Consultinvest Capital Allocation AE – Isin IT0005516528 (2023)

Privacy Policy

By pursuing a transparent and correct policy, in compliance with current regulations and with specific reference to EU Regulation 2016/679 (hereinafter referred to as "Privacy Policy”), Innovazione Finanziaria SIM S.p.A. (hereinafter referred to as “society"oh"Innofin"), belonging to the parent company Gruppo MutuiOnline S.p.A. (hereinafter referred to as "mutual push online group"), as an independent data controller, provides you with some information on the processing of your personal data communicated within the framework of pre-contractual, contractual and general purposes when using the services offered by the websitewww.fondionline.it, although it may be integrated with other websites in a "co-branded" model and/or adapted for mobile devices, also as an "application" (hereinafter referred to as "Fondi Online Site' even 'property”)。

1. Purpose and legal basis of treatment

1.1.According to Article 6, the collected data will be processed by the company without express consent. Section 6 para. 1 lit. b) of the Privacy Policy for the following purposes:

  • Allows Innofin to perfect and execute intermediary services for contracting potential customers through the website, as well as sub-hosting and management services;
  • Allow Innofin to process for purposes of insurance mediation;
  • provide Allfunds Bank S.A. (Innofin as a sub-distributor for investment funds and SICAV) with the necessary information to provide the services you have requested or agreed to in relation to the financial products covered by this sub-agreement;
  • Offer to entities with which Innofin has or will enter into commercial or partnership agreements (mainly managers of mutual funds, SICAV and open pension funds authorized to market in Italy, insurance companies and intermediaries), or entities carrying out professional activities in the field of investments Information necessary for the service to perform the services you have requested or agreed to with you using (such as an independent financial advisor);
  • Facilitate the use of the FondiOnline website in its different sections and versions, for example by identifying users returning to the website, simplifying and personalizing the user experience, storing searches and offers for each product;
  • Telephone customer support activities, necessary and necessary to provide services under contract and/or requested by potential customers;
  • Collect and manage customer feedback on services provided by Innofin and related partiespartnercommercially as part of the provision of services;
  • administration of the relations (including commercial relations) between Innofin and the third parties mentioned in the preceding points;
  • Respond to comments and reports sent by customers;
  • Allows website users to participate in competitions and prize promotions sponsored by Innofin.

According to Art. 6(1)(a) GDPR, the data collected will be processed by Innofin without explicit consent. Article 6 para. 1 lit. c) of the Data Protection Regulation in order to comply with general legal and regulatory obligations (e.g. anti-money laundering obligations, tax obligations, etc.). According to Article 9 of the Data Protection Regulation, Innofin will not continue to collect or process "certain categories of personal data" (such as data relating to health conditions).

1.2.The data collected will also be processed by Innofin without explicit consent in order to pursue its legitimate interests pursuant to Art. 6 para. 1 lit. f) of the Data Protection Regulation, namely:

  • Sending information and commercial communications by e-mail to promote your services to users who have already used them, without prejudice to the user's right to object to processing at any time. The processing is understood to be carried out in accordance with Section 130 para. 4 of the Privacy Act;
  • To develop analytical, observational and forecasting models based on historical and/or statistical basis, which can be used for company management, to increase the competitiveness of product offerings, to improve services and/or to disseminate them in a completely anonymous form, including to the public;
  • monitor and ensure the correct functioning of all tools used to send communications to website users;
  • Perform all in-depth analysis required to properly identify/authenticate successful transactions;
  • To prevent fraud and unauthorized use of services, to assess the economic reliability and/or solvency of potential customers, also through cross-checks with external databases and/or access to information systems of authorized companies.

1.3.According to Art. 6 para. 1 lit. a) of the Data Protection Regulation, Innofin may process the collected data for the following purposes, subject to the express and free consent of the party concerned:

  • Sending promotional information and promotional material by any means, offering own products and/or services or third parties, conducting surveys and market research, in particular using telephones with operators and/or automated systems (e.g. SMS, MMS, fax, automated replies, push notifications, social media); it is understood that non-consent to this treatment will not affect the treatment mentioned in point 1.2 above.
  • profiling of users for commercial and marketing purposes based on the method of using the FondiOnline website, the interest expressed in various products/services and exposure to promotional information;
  • Transfer of personal data to other companies belonging to the MutuiOnline group in order to send advertising messages and advertising material, to offer own or third party products and/or services, to carry out surveys and market research, by any means, in particular using an operator and/or or phone calls from automated systems (e.g. SMS, MMS, fax, autoresponders, push notifications, social media).

1.4.The data provided by the interested parties may also be used by Allfunds Bank S.A., Italian and foreign management companies and insurance companies and insurance intermediaries with which Innofin has or will enter into commercial or placement agreements without express consent according to art. 6. Privacy Policy No. 1 Subparagraph b), in order to improve and implement the mediation service and custody management service agreed with the user.

The data collected will be processed by Allfunds Bank S.A., Italian and foreign management companies, insurance companies and insurance intermediaries with which Innofin has concluded or will enter into commercial or cooperative contracts, without express consent under the terms of Art. Art. 6 para. 1 lit. c) GDPR for the full implementation of legal and regulatory obligations.

2. Data provision

2.1.We would like to point out that the transfer of personal data for the purposes mentioned in points 1.1 and 1.4 is mandatory and refusal to provide the data will not allow the establishment and/or continuation of a contractual relationship with Innofin.

3. Data Controller

3.1.The independent data controller is Innofin.

4. Scope of communication and dissemination of data, responsible for processing

4.1.For the purposes mentioned in point 1, the data you provide may be disclosed to the following persons as independent data controllers:

  • Allfunds Bank S.A., with which Innofin has entered into a sub-sale agreement for the provision of services provided by Innofin;
  • The updated list of Italian and foreign management companies (mainly managers of investment funds, SICAV and open pension funds, with which Innofin has or will enter into commercial agreements or placement agreements, authorized to issue in Italy, is published on the following website:https://www.fondionline.it/societa-di-gestione.html) to perform services you have received or to provide services you have requested;
  • Bank where Innofin customers cash and cash equivalents are deposited (Banca Intesa Sanpaolo, websitewww.intesasanpaolo.com);
  • Insurance companies and insurance intermediariespartnerwith whom Innofin has entered into a brokerage agreement for insurance products;
  • Other companies with which Innofin has entered into or will enter into agreements or cooperation for the purpose of managing and providing the services provided by Innofin;
  • Innofin is controlled and supervised by regulatory bodies and agencies (such as but not limited to Consob, Bank of Italy, Taxation Authority);
  • professionals employed by you to carry out activities in the field of investment services (such as independent financial advisors);
  • Empowering companies, such as commercial whistleblowers, to exercise legal control in the mutual interest of fair transactions and the smooth functioning of markets;
  • Other MutuiOnline group companies, with prior consent, for commercial and marketing purposes.

4.2.For the purposes mentioned in point 1, the data you provide may be communicated to the following persons, who have been designated as data controllers for this purpose:

  • Other companies of the MutuiOnline Group carry out activities in the following fields: customer service, operational marketing, administration, organization, back office, technology;
  • Conduct surveys on companies: quality of service provided, customer satisfaction, etc.;
  • companies providing services related to the provision, monitoring, navigation analysis, measurement and optimization of the website;
  • Companies specialized in the operation and management of marketing, remarketing, social media and communications campaigns via the Internet, email and/or telephone system;
  • companies specializing in data processing, archiving and/or analysis services, and IT platforms used by professionals employed by you in the field of investment services;
  • Companies that carry out activities related to the transmission, packaging, delivery and classification of communications to customers.

4.3.Your data will not be communicated, made available or made available in any form for inspection by persons other than those mentioned in the previous points or by unspecified persons.

5. Data export

5.1.For the purposes mentioned in point 1, the data you provide may be transferred to companies belonging to the categories mentioned in point 5 and located in EU countries.

5.2.To the extent required by tax law (e.g. FATCA and CRS law), personal data transferred to tax authorities may also be forwarded to the authorities of the tax domicile of the party concerned outside the European Union (e.g. USA, OECD countries). .

6. Data processing method

6.1.Data processing can be carried out using manual, automated, computerized or telematics tools for storing, managing and transmitting data.

6.2.The interested party is not bound by any decision solely based on automated processing (including profiling), which has legal effects on him or which significantly affects him personally in a similar way.

6.3.The Fondionline website uses cookies. For more information, please refer to the specific information required by current law and available on the website:www.fondionline.it/informativa-cookie.html.

7. Data retention period

7.1.Personal data processed for the purposes mentioned in points 1.1, 1.2 and 1.3 will be processed by December 31st of the 10th year following the date of termination of the continuing relationship or, if there is no continuing relationship, December 31st of the 5th year Date of processing before year. The year stored from the date the information was provided or the date the information was last used in response to a user's service request.

7.2.For user personal data and contact details which are processed on the basis of the user's express consent for the purposes stated in point 1.3, the retention period is deemed to be extended until the consent is withdrawn, even if it exceeds the period stated in point 1.3 7.1.

8. Rights of both parties

8.1.Innofin fully complies with Articles 15, 16, 17, 18, 20 and 21 of the Data Protection Regulation, informing you that you have the right to:

  • request access to personal data concerning you (Article 15) and their correction (Article 16) or deletion (Article 17) or restriction of processing (Article 18), or to object to processing (Article 21), and The right to data portability (Article 20);
  • Withdraw consent at any time, without affecting the lawfulness of treatment based on consent prior to withdrawal;
  • The right to lodge a complaint with the guarantor regarding personal data protection issues.

We inform you that you can object to the processing of your personal data for direct marketing purposes at any time pursuant to Art. 21 of the Data Protection Ordinance.

8.2.In order to exercise the above rights, we ask you to use the following specific notices:

  • Innofin SIM S.p.A.
  • Registered Office: Att.ne “Data Processing Privacy” – Via Casati, 1/A – 20124 Milan
  • Operational Centers: Attention to "Data Processing Privacy" – Via Desenzano, 2 – 20146 Milan
  • Toll free: 800 92 92 95
  • e-mail:privatsphäre@fondionline.it

8.3.To select the treatment for which you wish to exercise your right to object or to withdraw, you can fill in a dedicated form at any timeOnline model takingAnd follow the given simple procedure.

9. Duty to protect personal data

9.1.Innofin has appointed its own Data Protection Officer. Contact dpo@innofin.it. To exercise the rights mentioned in point 8.1, please contact the contact person mentioned in point 8.2, who is responsible for managing requests from interested parties to exercise their rights.

Information updated until May 31, 2023

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