Last Updated: March 27, 2026

This Cookie Policy ("Policy") explains how DIAMWALL, LDA ("DiamWall", "we", "us", or "our"), a company incorporated under Portuguese law with registered office at R. Fialho de Almeida 14 2 esq, 1070-129 Lisboa, Portugal, uses cookies and similar technologies on its websites (collectively, the "Websites").

DiamWall is the data controller for personal data collected through cookies placed directly by us. Where third-party cookies are used, the respective third party acts as an independent data controller. Capitalized terms not defined here have the meanings given in our Privacy Policy.

This Policy is issued in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation, "GDPR"), the Portuguese Law no. 58/2019 of 8 August (which implements the GDPR in Portugal), and Law no. 41/2004 of 18 August (as amended by Law no. 46/2012) on privacy in electronic communications.

For any privacy-related enquiries, please contact us at: privacy@diamwall.com

1. What Are Cookies?

Cookies are small text files placed on your device (computer, tablet, or mobile phone) by websites you visit. They are widely used to make websites work efficiently, to remember your preferences, and to provide information to website owners. Similar technologies include pixel tags (also called web beacons or tracking pixels), local storage objects, and device fingerprinting. This Policy refers to all such technologies collectively as "cookies".

2. How We Obtain Your Consent

When you first visit any DiamWall Website, a cookie banner is displayed that allows you to accept or refuse each category of non-essential cookies before they are placed on your device. Only Strictly Necessary cookies are activated automatically; all other categories require your prior, freely given, specific, informed, and unambiguous consent in accordance with Article 6(1)(a) GDPR.

You may change or withdraw your consent at any time through the cookie preferences tool made available on the relevant Website whenever non-essential cookies are in use. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

3. Categories of Cookies We Use

DiamWall currently uses only the following categories of cookies or similar technologies on its own Websites:

3.1 Strictly Necessary Cookies

Legal basis: Article 6(1)(f) GDPR, together with the applicable rules of Directive 2002/58/EC and Portuguese Law no. 41/2004 for technologies that are strictly necessary to provide a service explicitly requested by the user.

These cookies or similar technologies are essential to deliver core site functionality and security, such as session management, authentication, load balancing, and abuse prevention. They cannot be turned off without impairing the operation of the Websites.

Retention: Session-based or for the limited period strictly necessary for the relevant security or session function.

3.2 Performance / Analytics Cookies

Legal basis: Article 6(1)(a) GDPR — your consent, obtained via the cookie banner before any non-essential analytics technologies are used.

DiamWall currently uses Google Analytics on certain Websites to understand aggregated usage patterns and improve performance and design. Google Analytics is only activated after the user has provided consent through the cookie banner.

DiamWall may also use Sentry or equivalent error-monitoring tools for service reliability and debugging. Where a given implementation uses cookies, local storage, or other non-essential client-side identifiers, it will likewise only be activated after the user has provided consent. Where Sentry is configured in a strictly necessary manner without non-essential client-side storage or tracking, it may operate without consent to the extent permitted by applicable law.

Retention: Retention periods depend on the relevant provider configuration and are limited to what is reasonably necessary for analytics and error-monitoring purposes.

4. International Transfers of Personal Data

Some of the third-party cookies described above may result in personal data being transferred to countries outside the European Economic Area ("EEA"). DiamWall ensures that any such transfers are subject to appropriate safeguards as required by Chapter V GDPR, including:

• Adequacy decisions of the European Commission (e.g., the EU–US Data Privacy Framework for transfers to certified US companies such as Google LLC); or
• Standard Contractual Clauses (SCCs) adopted by the European Commission, where an adequacy decision is not available.

You may obtain further information about the safeguards applicable to specific transfers by contacting us at privacy@diamwall.com.

5. Your Rights Under GDPR

As a data subject in the EU/EEA or Portugal, you have the following rights regarding personal data processed through cookies, to the extent applicable:

• Right of access (Art. 15 GDPR) — to obtain confirmation of whether and how we process your personal data.
• Right to rectification (Art. 16 GDPR) — to correct inaccurate personal data we hold about you.
• Right to erasure (Art. 17 GDPR) — to request deletion of your personal data in certain circumstances.
• Right to restriction (Art. 18 GDPR) — to restrict processing of your personal data in certain circumstances.
• Right to data portability (Art. 20 GDPR) — to receive personal data in a structured, machine-readable format.
• Right to object (Art. 21 GDPR) — to object to processing based on legitimate interests.
• Right to withdraw consent (Art. 7(3) GDPR) — where processing is based on consent, you may withdraw it at any time via the cookie preferences tool made available on the relevant Website, without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at privacy@diamwall.com. We will respond within one month of receipt of your request (extendable by a further two months in complex cases).

6. Right to Lodge a Complaint

If you believe that our processing of your personal data infringes the GDPR or applicable Portuguese data protection law, you have the right to lodge a complaint with the competent supervisory authority:

Comissão Nacional de Proteção de Dados (CNPD)
Av. D. Carlos I, 134 – 1.º, 1200-651 Lisboa, Portugal
Website: https://www.cnpd.pt
Email: geral@cnpd.pt

This right is without prejudice to any other administrative or judicial remedy available to you.

7. Managing Cookies Through Your Browser

Most web browsers allow you to control cookies through their settings. You can typically configure your browser to refuse all cookies, accept only certain cookies, or to alert you when cookies are being sent. Please note that disabling cookies may reset your session, disable auto-login, and adversely affect the functionality of our Websites. Links to cookie management instructions for common browsers:

• Google Chrome
• Mozilla Firefox
• Microsoft Edge
• Apple Safari

8. Changes to This Policy

We may update this Cookie Policy from time to time to reflect changes in technology, regulation, or our business practices. Any material changes will be notified to you via a prominent notice on the Websites and, where required by law, by re-requesting your consent. The "Last Updated" date at the top of this page indicates when this Policy was last revised.