Note on Personal Data Treatment

Ex Art. 13 Regulation EU 2016/679

Dear Client,

in observance to Regulation (UE) 2016/679 “concerning the protection of physical people with regards to the treatment of personal data, as well as the free circulation of such data” (below the Regulation), we wish to make You aware of Your personal data treatment - following Your potential consensus in respect to the rights and fundamental liberties, with special reference to the confidentiality and protection of Your personal data – that we will be putting in place in the provision of our services.

Article 13 of the Regulation established that when the Data Controller gathers data from the person in question, he must supply a series of information that hereby we present You.

A. Data Controller is UCapital24 S.r.l., registered in Via Molino delle Armi n.11, 20123, in Milano, C.F. e P.Iva 10144280962.

B. Your data will be treated in legitimate, correct and transparent manner, ensuring they are adequate and correct, pertinent and limited to what necessary in regards to the pursued purpose of the treatment that, in this case, consist in the provision of the services acquired and all related activities.

C. The legal base of the treatment is formed by:

• Execution of the contractual obligations;

• Fulfilment of legal obligations.

D. We inform you that the personal data inherent to, connected and/or instrumental to the contractual relation, will also be treated for the legitimate interests of the Data Controller (such as, fraud prevention, intergroup communications for internal administrative reasons, network and information systems security and of the related services offered or made available through the network and the systems themselves, etc), in respect to the legislation and confidentiality obligations.

E. We inform you that Your personal data could be communicated to:

• personnel employed by the Data Controller regularly authorized and formed in compliance to what foreseen in the Regulation;

• suppliers/partners to the Data Controller which provide the services and all connected activities (such as brokers, real estate intermediaries, platform managers);

• free professionals and consultants charged with the elaboration of data aimed at the financial and accounting management of the writer;

• entities to whose access to data is recognized by arrangements of law, regulations or community legislations.

F. We wish to inform You that, in case the purchased service would require the communication of Your personal data to “Extra UE” Countries (namely not belonging to the EU and or the European Economic Area), we will transfer them to the supplies therein located.

We do care to precise that the Regulation admits the transfer of personal data to Extra UE Countries in case a decision of Adequacy by the European Commission exists according to art. 45 (as of today it exists for: Andorra, Argentina, Australia – PNR, Canada, Faer Oer, Guernsey, Isle of Man, Israel, Jersey, New Zealand, Switzerland and Uruguay), or adequate guarantees according to art. 46, including binding business legislation according to art. 47.

Differently, the Regulation admits transfer of personal data to countries where a decision of Adequacy does not exist (including those of the US which have not adhered to the EU-USA shield c.d. Privacy Shield)., nor adequate guarantees, only in the case in which it is necessary – among others – to the execution of a contract (art. 49, par. 1, lett. b).

It is our duty to inform You that in this last case, upon transfer of Your personal data, it will not be possible to exert the rights listed in favour of the person in question by the Regulation (e.g. access, modification, deletion, limitation of the data treatment, etc.) nor to the Data Controller, nor directly to the third parties because the obligation of treatment and/or conservation of data according to the European Union standards are not predicted by the hosting countries, consequently no guarantees exist on the treatment and security of Your personal data.

G. We inform you that communication of the personal data is compulsory for the purposes above listed, being the treatment predicted for the execution of the contractual and legal obligations; it is therefore not necessary to provide your consensus.

H. Your personal data will be stored for the period of the duration of the contract and, later, for the time during which we’ll be obliged to conserve them for fiscal reasons and/or any other reason predicted by the law or Regulations.

I. You have the right to demand Your Data Controller access (art. 15), amendments (art. 16) or removal (art. 17) of Your personal data, limitations to the treatment which affect it (art. 18) or to oppose to their treatment (art. 21), in addition to the right to portability of data (art. 20).

J. We further inform you that You will be able to exert such before paragraph mentioned rights by sending the Data Controller the specific form (downloadable on the website of the Personal Data Protection Authorities https://www.garanteprivacy.it/home/modulistica-e-servizi-online), correctly filled, through the following methods:

via e-mail at the following address: privacy@ucapital24.com;

via postal services to UCapital24 S.r.l., registered in Via Molino delle Armi n.11, 20123 - Milano.

K. In appliance of Regulation Ue 2016/679 regarding the Protection of Personal Data, the DPO (Data Protection Officer) has been named by UCapital24 S.r.l., who You will be able to address for any need or request concerning the Personal Data Treatment writing at the following email address: dpo@ucapital24.com

L. Always according to Regulation UE 2016/679, you have the right to propose a formal claim to the Guarantor Authority at the address: https://www.garanteprivacy.it/home/modulistica-e-servizi-online, also to propose a jurisdictional appeal (art. 79).

UCapital24 Srl

UCapital24 S.r.l.