Internal Due Diligence of Mirabello Consultancy

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CLIENT (CONTRACTING PARTY)

In order for us to conduct proper due diligence on you, we require certain personal information from you. You are kindly requested to enclose a copy of your passport with this Internal Due Diligence, duly completed, dated and signed.
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Are you aPolitically Exposed Person (“PEP”)?

FAMILY MEMBERS

In order for us to proceed with the due diligence process, we also require personal information about any family member who may be included in your Personal Application. You are kindly requested to enclose a copy of the passports of such family members within this process.. Full name(s) of family members / relationship to Client:
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BANKING REFERENCE

Please note that funds must generally be remitted from your personal bank account. In the exceptional event that Mirabello agrees to accept funds from a third party on your behalf, then the relevant account from which funds are actually transferred must be named below, and additional due diligence information and documentation will be required from that third party . Funds will in any case only be accepted by Mirabello if this Internal Due Diligence is duly completed, executed and passport copies are enclosed. Funds will be wired to Mirabello from the following bank account:

BENEFICIAL OWNER DECLARATION I the undersigned herewith declare:

Acknowledgment, Authorization & Consent

I acknowledge and agree that completion and submission of this Internal Due Diligence with applicable documentation authorizes and directs Mirabello to enquire and conduct due diligence and background verification checks on the persons named here in. I here by authorize Mirabello for the procurement of a Background Verification Report from a third-party service provider. In that regard, I consent for Mirabello to disclose the personal data, including this Internal Due Diligence and the provided passport copies, and the nature of my relationship with Mirabello, to such third-party service provider to be able to request such a report. I understand and consent to the use and processing of such personal information by the third-party provider in the ordinary and normal course of its business and function. I here by confirm that I am fully authorized by all family members named herein to provide Mirabello with their personal data and their passport copies for the purposes set out in this Internal Due Diligence.

THIRD PARTY ACCESS TO YOUR PERSONAL DATA

Personnel or other members of Mirabello may access your personal data for the reasons as set out above. We work closely with third parties in order to provide you the services you request. These third parties may have access to your personal data. Such third parties include cloud storage providers and IT service providers.
TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

Where we share your personal data with internal or external third parties as set out above, this may involve transferring your personal data outside the jurisdictionwhere Mirabello is established and outside the European Economic Area. We will transfer your personal data in accordance with standard contractual clauses(European Commission: Model contracts for the transfer of personal data to third countries) to ensure your personal data is transferred securely and in compliancewith data protection legislation, including the GDPR.

DATA SECURITY / DATA STORAGE / DATA MINIMISATION

We will ensure that appropriate security measures are taken against unlawful or unauthorized processing of personal data, and against accidental loss of, ordamage to, personal data. Such measures shall include (a) encrypting the personal data we process, (b) ensuring the ongoing confidentiality, integrity, availabilityand resilience of the processing systems and services that we use; (c) ensuring that the availability of and access to personal data can be restored in a timelymanner after an accident; (d) regularly assessing and evaluating the effectiveness of the technical and organizational measures adopted; and (e) carrying out a dataprotection impact assessment prior to implementing a new set of processing operations. All personal data is stored in a secure environment and we have physicaland electronical data access controls in place whereby access is granted only to persons authorized to access the data on a need to know basis, all of whom arebound by confidentiality obligations not to disclose any personal data. We have data integrity controls in place. Please contact us ondata@mirabelloconsultancy.com for further details with respect to our technical and organizational security measures. No method of transmission of data is onehundred percent (100%) secure and absolute security cannot be guaranteed. We shall only store your data as long as this is strictly necessary for the purposes forwhich it was collected. Retention of most data shall not exceed 10 years from the date of termination or completion of our services (in case we did not enter into acontract from the date of the data collection). This period of retention enables us to use the data for the defense of any potential legal claims (taking into accountthe applicable limitation periods prescribed at law) as well as to comply with our legal obligations such as applicable accounting and tax laws. Whenever and to theextent possible, we anonymize the data we hold about you when it is no longer necessary to identify you from the personal data which we hold about you.

YOUR RIGHTS AS A DATA SUBJECT

You are entitled to exercise the following rights:

7.1. Right to Access Information: You have the right to request information as to whether or not your personal data is being processed by us as well asinformation as to how and why it is processed. You may send an email to data@mirabelloconsultancy.com requesting information as to the personal data which weprocess. You shall receive one copy free of charge via email of the personal data which is undergoing processing. We may charge a reasonable fee, if your request isclearly unfounded, repetitive or excessive in which case we may also refuse to comply with your request in these circumstances.

7.2. Right to object: You may ask us not to process your personal data for marketing purposes and your data will no longer be processed for such purposes.

7.3. Right to withdraw consent: You have the right to withdraw your consent to this Notice, and the processing practices described herein, at any time by sendingan email to data@mirabelloconslutancy.com. This will not however affect the lawfulness of processing which we carried out on the basis of such consent before itswithdrawal. Withdrawal of consent may affect or impact the possibility of us providing you with the services.

7.4. Right to rectification:  You have the right to obtain rectification of any inaccurate personal data about you that we have processed, update any data which isout-of-date and the right to have incomplete personal data completed, including by means of a supplementary statement.

7.5. Right to erasure: You have the right to obtain the erasure of personal data we have concerning you when your personal data is no longer required where:You withdraw your consent to us processing your personal data;Your personal data no longer needs to be processed; orYour personal data has been unlawfully processed.

7.6. Right to Restriction of Processing: You have the right to restrict our processing activities where:

• You contest the accuracy of this personal data, for a periodenabling us to verify the accuracy of the same personal data;

• Our processing is deemed unlawful, and you oppose the erasure of your personal data and requestrestriction of its use instead;

• We no longer need your personal data for the purposes stated in this Notice, but you require it for the establishment, exercise ordefense of legal claims; or you have objected to our processing pending the verification whether the legitimate grounds of our processing activities overrode thosepertaining to you.

7.7. Right of Data Portability: As from 25 May 2018, you shall have the right to receive your personal data in a structured and machine-readable format andtransmit this data to another controller.

COMPLAINTS

We welcome any comments, complaints and queries in relation to data protection. As indicated above you may contact us at data@mirabelloconsultancy.com andwe shall try our best to deal with any issue or concern you may have. If we fail to address your concerns, you have the right to lodge a complaint with the dataprotection authority in the jurisdiction where you or Mirabello is based and where Mirabello is based and/or represented outside the European Economic Area withthe Swiss Federal Data Protection and Information Commissioner (FDPIC) at www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html, as the relevant nationalsupervisory authority on data protection matters for us.

DECLARATION

I hereby confirmthatthe information provided in this Internal Due Diligence, iscorrect,completeand notmisleading in any way. I hereby acknowledgemy obligation to informMirabello immediately of any changestothe information I have provided and know that if I intentionally provide wrong or incorrect information or falsify thisFormAthismay be prosecuted asacriminal offence underapplicable laws. I agreethat in case I intentionally provide wrong or incorrect information or falsify this Internal Due Diligence, I willindemnify Mirabelloagainstall losses, liabilities,actions, proceedings,claims,costsand expenses incurred orthreatened against Mirabellocaused by my actions.

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