Annex 5

Privacy Documentation

PRIVACY NOTICE

pursuant to article 13 of EU Regulation 679/2016 of 27 April 2016

General Data Protection Regulation

a) Data Controllers: The companies

- A.S. Roma S.p.A., with registered office in Rome (Italy), Piazzale Dino Viola n. 1, Tax Code and
Rome Business Register no. 03294210582, VAT no. 01180281006 (“AS Roma”);
- Soccer S.a.s. di Brand Management S.r.l., with registered office in Rome (Italy), Via Emilia 47, Tax
Code, VAT no. and Rome Companies Register no. 09305501000, holder of the rights to use the AS
Roma trademarks (“Soccer”);
- Roma Studio S.r.l., with registered office in Rome (Italy), Piazzale Dino Viola n. 1, Tax Code, VAT
no. and Roma Companies Register no. 14613831008, (“Roma Studio”);
which act as Data Controllers (hereafter the “Controllers” or “Companies”) – each for the purposes
indicated at letter b) – collect and process your personal data and the data regarding the child under your
parental authority (“Child”) provided and collected during the Child’s subscription and participation at
the initiatives and events of the AS Roma Academy (“Academy”) in compliance with EU Regulation
679/2016, General Data Protection Regulation (the “Regulation”) and with Italian Legislative Decree
no. 2003/196 Italian Data Protection Code (the “Data”). Under section 13 of the Regulation we provide
you with the following information.

b) Purposes and legal basis for the processing: The Data collected (personal details, contacts and images),
even through third parties (such as the company that manage the Academy), will be processed by AS
Roma in order to:
1. manage the Child participation at the activities / events organized during the Academy directly by
AS Roma (competitions, sport events, etc.);
2. comply with legal obligations, regulations, EU legislation, including tax or accounting obligations
(e.g. invoicing, keeping records and accounting records), connected to the organization of said events
/ initiatives managed directly by AS Roma during the Academy;
3. fulfill the obligations deriving from AS Roma membership of sports associations / federations (e.g.
FIGC, LNP, UEFA, FIFA).
Furthermore, subject to your specific consent, the Data (including the Child image) may also be used by
the Companies for the following purposes:
4. contact you (via newsletters, e-mail, telephone, instant messaging, post, messages or
communications on social networks and apps, etc.) in order to (i) provide information on the
 Academy and the Companies and (ii) keep you updated on the activities, products, services or
initiatives (e.g. promotions, contests, games, events, etc.) and send you commercial advertising and
promotional material on the Companies and their business Partners, as well to conduct market
research.
5. promotion of the activities/initiatives and events concerning the Academy through the dissemination
of the Child image (photographic and/or video) through (i) publication on the website, social and
media channels of AS Roma and on the press and magazine "La Roma", (ii) publications and
institutional communications of the AS Roma club, (iii) management of relations with the Press, (iv)
management of relations with public institutions and administrations, (v) management of relations
with commercial partners and Academy sponsors, within the limits and according to the procedures
described in the "Disclaimer" regarding the use of audio, video and photographic materials.
The Data processing:
- for purposes indicated at points 1, 2 and 3 does not require your consent under art. 6, co. 1, lett. b) and
c) of the Regulation;
- for purposes indicated at points 4 and 5 needs your consent (see par. c) below) under art. 6, co. 1, lett.
a) of the Regulation.
In any case, the Data processing will be carried out in compliance with the provisions of the current
decisions - and their subsequent amendments and / or additions - issued in this regard by the Italian
Supervisory Authority for the protection of personal data (including Guidelines on promotional activities
and spam of 4 July 2013).

c) Your consent: To be able to contact you for communications relating to Academy’s activities and send
commercial communications, or conduct surveys and market research, as well as to use the Child’s image
(photographic and / or video) we need your explicit consent. Your consent is optional and if you do not
intend to provide it you can in any case proceed with the subscription of the Child to the events and
initiatives organized at the Academy. The consent is in any case always freely withdrawn.
Please note that, in case of withdrawal of your consent for sending updates, advertising / promotional
communications or market research (purpose 4), you will no longer be the recipient of any type of
communication. If you wish, you may withdraw your consent limited to receiving communications by
electronic means (e.g. e-mail, text messages, instant messaging), continuing to receive commercial
communications only by mail or telephone contact with the operator, if provided.

d) Data processing methods: The data will be processed, both with the aid of electronic and paper tools,
in compliance with current legislation and, in any case, in order to guarantee its security, confidentiality
and prevent unauthorized disclosure or use, alteration or destruction.
In particular, if you have provided us with your consent, the Child’s image (photographic and / or video)
may be published, and then disseminated, both on the website and media and social channels of AS Roma
and through other channels (e.g. institutional publications even on paper) in order to illustrate the
activities of the Academy within the limits and according to the modalities described in the "Disclaimer"
regarding the use of audio, video and photographic materials containing the Child’s image.
e) How long do we keep the Data: Within the aforementioned purposes, the Data will be kept for the
time strictly necessary for the management of the contractual relationship relative to the Child’s
participation in specific initiatives / events organized during the Academy directly by AS Roma, and
subsequently for the fulfillment of all obligations or the exercise of the rights connected or deriving from
the participation of the Child to the same. As for the publication of the Child’s data and image, the same
will take place for a period not exceeding 12 (twelve) months from publication. The Data processed to
send commercial communications will be stored and used until its possible withdrawal of consent. Once
the aforementioned terms have expired, the Data will be destroyed or anonymized.

f) Recipients of the Data: To allow the pursuit of the purposes indicated above, the Data may be disclosed
to the following categories of subjects:
1. Federations, entities and sports authorities;
2. Entities, companies, or subjects that, even together with AS Roma take care of organizing, managing
and / or sponsoring events / initiatives at the Academy (e.g. contests and sporting events);
3. Tax, accounting and / or legal consultants.
The Child’s image may be disseminated within the limits and according to the procedures described in
the "Disclaimer" regarding the use of audio, video and photographic material (see letter d) above).
The Data may also come to knowledge of companies that on our behalf carry out the service of storage
and processing of computer files. These subjects will act as external Data Processors in accordance with
the Regulation: the names of all external data processors may be requested by communication to be sent
to the address indicated below.
The Data may come to knowledge also of the persons authorized to the processing (i) appointed for the
organization and management of specific events / initiatives at the Academy and (ii) at the Companies
Marketing and Communication Departments.

g) Is your data transmitted outside the European Union: In order for us to properly manage our marketing
activities (if you have provided your consent), your personal data will be sent to countries outside the
European Union, such as the USA where our CRM services supplier is located.
By writing to privacy@asroma.it, you can receive further information on the transfer of your data and
the safeguards provided for its protection.

h) Data subjects rights: By writing to privacy@asroma.it, you can exercise at any time, in respect of each
of the Companies the rights referred to in articles from 15 to 22 of the Regulation, including the right to:
- obtain confirmation of whether personal data relating to you is being processed;
- obtain access to your personal data and to the information listed in article 15 of the Regulation;
- obtain modification of inaccurate personal data regarding you without undue delay or have
incomplete personal data completed;
- obtain deletion of personal data regarding you without undue delay;
- obtain the restriction of processing of your personal data;
- be informed of any amendments or deletions or restrictions to processing performed in relation to the
personal data relating to you;
- receive or transfer to another Data controller the personal data concerning you in a structured,
commonly used and machine-readable format;
- oppose at any time, for reasons connected to your specific situation, the processing of personal data
relating to you.
This is without prejudice to your right to withdraw your consent to any processing at any time as well as
to oppose our marketing activities.

i) Who can be contacted to lodge a complaint: Should you consider the processing of the Data infringes
the Regulation, you may in any event lodge a complaint with the Italian Data Protection Authority
(www.garanteprivacy.it), or, if different, to the Data Protection Authority of the Member State of your
habitual residence, place of work or place of the alleged infringement.

l) Data Protection Officer; The Data Protection Officer appointed by AS Roma and by Soccer S.a.s di
Brand Management S.r.l. can be contacted at the e-mail address: dpo@asroma.it.

CONSENT
pursuant to art. 6 of Regulation (EU) 2016/679

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PRIVACY NOTICE - AUDIO, VIDEO AND PHOTOGRAPHIC MATERIAL

pursuant to article 13 of EU Regulation 679/2016 of 27 April 2016

General Data Protection Regulation

Dear Sir / Madam,

- A.S. Roma S.p.A., with registered office in Rome (Italy), P.le Dino Viola no. 1, Tax Code and registration
number in the Company Register of Rome 03294210582, VAT Number 01180281006;
- Soccer S.a.s. di Brand Management S.r.l., with registered office in Rome (Italy), Via Emilia no. 47, Tax
Code, VAT number and registration number in the Company Register of Rome 0930550100;
- Roma Studio S.r.l., with registered office in Rome (Italy), P.le Dino Viola no. 1, Tax Code, VAT Number
and registration number in the Company Register of Rome 14613831008
as Data Controllers (hereinafter jointly “Data Controllers” or “Companies”), inform you that the personal data
regarding the minor who is under your parental responsibility (“Minor”) (in particular, his/her image, and any
other personal data such as voice, age, name and surname; hereinafter “Data”), collected through the taking of
photographs and / or videos during the AS Roma Academy ("Event"), will be processed on paper, computer,
photographic and digital means, so as to ensure the Data’s security and confidentiality, in order to allow the
realization and dissemination, by the Companies and/or their official partners or sponsors, by any means
whatsoever, existing or of future invention, on any platform and communication channel (including Roma TV),
of photographic and/or visual and/or audiovisual content (including promotional content) relating to AS Roma,
the Companies and the Event ("Footage"). The Data processing will be carried out in full compliance with
Regulation (EU) 2016/679 General Regulation on data protection ("GDPR") and Italian Legislative Decree
2003/196 Italian Data Protection Code ("Code"). The provision of the Data is optional, but, in case of refusal, the
Companies will not be able to use the Footage, as better defined in the Release pursuant to art. 96 Italian Law
1941/633 Italian Law on Copyright, below this privacy notice ("Release"). The processing, communication,
transmission and dissemination of the Data for the purposes indicated above and in the manner described in the
Release, will be based on the consent provided by you pursuant to art. 6, par. 1, letter a), of the GDPR. Your
consent is optional and can be freely withdrawn at any time by writing to privacy@asroma.it without affecting the
lawfulness of processing based on consent before the withdrawal. The Data may be collected also through the
subjects who organize the Event together with the Companies. Within the scope of the purposes indicated above,
the Data will come to knowledge of the following recipients, as data controllers or data processors: (i) subjects in
charge of the creation of the Footage; (ii) subjects in charge of managing the digital platforms and communication
channels of the Companies (websites, social and media channels, etc..) and creating the content available therein;
(iii) subjects appointed by the Companies to produce promotional and marketing material; (iv) subjects providing
computer archiving services to the Companies; (iv) sponsors and official partners of AS Roma, the Companies
and / or the Event to report and promote such partnership and the Event itself. By writing to privacy@asroma.it,
you will receive information on the partners and official sponsors as well as on the Data processors. Internally to
the Companies, the Data will be processed by the persons authorized to the processing at the Departments involved
in the implementation and use of the Footage, such as Marketing, Digital, Communication, ICT, Sponsorship
Departments. The Data will be disclosed and communicated to third parties exclusively for the pursuit of the
purposes indicated above and within the terms of the Release. The Data will be processed for the period of time
provided for in the Release, and in any case until the withdrawal of your consent. Then the Data will be deleted or
processed only after the adoption of technical measures that do not allow to trace the Minor’s identity. In order to
allow us to properly manage our communication platforms and carry out our activities, the Data may be transferred
to countries outside the European Union, such as the USA and/or different countries where the sponsors and
official partners of the Companies and/or the Event are located. The transfer of Data to non-EU countries will take
place in full compliance with the safeguards, measures and rights as provided for in the GDPR. By simple request
to privacy@asroma.it you can receive information on the safeguards adopted to legitimately transfer the Data, as
well as on the means to obtain them or the place where they were made available.

The Data Protection Officer (DPO) appointed by AS Roma S.p.A. and Soccer S.a.s. di Brand Management S.r.l.
can be contacted by writing at dpo@asroma.it.

By writing to privacy@asroma.it, you will be able to exercise the rights granted by Articles 15 to 22 of the GDPR
including, in summary, those of obtaining access to personal data, rectification of inaccurate personal data or the
cancellation or limitation of the same, request to receive or transmit to another data controller the data in a
structured format, commonly used and readable by automatic devices, and withdraw your consent. You can find
the complete list of rights at www.garanteprivacy.it. We remind you that, if you believe that the processing of
personal data concerning the Minor violates the provisions of the GDPR, you can always lodge a complaint to the
Italian Data Protection Supervisory Authority (www.garanteprivacy.it), or, if different, to the Supervisory
Authority of the Member State in which the Minor habitually resides, works or the place where the alleged
violation occurred.

RELEASE
pursuant to article 96 of Italian Law n. 633 dated 22 April 1941

The parents and/or guardian and/or exercising parental responsibility over the child
__________________________ born in _____________________ on ___________, Fiscal
Code____________________ ("Minor"), in relation to any photographs and/or videos involving the Minor taken
and/or filmed on the occasion of the AS Roma Academy ("Event") and the use of the image of the Minor by:
- A.S. Roma S.p.A., with registered office in Rome (Italy), P.le Dino Viola no. 1, Tax Code and registration
number in the Company Register of Rome 03294210582, VAT Number 01180281006;
- Soccer S.a.s. di Brand Management S.r.l., with registered office in Rome (Italy), Via Emilia no. 47, Tax Code,
VAT number and registration number in the Company Register of Rome 0930550100;
- Roma Studio S.r.l., with registered office in Rome (Italy), P.le Dino Viola No. 1, Tax Code, VAT Number and
registration number in the Company Register of Rome 14613831008;
(hereinafter jointly referred to as the "Companies")

DECLARE THE FOLLOWING:

1. That nothing prevents the release of the following authorization, and that I expressly assume any liability should
any of the following statements be false or incorrect.
2. I authorize, for no compensation whatsoever, the Companies to take and/or cause any third party to take
photographs of the Minor and to film and/or cause any third party to film the Minor during the Event, by any
means, including any audio, audiovisual, multimedia and/or photographic means (the results of any such
filming or photographing, hereinafter the “Footage”), and I grant, for no compensation whatsoever, to the
Companies all rights of use and economic and commercial exploitation of the aforesaid Footage, in any form
or manner, in whole or in part (including all materials and files – including preparatory – produced in occasion
of the Footage), without any limitation of time, passages, language, modality and territory, in any location and
by any means currently known and / or invented in the future, including the right to transfer or license any such
right to third parties without the need for my further authorization.
As a result of this release, the Companies will be exclusively entitled, until revocation of this authorization, to
any and all rights of use and economic exploitation of the Footage, in whole and in part, without any limitation
in time or space, by any means currently known and / or invented in the future.

The Companies will have, in particular but without limitation of any kind, the exclusive right to record, fix,
reproduce by any process, publish, communicate, transmit and/or broadcast or otherwise use the Footage, and
for the effect, the Minor’s voice and image: (i) by any means and / or system of transmission and broadcasting
currently existing or invented in the future, by way of example only: in television, radio, or any other
audiovisual process, whether or not requiring the use of a computer for processing, development and / or
 broadcasting), via computer network (including via the Internet and intranet) and telephone both fixed and
mobile; (ii) using any instrument of transmission, broadcasting and reception, currently existing or invented in
the future (for example: satellite, fiber optic cable, telephone cable, wire, mmds, digital, DVBH, DVBX, etc.;
(iii) in any form and manner and therefore, by way of example only, in clear, conditional access, encoded and/or
encrypted, free and/or paid, analogue and/or digital, multimedia and/or interactive; (iv) with the use of any
technology (wireless, optical fiber, broadband, etc.) and protocol (TCP/IP, GSM, GSPRS, UMTS); (v) for
reception on any terminal, even if it does not currently exist (television screens, personal computer displays,
fixed and mobile, display of fixed and mobile phones, video), for the purpose of production and broadcasting
by the Company and / or its partners and official sponsors, by any means existing or of future invention, on any
platform and on any channel of communication of audiovisual contents, including of a promotional nature,
relating to the Companies and / or the Event.
3. I acknowledge that any obligation for the Companies and/or their successors in title to actually use the Footage
is hereby excluded and that the failure or incomplete use of the same shall not entitle me to any right or claim.
4. I declare that I have and shall have nothing to claim from the Companies and/or their assignees and, in general,
from anyone who uses and exploits the Footage, pursuant to terms and conditions of Paragraph 2 above,
including for any lawful purposes other than those for which it was initially carried out.
5. I hereby declare and acknowledge that the circumstances and characteristics of the Footage have been explained
to me in details and that I have freely decided to let the Minor participate in the Footage and to authorize the
use of the Footage in accordance with the foregoing, and I hereby to release the Companies from any
responsibility in this regard.
6. I am aware of the fact that the rights covered by this release may be freely transferred by the Companies and
in any case made available to third parties, including through subsequent sub-licensing by the various assignees,
in the forms and manner deemed more appropriate by such assignees, and that I shall have no claim whatsoever
in this regard.
7. I represent and warrant that I have parental responsibility for the Minor and to be fully entitled to grant this
authorization and that I shall be exclusively liable should this show to be untrue.
8. I am aware that the Footage may also be used for commercial and promotional purposes of the Companies and
their partners and I declare that I have nothing to claim from the Companies and/or from their partners and
their successors in title, present and future for the broadcasting of the Footage for such purposes.
9. I declare to renounce and waive any right to any fee or compensation whatsoever in connection with any
exploitation of the Footage, and that the Minor has been adequately compensated through the opportunity to
participate in the Event.

CONSENT AND AUTHORIZATION TO THE USE OF AUDIO, VIDEO AND PHOTOGRAPHIC

FOOTAGE

pursuant to art. 6 of Regulation (EU) 2016/679 and art. 96 of Italian Law 1941/633

Having read and understood the above Privacy notice and Release, I, the undersigned, as parent/ parental
responsibility holder of the Minor, authorize AS Roma S.p.A., Soccer S.a.s. di Brand Management S.r.l., Roma
Studio S.r.l., pursuant to article 6, par. 1, letter a) of EU Regulation 2016/679 on the protection of personal data
as well as pursuant to article 96 of Italian Law 1941/633 on Copyright
A) to process the Minor’s personal data and, in particular, to reproduce, disseminate and store the Footage
including the Minor’s image and any other data (e.g. voice, age, name and surname) in the manner and in
compliance with what is indicated in the Privacy notice and Release that I have received.

I authorize I do not authorize

Place and date_________________

Signature (of both Minor’s parents/parental responsibility holders)___________________________

B) to communicate and transmit the Minor’s personal, and in particular, the Footage including the Minor’s
image and any other data (e.g. voice, age, name and surname) to third parties (sponsors and official partners
of AS Roma, the Companies and / or the Event), in the manner and in compliance with the purposes indicated
in the Privacy notice and Release that I have received.

I authorize I do not authorize

Place and date

Signature (of both Minor’s parents/parental responsibility holders __________________________________