Privacy

Information on the processing of personal data of users of the Gardant Investor SGR S.p.A. website

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Gardant Investor SGR Società di Gestione del Risparmio S.p.A., with registered office in Via Curtatone 3, 00185 Roma RM, in its capacity as data controller (hereinafter also “Gardant Investor SGR” or the “Data Controller”) is committed to respecting your privacy and protecting your personal data and wants you to feel safe both during the simple navigation of the site www.gardantsgr.eu (the “Site”), and in the event that you decide to register, providing us with your personal data to take advantage of the services made available to Users and/or Customers. On this page, Gardant Investor SGR therefore intends to provide some information on the processing of personal data relating to users who visit or consult the Site. This information is provided by Gardant Investor SGR, in its capacity as Data Controller, only with regard to the Website and not for other websites that may be consulted by the user through links contained therein (for which reference is made to the respective data protection policies).

Gardant Investor SGR informs users that the personal data provided by them or, in any case, acquired at the same time as the request for information and/or contact, registration on the Site and use of services via smartphone or any other tool used to access the Internet, including navigation data and data used for any purchase of the services offered by Gardant Investor SGR, also through the websites of the companies of the doValue Group, will be processed in compliance with the applicable data protection legislation, with particular reference to Regulation (EU) 679/2016 on the Protection of Personal Data (“GDPR”) and the national adaptation legislation in force.

Browsing data

The computer systems and software procedures used for the operation of the Site acquire, during their normal operation, some personal data whose transmission, based on the TCP/IP protocol, is implicit in the use of the Internet. This information is not collected to be associated with identified data subjects, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the “IP addresses” or domain names of the computers used by users who connect to the site, the URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the web server, the size of the file obtained in response, the numerical code indicating the status of the response given by the web server (successful, successful, error, etc.) and other parameters related to the user’s operating system and computer environment.

Information you provide

The user may be asked to provide his/her personal data (e.g. personal data, bank details) to allow Gardant Investor SGR to provide the requested services. In addition, the use of some features of the Site, the sending of e-mail communications, the spontaneous completion of contact forms, as well as contacts via the toll-free number, may involve the processing of additional personal data of the user in order to follow up on the request for information and/or the forwarding of documentation, pamphlets, information brochures that provide an exhaustive picture of the products and services offered by Gardant Investor SGR and other companies of the Group. Specific detailed information may be reported or displayed on the pages of the site prepared for particular services.

Cookies

A cookie is a short string of text that is sent to your browser and, possibly, saved on your computer (alternatively on your smartphone/tablet or any other tool used to access the Internet); this is generally sent every time you visit a website. Gardant Investor SGR uses cookies for various purposes, in order to offer you a fast and secure digital experience, for example, allowing you to keep your connection to the protected area active while browsing through the pages of the site. Cookies stored on your device cannot be used to retrieve any data from your hard drive, transmit computer viruses or identify and use your e-mail address. Each cookie is unique in relation to the browser and device you use to access the Website. Generally, the purpose of cookies is to improve the functioning of the website and the user experience in using it, although cookies can be used to send advertising messages (as specified below). For more information on what cookies are and how they work, you can consult the “All about cookies” website http://www.allaboutcookies.org. For detailed information on Cookies, please read the dedicated Cookies Policy page.

Purposes and conditions of lawfulness of the processing

Users’ personal data will be processed to provide users with the requested service, i.e. access, navigation and provision of the contents of the Site. Further processing other than those indicated above may also be based on the execution of contractual relationships to which users are parties, or to fulfil the pre-contractual measures envisaged for them. In addition, in the event that it is necessary under the GDPR, user data will be processed on the basis of users’ free and express consent for one or more specified purposes.

Without prejudice to the legal bases identified above, user data will be processed within the limits of what is strictly necessary for the pursuit of the following purposes:

registration on the Website www.gardantsgr.eu, on the services and/or Apps developed or made available by the Data Controller in connection with the Website, use of the related information services, management of contact or information requests. The provision of data for these purposes, connected to a pre-contractual and/or contractual phase or functional to a user request, is optional. However, if you do not provide the data, it may not be possible for Gardant Investor SGR to provide users with the services that may be requested;
processing of anonymous statistics on the use of the Site and verification of its correct functioning;
only after obtaining the specific consent of the Users, sending advertising, information, promotional material and updates on initiatives and offers intended for users, market research, economic and statistical analyses. For these purposes, the provision of data is optional and does not entail any consequences for the user, except for the impossibility for Gardant Investor SGR to provide any updates on new products and services;
ascertainment of responsibility in the event of computer crimes against the Gardant Investor SGR website or other sites connected or linked to it;
fulfilment of obligations provided for by EU and national legislation, protection of public order, detection and repression of crimes.

Methods, processing logics, storage times and security measures

For the performance of the activities highlighted above, personal data may be known by the staff in charge of Gardant Investor SGR, within the structures responsible for web services and services, and will also be processed through computerized procedures and electronic communication systems, protected by appropriate security and confidentiality measures, as well as with methods and logics consistent with the purposes pursued and for the strictly necessary retention times to the fulfilment of contractual and legal obligations. In particular, in the sections of the website set up for particular services, where personal data is requested from the user, the data is encrypted using a security technology called Secure Sockets Layer, abbreviated as SSL. SSL technology encrypts the information before it is exchanged via the Internet between the user’s computer and Gardant Investor SGR’s central systems, making it incomprehensible to unauthorised persons and thus guaranteeing the confidentiality of the information transmitted.

Areas of communication and data transfer

For the pursuit of the purposes indicated above, your data may be transferred in Italy and abroad, including outside the European Economic Area if this is necessary for the pursuit of the aforementioned purposes. In this case, the recipients of the data will be subject to protection and security obligations equivalent to those guaranteed by the Data Controller. In any case, only the data necessary for the pursuit of the intended purposes will be communicated and the guarantees applicable to data transfers to third countries will be applied, where required. In addition to the companies of the doValue Group, affiliates, subsidiaries and/or parent companies, we may also disclose personal data to our commercial service providers, for marketing reasons, appointed for this purpose as external data processors. In addition, personal data may be communicated to the competent public bodies and authorities for the purposes of compliance with regulatory obligations or to ascertain responsibility in the event of computer crimes against the site, as well as communicated to third parties, who provide IT and telematic services (e.g. hosting services, management and development of websites) and which Gardant Investor SGR uses to carry out tasks and activities of a technical nature instrumental to the operation of the Site. Subjects belonging to the above categories may operate as independent data controllers or, when necessary, as data processors duly appointed by Gardant Investor SGR. Personal data may also be known by employees/consultants of Gardant Investor SGR specifically appointed as data processors or persons in charge of processing. The updated list of Data Processors can be consulted by request to be sent to Gardant Investor SGR at the addresses indicated below.

Rights of the data subjects

Users may exercise at any time the rights recognized by the legislation on the protection of personal data, including the right to:

to request confirmation as to whether or not your personal data is being processed;
to access the personal data concerning you, obtaining evidence of the purposes pursued by the Data Controller, the categories of data involved, the recipients to whom they may be communicated, the applicable retention period, the existence of automated decision-making processes;
to obtain without delay the rectification of inaccurate personal data concerning you and the related notification to those to whom the data have been transmitted by Gardant Investor SGR;
to obtain, in the cases envisaged, the cancellation of your data and the related notification to those to whom the data have been transmitted by Gardant Investor SGR;
to obtain the limitation of processing, when provided;
to object to the processing of your personal data, when possible;
to request and obtain the portability of personal data – provided by you to Gardant Investor SGR – in the established cases and in a structured, commonly used and machine-readable format, also to transmit such data to another controller, without any hindrance from Gardant Investor SGR itself;
to lodge a complaint with the Guarantor Authority for the Protection of Personal Data.

For processing that is based on your consent, you may withdraw your consent at any time. In any case, the withdrawal of consent will not affect the lawfulness of the processing carried out up to that moment. For any exercise of your rights, you can contact the Data Protection Officer at the contacts indicated in the following paragraph.

Data Controller and Data Protection Officer

The Data Controller, pursuant to current legislation, is Gardant Investor SGR Società di Gestione del Risparmio S.p.A., with registered office in Via Curtatone 3, 00185 Roma RM.

To contact the Data Protection Officer, you can write to:

Gardant Investor SGR S.p.A.
c.a. Data Protection Officer

Via Curtatone 3, 00185 Roma RM
E-mail address: dpo@dovalue.it

This document will be updated (the various versions of the document will be made available). We therefore invite you to periodically visit this section of our website to view any changes or additions.

Sustainability

Information on the processing of personal data of users of the Gardant Investor SGR S.p.A. website