Information regarding data processing

Pursuant to Article 13 of Regulation (EU) No. 2016/679 on the protection of personal data (hereinafter the "Regulation"), Investire SGR S.p.A., as the data controller (hereinafter "Investire" or the "Company" or the "Controller"), provides the data subject (hereinafter "Data Subject") with certain information regarding the processing of personal data concerning him/her carried out with reference to a request for information on a asset owned by a reserved closed-end real estate alternative investment fund (hereinafter the 'Fund'), managed by the Company.

1. Purpose and legal basis for processing

Personal data will be processed for the following purposes:

  1. to enable the data subject to be contacted to receive information regarding a property.
    For these purposes, the processing of personal data is therefore necessary for the execution of pre-contractual measures requested by the data subject and for the pursuit of legitimate interests related to the performance of related administrative, organisational, technical and security activities of the Controller;
  1. to send commercial or promotional communications, advertising material, market research (so-called direct marketing purposes), by means of traditional contact systems (telephone with operator, mail and/or e-mail) and automated computer systems, by e-mail or SMS. For these purposes, personal data are processed only if the data subject has given his/her specific consent, indicated at the end of the form.

2. Source and categories of processed data

  1. Source from which personal data originate
    The personal data subject to processing are provided to the Controller directly by the Data Subject.
  1. Categories of data subject to processing
  1. Personal data of the Data Subject
    In relation to the purposes indicated in point 1 above, the Company processes the following personal data of the Data Subject: name, surname, e-mail address, telephone contact and any personal data entered in the contact form.  
    In relation to the purposes indicated in point 1 above, the Company does not normally collect or process special data from the Data Subject.
    Personal data will hereinafter be collectively referred to as "Data".

3. Nature of provision of Data

The provision of Personal Data is mandatory for the pursuit of the purposes set out in point 1, letter a) above, and any refusal by the User to provide such Data will result in the impossibility of receiving the service of the Site.

On the other hand, the release of Data is optional for the purposes of direct marketing referred to in point 1, letter b) above. In case of refusal, the Data Subject will not be able to receive updates or communications on new offers or promotions of his/her possible interest.

4. Method of processing and data retention time

In relation to personal data processed for the purposes referred to in point 1, letter a) above (marketing purposes), the processing will be carried out by means of automated logic and the use of management software managed in the cloud, which will allow the best possible management of the fulfilment of contractual and legal obligations.

In relation to the personal data processed for the purposes referred to in point 1, letter b) of this notice (marketing purposes), the processing will be carried out by means of software for sending commercial information, also by means of traditional and automated contact systems.

The processing of the Data Subject's Data shall be carried out by means of instruments and procedures suitable to guarantee their security and confidentiality in compliance with the law. The Data are not subject to an automated decision-making process.

The Controller will keep the Data of the Data Subject:

  • in relation to the pre-contractual purposes referred to in point 1 letter a) above, for 2 years from the response to the data subject's request for information, without prejudice to further storage if, following such request, a pre-contractual or contractual relationship is established with the data subject. In this case, for the duration of the relationship and, upon its termination, for the time provided for by the regulations in force for administrative, accounting, tax and anti-money laundering purposes (generally 10 years);
  • in relation to the marketing purposes referred to in point 1 letter b) above for a period of 2 years after the consent has been given, or before that period if the data subject requests the relevant cancellation and/or the consent is revoked.

5. Categories of subjects to whom the Data may be communicated or who may be made aware of it and the scope of dissemination thereof

Certain categories of employees of the Company, in their capacity as persons authorized to process, may have access to the Data Subject's Data for the purpose of the fulfillment of the duties assigned to them by the Company, aimed at the pursuit of the purposes illustrated above.

In addition, the Company, again for the pursuit of the purposes illustrated in this policy, may need to communicate the Data Subject's Data to the following recipients:

  • subjects who perform, on behalf of or for the Company, tasks of a technical nature and professional assistance or advice;
  • companies offering information society services, including, in particular, those offering hosting services;
  • the companies that make software available in the cloud;
  • companies managing and maintaining the Site.

Recipients in the above categories may act as data processors where they act on behalf of Investire or operate independently as separate data controllers.

The Data Subject's Data processed by the Company will not be published or otherwise disseminated and will also not be transferred to third countries outside the European Economic Area.

6. Rights of the Data Subject

The Data Subject may exercise, at any time, his/her rights towards the Controller, pursuant to the Regulation, namely:

  • access the Data concerning him/her and obtain certain information on their processing;
  • rectify or complete them if inaccurate or incomplete;
  • delete or restrict their processing, where applicable;
  • object to their processing on grounds relating to his particular situation;
  • withdraw consent, where the processing is based on such consent;
  • obtain the portability of data subject to automated processing and based on consent or a contract with the Data Subject;
  • lodge a complaint with the Data Protection Supervisor.

7. Controller of data processing

The Data Controller referred to in this information document is "Investire SGR S.p.A.", with registered offices in Via Po, 16 / a - 00198 Rome and with offices in Milan, Largo Donegani, n.2– 20121, which can be contacted at the following addresses: Tel: 06 - 696291; Fax: 06 - 69629212; E-mail: trattamentodati@investiresgr.it.

8. Procedures for the exercise of rights by the Data Subject

Claims relating to the exercise of the rights referred to in Section 8 of this Privacy Policy may be submitted in writing by e-mail to the following address: trattamentodati@investiresgr.it.