Privacy Policy of FSI SGR S.p.A.

This Privacy Policy (the Policy) is provided in relation to the processing of personal data of users of FSI SGR S.p.A. website available at the address staging-new.fondofsi.it (the “Website”).

1. Data Controller

For the purposes of this Policy, the Data Controller is FSI SGR S.p.A., with registered office in Passaggio Centrale,  7 20123, Milan, enrolled in the Register of AIF Managers under No. 157, and enrolled in Milan Companies’ Register under no. 09422290966 (the “Data Controller”).

The Data Controller provides collective asset management services through the promotion, establishment, organisation and management of one or more closed-end mutual funds reserved to professional investors.

2. Data collected

Your personal Data – collected through access to the Website, access to the restricted area and the sending of any requests to the dedicated address – are limited to those necessary for the use of the Site by users of the same as well as those necessary to reply to any requests submitted by users (hereinafter, collectively, the “Data”).

The information systems and the software procedures used for the functioning of the Website acquire, during their normal operation, certain personal data whose transmission is implicit in the use of the Internet, which is based on the TCP/IP protocol.

This information is not collected for association with identified data subjects, but given its nature could, through processing and association with data held by third parties, result in the identification of users

This category of data includes “IP addresses” or the domain names of the computers used by users who connect to the site, URI (Uniform Resource Identifier) addresses of requested resources, the time of 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 provided by the web server (successful, error, etc.) and other parameters relating to the operating system and the IT environment of users who access the Website.

These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Website and to check the correct functioning of the Website such as to ensure its usability for users.

3. Purpose and legal basis of processing

The Data Controller may process your Data in order to reply to any requests sent by the data subjects through the site to the contacts indicated on the same for information requests. The legal basis for the processing of the Data collected through access to the Website and communications sent to the contacts indicated on the same for information requests is the legitimate interest of the Data Controller to reply to the requests of the data subjects. The Data Controller’s interest has been balanced with that of the data subjects and is compatible with the reasonable expectations of the latter, since it is reasonable to assume that they wish to receive feedback to their requests.

The Data Controller may also process your Data in order to allow access to the restricted area of the Website. The legal basis for the processing of Data collected through access to the restricted area of the Website, using the credentials provided by the Data Controller on the basis of separate agreements, is the execution of the existing contract with the Data Controller.

The provision of your Data for the aforementioned purposes is mandatory and necessary. Any partial or total refusal to provide such Data will make it impossible for the Data Controller to respond to requests for which Data are collected, to process requests for press accreditation, to reply to applications for jobs and internships, or to allow access to the restricted area.

4. Processing methods

Your Data will be processed by employees and / or collaborators of the Data Controller, specifically authorised to carry out processing and external data processors, whose names can be made available upon request to the Data Controller.

The Data Controller and the third parties used by the same process your Data using manual processing and electronic, or in any case, automated tools, according to logic strictly related to the purposes themselves and in order to guarantee the security and confidentiality of the Data.

5. Communication (recipients) of the Data

Your Data may only be communicated to third parties where necessary for the establishment, management, execution and / or termination of the contractual relationship with the Data Controller.

The third-party recipients of your Data, independent data controllers or duly authorised data processors, belong, inter alia, to categories of persons who perform, on behalf or in favour of the Data Controller, tasks of a technical and organisational nature or provide professional assistance / consultancy, in particular the managers of the software infrastructures used by the Data Controller.

The complete list of data processors is kept at the headquarters of the Data Controller and can be consulted upon request to be sent to the addresses indicated in Article 8 below.

6. Data dissemination

Your Data will not be disseminated.

7. Data retention

Your Data shall only be processed for the time strictly necessary to achieve the purposes for which they are collected.

8. Rights of the Data Subject

Data Subjects have the right at any time to: (I) obtain confirmation of the existence of any personal data concerning them; (II) know the purposes and methods of processing, the recipients of their Data and the retention period; (III) obtain the correction or erasure, and where applicable, limitation of the processing; (IV) oppose the processing; (V) where applicable, receive in a structured, commonly used and readable format, the Data concerning them provided to the Data Controller and to transmit such data to another data controller without impediment by the Data Controller; (VI) file a complaint with the Italian Data Protection Authority.

The rights above may be exercised at any time, by simple request to be sent to the Data Controller:

• via email, to the address: [email protected]; or
• via post to the address: FSI SGR S.p.A., Passaggio Centrale, 7 20123, Milan, to the attention of Mr. Simone Terenzi.