DIAMANTE Ecosystem - The Italian Culture Empire

Effective Date: 11/25/2025

INTRODUCTION

This Privacy Policy ("Policy") describes how Ass. Culturale Officina Del Territorio ("DIAMANTE", "we", "us", "our") collects, uses, shares, and protects the personal information of users who access and use the DIAMANTE ecosystem, accessible primarily through the domain diamante.live and all associated platforms, services, and brands, including but not limited to: TV/Streaming services, eCommerce Store, Community, educational and cultural content about Italian culture.

DIAMANTE operates globally and is committed to complying with applicable data protection regulations in all jurisdictions where it operates, including the European Union General Data Protection Regulation (GDPR), the United States California Consumer Privacy Act (CCPA/CPRA), Brazil's Lei Geral de Proteção de Dados (LGPD), Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), and other international privacy laws.

FUNDAMENTAL PRINCIPLES

A. NO SALE OF DATA

DIAMANTE DOES NOT SELL, RENT, OR TRANSFER YOUR PERSONAL DATA TO THIRD PARTIES FOR COMMERCIAL PURPOSES.

Your personal data is valuable and protected. We never sell it to data brokers, advertising agencies, or other third parties for commercial, advertising, or profiling purposes. This is a fundamental guarantee of our commitment to your privacy.

We share your data ONLY in the following strictly necessary cases:

·       With essential service providers acting on our behalf (hosting, payments, shipping)

·       With competent authorities when required by law (e.g., tax authorities, customs)

·       With your explicit consent for specific purposes (marketing, remarketing)

B. EXCLUSIVE USE WITHIN DIAMANTE ECOSYSTEM

DATA COLLECTED IS USED EXCLUSIVELY WITHIN THE DIAMANTE ECOSYSTEM.

All personal information we collect is used solely to provide and improve DIAMANTE ecosystem services:

·       TV/Streaming services for Italian cultural content

·       eCommerce Store for Made in Italy products

·       Community for Italian culture enthusiasts

·       Educational content and Italian language courses

·       Gamification system (points, levels, missions)

Your data is not used for purposes unrelated to our services and is not shared with third parties for commercial activities independent of the DIAMANTE ecosystem operations, except as expressly indicated in this Policy (necessary service providers, legal obligations, or with your explicit consent).

1. DATA CONTROLLER AND CONTACTS

Data Controller:

Ass. Culturale Officina Del Territorio

Registered Office: C.da Vibrata Snc, 64010 Colonella, Italia

VAT Number: 02188290676

Tax Code: 91049140675

Data Protection Officer (DPO):

Email: privacy@diamante.live

PEC: harvest@arubapec.it

EU Representative (Art. 27 GDPR):

Not applicable - Ass. Culturale Officina Del Territorio is based in the European Union (Italy)

2. PERSONAL DATA WE COLLECT

We collect different categories of personal data depending on the type of interaction you have with our services:

2.1 Identification and Contact Data

·       Full name

·       Email address

·       Phone number (optional)

·       Username and password (encrypted)

·       Date of birth (for age verification)

·       Country of residence

2.2 Billing and Payment Data

·       Complete billing address

·       Shipping address

·       Payment information (handled through PCI-DSS certified payment providers)

·       Tax code or VAT number (for invoicing, where applicable)

·       Local tax identification number (where required for customs procedures)

·       Order and transaction history

2.3 Data for DDP International Shipping

For international shipments from the eCommerce Store with DDP (Delivered Duty Paid) formula, we collect and share with carriers and customs authorities:

·       Recipient's full name

·       Complete shipping address

·       Phone number

·       Tax code or tax identification number (only if required by law)

·       Description and declared value of products

IMPORTANT: Our prices include EVERYTHING (shipping + VAT + duties + customs clearance where applicable). You will NOT pay additional costs upon delivery. Tax data is shared with customs authorities exclusively to comply with international legal obligations.

2.4 Usage and Navigation Data

·       IP address

·       Browser type and device

·       Operating system

·       Approximate geolocation data (country/city)

·       Pages visited and navigation path

·       Session duration

·       Referrer URL (origin)

·       Cookies and unique identifiers

2.5 Gamification and Learning Data

·       Points, levels, and badges earned

·       Completed missions

·       Progress in Italian language and culture courses

·       User-generated content (comments, reviews, Community posts)

·       Preferences and interests in cultural content

2.6 Communication Data

·       Email and text message history with our support

·       Customer service conversations

·       Feedback and surveys (if provided voluntarily)

2.7 Data We DO NOT Collect

DIAMANTE does NOT collect special categories of personal data (Art. 9 GDPR), such as:

·       Racial or ethnic origin

·       Political opinions

·       Religious or philosophical beliefs

·       Trade union membership

·       Genetic or biometric data

·       Health data

·       Data concerning sex life or sexual orientation

3. PURPOSES AND LEGAL BASES OF PROCESSING

We process your personal data only when a valid legal basis exists under applicable regulations:

3.1 Contract Performance (Necessary Basis)

We process your data to provide you with requested services:

Purposes:

·       Creation and management of your user account

·       Provision of TV streaming services and cultural content

·       Processing and fulfillment of eCommerce orders

·       Payment management and invoicing

·       International shipping of products with DDP (Delivered Duty Paid) formula

·       Management of customs procedures and payment of VAT, duties, and customs clearance on your behalf

·       Management of gamification system (points, levels, missions)

·       Provision of courses and educational content on Italian culture

·       Customer assistance and technical support

·       Sending functional communications (order confirmations, shipments, account updates)

Legal basis: Contract performance (Art. 6(1)(b) GDPR)

3.2 Legal Obligations (Necessary Basis)

We process your data to comply with legal obligations:

Purposes:

·       Retention of invoicing data for tax obligations (10 years)

·       Management of customs procedures for international shipments

·       VAT, duties, and tax declarations to competent authorities

·       Response to requests from competent authorities

·       Fulfillment of accounting and administrative obligations

·       Compliance with anti-money laundering regulations

Legal basis: Legal obligation (Art. 6(1)(c) GDPR)

3.3 Legitimate Interest (Necessary Basis)

We process your data for our legitimate business interests:

Purposes:

·       Security and fraud prevention

·       Protection of IT systems

·       Service and user experience improvement

·       Aggregate and anonymous statistical analysis

·       Display of non-personalized advertising through internal SSP

·       Litigation management and defense of rights in court

·       Detection and prevention of illicit activities

Legal basis: Legitimate interest (Art. 6(1)(f) GDPR)

Balancing of interests: We have assessed that these processing activities do not override your fundamental rights and freedoms. You can object at any time by contacting privacy@diamante.live.

3.4 Explicit Consent (Optional Basis)

We request your explicit consent for:

Purposes:

·       Sending newsletters and promotional communications

·       Direct marketing on DIAMANTE products and services

·       Profiling for personalized offers

·       Remarketing and personalized advertising on third-party platforms (Meta, Google, etc.)

·       Profiling cookies and behavioral tracking

·       Use of data for market research

Legal basis: Consent (Art. 6(1)(a) GDPR and Art. 7 GDPR)

You can withdraw consent at any time without prejudice to the lawfulness of processing based on consent before withdrawal. Withdrawal can be made through your account settings, clicking the "Unsubscribe" link in emails, or by contacting privacy@diamante.live.

4. COMMUNICATIONS AND MARKETING

4.1 Functional Service Communications

We send essential communications for service delivery, which do not require your separate consent:

·       Registration and welcome confirmations

·       Order confirmations and shipping updates

·       Customs procedures and DDP delivery notifications

·       Notifications about missions, progress, and rewards in gamification system

·       Updates on educational content and lessons

·       Changes to terms of service or privacy policy

·       Account security communications

·       Responses to assistance requests

These communications are integral to the service and cannot be disabled without compromising platform use.

4.2 Marketing Communications

We send promotional communications ONLY if you have provided explicit consent:

·       Periodic newsletters on DIAMANTE news

·       Special offers and exclusive discounts

·       Launch of new Store products

·       Previews of new TV/Streaming content

·       Invitations to cultural events and initiatives

·       Satisfaction surveys (optional)

You can modify your marketing preferences anytime through your account settings or by clicking the 'Unsubscribe' link in each promotional email.

5. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar technologies to improve user experience and for marketing purposes. Our detailed Cookie Policy is available separately, but below is a summary:

5.1 Technical and Functional Cookies (Always Active)

These cookies are essential for the website to function and do not require consent:

·       Session cookies (login management)

·       Security cookies (fraud prevention)

·       Preference cookies (language, currency)

·       eCommerce cart cookies

·       Load balancing cookies

5.2 Analytical Cookies

We use analytical tools to understand how users interact with the platform:

·       Google Analytics (anonymized mode)

·       Hotjar or similar tools for heatmaps

·       Aggregate usage statistics

These cookies require your consent, managed through the cookie banner.

5.3 Profiling and Remarketing Cookies

Require your explicit consent and are used for personalized advertising:

·       Meta Pixel (Facebook/Instagram Ads)

·       Google Ads and Google Tag Manager

·       Third-party retargeting pixels

·       Affiliate cookies

IMPORTANT: These cookies are activated ONLY after your explicit consent through the cookie banner.

5.4 Consent Management (CMP)

We use a Consent Management Platform (CMP) compliant with IAB TCF v2.2. Upon first access, you are shown a banner that allows you to:

·       Accept all cookies

·       Reject non-essential cookies

·       Customize your choices by category

Your choices are stored for 12 months, after which you will be asked to renew consent.

6. DATA SHARING AND DISCLOSURE

We share data only in the following cases:

6.1 Service Providers (Data Processors)

We collaborate with service providers who act on our behalf:

Hosting and Infrastructure:

·       AWS, Google Cloud, or equivalent (EU servers)

·       CDN for content distribution (CloudFlare, etc.)

Payment Gateways (PCI-DSS):

·       Stripe, PayPal, or other processors

·       We do not store complete card data

International Logistics:

·       DHL, FedEx, UPS, Poste Italiane

·       Customs brokers for DDP procedures

Customs and Tax Authorities:

·       Mandatory sharing with customs authorities by law

·       Data transmission for VAT, duties, and import tax declarations

Email Service Providers:

·       Mailchimp, SendGrid, or equivalent

Customer Support Platforms:

·       Zendesk, Intercom, or CRM tools

Analytics Services:

·       Google Analytics, Hotjar (with consent)

All providers are bound by data protection agreements (DPA) compliant with GDPR Art. 28.

6.2 Advertising Partners (Only with Consent)

With your explicit consent, we share data with:

·       Meta (Facebook/Instagram) for remarketing

·       Google Ads for advertising campaigns

·       Third-party advertising networks

6.3 Authorities and Legal Obligations

We may disclose your data if required to:

·       Comply with legal obligations

·       Respond to legitimate requests from authorities

·       Protect our rights, property, or safety

·       Prevent fraud or illicit activities

7. INTERNATIONAL DATA TRANSFERS

DIAMANTE operates globally. When we transfer personal data outside the EEA, we adopt appropriate safeguards: Standard Contractual Clauses (SCC), EU-US Data Privacy Framework, Adequacy Decisions, Binding Corporate Rules (BCR). Main destination countries: United States, United Kingdom, Switzerland, Canada, Japan, and shipping destination countries. You can request specific information about transfers by contacting privacy@diamante.live.

8. DATA RETENTION

We retain your personal data only for the time necessary. Retention periods: Active Account Data (until deletion), Invoicing Data (10 years for tax obligations), Gamification Data (until deletion), Marketing Data (max 24 months from last consent), Cookie Data (max 12 months), Legal Disputes (until resolution), Security Backups (max 90 days). At the end of retention period, data is automatically deleted or anonymized.

9. DATA SECURITY

We adopt technical and organizational measures: SSL/TLS encryption, Encryption of sensitive data at-rest, Password encryption (bcrypt/Argon2), Firewalls and IDS/IPS, Two-factor authentication (2FA), Daily encrypted backups, Continuous monitoring, Payment tokenization (PCI-DSS), Data segregation, Regular security patches. Organizational measures: Access limited to authorized personnel, Staff training, Confidentiality agreements (NDA), Incident Response Plan, Security audits, DPIA for high-risk processing. Data Breach Notification: Within 72 hours to authorities (Art. 33 GDPR) and to affected users (Art. 34 GDPR).

10. YOUR PRIVACY RIGHTS

As a user, you have rights depending on your jurisdiction. GDPR Rights (EU/EEA): Right of Access (Art. 15), Rectification (Art. 16), Erasure/Right to be Forgotten (Art. 17), Restriction of Processing (Art. 18), Data Portability (Art. 20), Object (Art. 21), Withdraw Consent (Art. 7), Lodge a Complaint (Art. 77) - Italy: Garante per la Protezione dei Dati Personali, www.garanteprivacy.it. CCPA/CPRA Rights (California): Right to Know, Delete, Opt-Out of Sale/Sharing (DIAMANTE DOES NOT SELL your data), Correct, Non-Discrimination. LGPD Rights (Brazil): Confirmation, access, correction, deletion, portability - ANPD www.gov.br/anpd. Other Rights: PIPEDA (Canada), UK GDPR (ICO), Australia (OAIC), POPIA (South Africa). How to Exercise Rights: Send request to privacy@diamante.live or through account settings. Response times: GDPR 1 month, CCPA 45 days, LGPD 15 days. Free of charge.

11. PROTECTION OF MINORS

Minimum age: 16 years (EU), 14 years (Italy), 13 years (USA-COPPA). Parental consent required for users between minimum age and 18 years. Special protections for minors: no profiling for marketing, filtered content, enhanced privacy controls. Parents can access/delete minor's data by contacting privacy@diamante.live.

12. CHANGES TO PRIVACY POLICY

We reserve the right to modify this Policy. Substantial changes will be notified via email at least 30 days before effective date and through website banner. Continuing to use services after changes constitutes acceptance. Current version always available at diamante.live/privacy-policy.

13. E-COMMERCE SECTOR COMPLIANCE - DDP INTERNATIONAL SHIPPING

DIAMANTE applies DDP (Delivered Duty Paid) regime for all international shipments. This means: Displayed prices INCLUDE EVERYTHING: product + shipping + VAT (where applicable) + customs duties (where applicable) + customs clearance. You will NOT pay additional costs upon delivery. We share data (name, address, phone, tax ID if required, product description and value) with international carriers (DHL, FedEx, UPS, Poste) and customs authorities. Legal basis: Legal obligation (Art. 6(1)(c) GDPR) and Contract performance (Art. 6(1)(b) GDPR). Sharing with customs authorities is mandatory by law under international trade regulations (Kyoto Convention, WCO Framework, national customs regulations).

14. PRIVACY ASSISTANCE CONTACTS

Data Protection Officer (DPO): privacy@diamante.live | PEC: harvest@arubapec.it | Hours: Mon-Fri 9:00-18:00 CET/CEST | Average response time: 48 business hours | Customer Support: support@diamante.live | Security Reports: security@diamante.live

15. DO NOT SELL OR SHARE MY PERSONAL INFORMATION

DIAMANTE DOES NOT SELL your personal data to third parties for money. However, use of third-party cookies for behavioral advertising may constitute 'sharing' under California law. To opt out: Click 'Do not sell or share my personal information' in footer, manage cookie preferences, or contact privacy@diamante.live. California residents can exercise CCPA rights as described in Section 10.2.

16. REGION-SPECIFIC INFORMATION

United States: California (CCPA/CPRA), Virginia, Colorado, Connecticut, Utah (similar rights), Nevada (opt-out of sale). Latin America: Brazil (LGPD - ANPD), Argentina (PDPA - AAIP), Mexico (LFPDPPP - INAI). Asia-Pacific: Australia (OAIC), Japan (APPI - PPC), South Korea (PIPA - PIPC), Singapore (PDPA - PDPC). Africa: South Africa (POPIA - Info Regulator). Middle East: UAE (Federal Decree-Law No. 45 of 2021).

17. FINAL STATEMENT

DIAMANTE - The Italian Culture Empire is committed to treating your personal data with care, transparency, and in compliance with all international privacy regulations. Your trust is fundamental to us. Thanks to our DDP (Delivered Duty Paid) model, we guarantee prices are always complete and transparent, with no surprises upon delivery. All customs, tax, and shipping costs are included. If you have questions or wish to exercise your rights, contact us at privacy@diamante.live. We are here to help you.

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© 2025 Ass. Culturale Officina Del Territorio - DIAMANTE: The Italian Culture Empire
All rights reserved.

Registered Office: C.da Vibrata Snc, 64010 Colonella, Italia
VAT Number: 02188290676 | Tax Code: 91049140675
Email: privacy@diamante.live | PEC: harvest@arubapec.it

Document compliant with: GDPR (EU), CCPA/CPRA (California), LGPD (Brazil), PIPEDA (Canada), POPIA (South Africa), UK GDPR, and other international privacy regulations.

International shipments with DDP (Delivered Duty Paid) formula:
All prices include shipping, VAT, customs duties, and customs clearance where applicable.