The information about the processing of personal data are disclosed exclusively for the Website and the processing carried out by the Company and does not refer to the processing operations carried out by third parties through other websites you may visit by opening a link. The Company shall take no responsibility for such additional processing operations, as you have to refer to the individual Privacy Policies of the third-party websites you visit.
1.Controller and place of the processing
The Data Controller is COIMA SGR S.p.A., with registered office at Piazza Gae Aulenti, 12, 20154, Milan (Italy).
The data are mainly processed at the headquarters of the Controller, by technical personnel of the Company appointed as persons in charge of the processing, within the European Union.
2. Modalities of data processing
The Company shall process your data by adopting all the appropriate security measures intended to prevent any unauthorized access, as well as the unauthorized disclosure, modification, or destruction of the data. The data shall be processed both with manual and computer and/or telecommunication means, with organizational modalities and logics strictly connected with, and limited to, the specified purposes.
3. Purposes and legal basis of data processing
The Company, through the Website, may process your data for the following purposes:
a. Contacting the Company. The User may contact the Company for requesting information by Company’s contact information indicated on the Website. In this regard, the personal data disclosed by you (for example, email address, possible telephone number and/or other information spontaneously provided by you) will be processed by the Company to receive, correctly manage, and answer to your communications and/or requests. The legal basis for the processing is represented by the performance of the service expressly requested by you, and any refusal to provide the personal data will cause the impossibility for the Company to manage and answer to the communication or request for information.
b. Pursuance of the legitimate interests of the Company and/or third parties. Your data may also be used for the exercise of the rights and legitimate interests of the Company and/or third parties, for example, the right of defence in court, the management of complaints and situations of litigation, fraud prevention and/or unlawful activities. In these cases, even if the disclosure of your personal data is not mandatory, it is in any case necessary taking into account that such data are strictly connected and instrumental to the pursuance of the said legitimate interests, which do not prevail on your fundamental rights and freedoms, and any refusal to disclose them could cause the impossibility to provide the services required (for example, requesting information to the Company).
c. Fulfilling legal obligations and/or applicable obligations. The Company may also use the personal data provided by you or otherwise acquired during your interaction with the Website for purposes related to the fulfilment of legal obligations, regulations, domestic and EU legislation, and purposes resulting from provisions issued by authorities empowered to do so by law, which represent the legal basis for the processing, without the need to obtain your prior consent.
d. Performing aggregate statistics on an anonymous basis in order to improve the performances and services offered by the Company through the Website. In this case, your consent shall not be required, as for the processing specified shall be carried out exclusively on anonymous data.
4. Categories of data to be processed
The Company shall receive and collect, through the Website, information related to the users who visit the pages of the Website and use the web services available thereon. In particular, the Company shall acquire and process the following information.
4.1 Data collected through surfing and cookies
When you visit the Website, the latter shall collect some data such as the pages viewed, the links or the buttons you clicked, the date and time of access, your IP address, the navigation browser, and the operating system used (so-called “web-browsing data”). The web-browsing data could, by their nature, enable your identification also through elaborations and associations with data stored by third parties. However, the Company shall use these data for the sole purpose of obtaining statistical and anonymous information on the use of the Website for purposes strictly connected with the operation thereof. The web-browsing data could also be used to ascertain liability in the case of computer crimes that damage the Website.
4.2 Data voluntarily provided by You
The Company limits the collection of the information voluntarily provided by you to the information necessary to pursue the purposes illustrated in paragraph 3 above and the services expressly requested. Moreover, the Company may collect and process additional personal data, if the same have been voluntarily disclosed by you within the services offered by the Website, for example in the case in which you contact the Company to report failures or malfunctioning, exercise your rights on data processing, etc. Such data will be processed by the Company exclusively for the purposes strictly connected to your request. The failure to disclose the data may cause the impossibility to obtain the service required.
5. Disclosure of data to third parties
- companies belonging to the COIMA Group and Residenze Porta Nuova Agency, for administrative-accounting purposes, for the pursuance of legitimate interests of the Company and/or third parties, and for the purpose of performing the services expressly requested by you;
- companies, consultants, advisors or independent contractors of whom/which the Company avails itself for the performance of technical or organisational tasks (such as, for example, providers of IT services), or with whom/which the Company cooperates (including the other COIMA Companies and Residenze Porta Nuova Agency), in order to provide and operate their services, or for any communication activities;
- natural persons, companies, or professional firms that provide the Company with assistance and advisory services or activities, especially, but not exclusively, with reference to accounting, administrative, legal, tax, and financial issues;
- parties whose right to access the data is provided for by legal provisions or orders of the relevant authorities.
The parties belonging to the categories indicated above shall use the data in their capacity as autonomous data controllers pursuant to law or as data processors, in this case duly appointed by the Company.
The list of the persons to whom the data are or may be disclosed, may be requested to the Company by contacting the persons specified in the “Rights of Data Subjects and Contact Details” section.
6. Data retention
The Data will be processed for as long as it is necessary for the performance of the activities indicated in paragraph 3 above, and they will be erased when the purposes for which they have been collected and processed do not apply any longer.
In particular, the Company will erase the personal data of those users who have asked for information or sent communications by contacting the Company through the Website 3 years after disclosure thereof.
7. Your Rights and contact details
You may exercise the rights provided for by the Regulation in the cases expressly provided for by law and where applicable. In particular, you have the right to:
- request confirmation as to whether or not your personal data are being processed and, in this case, request from the controller access to the information related to the same processing (for example, purposes, categories of data processed, intended recipients, or categories of intended recipients of the data, retention period, etc.);
- right to request from the controller the rectification of inaccurate or incomplete data;
- request from the controller the erasure of the data (for example, if the personal data are no longer necessary for the purposes for which they have been collected, in the case of revocation of the consent on which the processing is based, etc.);
- request the restriction of the processing (e.g., in the event that you challenge the accuracy of the data; if the processing is unlawful and you object to the erasure of personal data; if the data are necessary to exercise or defend in court one of your rights, even if the controller no longer needs them; in the event that the right to object is exercised, for the time necessary to verify the existence of legitimate grounds).
- receive the data concerning you in a commonly used and machine-readable format (for example, PDF), and transmit them to another controller, or obtain the transmission of those data directly from one controller to another, if technically possible (so-called data portability).
Moreover, you shall have the right to object in whole or in part, on legitimate grounds, to the processing of the data regarding you.
Such rights may be exercised directly by sending a notice to the following email address: firstname.lastname@example.org.
Finally, if you deem that the processing of the data disclosed is in breach of data protection provisions, you shall have the right to file a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).
8. Collecting data through Cookies
A cookie is a small string of text that the websites visited send to the browser of your computer, where it is stored when you visit an Internet website, and are then re-transmitted to the same sites on the occasion of your next visit.
Cookies are used by the Company for the functioning of the Website or to improve its performance as well as to provide information about the Website or your browsing.
8.1 Technical cookies
Technical cookies are fundamental to enable you to browse on the Website and use its functionalities, remember your preferences (for example, language, country of origin, etc.), distribute requests on more servers, remember when you consent to certain options (for example, by accepting the use of certain cookies to remove the informative banner), in order to enable you to view contents and videos through Adobe Flash Player. Such cookies shall last for no longer than 2 years and do not require your consent. The technical cookies used are:
- hypo-disclaimer: allows access to the Investor Relations area after you have confirmed to be able to access it by filling in the relative on-line form;
- gat_gtag_UA_[xxx]: allows Google to distinguish users.
8.2 Performance and analytics cookies of the Company
These cookies may be session or permanent cookies, and their use is limited to the Website’s performance and improvement. These cookies enable us to identify, measure and track the Website’s visitors, thus allowing us to improve and refine the Website, for example, by determining whether you can easily find the information desired, or by identifying which aspects of the Website are of greatest interest. These cookies are used by the Company to carry out statistical and anonymous analyses on how users navigate the Website, on the number of pages visited or the number of clicks made on a page during navigation. According to privacy regulations, these cookies are equated to technical cookies, therefore they do not require your consent.
8.3 Performance and Analytics Cookies of Third Parties
To activate these cookies, you can choose to give your consent (which therefore represents the legal basis for the processing) through the mechanism shown in the banner providing information on the Company’s cookies, which appears on the homepage/landing page of the Website when you access it.
8.4 Disabling cookies through the browser
Most of surfing browsers are set to accept cookies. However, you may set your browser in such a way as to restrict the number of cookies accepted or block all the cookies, changing the browser settings as follows:
Microsoft Internet Explorer
Click on the “Tools” icon in the top corner on the right and select “Internet Options”. Select “Privacy” in the pop-up window. Here you may change the cookies settings.
Click on the “wrench” icon in the top corner on the right and select “Settings”. At this point, select “Show advanced settings” and change the “privacy” settings.
From the menu button in the top corner on the left, select “Options”. Select “Privacy” in the pop-up window. Here you may change the cookies settings.
From the menu button in the top corner on the right, select “Preferences”. Select “Security” and there you may change the cookies settings.
However, please be aware that by disabling the use of all the cookies on the Website (including technical cookies), some functionalities will be compromised.
8.5 Additional information related to the cookies
The www.allaboutcookie.org website contains the instructions to manage the cookies on the most common browsers; alternatively, it is possible to consult the documentation attached to the software used on one’s own device.
If the changes are particularly significant and/or their impact on your rights were substantial, the Company may notify you of such changes also through other modalities (for example, by sending an email).