Privacy Policy

The website www.clessidraprivateequity.it (hereinafter, the “Site”) is owned by Clessidra Private Equity SGR S.p.A. (hereinafter, the “Company“) as Data Controller. The security measures relevant to the Site have been defined and developed to ensure that the information provided by users (hereinafter “Users” or “User“) is processed in compliance with the personal data’s protection and  privacy legislation, to which our activity is dutifully inspired, for the purposes and modalities better described in the present information notice (hereinafter, the “Privacy Policy”).
The Privacy Policy is provided pursuant to art. 13 of the EU General Data Protection Regulation 2016/679 (hereinafter, the “GDPR“) and is intended to describe the management of this Site, with reference to the processing of personal data of the consulting Users, as well as to allow the Site Users to became aware of the purposes and modalities of the personal data’s processing by the Company.
The Privacy Policy is also based on Recommendation no. 2/2001 on certain minimum requirements for collecting personal data on-line in the European Union, which was adopted on 17 May 2001 by the Working Party set up under Article 29.
The Privacy Policy is made only for this Site and does not apply to other websites that may be consulted by the User through links on the pages of the Site. The Company declares that it has not carried out any verification of websites belonging to third parties and therefore it assumes no responsibility and does not offer any guarantee in relation to the privacy rules by them adopted.
The Privacy Policy can be easily consulted as it is accessible from the home page of the Site and through links on any other page.
This Policy also provides detailed information on the types and modalities of use of cookies, and it also illustrates the options available to users to accept or reject cookies used by the Site.

1. Data Controller and Data Processor 

 
The Data Controller is the Company with registered office in Piazza degli Affari 2 – 20123, Milano (MI), in  person of its interim Chief Executive Officer domiciled at the Company’s registered office.
The User can contact the Data Controller at the following addresses:
by email: info@clessidrasgr.it
by post: Clessidra Private Equity SGR SPA – Piazza degli Affari, 2 – 20123 MI.
The Data Controller has appointed the Data Processor. The Data Controller can appoint other internal or external Data Processors as well as a person in charge of the processing. A complete and updated list of Data Processors and person in charge of the processing can be requested to the following e-mail address: info@clessidrasgr.it

2. Personal data object of the processing

 
“Personal data” means any information concerning an identified or identifiable physical person with particular reference to an identifier such as a name, an identification number, location data or an online identifier.
The personal data collected by the Site are the following:
2.1 Navigation Data
The information systems and software procedures relied upon to operate this Site acquire personal data as part of their standard functioning; the transmission of such data is an inherent feature of Internet communication protocols. Such information is not collected in order to relate it to identified data subjects, however it might allow user identification after being processed and matched with data held by third parties.This data category includes IP addresses and/or the domain names of the computers used by any user connecting with this Site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.), and other parameters related to the user’s operating system and computer environment.
These data are only used to extract anonymous statistical information on Site use, without therefore the possibility of identifying the user, as well as to check its functioning including the resolution of technical problems; they are erased immediately after being processed. The data might be used to establish liability in case computer crimes are committed against the Site.
This processing is aimed at pursuing a legitimate interest of the Company.
2.2 Data Provided Voluntarily by Users
These are all personal data voluntarily released by the User on the Site, such as: User’s contact details voluntary provided by sending e-mail to the addresses indicated on the Site in order to have a direct contact with the customer service, as well as any other personal data included in the message; data provided by sending CV (curriculum vitae) to the Company and other relevant information for personnel selection purposes; data provided in order to register and / or access the reserved area, or in order  to request information on a specific product or service via form.
Each User can change his/herdata by sending an email to info@clessidrasgr.it, taking care to specify in the heading “Exercise of rights regarding the protection of personal data”.
Specific summary information notices will be shown and/or displayed on the pages that are used for providing services on demand.

3. Data Processing purposes and legal basis of data processing 

For the purposes of access to the Site as a User, it is necessary to register by filling in the fields of the form.
Apart from that specified for the navigation data referred to in paragraph 2.1), the personal data provided by Users through the Site are processed for the following purposes:
a) to allow the execution of operations strictly connected and instrumental to the management of relations with the Users, such as – merely by way of example – the answer to questions received with the contact forms, the authorization to the reserved area and the execution of sales contracts of goods and /or services and the verification of their development, the management for the selection of CV personnel (curriculum vitae) and other relevant information provided by the User;
b) to allow the correct execution of the contractual obligations assumed by the Company towards the Users and customers and vice versa, as well as the consequent accounting and tax obligations;
c) to allow the fulfillment of the obligations established by law, regulations and European legislation, or provisions issued by authorities entitled by law and by supervisory and control authorities;
d) the purposes necessary for the establishment, exercise or defense of a right in court or whenever the courts exercise their judicial functions;
e) purposes of statistical research/analysis on aggregated or anonymous data, without the possibility of identifying the User, aimed at measuring the functioning of the Site and the related operational functions, including the resolution of any technical problem.
The legal basis for the processing of personal data for the purposes listed in point a) is the provision of a service or the answer to a request. Pursuant to the applicable law, the consent of the Users is not necessary for those activities.
As to the purposes listed in points b), c) and d), the processing is necessary for the pursuit of a legitimate interest of the Company.
The purposes listed in point e) do not involve personal data processing.
It is always possible to withdraw consent to the processing of data for this purpose, even in a disjointed way, for example, to decide to receive advertising only by postal service and not through automated systems.

4. Nature of the provision of personal data and consequences of any refusal

Apart from what is specified for navigation data that are automatically collected by the system and for the operation of cookies (please refer to the related information notice), the User is free to provide or not his/her personal data.
For the free registration as a User to the Site it is necessary to fill in the form, inserting some personal data in the predefined fields.
The compilation, completely optional, allows to assign credentials for the management of online services; the missed conferment, as well as the partial or inexact conferment, does not allow, therefore, the provision of the service.
The use of passwords, identification numbers (IDs) or other special access keys on this Site is under the Users’ responsibility.

5. Processing modalities and storage periods

Users’ data will be processed with or without the aid of electronic and / or automated means for the time strictly necessary for the purposes for which the data are collected and subsequently processed and, in any case, for the times established by the legislation GDPR and the regulations in the applicable time. Further information about the retention period of personal data and / or the criteria used to determine this period can be requested by writing to the Data Controller at the following address info@clessidrasgr.it.
Specific security measures are observed to prevent data loss, confidentiality and illicit or incorrect use of unauthorized access.

6. Scope of communication and disclosure of data

For the pursuit of the purposes indicated above, the provided Personal Data will be only communicated to persons entrusted by the Company, e.g. employees, collaborators and internal and external consultants, appointed in writing as persons in charge for the processing or internal or external data processors. Specific instructions have been provided to the pre-mentioned persons.
Your Personal Data may also be communicated and transferred to subjects whose right to access is recognized by provisions of law or by instructions given by authorities legitimated by the legislation.

7. Rights of the Data Subject 

Pursuant to art. 13 of the Privacy Regulation, the Data Subject can at any time:
request from the Controller access to and rectification or erasure of Personal Data or restriction of Data processing;
a) object to Data processing; 
b) exercise the right to Data portability;
c) withdraw consent, without affecting the lawfulness of processing based on consent before its withdrawal;
d) lodge a complaint with a supervisory authority;
e) get information about the possible existence of automated decision-making, including profiling.
The aforementioned rights can be exercised with a request made without formalities towards the Data Controller at the following addresses:
by e-mail: info@clessidrasgr.it
by post: Clessidra Private Equity SGR SPA – Piazza degli Affari, 2 – 20123 Milano.

8. Amendments

The Company reserves the right at any time to modify, also due to changes in applicable law, the Privacy Policy updating this page. The User is therefore requested to periodically check the Privacy Policy in order to become aware of the related updates.
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