Information on the Processing of Personal Data Pursuant to EU Regulation 2016/679

Lungomare Immobiliare, headquartered in Muggia, Lungomare Venezia no. 7, VAT no. 01423650322, email address: dm@lungomareimm.com, in its capacity as the "Data Controller" (hereinafter "Controller") of your personal data (hereinafter collectively referred to as "Data"), of which you are the "Data Subject," pursuant to EU Regulation 2016/679 (hereinafter "Regulation"), and which Lungomare Immobiliare has acquired through the assignment of the mediation task, provides you with the following information so that you can give specific, unequivocal, informed, free, and conscious consent to the processing of the Data, which may also occur using IT and/or telematic tools.

1. Source of Data

The data necessary for the execution of the contractual relationship between the Parties, as well as data otherwise acquired within the scope of such activity, are collected by Lungomare Immobiliare directly from you and/or through third parties, as well as obtained by consulting certain public and private external databases.

2. Availability of the Information Notice

Lungomare Immobiliare provides you with the possibility to consult this information notice: a) at the first contact and, in any case, every time personal data of Clients are collected; b) whenever an express request is made to the Controller; c) by consulting the website homepage at https://lungomareimm.com.

3. Purposes of Data Processing

Lungomare Immobiliare processes your data for its business purposes, related or instrumental to its activity, for the following purposes:

a) purposes prescribed, in particular, by anti-money laundering legislation (Legislative Decree 231/2007, as amended and supplemented by Legislative Decree 90/2017), and, in any case, related to obligations established by laws, regulations, and EU regulations, as well as provisions issued by Authorities legally authorized by law or by supervisory and/or control bodies;

b) contractual purposes, related and instrumental to the establishment and management of relationships with clients, such as acquiring preliminary information for the possible conclusion of a contract;

c) assessing customer satisfaction regarding service quality, carried out directly by Lungomare Immobiliare or through specialized companies via personal or telephone interviews, interactive questionnaires, market research;

d) promotion of Lungomare Immobiliare's services through advertising materials, telephone contacts, and any other form of electronic communication (email, SMS, MMS, social network publications);

e) communication and/or transfer of data to third parties for the promotion and/or sale of products and services, using traditional and/or automated methods.

Regarding the purposes outlined in points c), d), and e), you are informed that you may revoke the expressed consent at any time according to the methods specified in this information notice.

4. Nature and Legal Basis of Data Provision

You have the right to know that data provision may be mandatory or optional and may entail consequences in case of refusal. In this regard, we specify that:

a) the processing of your data for the purposes outlined in points a) and b) of section 3 is mandatory, as it is imposed by law or otherwise necessary to fulfill contractual obligations (as indicated in Art. 6, paragraph 1, letters b and c) of the EU Regulation). Any refusal to process the data for the purposes indicated in point b) of section 3 will prevent Lungomare Immobiliare from executing the assigned task or concluding the contract of which you are a party;

b) refusal to process Data for the purposes outlined in points c), d), and e) of section 3 is optional and will not entail any detrimental consequences for you. You may revoke your consent at any time, limited to purposes related to sending advertising material, assessing service quality, conducting market research or commercial communication via telephone contacts or any other form of electronic communication (email, SMS, MMS, WhatsApp, website publications, social networks, etc.), carried out directly by Lungomare Immobiliare or through specialized companies via personal or telephone interviews, interactive questionnaires.

5. Special Categories of Data

Article 9 of the Regulation defines certain special categories of Data, indicating them as data suitable for revealing racial and ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, as well as genetic and biometric data, data relating to health or sexual life or sexual orientation. It is possible that Lungomare Immobiliare may come into possession of such data in relation to specific operations requested by you. In such a case, specific consent will be requested for the processing of such sensitive data, and Lungomare Immobiliare may use them only to the extent necessary to perform the requested services and operations.

6. Data Retention

Data will be retained for the time necessary to manage the contractual relationship and fulfill legal obligations, with particular reference to Anti-Money Laundering regulations. Data is always processed in full compliance with the principle of proportionality of processing (Art. 5, paragraph 1, letter c) of the EU Regulation), according to which all personal data and the various methods of processing must be relevant and not excessive concerning the pursued purposes, ensuring adequate security and confidentiality, also to prevent unauthorized access or use of personal data and the equipment used for processing, as well as lawful and fair processing.

7. Data Retention Periods.

Pursuant to Article 13, paragraph 2, letter a) of the Regulation, the following indications are provided regarding the data retention periods based on the different purposes of processing:

• With reference to letters a) and b) of section 3 above, the retention period is set at 10 years.

• With reference to letters c), d), and e) of section 3 above, the data is retained for the period necessary to manage the contract and fulfill legal obligations.

8. Data Processing Methods.

In relation to the purposes indicated in section 3 above, personal data may also be processed by a "Data Processor," meaning a natural person or a company external to Lungomare Immobiliare, to whom specific and defined data management and control tasks may be entrusted, and by one or more "Authorized Persons," who will process or use the data based on the instructions received from the Data Controller or the Data Processor (persons who, if not expressly indicated in this notice, are to be considered not yet designated and not necessarily to be designated if the processing is occasional, and whose details will be provided in case of their appointment).

Still in relation to the purposes mentioned above, data may be processed using manual, computer, and/or otherwise automated tools according to logic strictly related to the purposes of processing and, in any case, in a manner that ensures their security and confidentiality, even in the case of processing through remote communication tools.

9. Transfer of Data Abroad.

Data may be transferred to countries within the European Union and to third countries (i.e., non-EU countries) exclusively within the scope of the purposes referred to in letters a) and b) of section 3. In such cases, the intention to transfer personal data must be communicated to you in advance and authorized by you only if an adequate level of data protection equivalent to that of the European Union is ensured.

10. Data Communication.

Data, due to the established relationship and in order to facilitate and enable the completion of transactions, may be communicated to: i) external collaborators; ii) other business mediation agents (including companies) identified by the Data Controller to collaborate in fulfilling the assignment given by the Data Subject; iii) banks and other entities operating in the banking sector; iv) counterparties and their possible technicians and consultants; v) notaries for the preparation of notarial deeds and/or related activities pertaining to the assignment given to the Data Controller; vi) companies and/or professionals providing services for the completion of technical/cadastral/building/urban planning/legal and fiscal procedures; vii) insurance companies for the stipulation of policies related to the assignment given to the Data Controller; viii) websites for real estate advertising; ix) arbitration panels and, in general, all public and private entities to whom communication is necessary for the proper fulfillment of the purposes indicated in section 3); x) Supervisory/Control Bodies and other Authorities for purposes related to obligations provided by law (anti-usury law, anti-money laundering regulations) and/or by regulations, as well as by provisions issued by the same Authorities.

All entities belonging to the categories to which data may be communicated will use the data as "data controllers" pursuant to the law or specific consent, in full autonomy, as they are unrelated to the original processing carried out by Lungomare Immobiliare, or as "external data processors." To know at any time the entities to whom your data has been communicated, you may request an updated list by writing to the Data Controller at the Lungomare Immobiliare office.

Finally, your data will be known by all employees and collaborators of Lungomare Immobiliare, designated as data processors and/or authorized persons, in relation to the performance of the tasks and duties assigned to each.

The data processed by Lungomare Immobiliare will not be subject to dissemination.

11. Data Subject's Rights.

Within the limits and under the conditions provided by Articles 15 - 23 of the Regulation, Lungomare Immobiliare guarantees and recognizes the exercise of the following rights:

• The right to access personal data stored in its paper and/or electronic archives;

• The right to request rectification, updating, and deletion of data if incomplete or incorrect, as well as to object to their processing for legitimate and specific reasons;

• The right to obtain the rectification of inaccurate personal data without undue delay. Considering the purposes of the processing, you have the right to obtain the integration of incomplete personal data, including by providing a supplementary statement;

• The right to obtain the deletion of personal data concerning you without undue delay if one of the reasons listed in Article 17, paragraph 1 of the Regulation applies;

• The right to obtain the restriction of processing when one of the cases outlined in Article 18, paragraph 1 of the Regulation applies;

• The right to data portability within the limits and in the manner provided by Article 20 of the Regulation.

Furthermore, you have the right to withdraw consent for data processing at any time without affecting the lawfulness of processing based on consent given before withdrawal, as well as to object at any time to processing for marketing purposes (right to object).

You have the right to receive information about the actions taken regarding any of the above requests or the consequences arising from the exercise of any of the above rights without undue delay and, in any case, no later than one month from the receipt of the request, extendable by two months if necessary; you also have the right to file a complaint with a supervisory authority and to seek judicial remedies.

Except in cases where data processing violates the general principles established by the Regulation, the exercise of these rights must be relevant and justified and cannot imply the withdrawal of consent given or the request for deletion of data provided by you for the conclusion and execution of the contract referred to in section 3), letters a) and b), to the extent and as long as the data is necessary for such purposes.

These rights may be exercised, also through a representative, by submitting a request to the Data Controller at the following addresses:

Lungomare Venezia No. 7, 34015 Muggia, cell.: +393501439885, email address: dm@lungomareimm.com

In exercising your rights, you may grant, in writing, delegation or power of attorney to individuals, entities, associations, or organizations; you may also be assisted by a trusted person. To ensure the effective exercise of your rights, Lungomare Immobiliare will adopt appropriate measures to facilitate access to data, simplify procedures, and reduce response times to your request.

Finally, please note that you may lodge a complaint with the supervisory authority, the Italian Data Protection Authority, through the following means:

a) Registered letter with return receipt addressed to: Garante per la protezione dei dati personali, Piazza di Monte Citorio No. 121, 00186 Rome;

b) Email to: garante@gpdp.it or protocollo@pec.gpdp.it;

c) Fax to: 06/69677.3785.

All relevant information regarding complaints you may file is available on the Data Protection Authority's website at www.garanteprivacy.it