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Privacy Policy

**Privacy Statement Koninklijke Asscher Diamant Maatschappij BV (KADM) and its subsidiaries in the EU. **

Introduction This is an informal translation of the published Dutch version, in case of discussions about interpretation or whatsoever, the Dutch version is leading. KADM (further: "We") processes personal data of her executive board, staff, applicants and other contacts.

We do this for the following reasons: • Legal Requirements, this applies in particular to staff related data • Other data being held for maintaining other contacts

In this Privacy Statement we explain why and in which way we process your personal data. We do not have an “Official Data Protection (FG)”, but we like to help you with your questions. For this you can contact us at Privacy@royalasscher.com or 020-679.1311, Tolstraat 127 1074 VJ Amsterdam.

This Privacy Statement is applicable on all data processing, also when we process personal data together with third parties. (Such as in the case of Personnel Insurance and Payroll processing).

Our data processing is not registered at The Authority Personal data (AP), as we do not process data which falls under article 31 of the Law Personal Data Protection.

Which Personal data are we processing? We process the following personal data:

Staff and former Staff; First- and surname, address, phone number, gender, e-mail address, payment details, job title, photos, tax number, emergency contact data, followed training, courses and obtained diplomas.

**Applicants; ** First- and surname, address, phone number, gender, e-mail address, payment details, job title, areas of interest, photos, tax number, emergency contact data, followed training, courses and obtained diplomas.

Other Contacts; First- and surname, phone number, e-mail address. Other data we keep only if the contacts provide this Information themselves or data provided by others to us, after their permission. We do not actively search for additional information on internet or other social media with the purpose to process this data.

Why do we process personal data? We process personal data with the following goals: • Legal obligations An important part of data processing is legally required. Hereby it is especially about personal data that are needed to comply to tax liabilities and to meet legal requirements to retain data for a certain period of time. But it is also because we process data in case of emergency or calamities at KADM. • Newsletters and mailings Contacts can sign up themselves for incidental newsletters. Sometimes personalized, sometimes not. If you do not wish to receive our newsletters anymore, you will be unsubscribed on your request. • Privacy guarantee Personal data can be processed in order to be able to perform an audit about the Privacy Guarantee. • Special data: We process special personal data, such as gender and if provided, photos. Gender we use the address people with Madam, Sir etc. Photos we process for internal communication. This processing is always voluntary and (of course) not used for other purposes.

Rights of stakeholders Under the AVG everybody involved has certain rights. We put a lot of effort in it to perform as good as possible to meet these criteria. In general: If you have questions or remarks, please let us know. Do you have tips or comments? Please let know! To make use of your rights, you can contact us at Privacy@royalasscher.com or 020-679.1311.

**Information and access to personal data: ** Of course, you can request which of your personal data we have processed. We then shall inform you how and why we have processed these data. • Rectification: Do you think we have wrong data from you? Please let us know and we will adjust. • Oblivion: If you request, we will delete your data, unless we are forced to keep these for legal and tax purposes. • Limitation: If you think processing of your personal data is illegal or incorrect, you can request limitation. • Objection: You can object the processing of personal data. If it is about marketing, we shall discontinue as soon as we can. • Portability: This is a new right under the AVG, you can ask to transfer your personal data. If you want to make use of this, please let us know. In addition you can also: • Permission withdrawal: For example, receiving of mailings, if you want to withdraw your permission, please let us know and we will take action. • Complaint submission at the AP: If you think we are not acting in line with the Privacy laws, please let us know. You can submit a complaint to us and/or the AP.

Storage time We save personal data not longer than necessary, more explicitly: • For personnel data we use that legally requirement time. • Information about applicants who will not come in service, is • kept for 2 years and then being destroyed. On request of the applicant the data will removed earlier. • Of other contacts information is kept as long as it is considered necessary for running the business. On request of the contact the data will removed earlier.

Basis for data processing As above explained some data we need to process to comply with the law, some for the execution of agreements (such as events), and justifiable importance for KADM. If you want to know more about how we measure this balance, please contact us. Finally, we process some data with your permission: this is In particular about information which you provided to us, or provided by others with your permission.

**Third party recipients ** We will never share your data with marketing companies or for other commercial purposes.

Sometimes we are legally forced to share personal data with third parties, such as the tax authorities. We also provide information to companies that: • Are executing our salary administration • Execute our personnel insurances (i.e. sickness insurance and pensions) • Perform the ARBO services (external Health & Safety advisor)

Further we will only share data with other third parties if we have received your explicit permission.

Websites On the websites of KADM is possible leave personal Information behind, this Information will only be used for the indicated purpose and will not be shared with other companies, unless this is the clearly indicated purpose.

Cookie statement Our website does use cookies to collect personal data. Amsterdam 28th June 2019   Privacy Policy Royal Asscher Diamond Company B.V. and Royal Asscher of America-USA Inc. Dear Visitor: www.royalasscher.com "Website" is a site which is operated by Royal Asscher Diamond Company in Amsterdam and its subsidiary Royal Asscher of America in New York, N.Y.USA and its subsidiaries (collectively, "Royal Asscher.", "we", "us", "our",). For the purpose of the applicable data protection legislation, the data controller is Royal Asscher of America, 529 Fifth Avenue Floor 16, New York 10017 We are committed to protecting and respecting your privacy. We want you to know how we use and protect the personal information you give us. This policy ("Privacy Policy") sets out how we use and protect any personal information that you give us when you use this Website. If you have any questions about this policy or do not agree with it, please contact privacy@royalasscher.com We may change this policy from time to time by updating this page. You should check this page from time to time to ensure you are happy with any changes. This policy is effective from June 21, 2019.

**What information do we collect? ** In general, you can use this Website without giving us any information. However, additional services may be available if we have certain information about you. We may collect the following information: • billing information, transaction and credit card information (should you make a purchase with us); • if you contact us, we shall a record of that correspondence; and information regarding your personal or professional interests, demographics, experiences with our products and contact preferences in order to provide you with further correspondence about our products and services. Given that we are an international company, this process may include sending personal information to other countries, whose data protection laws may not be the same as may exist in your country of residence. However, we have taken appropriate steps to ensure a responsible and high level of protection for the processing carried out in all countries in which we operate. Please see the section on 'Security and storage' below.

How to get copies of or amend the information we have collected? You may request details of personal information which we hold about you under the applicable data protection legislation. If you would like a copy of the information we have about you please write to privacy@royalasscher.com If you think any information we have about you is incorrect or incomplete, or you wish to have your details removed from our contact database please write to privacy@royalasscher.com as soon as possible. We will correct or update any information as soon as possible within the laws of The Netherlands for keeping data.

**Security and storage ** In order to prevent unauthorized access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect on line.

We ask you not to share your password with anyone. All information provided through our Website, is stored on servers located in the USA and/or EU.

Such information will be processed by staff operating in the USA who work for Royal Asscher. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal information, you agree to this transfer, storing or processing. Royal Asscher will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Linking We may link to other websites which are not within our control. When we do this, we will try and make it as clear as possible that you are leaving our Website. We are not responsible for these websites in any way. Once you have left our Website, we cannot be responsible for the protection and privacy of any information which you provide. You should exercise caution and look at the privacy statement applicable to the website in question.

**Cookies ** We use cookies for certain areas of our Website, including but not limited to session cookies, persistent cookies and web beacons. Cookies are files that store information on your hard drive or browser that allow our Website to recognize that you have visited our Website before. They make it easier for you to maintain your preferences on the Website, and by seeing how you use the Website, we can tailor the Website around your preferences and measure usability of the Website. We use cookies to: o Record your session information (such as the particular Products you purchase from our Website); o Record your specific information on the web pages you select to view; and o Retain your answer to our question regarding residency. You can, should you choose, disable the cookies from your browser and delete all cookies currently stored on your computer. On Microsoft Internet Explorer, this can be done by selecting "Tools/Internet Options" and reviewing your privacy settings or by selecting "delete cookies". However please note that this may prevent you from taking full advantage of the Website. You can find out how to do this for your particular browser by clicking "help" on your browser's menu or by visiting www.allaboutcookies.org. No information obtained from cookies from which individual customers can be identified will be used by us for marketing purposes.

New York, June 21 2019.