This Privacy Policy describes the purposes and methods by which COIMA SGR S.p.A. collects and processes personal data relating to the user (“User”) who interacts with the website http://www.portanuova.com/ (“Website”) and with the various services it offers.
The information contained in this Privacy Policy is provided under Art. 13 of Regulation EU of 27 April 2016 no. 679 (“Regulation”), as well as the Measures issued by the Data Protection Supervisory Authority and the Guidelines of the European authorities.
Information on the processing of data is provided only for the Website and for data processing operations carried out by the Company and it does not extend to processing carried out by third parties on other websites that may be consulted by Users via links. The Company does not accept any liability for this further processing; the User should refer to the individual Privacy Policies of the third party websites.
1. Data Controller
COIMA SGR S.p.A., based in Milan (Italy), Piazza Gae Aulenti no. 12, 20154 (“Company” or “Data Controller”)
2. Data processing methods
The Company processes the User’s data while adopting all appropriate data security measures to prevent unauthorised access, unauthorised disclosure, modification or destruction of the data. The processing is carried out using both manual and/or electronic tools, using organisational methods and logics strictly related and limited to the indicated purposes.
3. Data processing purpose and legal basis
The Company, through the Website, may process the User’s data for the following purposes:
a. Contacting the Company. The User may contact the Company to request information using the contact details specified on the Website. Personal data provided voluntarily by the User (e.g. email address, telephone number if any or other information freely provided to the User) will be processed by the Company to manage and respond to the User's communications or requests. The legal basis of the data processing is the implementation of the service specifically requested by the User, and any refusal to provide the personal data will make it impossible for the Company to manage and respond to communications or requests for information (art. 6(1) (b) GDPR).
b. Pursuance of the legitimate interests of the Company or third parties. The User’s data may be used to exercise the rights and legitimate interests of the Company or third parties, for example, handling claims and litigation, credit recovery, fraud prevention or prevention of unlawful activities. In these cases, although the provision of the User’s personal data is not mandatory, it is necessary as those data are closely linked and are instrumental to the pursuit of those legitimate interests, which do not prevail over the rights and fundamental freedoms of the User, and any refusal to provide them could make it impossible to implement the requested services (e.g. requesting information from the Company) (art. 6(1)(f) GDPR).
c. Fulfilling applicable legal or other obligations. The Company may use personal data that is provided by the User or otherwise acquired during the User's interaction with the Website for compliance with legislative and regulatory obligations, national and EU legislation, ad obligations deriving from measures issued by authorities who are legally authorised to do so, which represent the data processing legal basis (art. 6(1)(c) GDPR).
4. Data categories
The Company receives and collects information through the Website relating to the User who visits the pages of the Website and who uses the web services available on the Website. The Company acquires and processes the following information.
4.1 Data collected from browsing and cookies
When the User visits the Website, the latter collects certain data, such as pages viewed, connections or buttons clicked by the User, date and time of access, IP address, browser and operating system used (known as “navigation data”). The Company uses this data for the sole purpose of obtaining statistical information on the use of the Website for purposes related to its operation and assess the effectiveness of the services offered by the Website. Navigation data could be used to ascertain responsibility in the event of any computer crimes being committed against the Website.
For the collection of the User’s data through cookies and similar technologies, please visit the Cookie Policy.
4.2 Data provided voluntarily by the User
The Company limits the gathering of voluntarily provided information to data necessary to achieve the purposes described in paragraph 3 above and receive the services requested. Additional personal data may be collected and processed by the Company, if the same are provided voluntarily by you as part of the services offered by the Website, for example, if you contact the Company to report disservice or malfunctioning, to exercise your rights in relation to personal data processing, etc. Those data will be processed by the Company only for purposes strictly linked to your request. Any failure to provide the data may make it impossible to obtain the requested service.
5. Disclosure of data to third parties
The data provided by the User as well as those collected by the Website as part of the relevant services (e.g. IP address) will not be disseminated and may be communicated - for the purposes and using the methods illustrated in this Privacy Policy - to the categories of persons/entities listed below:
- COIMA, Residenze Porta Nuova platform companies, for organisational purposes, internal control purposes, pursue the Company or third-party legitimate interests and carry out the User services/requests;
- companies, collaborators, consultants or freelancers that the Company uses in order to implement technical or organisational tasks (e.g. IT service providers), or with whom the Company collaborates (including other COIMA and Residenze Porta Nuova Companies) in order to provide and operate its own services, or for any communication activities;
- persons, companies or professional firms that provide assistance and advice to the Company, particularly (but not exclusively) in accounting, administrative, legal, tax and financial matters;
- persons/entities entitled by law or by order of a public authority to access the data.
The persons/entities belonging to the categories indicated above will use the data as independent data controllers pursuant to law or as data processors properly appointed by the Company.
The list of entities to which the data are or may be disclosed, can be requested from the Company by using the contact details indicated in the “Rights of Users and Contact Details” section.
6. Data retention
The data are processed for the period of time necessary to carry out the activities indicated in paragraph 3 above, and are erased when the purposes for which they were collected and processed no longer apply.
The Company will provide feedback to email requests without further processing the personal data. It may hold the data for longer periods to meet the user’s request
The information collected through cookies will be stored for the periods specified in each table in section 8 below.
7. User rights and contact details
The User may exercise the rights provided for by the Regulation in the cases expressly envisaged by law and where applicable. The User has the right to:
- obtain confirmation of whether or not the processing of his/her personal data is in progress and, in that case, to request from the Controller access to information relating to that processing (e.g. purposes, categories of data processed, recipients or categories of recipients of data, retention period, etc.);
- request the rectification of inaccurate or incomplete data;
- request the Controller to erase the data (e.g. if the personal data are no longer necessary in relation to the purposes for which they were collected, or if the consent on which the data processing is based is withdrawn, etc.);
- request the data processing limitation (e.g. if the User disputes the accuracy of the data; if the data processing is unlawful and they object to the erasure of personal data; if data is required to exercise or defend the User's rights in court, even where the Controller no longer requires it; when the User exercises their right to oppose data processing, for the time required to verify whether legitimate reasons exists).
- receive personal data relating to him/her in a commonly-used and machine-readable format (e.g. pdf) and to send them to a different data controller, or to obtain direct transmission from one controller to the other, if technically possible (known as data portability).
The User also has the right to object, in whole or in part, for legitimate reasons, to the processing of personal data relating to him/her.
Those rights may be exercised directly by sending a communication to the following email address: privacy@coimasgr.com.
Finally, if the User considers that the processing of data provided violates personal data protection rules, he/she has the right to lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).
8. Data collection using Cookies
8.1 What are cookies?
Cookies are small text files that the websites visited by the user send to the device being used by the user to access the Internet (usually via a browser), where they are stored in order to later be retransmitted to the same websites the next time that the same user visits them. Each cookie is unique in relation to the browser and device used to access the Website
Cookies cannot view or retrieve data from other cookies, transmit computer viruses, or identify and use email addresses or passwords, nor can they acquire files or data stored on the user’s device.
Cookies can be installed by the owner or manager of the website that the user is visiting (known as “first-party cookies”) or by other providers (known as “third-party cookies”).
Cookies can be stored permanently on the user’s device. Once the browser is closed, cookies are not removed but remain until a pre-set expiry date or are deleted by the user (“persistent cookies”), or they can be automatically deleted every time the user leaves the Website or closes the browser (“session cookies”).
Cookies can be:
- Technical: cookies necessary for the proper website operation or are useful for storing information about users during later visits to the website. Technical cookies are essential to allow the user to navigate through the website and use its functions, so they do not require the user's express consent;
- Analytics: cookies which collect aggregate information about the number of users and how they use a website, including the pages they visit;
- Profiling: cookies which allow the creation of user profiles and are used to send advertising messages based on the preferences expressed by the user when browsing;
- Social Network: cookies which allow the user's social account to interact with a website (to make the user express a preference and share it with friends on social media).
8.2 Cookies used by the Website
The cookies used by the Website are technical and analytics cookies, as listed below:
TECHNICAL COOKIES
are used to enable Website operation and for the specific purposes indicated in the table below; these cookies are necessary to navigate on the Website and use its functions, so they do not require the user’s express consent.
Google Cookie:
- _gat_gtag_UA_99071980_6: Enables Google to distinguish between users (retention period: maximum two years)
Portanuova Cookies:
- CookieConsent: Stores the User's cookie consent status for the current domain (retention period: one year)
- _pc_vis: Registers an anonymous visitor ID, which identifies visits to the Website or content visited, identifying unique visitors retention period: one year)
- _pc_ses: Necessary cookie for the Pimcore session (retention period: session)
- _pc_tvs: Registers an anonymous visitor ID, which identifies visits to the Website or content visited (retention period: one year)
- ApplicationGatewayAffinity: Cookie used by the application gateway to maintain the sticky session (retention period: session)
- ApplicationGatewayAffinityCORS: Cookie used by the application gateway to maintain the sticky session on cross origin requests (retention period: session)
THIRD-PARTY ANALYTICS COOKIES
They are used to carry out statistical surveys based on aggregated data, on how users use the Website, to optimise and improve the Website. You can authorise or disable analytics cookies by clicking on the “Accept” or “Reject” buttons, respectively, or on the Banner or on “Other Options” if you want to know the types of cookies and choose whether to activate or reject them. Users can change their cookies settings at any time by accessing the cookie settings functions
The Company is not responsible for the possible use of information collected by third parties using the cookies specified in the table below, analytics cookies section (third-party) as the Company does not directly control these cookies. The Company thus invites you to take a look at the relevant cookie policy in the link shown below.
- _ga: Used to distinguish users (link: https://policies.google.com/privacy). Duration: two years
- _gat_gtag_ UA_99071980_6: Used to limit the request speed. If Google Analytics is distributed via Google Tag Manager, this cookie will be called _dc_gtm_<property-id> (link: https://policies.google.com/privacy). Duration: one minute
- _gid: Used to distinguish users (link: https://policies.google.com/privacy). Duration: one day
8.3 Changing and managing cookie preferences
It is possible to change and manage cookie preferences through the Website or browser settings or by using third party websites
1) through the Website: you can enable/disable third-party cookies using the selections in the table in the paragraph above
2) through the Websites www.youronlinechoices.org or www.aboutcookies.org
3) through your browser settings, you can block or delete cookies received from the Website or any other website by changing your browser settings through your browser function.
Below are links to the instructions for the following browsers:
Internet Explorer - http://windows.microsoft.com/en-gb/windows-vista/block-or-allow-cookies
Chrome - https://support.google.com/chrome/answer/95647
Firefox - https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Opera - http://www.opera.com/help/tutorials/security/privacy/
Safari - http://support.apple.com/kb/PH17191
Please note that disabling cookies - including strictly necessary cookies - could cause issues with browsing the Website and prevent certain features of the Website from functioning properly.
9. Third Party Plugins
The Website may also incorporate plugins and/or buttons for social networks in order to make it easier for the user to share content on their preferred social networks. These plugins do not set a cookie, but if one is already present on the user’s computer, they can read it and use it within the limits of its settings. The collection and use of information by these third parties is regulated by the relevant privacy policies, which the user is recommended to read.
10. Use of other websites
The user is recommended to read the privacy and cookie policies of any websites that they visit through the links present on the Website.
Please note that the cookie preferences applicable to this Website will not be active on the websites of other companies.
11. Transfer to non-EU countries
The Company will not transfer your data to entities established outside the European Union. For information on the possible transfer of personal data collected through third-party cookies established in non-EU countries, please refer to the third-party privacy policy on its website.
12. Changes to the Privacy and Cookie Policy
The Company reserves the right to make changes to this Privacy Policy at any time, giving notice of this by publication on the Website.
We invite the User to check these updates on the Website.
Should the changes be particularly significant and/or notably impact the User's rights, the Company may also communicate them to the User in a different manner (e.g. by sending an email).
Privacy and Cookie Policy as at 15.04.2022