fraud, or for orders of the Authorities.

The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of internet communication protocols. This is information that is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of the computers used by users connecting to the site, the addresses in the Uniform Resource Identifier (URI) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (success, error, ...) and other parameters related to the operating system and the user's computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site.

CONSERVATION OF PERSONAL DATA

Personal Data processed for the purpose of "Provision of Service / Contractual obligations" will be kept for the time strictly necessary for the pursuit of the aforementioned purpose.

In any case, as such Personal Data are processed to provide the Services, the Company may retain them for a longer period, in particular as may be necessary to protect its interests from possible liability for the Services provided.

The Personal Data processed for the purposes of Marketing, will be kept by the Company until the revocation of the consent given by the Interested Party.

Once the consent has been withdrawn, the use of the data for these purposes will cease, but the related data may be stored in order to protect the interests of the Company from possible liability based on such processing.

Personal Data processed for the purpose of sending commercial information will be retained by the Company until the Data Subject objects to the processing through the procedure available at the bottom of each e-mail.

The Personal Data processed for the purpose of Compliance with legal obligations, will be kept by the Company for the period provided for by specific legal obligations or applicable regulations.

FACULTY TO CONFER THE DATA

The optional, explicit and voluntary sending of e-mails to the addresses indicated on this site entails the subsequent acquisition of the sender's address, necessary to respond to requests, as well as any other personal data included in the message. Personal data will be processed for the time strictly necessary to achieve the purposes for which they were collected or to fulfil specific legal obligations: specific security measures are observed to prevent the loss of data, illicit or incorrect use and unauthorized access.

COOKIES

Cookies are fragments of text sent by the software that manages the site to the personal computer of the user / visitor. A cookie may contain information such as the user's ID, which the site uses to check the pages visited, but the only personal information that a cookie can contain are those provided by the user: in any case it is reiterated that no personal data of users is acquired from the site and cookies are not used to transmit information of a personal nature, nor are so-called persistent cookies of any kind or systems for tracing users. The use of session variables (whose values are not stored permanently on the user's computer and disappear when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) and data on the use of the software necessary to allow the safe and efficient exploration of the site: the session variables (cd cookies) can avoid the use of computer techniques that are potentially detrimental to the privacy of users' browsing and do not allow the acquisition of personal data user identifiers. In this site a session cookie is active, in order to store temporary data, which expires 30 minutes after the end of browsing. This site is also registered in Google Analytics for the sole purpose of collecting statistical navigation data. All data collected is anonymous and is not used for other purposes. If the site is the subject of promotion and webmarketing the additional cookies are related to the circuit used for the same (eg Google Adwords) but is not under any circumstances made use of profiling cookies. Finally, if the buttons or "social" modules are activated on the site, the cookies further present are those of the respective channels.

ReCAPTCHA

Some forms on this site require the use of Google's reCAPTCHA service before they can be submitted. If you consent to the use of Google's reCAPTCHA service, a cookie is created that stores your consent. This cookie is deleted after thirty days.

DATA KNOWLEDGE

Only data subjects appointed by the writing company DIAMAN Tech S.r.l. and DIAMAN Capital Ltd the data controller, as managers or processors.

COMMUNICATION AND DIFFUSION

The data can be communicated, with this term meaning to give it information to one or more specific subjects, in the following terms:

to subjects, public and private, who can access the data by virtue of the provision of law, regulation or community legislation, within the limits set by these rules (for example, institutions and social security and welfare institutions, associations of local authorities, public administrations and bodies, associations, foundations, associations or bodies of an associative and / or insurance type).
to subjects who need access to data for purposes that are ancillary to the relationship between the parties, within the limits strictly necessary to carry out auxiliary tasks (cited as indicative, banks and credit institutions, service companies, carriers and companies of shipments).
to our consultants, within the limits necessary to carry out their duties in our organization, subject to our letter of appointment which imposes the duty of confidentiality and security.

The data will not be disclosed, with this term being intended to give it knowledge to indeterminate subjects in any way, including through their availability or consultation, unless a specific consent, free and informed, granted for each type of treatment.

For purposes related to the execution of the contract, some data could be communicated to recipients sites outside the EU Economic Area. If this happens, the Company ensures that the processing of personal data by these recipients will be in compliance with applicable law.

The subjects to whom the data will be communicated will be appointed as Data Processors. A complete list of Company Managers can be requested by contacting the e-mail address: info@ex-ante.it.

RIGHTS OF THE INTERESTED

The interested party has the right to ask the data controller at any time:

Access to your Personal Data, (and / or a copy of such Personal Data), as well as further information on the treatments being carried out on them;
The correction or updating of personal data;
Cancellation of personal data from databases;
Limiting the processing of personal data;
To exercise the right to the portability of data, that is to obtain in a structured format, in common use and readable by automatic device, a copy of the Personal Data provided to the Company, or to request transmission to another Data Controller;
To oppose the processing of personal data;
Revoke your consent for the purposes of marketing.

The holder will provide the interested party with information on one or more of the actions taken in the previous list without justified delay and, in any case, no later than one month after the request itself. This deadline may be extended by two months, taking into account the complexity and the number of requests, with consequent disclosure to the interested party of this extension and of the reasons for the delay, to be provided within one month of receiving the request.

The Data Subject also has the right to lodge a complaint with the competent Supervisory Authority (for Italy, Garante Privacy, http://www.garanteprivacy.it ), if he / she considers that the processing of his Personal Data is contrary to current legislation.

The interested party may exercise the rights referred to in this article by sending an e-mail to the following address: info@ex-ante.it, or to the e-mail address of the data controller.

CHANGES

This Information Notice is effective from 24 May 2018. The Company reserves the right to modify or simply update its content, in part or completely, also due to changes in the applicable legislation. The Company invites the interested party to regularly visit the specific section of the website (https://www.ex-ante.it/privacy-policy/ or https://app.exantecrypto.com/d/indexPrivacy.ic) to take cognizance of the most recent and updated version of the Information in order to be always updated on Personal Data collected and on the use made of it by the Company.