Privacy and Cookie Policy

Portanuova – Privacy and Cookie Policy

The purpose of this Privacy and Cookie Policy is to describe the purposes and methods by which COIMA SGR S.p.A. collects and processes personal data relating to the user (“User“) who interacts with the websitehttps://172-232-218-68.ip.linodeusercontent.com/(“Website“) and with the various services offered thereby, as well as how COIMA SGR S.p.A. uses cookies and/or other tracking tools in the Website.

The information contained in this Privacy and Cookie Policy is provided pursuant to Article 13 of Regulation EU no. 679 of 27 April 2016 (“Regulation” or “GDPR“), as well as the Measures issued by the Italian Personal Data Protection Authority and Guidelines of the European authorities.

The information on the processing of data is provided only for the Website and for the processing carried out by the Company and does not extend to the processing carried out by third parties through other sites that may be viewed by the User through links. The Company accepts no liability with respect to such other processing, and the User must refer to the individual privacy policies of such third-party sites.

• Data Controller

COIMA SGR S.p.A., with registered office in Milan, Italy, Piazza Gae Aulenti 12, 20154, (“Company” or “Data Controller“)

• Data processing methods

The Company processes the User’s data by taking all appropriate security measures to prevent unauthorised access to and unauthorised disclosure, modification or destruction of the data. The processing is carried out using both manual and computerised and/or electronic tools, with organisational methods and logic strictly related and limited to the purposes indicated.

• Purposes and legal basis of the processing

The Company may process the User’s data through the Website for the following purposes:

1. Contact the Company.The User has the option of contacting the Company to request information via the Company’s contact details provided on the Website. In this regard, the personal data voluntarily provided by the User (e.g. email address, telephone number and/or any other information voluntarily provided by the User) will be processed by the Company in order to assign, correctly manage and respond to communications and/or requests received from the User. The legal basis of the processing is represented by the execution of the service expressly requested by the User, and any refusal to provide personal data entails the impossibility for the Company to manage and respond to the communication or request for information (Article 6(1)(b) of the GDPR).
2. Pursuit of the legitimate interests of the Company and/or third parties. The User’s data may also be used for the exercise of the rights and legitimate interests of the Company and/or third parties, e.g. the handling of complaints and litigation, debt collection where required and the prevention of fraud and/or illegal activities. In these cases, while the provision of the User’s personal data is not mandatory, it is nevertheless necessary because such data are strictly connected and instrumental to the pursuit of such legitimate interests, which do not prevail over the User’s fundamental rights and freedoms, and any refusal to provide such data may make it impossible to provide the services requested (e.g. requesting information from the Company) (Article 6(1)(f) of the GDPR).
3. Fulfil legal and/or applicable obligations. The Company may also use the personal data provided by the User or otherwise acquired in the course of the User’s interaction with the Website for purposes related to the execution of legal obligations, regulations, national and European Community rules as well as deriving from provisions issued by authorities entitled to do so by law, which represent the legal basis for the processing (Article 6(1)(c) of the GDPR).

• Categories of data processed

The Company receives and collects information through the Website relating to the User who visits its pages and who uses the web services available thereon. Specifically, the Company acquires and processes the following information.

4.1 Data collected through browsing and cookies

When the User visits the Website, the latter logs certain data such as the pages displayed, the links or buttons clicked by the User, the date and time of access, the User’s IP address, the browser and the operating system used (“browsing data”). The Company uses this data for the sole purpose of gathering statistical information on the use of the Website for purposes related to its operation and the evaluation of the effectiveness of the services offered thereby. The browsing data could also be used to ascertain liability in the event of any cyber crimes against the Website.

With regard to the collection of User data through cookies and similar technologies, please see theCookie Policy(i.e. section 8).

4.2 Data provided voluntarily by the User

The Company limits the collection of information provided voluntarily by the User to that which is necessary to pursue the purposes set out in section 3 above and the services expressly requested. Moreover, the Company may collect and process additional personal data where such data are voluntarily provided by the User in the context of the services offered by the Website, for example if the User contacts the Company to report inefficiencies or malfunctions, to exercise their rights regarding the processing of personal data, etc.These data will be processed by the Company solely for the purposes strictly related to the User’s request. Failure to provide such data may entail the failure to provide the service requested.

• Disclosure of the data to third parties

The data provided by the User as well as those collected by the Website as part of its services (e.g. IP address) will not be disseminated and may be disclosed to the categories of parties indicated below for the purposes and in the manner set out in this Privacy and Cookie Policy:

• Companies of the COIMA platform, Residenze Porta Nuova, for organisational purposes, for internal control purposes, for the pursuit of the legitimate interests of the Company and/or third parties, and for the purposes of performing the services/requests expressly made by the User.
• Companies, contractors, consultants or freelance professionals that the Company works with to carry out tasks of a technical or organisational nature (such as IT service providers), or with which the Company collaborates (including the other COIMA Companies and Residenze Porta Nuova) for the provision and operation of its services, or for any communication activities.
• Persons, companies or professional firms providing assistance and advice to the Company, with particular but not exclusive reference to accounting, administrative, legal, tax and financial matters.
• Parties whose right to access the data is recognised by law or by orders of the authorities.

Parties belonging to the aforementioned categories will use the data as autonomous data controllers in accordance with the law or as data processors duly appointed by the Company.

The list of parties the data are or may be disclosed to may be requested from the Company by contacting the addresses provided in the “User rights and contacts” section.

• Storage of data

The data are processed for the time necessary to carry out the activities detailed in section 3 above, and are deleted when the purposes for which they were collected and processed no longer exist.

Specifically, the Company will provide a response to requests received by email without further processing the personal data provided, except for the need to retain the data for longer periods if necessary for the timely execution of the user’s request.

The information collected in cookies will be retained for the times indicated in each table in section 8 below.

• User rights and contacts

In the cases expressly envisaged by law and where applicable, the User may exercise the rights envisaged in the Regulation. Specifically, the User has the right to:

• Receive confirmation that their personal data are being processed, and if so to request that the data controller provide information relating to such processing (e.g. purposes, categories of data processed, recipients or categories of recipients of the data, storage period, etc.).
• Request the rectification of any inaccurate or incomplete data.
• Ask the data controller to erase the data (e.g. if the personal data are no longer necessary for the purposes for which they were collected, if the consent on which the processing is based is withdrawn, etc.).
• Request the restriction of the processing (e.g. if the User disputes the accuracy of the data; if the processing is unlawful and the User objects to the erasure of the personal data; if the data are necessary for the exercise or defence of a right of the User in court, even if the data controller no longer needs them; if the User exercises the right to object, for the time necessary to verify the existence of legitimate reasons).
• Receive their personal data in a commonly used, machine-readable format (e.g. PDF) and to transmit them to another data controller, or to obtain direct transmission from one data controller to another, where technically feasible (so-called data portability).

The User also has the right to object in whole or in part, on legitimate grounds, to the processing of their personal data.

These rights may be exercised directly by sending a communication to the following email address:privacy@coimasgr.com.

Finally, if the User considers that the processing of the data provided violates data protection laws, they have the right to lodge a complaint with the Italian Personal Data Protection Authority (www.garanteprivacy.it).

• Collection of data through Cookies

8.1 What are cookies?

Cookies are small text files that sites visited by the user send to the user’s device (usually the browser), where they are stored and then transmitted back to the same sites on the next visit by the same user. Each cookie is unique in relation to the browser and device used to access the Website.

Cookies can be installed by the owner or operator of the site the user is visiting (so-called “first-party cookies”) or by other providers (so-called “third-party cookies”).

Cookies can be stored on the user’s device permanently, in which case once the browser is closed they are not removed but instead remain until a pre-set expiry date or deletion by the user (so-called “permanent cookies“), or they can be automatically deleted each time the user leaves the Website or closes the browser (so-called “session cookies“).

Cookies can be:

• Technical: these cookies are necessary for the proper operation of a site, i.e. they are useful for storing information about users during subsequent visits to the site. Consequently, they do not require the User’s consent.
• Analytical:these cookies may be used among other things to assess the effectiveness of an information society service, to design a website or to help measure its “traffic”, i.e. the number of visitors, possibly broken down by geographical area, time of connection or other characteristics. The use of analytical cookies installed and managed directly by the first party for statistical purposes (which do not go beyond the boundaries of a mere statistical count) does not require the User’s consent, as they are considered similar to technical cookies. If, on the other hand, they are used by third parties, in order for the analytical cookies to be treated in the same way as technical cookies it is indispensable to preclude the possibility that the direct identification of the person concerned be achieved through their use (singling out). In other words, the User’s consent will not be required if (i) the same cookie relates not to one but to several devices, in such a way as to create reasonable uncertainty as to the electronic identity of the person receiving it (e.g. through the masking of parts of the IP address), (ii) such cookies are only used to produce aggregate statistics and in relation to a single site or mobile application and (iii) third parties refrain from combining these minimised analytical cookies with other processing or passing them on to other third parties. If, on the other hand, they are not similar to technical cookies, they require the User’s consent.
• Profiling:these cookies are used to link specific actions or behavioural patterns recurring in the use of the functions offered on the sites to specific identified or identifiable persons, in order to group the various profiles within homogeneous groups of different sizes so that the data controller can, among other things, modulate the provision of the service in an increasingly personalised manner beyond what is strictly necessary to provide the service, and send advertising messages consistent with the preferences expressed by the user while browsing online. Such cookies require the User’s consent in order to be used.

The user’s consent will also be required for “mixed” cookies (i.e. cookies that are installed and used for different purposes and that do not merely have a technical function).

8.3 Changing and managing cookie preferences

• Banner cookie

Consent to the use of cookies is requested by means of the banner shown when the Website is first accessed, and thereafter no earlier than six months after the User’s preferences have been provided (except as indicated below).

Through such banner, the User will be able to (i) accept all cookies (by clicking on “I accept all cookies”), (ii) keep the default settings, which only allow the installation of technical cookies (by clicking on “Use only necessary cookies”), as well as (iii) choose which individual cookies to install (by clicking on “Other options”).

The User may also manage their cookie preferences at any time through the designated area in thefooter ofthe Website (“Review your cookie choices”).

Finally, note that – in addition to the above – the Company may display the banner again:

(i) If one or more conditions of the processing significantly change (e.g. if the “third parties” change), so as to provide the Users with information about such changes.

(ii) If it is impossible for the Website to know whether a cookie has already been stored on the device.

• Browser settings

Most browsers (Internet Explorer, Firefox, Chrome, etc.) are configured to accept, manage and disable cookies through their settings. With these browser settings it is possible to block or delete the cookies received from the Website or any other site by changing the browser settings using the relevant browser function.

The settings for managing cookie preferences are usually found in the browser menu under “Options” or “Preferences”.

Below are links to the instructions for the most common browsers:

Internet Explorer – http://windows.microsoft.com/en-gb/windows-vista/block-or-allow-cookies

Chrome–https://support.google.com/chrome/answer/95647

Firefox–https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Opera–http://www.opera.com/help/tutorials/security/privacy/

Safari–http://support.apple.com/kb/PH17191

Alternatively, choices regarding cookies can be managed at www.youronlinechoices.orgorwww.aboutcookies.org.

Remember that disabling all cookies – including those that are strictly necessary – may cause problems when browsing the Website and prevent the use of certain functions.

Furthermore, if the User wishes not to be tracked by the analytical cookies provided by Google, they can install the specificGoogle Analytics Opt-out Browser Add-onavailable athttps://tools.google.com/dlpage/gaoptout.

9Third-party plug-ins

The Website may also incorporate plug-ins and/or buttons for social networks in order to allow easy sharing of content on the user’s favourite social networks. Suchplug-insdo not set a cookie, but if it is already present on the user’s computer they are able to read it and use it according to the settings. The collection and use of information by such third parties is governed by their respective privacy policies, to which reference should be made.

10 Use of other websites

We recommend that you read the privacy and cookie policies of the websites you access via links on the Website.

Remember that cookie preferences on this Website will not be active on the websites of other companies.

• Transfer to non-EU countries

Unless strictly necessary for the purposes set out in this Privacy and Cookie Policy, the Company will not transfer your personal data to entities established outside the European Economic Area (“EEA“). Where data are transferred outside the EEA, the Company will take all necessary measures to ensure compliance with Chapter V of the Regulation. For information on the possible transfer of personal data collected through third-party cookies established in non-EU countries, see the privacy policy of the third party, available on its website and set out in the text of this Privacy and Cookie Policy.

• Changes to the Privacy and Cookie Policy

The Company reserves the right to make changes to this Privacy and Cookie Policy at any time, providing notice by publishing the policy on the Website.
We invite the User to check the Website for such updates.

If the changes are particularly significant and/or have a major impact on the User’s rights, the Company may also notify the User by a different means (e.g. by sending an email).

Privacy and Cookie Policy updated on 05/08/2024