Privacy Policy

USER PRIVACY NOTICE PURSUANT TO ARTICLE 13 AND 14] OF THE EU REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL OF 27 APRIL 2016 N. 679 (THE “GDPR”)

DeA Capital Alternative Funds SGR S.P.A., with registered office in Milan, Via Brera n. 21, e-mail privacy-AF@deacapital.com, as the DataController (hereinafter, the “Company” or the “Controller”), provides this information on the use of technologies that enable the Data Controller to collect and store information (via cookies or other tracking tools).

The navigation data of the user of the Website (the “User“) collected by the Company through the use of cookies or other tracking tools are processed by the Company in accordance with the provisions of the privacy policy in relation to navigation data and in accordance with the provisions of this policy.

  1. WHAT ARE COOKIES

Cookies are small strings of text that websites (so-called first party) visited by the user or different websites or web servers (so-called third parties) send to the user’s terminal, where they are stored, to be retransmitted to the same sites on subsequent visits. As better specified in paragraph 4 below, the cookies used on the Website are used by the Company for technical purposes.

  1. WHAT TYPES OF PERSONAL DATA ARE PROCESSED BY THE COMPANY?
    • Browsing data, technical and analytics cookies

The procedures and IT systems set up for the Website acquire, during their normal operation, some personal data the transmission of which is implicit in the use of internet communication protocols, to allow the User to browse the Website or provide a service requested by said User.

The Company uses:

  • technical cookies, without which the viewing of the Website or some operations could not be performed or would be more complex and/or less secure;
  • analytics cookies, to collect browsing data in aggregate and anonymous form for solely statistical purposes.
  1. FOR WHAT PURPOSES ARE PERSONAL DATA PROCESSED? WHAT IS THE LEGAL BASIS FOR THE PROCESSING?

The cookies used on the Website are divided into two categories:

  • cookies installed by the Data Controller, referred to as first-party cookies;
  • cookies installed by Third Parties (responsible parties outside the Website), referred to as third party cookies.

The responsibility and management of first party cookies is taken over directly by the Data Controller. The processing of navigation data collected by the Data Controller through first-party cookies is carried out, as regards navigation data collected through technical and analytics cookies, in accordance with the privacy policy prepared by the Data Controller pursuant to Articles 13 and 14 of Regulation (EU) of the European Parliament and of the Council of 27 April 2016 no. 679 (the “GDPR”) and, as regards navigation data collected through profiling cookies or other tracking tools other than technical and analytics cookies, in accordance with the provisions of this policy, where present.

The responsibility for and management of third-party cookies lies with their respective owners and operators. The User can consult the privacy policy and cookie policy of the Third Parties on the page of the Third Party website available at the links indicated in paragraph 4 below. The following types of cookies are used on the Website:

  1. Technical, session and analytical cookies

These cookies are necessary for the proper functioning of the site and to allow the User to navigate on the site; to record configuration preferences where available or to integrate plug-ins necessary to display certain content.

Cookies used for statistical and performance analysis are also considered technical cookies, as long as they are configured to collect data in aggregate and anonymous form that provide an overview of the website’s performance and content in order to assess and improve the effectiveness of the service and the website.

Browsing Data, as referred to in paragraph 2.1 above, are processed for the purposes of carrying out activities necessary to (i) check the correct functioning of the services offered and allow the User to consult the Website in a safe and efficient manner; (ii) collect statistical information in aggregate form to assess the effectiveness of the web services; the User’s consent is not required for these purposes.

  1. WHAT COOKIES ARE INSTALLED ON THIS SITE? WHICH COOKIES ARE COMMUNICATED TO THIRD PARTIES?

The Data Controller processes the navigation data necessary to pursue the purposes described above and for the duration indicated in paragraph 5 below.

The list of cookies used on the Website, whose use does not require the User’s consent, can be found in the Cookie Policy at this link https://www.deacapitalaf.com/cookies-policy/?lang=en.

All technical cookies are installed automatically following access to the Website.

The Website uses Google Analytics solely for statistical purposes and in order to assess the effectiveness of the Website or the services offered.

These cookies collect information in aggregate and anonymous form in order to monitor and analyse access to the pages of the Website.

The information generated by the cookie about the use of the Website is transmitted to Google Inc.

The Google Analitycs cookies installed by the Website are anonymised and, consequently, do not carry out profiling of Users. These cookies are installed automatically following access to the Website.

  1. HOW LONG WILL THE DATA BE STORED?

The browsing data collected through the cookies managed by the Data Controller will be stored for a period of time not exceeding 365 days from, as far as technical and analytics cookies are concerned, the last time the User consults the Website.

The cookies managed by third parties are stored for the durations indicated in their respective privacy policy and cookie policy available at the links indicated in paragraph 4 above.

  1. HOW WILL THE DATA PROCESSING BE CARRIED OUT?

The processing of personal data will be carried out using electronic and/or telecommunications tools, with a logic strictly related to the purposes referred to in section 3. above, and in any case in such a way as to guarantee the security and confidentiality of said data.

  1. WHAT RIGHTS DOES THE USER HAVE WITH REGARDS TO THEIR PERSONAL DATA?

With regard to your browsing Data, you may, at any time, exercise your rights under Articles 15 to 22 of the GDPR in the manner and under the terms set out therein. In particular, the User has the right to:

  • ask the Controller for access to, correction of, and erasure of browsing data (“right to be forgotten”) which pertain to said User or the limitation of the processing of such data;
  • oppose the processing of browsing data;
  • obtain the portability of the browsing data;
  • withdraw the consent requested by the Controller and potentially given by the user, at any time, and without compromising the lawfulness of the processing based on the consent given before its withdrawal.
  1. LODGING COMPLAINTS

In regards to any type of data processed by the Controller, the User has the right — if they believe that the processing of their browsing data has occurred or is occurring in violation of the GDPR and of the applicable regulations at the time, and with no prejudice to their right to file an appeal to any other court — to lodge a complaint with the Supervisory Authority for personal data protection, in the manner indicated on the site www.garanteprivacy.it.

  1. HOW TO EXERCISE THE RIGHTS. HOW TO CONTACT THE CONTROLLER

The user can exercise their rights at any time, as per section 7. above, by sending a communication to the following address: privacy-AF@deacapital.com or to the Company’s registered office, Via Brera n. 21 – 20121, Milan.

The Data Controller