Privacy and cookie policy

Website

REGULATORY REFERENCES

Guidelines for cookies and other tracking tools dated 10 June 2021 [doc. no. 9677876]; Directive 2002/58/EC of 12 July 2002 (Directive and Privacy) and Art. 122 of the Privacy Code; EU Regulation 2016/679 of 27 April 2016 (General Data Protection Regulation).

THE DATA CONTROLLER

Pursuant to Article 13 of Regulation (EU) 2016/679 (GDPR), the Data Controller is Etica SGR S.p.A. with registered office in Milan, Via Napo Torriani, 29 – 20124 Milan (hereinafter, “Etica SGR”), which provides you with the following information regarding the cookies installed on the domain www.eticasgr.com/en (hereinafter, “website”).

WHAT ARE COOKIES?

Cookies are small text files, usually consisting of letters and/or numbers, which are sent by the Website and stored by the browser installed on your device. Cookies are then sent back to the Website on your next visit.

Cookies make it possible to store information about visits to the Website and are a very useful technology, as they help the Website to function more efficiently. Without cookies, the Website would have no way of tracking certain information, such as storing your authentication credentials

Cookies can be classified according to:

  • duration: session or persistent cookies;
  • origin: first-party or third-party cookies;
  • purpose: strictly necessary cookies, performance analysis cookies and behavioural advertising cookies.

Cookies which expire at the end of a browser session (normally when the browser is closed or when the session expires) are referred to as session cookies and are useful, for instance, for keeping the browsing session active. Cookies which, on the other hand, are stored for a longer period of time (between sessions) are called persistent cookies and are used, for example, to remember your preferences or to recommend targeted advertising.

The definition of first or third party refers to the website or web server that installs the cookie. First-party cookies are installed directly by the Website, whereas third-party cookies are installed by a different Website or web server, for instance, if the Website incorporates elements from other services, such as advertising platforms.

It should be specified that the purposes usually fulfilled by a cookie can also be achieved through other similar technologies, including the use of certain functionalities that allow devices to be identified so that visits to the Website can be analysed. In fact, this policy applies to any technology that stores or accesses information on your device. This could include, for instance, HTML5 local storage, Local Shared Objects (also called flash cookies) and fingerprinting techniques. Henceforth, when reference is made to cookies, this definition will also include other assimilated technologies.

What are the purposes of the cookies used by the Website?

Strictly necessary cookies

These cookies enable the Website to function properly and allow you to use its content and services easily. For example, you can browse the Website while keeping your language settings or store your authentication credentials. Strictly necessary cookies cannot be disabled. These cookies are stored in your browser for the time necessary to ensure the proper functioning of the Website.

Strictly necessary cookies
Cookies subgroup Cookies Cookies used Duration
eticasgr.com/en _ga, _gat_UA- Part One 730 Days, A few seconds
www.eticasgr.com/en PHPSESSID, OptanonAlertBoxClosed, OptanonConsent Part One Session, 365 Days, 365 Days

Performance analysis cookies

These cookies are installed to collect aggregate information of a mainly statistical nature (how long you stay on a web page, number of visitors to the Website, etc.). The following are present: a. first-party analytical cookies, similar to technical cookies in that they are installed directly by the Website to improve usability. b. third-party analytical cookies, analytical cookies created and installed by third parties to analyse user browsing in order to produce statistics on visits or improve the content offer, show similar products and possibly place targeted advertising on web pages. You may refuse to use cookies by changing the appropriate setting on your browser, but this may prevent you from using the full functionality of the Website. Analytical cookies can be equated with the category of technical cookies and, as such, can be used without the prior consent of the data subject. In this case (as with technical cookies), the legal basis is contractual. Analytical cookies will only be equated with technical cookies if their use precludes the possibility of directly identifying the data subject. If, on the other hand, the analytical cookies should identify the data subject, even with a reduced power of identification, the data subject’s consent will be required. The choice of consent collection, therefore, depends on how Etica SGR uses analytical cookies.

Performance analysis cookies
Cookies subgroup Cookies Cookies used Duration
eticasgr.com/en _gid, _gclxxxx Part One 1 Day, 90 Days
tr.outbrain.com outbrain_cid_fetch Third Parties A few seconds

Functionality cookies

These cookies enable the Website to provide enhanced functionality and personalisation. They may be set by us or by third-party providers whose services have been added to our pages. If you do not authorise these cookies, some or all of these services may not function properly.

Functionality cookies
Cookies subgroup Cookies Cookies used Duration
my.eticasgr.com pll_language Part One 365 Days

Social media cookies

These cookies are set by a number of social media services we have added to the Website to enable you to share our content with your friends and connections. They are able to monitor your browser on other Websites and create a profile of your interests. This may have an impact on the content and messages displayed on other websites you visit. If you do not accept these cookies, you cannot use or view these sharing tools.

Social media cookies
Cookies subgroup Cookies Cookies used Duration
linkedin.com li_gc, bcookie, lidc Third Parties 729 Days, 730 Days, 1 Day

 

Behavioural advertising cookies

These cookies are used to track your navigation on the Website in order to analyse your behaviour for marketing purposes and create a profile of your tastes, habits and choices. In this way, Etica SGR can send you targeted advertising messages in relation to your interests and in line with the preferences you have expressed when browsing. These cookies are not necessary for the operation of the Website, so your consent is required for their installation.

Behavioural advertising cookies
Cookies subgroup Cookies Cookies used Duration
www.eticasgr.com/en outbrain_cid_fetch Part One A few seconds
eticasgr.com/en _fbp Part One 90 Days
twitter.com personalization_id Third Parties 730 Days
linkedin.com AnalyticsSyncHistory, lang, UserMatchHistory Third Parties 30 Days, Session, 30 Days
youtube.com CONSENT, YSC, VISITOR_INFO1_LIVE Third Parties 5,957 Days, Session, 180 Days
www.linkedin.com bscookie Third Parties 730 Days
ads.linkedin.com lang Third Parties Session
www.facebook.com Third Parties Session

Name of service and purpose

Name of service Origin Purpose
www.eticasgr.com/en Part One Ensuring the functioning of the Website.
Vimeo Third party
AddToAny (AddToAny LLC) Third party AddToAny is a service provided by AddToAny LLC that displays a widget enabling interaction with social networks and external platforms and the sharing of content on this Application. Depending on the configuration, this service may display widgets belonging to third parties, e.g. the managers of social networks on which interactions are shared. In this case, the third parties providing the widget will also become aware of the interactions and Usage Data relating to the pages where this service is installed. For further information: http://www.addtoany.com/privacy
Ads Remarketing (Google, Inc.) Profiling Ads Remarketing is a remarketing and behavioural targeting service provided by Google, Inc. that links Etica Sgr’s activities with the Adwords advertising network. Personal data collected: Cookies and Usage Data. Processing location: USA – Privacy Policy – Opt Out.
Facebook Remarketing (Facebook, Inc.) Profiling Facebook Remarketing is a remarketing and behavioural targeting service provided by Facebook, Inc. that links Etica Sgr’s activities with the Facebook advertising network. Personal data collected: Cookies and Usage Data. Processing location: USA – Privacy Policy – Opt Out.
Facebook Audience Network (Facebook, Inc.) Profiling Facebook Audience Network is an advertising service provided by Facebook, Inc. For an understanding of Facebook’s use of data, please see Facebook’s data policy. Among the ways Audience Network proposes advertising messages to the User, there is also the use of the User’s advertising preferences. Users can control the sharing of their advertising preferences within Facebook’s ad settings. The User can opt out of certain Audience Network targeting functions via their device settings. For example, you can change the advertising settings available for mobile devices or follow the instructions applicable to Audience Network that may be included in this privacy policy. Personal data collected: Cookies, Usage Data and unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for instance). Processing location: USA – Privacy Policy – Opt Out.
Facebook Custom Audience (Facebook, Inc.) Profiling Facebook Custom Audience is a remarketing and behavioural targeting service provided by Facebook, Inc. that links Etica Sgr’s activity with Facebook’s advertising network. Personal data collected: Cookies and email address. Processing location: USA – Privacy Policy – Opt Out.
Google Analytics Third party The Website uses Google Analytics, an analysis tool from Google that helps website and app owners understand how visitors interact with their content. A set of cookies may be used to collect information and generate website usage statistics without Google personally identifying individual visitors. In addition to generating reports on website usage statistics, the Google Analytics pixel tag may be used along with some advertising cookies to enable more relevant results to be displayed in Google properties (such as Google Search) and across the Web. More information on Analytics cookies and privacy: https://www.google.com/analytics/learn/privacy.html?hl=it. Add-on to deactivate Google Analytics: https://tools.google.com/dlpage/gaoptout/
Google Maps Third party Google Maps is a map display service operated by Google, Inc. which allows this Application to integrate such content into its pages. Google uses these cookies to store user preferences and information every time the user visits web pages containing Google Maps. These cookies contain enough information to allow tracking. Read more about the use of data and its processing by Google: https://policies.google.com/technologies/partner-sites?gl=it&hl=en-GB
Google Ads Third party Etica Sgr could also use the advertising and remarketing tool Google Adwords. This tool makes it possible to promote Etica Sgr’s Website and publish personalised advertisements based on users’ visits to our Website. That’s why some pages of the Website may include a code called “remarketing code”. This code makes it possible to read and configure the browser’s cookies to determine which type of ad you will see, depending on the data relating to your visit to the Website, such as the navigation circuit chosen, the pages actually visited or the actions performed within them. The remarketing lists thus created are stored in a database on Google’s servers on which all the IDs of the cookies associated with each list or category of interests are stored. The information obtained only identifies the browser, as Google is not able to identify the user with this information. For more information on Google Remarketing, please visit https://support.google.com/adwords/answer/2454000?hl=it&ref_topic=2677326. More information on Google’s Privacy Policy and Principles can be found at http://www.google.it/policies/technologies/ads/. Authorisation to collect and store data may be revoked at any time. The user can deactivate Google’s use of cookies through the specific setting options of the different browsers. To manage Google’s ad preferences visit: https://adssettings.google.com/authenticated?hl=it
Google Tag Manager (Google, Inc.) Third party Google Tag Manager is a statistics service provided by Google, Inc. Personal data collected: Cookies and Usage Data. Processing location: USA – Privacy Policy.
Ligatus (Ligatus GmbH) Third party Ligatus is an advertising service provided by Ligatus GmbH. Personal data collected: Cookies and Usage Data. Privacy Policy – Opt Out.
LinkedIn Website Retargeting (LinkedIn Corporation) Profiling LinkedIn Website Retargeting is a remarketing and behavioural targeting service provided by LinkedIn Corporation that links the activity of Etica Sgr with the LinkedIn advertising network. Personal data collected: Cookies and Usage Data. Processing location: USA – Privacy Policy – Opt Out.
Conversion monitoring by Google Ads (Google, Inc.) Third party Google Ads conversion monitoring is a statistics service provided by Google, Inc. that links data from the Google Ads network with actions taken within Etica Sgr. Personal data collected: Cookies and Usage Data. Processing location: USA – Privacy Policy. Data Privacy Framework Program.
Facebook Ads Conversion Monitoring (Facebook, Inc.) Third party Facebook Ads conversion tracking is a statistics service provided by Facebook, Inc. that links data from the Facebook ad network with actions taken within Etica Sgr. Personal data collected: Cookies and Usage Data. Processing location: USA – Privacy Policy.
X Ads Conversion Monitoring (X Corp.) Third party X Ads conversion monitoring is a statistics service provided by X Corp. that links data from the X ad network with actions taken within Etica Sgr. Personal data collected: Cookies and Usage Data. Processing location: USA – Privacy Policy.
Outbrain (Outbrain, Inc.) Third party Outbrain is an advertising service provided by Outbrain, Inc. Personal data collected: Cookies and various types of Data as specified by the privacy policy of the service. Privacy Policy – Opt Out.
Remarketing with Google Analytics (Google, Inc.) Profiling Remarketing with Google Analytics is a remarketing and behavioural targeting service provided by Google, Inc. that links the tracking activity performed by Google Analytics and its cookies with the Google Ads network. Personal data collected: Cookies and Usage Data. Processing location: USA – Privacy Policy – Opt Out. Data Privacy Framework Program.
ScorecardResearch Third party Tracks the online behaviour patterns of our users anonymously (i.e. without making data subjects identifiable). The tags used by ScorecardResearch cannot identify the user visiting a page. For instance, ScorecardResearch Beacon tags can collect data such as timestamps, the URL and the title of the web page. In addition, the data collected by ScorecardResearch is only used in aggregate form. In other words, the reports created from this data will not say that Computer 1 went from Website A to Website B to Website C. For more information: http://www.scorecardresearch.com/privacy.aspx
SoundCloud Third party Audio tracks from the company’s official SoundCloud channel can be embedded on the Website. SoundCloud is an audio content delivery service operated by SoundCloud Limited which allows this Application to integrate such content into its pages. The personal data collected is usage data. For more information: https://soundcloud.com/pages/cookies
Taboola Third party Taboola uses cookies and other device identifiers to collect information about users, users of the service. These static data send information to Taboola about the use of the service and enables it to propose more relevant and appealing content to the users of the service. Privacy Policy – Opt Out
Turbo Adv Third party An online advertising service provided by Turbo S.r.l. Turbo’s technology makes it possible to optimise the delivery of online advertisements so that they have maximum relevance for the people who are exposed to them. Turbo cooperates with advertisers and third parties to deliver advertising messages relevant to Internet users. Turbo voluntarily joins the European Interactive Digital Advertising Alliance (EDAA) to improve transparency and control of data used for behavioural advertising. The voluntary initiative is based on the IAB Europe OBA framework and the EASA BPR OBA. Privacy policy and opt-out: http://www.turboadv.com/white-rabbit-privacy-policy/
X Third party X social widgets can be embedded on the Website, showing recent tweets from the company’s official X profile. X social widgets are services for interacting with the social network X, provided by X Corp. For more information: https://twitter.com/en/privacy
Twitter Remarketing (X Corp.) Profiling Twitter Remarketing is a remarketing and behavioural targeting service provided by X Corp. that links Etica Sgr’s activities with the X advertising network. Personal data collected: Cookies and Usage Data. Processing location: USA – Privacy Policy – Opt Out.
Custom Audiences (X Corp.) Profiling Custom Audiences is a remarketing and behavioural targeting service provided by X Corp. that links the activity of Etica Sgr with the X advertising network. Personal data collected: Cookies and email address. Processing location: USA – Privacy Policy – Opt Out.
YouTube Third party Videos from the company’s official YouTube channel can be embedded on the Website. YouTube is a video content display service operated by Google, Inc. which allows this application to integrate such content into its pages. The personal data collected are cookies and usage data. For more information: https://www.youtube.com/static?template=terms

 How do you manage cookie preferences?

When you first access any page of the Website, you will see a banner containing a short disclosure and a link to open the cookie consent centre through which you can easily choose which cookies to install. You can access the cookie consent centre at any time and easily via a specific link in the footer of the Website.

In addition to the above, you can also change your cookie settings via your browser, either by deleting all or some cookies or by restricting cookies to certain Websites. Below are instructions for changing the cookie settings for the most common browsers used:

Please note that you can selectively disable the action of Google Analytics by installing the opt-out component provided by Google on your browser. To disable Google Analytics, please refer to the link below: https://tools.google.com/dlpage/gaoptout. Disabling cookies or deleting them may affect the optimal use of certain areas of the Website or prevent certain functionalities, as well as affect the functioning of third-party services.

Communication and dissemination of data

The data collected using cookies may be processed by employees and collaborators of the company functions assigned to the pursuit of the above-mentioned purposes who have been expressly authorised to process them and who have received appropriate operating instructions. Such data may also be processed by trusted companies that perform tasks of a technical and organisational nature on behalf of Etica SGR. These companies act as data controllers. Furthermore, they may be processed by external parties acting as independent data controllers, such as, for example, authorities and supervisory and control bodies. Data collected using cookies may be transferred to the United States of America, subject to the guarantees set out in Chapter V of the GDPR.

Your rights

By contacting the Data Controller by sending an e-mail to privacy@eticasgr.it, you may ask Etica SGR for access to the data concerning you, their deletion, the restriction of their processing in the cases provided for by At. 18 of the GDPR, as well as objection to processing in cases of legitimate interest.

If the processing is based on consent or a contract and is carried out by automated means, you have the right to receive the data in a structured, commonly used and machine-readable format and, if technically feasible, to send them to another data controller without hindrance. You also have the right to withdraw consent for unnecessary cookies without affecting the operation and functionality of the Website. Additionally, you have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali).

Data Controller and Data Protection Officer

The Data Controller is Etica SGR, which can be contacted at Via privacy@eticasgr.it with registered office at Via Napo Torriani, 29 – 20124 Milan, Italy

The Data Protection Officer can be contacted at dpo@eticasgr.it.

Newsletter

INFORMATION IN ACCORDANCE WITH ARTICLE 13 Regulation (EU) 2016/679 (General Data Protection Regulation, hereinafter the “Regulation”).

Etica Sgr S.p.A., in its role as Data Controller, wishes to provide you with some information regarding the use of the personal data you have entered in the newsletter registration form.

  1. Purpose of processing, legal basis for processing and data retention periods

The personal data you register will be processed to manage your registration and send you our regular newsletter. The legal basis for carrying out such processing is the consent you have given in an informed manner and manifested by means of the newsletter subscription request (Article 6(1)(a) of the Regulation). In this regard, we would like to inform you that, since the processing of your data through this form is exclusively dedicated to guaranteeing your subscription to the newsletter, your consent will be expressed by clicking on the “Subscribe” button, thereby expressing your unequivocal intention to receive the newsletter. The data will be stored for as long as the newsletter service is active, i.e. until your consent is revoked.

In addition, personal data may be processed, subject to specific consent, for the following purposes:

  1. sending marketing information relating to Etica Sgr products and services, other than the information covered by the newsletter. The legal basis for carrying out such processing is your freely given and informed consent (Article 6(1)(a) of the Regulation). The data will be stored for as long as the newsletter service is active, i.e. until your consent is revoked.
  2. contacting you for direct offers or to ask you to complete satisfaction questionnaires and/or carry out market surveys regarding Etica Sgr’s products and services. The legal basis for carrying out such processing is your freely given and informed consent (Article 6(1)(a) of the Regulation). The data will be kept for the period of time necessary to achieve the purposes in question and, in any case, until you revoke your consent.
  3. responding to enquiries or complaints that you may have sent us by e-mail following subscription to the newsletter. The provision of data for this purpose is necessary for the provision of the service you have requested. The legal basis for such processing is the performance of the contract to which you are party or the performance of pre-contractual measures taken at your request (Article 6(1)(b) of the Regulation). The data will be kept for the period of time strictly necessary to comply with your request and, in any case, for a period not exceeding ten years from the time of conclusion of the contract.

With exclusive regard to processing based on consent, we inform you that, if given, you have the right to revoke your consent at any time without prejudice to the lawfulness of processing based on consent given prior to revocation. The provision of data for the purposes described in a and b above is optional. It is understood that, if you do not provide the data marked as mandatory, it will be impossible to proceed with your subscription to our newsletter.

  1. Data recipients and transfer to third countries

Your data will not be disseminated. In the event that it is necessary for the performance of specific processing activities, personal data may be communicated and/or transferred to third parties entrusted with carrying out instrumental activities for achieving the envisaged purposes and designated pursuant to Article 28 of the Regulation as Data Processors. In order to ensure the lawful processing of Data, third parties may only use Data in accordance with instructions given and documented by us. Third parties may include but are not limited to companies that manage and maintain the company’s information systems or companies appointed to carry out services related to email marketing activities. Your personal data may be transferred to entities located in third countries (meaning countries outside the EU and EEA). In such cases, Etica SGR shall obtain the necessary guarantees that the transfer of Data is carried out in compliance with the provisions of Chapter V of the Regulation.

  1. Rights of Data Subjects and Contact Details

As a data subject, you have the right to obtain from the Data Controller, in the cases provided for, access to your personal data, rectification of inaccurate data, deletion of data, restriction of processing, portability of Data, as well as the right to notify or object to processing, including the right not to be subject to a decision based solely on automated processing, including profiling. You may exercise your rights at any time by contacting the Data Controller using the following contact details:

Etica Sgr S.p.A.

Corporate Protection – Privacy

Via Napo Torriani, 29 – 20124 Milan, Italy.

Tel. +39 02/67071422

Fax +39 02/67382896

E-mail: privacy@eticasgr.it

 

  1. Contact details for the Data Protection Officer (DPO)

Pursuant to Article 37 of the Regulation, the Data Controller has appointed a Data Protection Officer (DPO) who can be reached at the following e-mail address: dpo@eticasgr.it

  1. Right to complain

If you believe that the processing of your data is in breach of the Regulation, you have the right to lodge a complaint with a supervisory authority.

Private area

DISCLOSURE PURSUANT TO ARTICLE 13 of Regulation (EU) 2016/679 (General Data Protection Regulation) hereinafter the “Regulation”.

Etica Sgr S.p.A., as Data Controller, is required to provide some information regarding the use of personal data.

PURPOSE OF DATA PROCESSING

Personal data subject to registration will be processed for activities strictly related to the provision of the requested service.

The same data may also be processed, in the event of explicit consent of the customer pursuant to Art. 6 of the Regulation, for the following purposes:

  1. sending marketing information for Etica Sgr products and services, including the sending of the newsletter;
  2. direct offers or market surveys relating to Etica Sgr products and services.

Consent for the purposes described in points a and b is optional.

DATA CONTROLLER

As part of the consultation of this Website, data relating to identified or identifiable persons may be processed. The Data Controller for the purpose of their processing is Etica SGR S.p.A, Via Napo Torriani 29, 20124 – Milan, Italy.

LOCATION OF DATA PROCESSING

The processing connected to the web services of this Website take place at the premises of the supplier and is carried out only by technical personnel duly appointed for the purpose or by persons responsible for performing occasional maintenance.

DATA PROCESSING METHODS

Personal data is processed, including by means of automated tools, for the time strictly necessary to achieve the purposes for which they were collected. Specific security measures are followed to prevent loss of data, unlawful or incorrect use and unauthorised access. Etica Sgr S.p.A has adopted all the minimum security measures required by law and, drawing inspiration from the main international standards, has also adopted additional security measures to minimise the risks concerning the confidentiality, availability and integrity of the personal data collected and processed.

DATA SHARING, COMMUNICATION AND DISSEMINATION

The data collected may be transferred or communicated to other companies for activities strictly connected with and instrumental to the operation of the service, such as managing the IT system. The personal data provided by users who request dispatch of informative material (brochures, informational material, etc.) is used for the sole purpose of performing the service or provision requested and are communicated to third parties only if necessary for that purpose (companies that provide enveloping, labelling, mailing services). Outside of these cases, personal data will not be communicated or granted to anyone, unless contractually stipulated or authorised by the parties. In this sense, personal data may be sent to third parties, but only and exclusively in the event that there is explicit consent to share the data with third parties, there is a need to share the information with third parties in order to provide the requested service, and it is necessary to comply with requests from judicial or public security authorities. No data from the web service is disseminated.

ACCESS VIA EXTERNAL IT SYSTEMS

If access to the reserved area is through an IT service equipped with an identification system, a service for which a party other than Etica Sgr S.p.A. is the Data Controller, this party will provide Etica Sgr with the personal data necessary to use the service requested (name, surname and tax ID).

DATA RETENTION

Data shall be stored in its entirety for the entire duration of the contract; subsequently, data shall be stored for a period of ten years in compliance with legal obligations, including the provisions of Article 2220 of the Italian Civil Code. Any further storage of the data or part of the data may be arranged to assert or defend rights in any court and, in particular, in the judicial courts.

RIGHTS OF DATA SUBJECTS

With regard to your personal data, we would like to inform you that you may exercise your rights under Articles 15 to 22 of Regulation (EU) 2016/679:

  1. Access to the following information:
    • purpose of processing,
    • categories of personal data concerned,
    • recipients or categories of recipients to whom such personal data have been or will be disclosed, in particular if they are recipients from third countries or international organisations,
    • existence of the data subject’s right to request from the data controller the rectification or erasure of personal data concerning them or to object to the processing of personal data concerning them;
  2. Rectification, by which we mean:
    • correction of inaccurate personal data concerning them without justified delay,
    • supplementation of incomplete personal data, including by providing a supplementary statement;
  3. deletion of data concerning you without undue delay, if:
    • the data are no longer necessary in relation to the purposes for which they were collected or otherwise processed,
    • consent is revoked and there is no other legal basis for the processing,
    • you object to the processing and there is no overriding legitimate reason to proceed with the processing,
    • personal data has been unlawfully processed,
    • personal data must be deleted to fulfil a legal obligation,
    • personal data was collected in connection with the provision of information society services;
  4. limitation of the data processing:
    • if you contest the accuracy of the personal data, for the period necessary for the data controller to verify the accuracy of such personal data;
    • when the processing is unlawful and the data subject objects to the deletion of the personal data and requests instead that its use be restricted;
    • when the personal data is necessary to the data subject for the establishment, exercise or defence of a legal claim, even though the data controller no longer needs them for the purposes of the processing;
    • if you object to the processing by virtue of your right to object;
  5. Receipt of notification in the event of rectification or deletion of personal data or restriction of processing;
  6. Data portability, i.e. the right to receive personal data concerning you in a structured, commonly used and machine-readable format, and the right to send such data to another data controller if:
    • processing is based on the express consent of the data subject for one or more specific purposes or takes place pursuant to a contract entered into with the data subject, and
    • the processing is carried out by automated means;
  7. Objection at any time, on grounds relating to their particular situation, to the processing of personal data concerning them.

You have the right to lodge a complaint with a supervisory authority if you feel that you have not been granted the rights set out herein.

To exercise the above rights, you may contact the Data Controller by sending a registered letter with acknowledgement of receipt to the address indicated or an email to privacy@eticasgr.it

CHANGES TO THIS PRIVACY POLICY

Etica Sgr S.p.A periodically checks its privacy and security policy and, if necessary, revises it in relation to regulatory, organisational or technological changes. If the policies change, the new version will be published on this page of the Website.

QUESTIONS, COMPLAINTS AND SUGGESTIONS

Anyone wishing to obtain more information, contribute their suggestions or lodge a complaint about or dispute our privacy policies or the way our company processes personal data may do so by writing to privacy@eticasgr.it.

Any enquiries regarding the protection of personal data may be addressed to:

Etica Sgr S.p.A.

Corporate Protection – Privacy

Via Napo Torriani, 29 – 20124 Milan, Italy.

Tel. +39 02/67071422

Fax +39 02/67382896

E-mail: posta@eticasgr.it

The company uses the Group’s DPO, who can be reached at the following e-mail address: dpo@eticasgr.it

 

Institutional Customers

Information pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (“GDPR”)

Etica SGR (hereinafter, “Etica” or “Data Controller”) provides the information required by the GDPR regarding the processing of personal data related to the possible establishment and subsequent execution of the contractual relationship between Etica and “institutional clients”, i.e. professional/qualified investors, such as pension funds, insurance companies, investment companies, etc. (hereinafter, “Institutional Client”).

  1. Data Controller

The Data Controller is Etica SGR with registered office at Via Napo Torriani 29, Milan, Italy.

Tel. +39 02-67071422, fax +39 02-67382896, e-mail address posta@eticasgr.it

  1. Contact details of the Data Protection Officer (“DPO”)

The DPO can be contacted at the following e-mail address: dpo@eticasgr.it

  1. Categories and sources of processed data

Data processed:

  • common data (e.g. name, surname, e-mail) referring to the Institutional Client’s legal representative or possibly referring to the Institutional Client as a natural person (sole proprietor or freelance professional), as well as to the Institutional Client’s employees/collaborators;
  • special data, if necessary, for anti-money laundering purposes;
  • data on criminal convictions and offences, for anti-money laundering purposes.

Data source: data are either provided directly by the data subjects (also by handing over a business card) or:

  • by the Institutional Client, when establishing or executing the relationship, in the case of employees/collaborators;
  • by third parties, e.g. agencies organising industry events or public databases 
  1. Purposes of processing, legal bases and data retention periods
WHY IS PERSONAL DATA PROCESSED? WHAT IS THE CONDITION THAT MAKES THE PROCESSING LAWFUL? HOW LONG DO WE KEEP PERSONAL DATA?
For the possible establishment and consequent execution of the contractual relationship (e.g. acquisition of information prior to the conclusion of the contract, execution of operations on the basis of the obligations arising from the contract, sending of informative communications/updates/etc. concerning the service provided). The legal basis of the processing consists of:
– in the performance of pre-contractual measures taken at the request of the data subject or in the performance of a contract to which the data subject is a party for the data of the Institutional Client (natural person individual entrepreneur or legal representative of the exhibitor legal person);
– in the legitimate interest for the data of the Institutional Client’s employees/collaborators.		 For the entire duration of the contractual relationship and, upon termination, for 10 years thereafter, without prejudice to further legal obligations.
The data will be retained in accordance with the terms of the law, i.e. for a period of 10 years after the termination of the ongoing relationship, professional service or occasional transaction.
In the event of the establishment of a contractual relationship, for the performance of administrative, accounting, tax and further legal obligations (e.g. anti-money laundering), as required by the law, regulations and EU legislation or by provisions issued by authorities empowered to do so by law and by Supervisory and Control Bodies. The legal basis for the processing is found:
– in a legal obligation to which the Data Controller is subject for the performance of administrative, accounting, tax and other legal obligations;
– for anti-money laundering purposes, in the public interest as referred to in Article 6 let. e) of the GDPR, for which the processing is necessary for the performance of a task carried out in the public interest or in connection with the exercise of public authority vested in the Data Controller. This legal basis is explicitly referred to as a condition of lawfulness legitimising the processing of such information in Art. 2(6-bis) of Legislative Decree no. 231/07
For the possible establishment, exercise or defence of the Data Controller’s rights in court. The legal basis for the processing is the legitimate interest of the Data Controller. For the entire duration of the litigation, until the time limits for appeal have been exhausted.
For sending commercial communications on services similar to those purchased by the data subject. The legal basis for the processing consists of thelegitimate interest of the Data Controller (“soft spam” pursuant to Art. 130, c. 4 Legislative Decree 196/03). Until objection exercised by the data subject.
For the implementation of customer satisfaction aimed at obtaining information from customers on the quality of the services offered. The legal basis for the processing is the legitimate interest of the Data Controller to improve its services by shaping them on the basis of customer feedback. Up to the processing of the (anonymised) survey results.

 

  1. Provision of data

The provision of data is mandatory for the establishment and execution of the contractual relationship with the Institutional Client. In the event of failure to do so, it will therefore not be possible to finalise the contract and provide the services. Furthermore, the provision of data is also mandatory for the fulfilment of administrative, accounting, tax and further legal obligations. Refusal to provide the requested information may make it impossible to perform the requested operation.

  1. Categories of data recipients

The data may be communicated to third parties acting as independent data controllers, such as public authorities and supervisory and control bodies entitled to request them, professional firms and auditing firms.

The data may also be processed, on behalf of Etica, by third parties, designated as Data Processors pursuant to Art. 28 of the GDPR, such as natural and/or legal persons carrying out activities functional to or connected with the contractual relationship (e.g. IT service providers, outsourcing companies, banks and credit institutions, etc.).

The data will not be disseminated in any way or transferred outside the European Union.

  1. Rights of the Data Subject

The GDPR gives the data subject specific rights, including the right to obtain from Etica confirmation as to whether or not personal data relating to them is being processed and, if so, access to such data and the information referred to in Art. 15, rectification of inaccurate data, integration of incomplete data, deletion of data in the cases provided for by Art. 17 (it is specified that the right to erasure of data cannot be exercised where the processing is carried out in compliance with a legal obligation requiring the processing to be carried out in accordance with the law of the Union or of the Member State to which the data controller is subject or in the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller), the restriction of the processing in the cases provided for in Article 18, as well as to object, on grounds relating to their particular situation, to the processing carried out in the legitimate interest of the data controller (e.g. to object to the sending of commercial communications about services similar to those purchased by the data subject.)

The data subject also has the right to receive the data in a structured, commonly used and machine-readable format and, if technically feasible, to pass them on to another data controller without hindrance (“right to data portability”) where the processing is based on a contract and is carried out by automated means.

In order to exercise their rights, the data subject may contact the Controller by sending a written communication to the above address or an e-mail to the following address privacy@eticasgr.it

The data subject has the right to lodge a complaint with the competent supervisory authority in the Member State where they normally reside or work or in the State where the alleged infringement occurred.