Privacy and Cookies Policy

The main elements of this site’s Privacy Policy are shown below.

CDP Equity S.p.A. (hereinafter “CDPE”) manages the data provided by the user when browsing in accordance with that prescribed by European Regulation 2016/679 (hereinafter GDPR).

The procedures for managing the site www.cdpequity.it (reference site for the remote communication techniques offered by CDPE) relating to the processing of the personal data of the users who consult it are shown below. The Privacy Policy only relates to this site and does not concern other websites that may be consulted by the user connected by links.

CDPE informs a user who consults this website about the purposes and methods for processing personal data. If the user requests registration to restricted areas of this website, they will receive an additional privacy policy in relation to the processing of data provided for said purpose.

The data controller

The Data Controller of personal data is CDP Equity S.p.A., whose registered office is in via San Marco 21/A, 20121, Milan.

Any request for clarification can be sent to the Compliance Department of CDPE at the following email address: privacy@cdpequity.it

Types of data processed

Browsing data

During normal operation, the computer systems and software procedures used to operate this website acquire some personal data, the submission of which is implied in the use of Internet communication protocols.

This information, which is not collected to be associated with identified data subjects, but by their very nature could, by means of processing and associations with data held by third parties, allow users to be identified.

This category of data includes the IP addresses or domain names of the computers used by the users who connect to the site, addresses in URI (Uniform Resource Identifier) notation of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (completed, error, etc.) and other parameters related to the user’s operating system and computer environment.

Cookies

Cookies are text strings present in the each user’s browser that the sites visited by users send to its terminal. Some operations cannot be carried out without using cookies, which in some cases are therefore technically necessary.

CDPE uses technical cookies to optimise users’ browsing experience, in order to:

· identify the user’s device when logging in to its sites. In this way, it is possible to provide information on products, allow personalised content to be viewed and make other functions and services available.

· Analyse browsing in order to make it even simpler to access CDPE’s services. · Conduct research and analysis to improve CDPE’s content, products and services.

· Improve security.

The Measure of the Data Protection Authority dated 8 May 2014 (identification of simplified procedures for the privacy policy and the acquisition of consent for the use of cookies) states that ‘technical’ cookies can also be used in the absence of consent.

These technologies do not in any case allow data, user credentials or other information to be saved on the device in order to keep the site’s security level unchanged.

Each user, if they prefer, can still set their browser to receive a warning of the presence of a cookie and decide whether or not to accept it. It is also possible to automatically refuse the receipt of cookies by activating the appropriate option in the browser used by the user for browsing: not using cookies, however, could result in difficulty interacting with CDPE’s site.

Third-party profiling cookies

Profiling cookies can be used to understand the habits and preferences expressed by the user when browsing: some types of cookies, managed by Third Parties, also allow the obtaining of aggregate statistical information relating to the visits made and browsing habits, in order to improve the usability and performance of our sites.

CDPE uses Google Analytics Cookies as “third-party” profiling cookies to analyse the use of this website. For more information on the individual analytics cookies, you can consult Google’s Privacy Policy available at the address https://www.google.com/analytics/learn/privacy.html?hl=it.

In line with that required by the current regulations, prior consent is required to send third-party profiling cookies during the user’s first visit to CDPE’s site, which can be expressed in the following ways:

· by clicking on any link in the page;

· by continuing to browse the website.

To not consent to the sending of third-party profiling cookies the user needs to deactivate them by accessing the “Privacy Controls” section via the following link: https://www.google.com/analytics/learn/privacy.html?hl=it.

Purpose and legal grounds for processing

Apart from that specified for browsing data, the user is free to provide the personal data indicated in the request forms. Not providing such data may, however, make it impossible to obtain that requested.

Processing methods

Personal data will be processed with automated tools for the time strictly necessary to achieve the purposes for which they were collected. Specific security measures are observed to prevent a data loss, unlawful or incorrect use and unauthorised access.

Data subject’s rights

Lastly, we inform you that articles 15-22 GDPR give data subjects the opportunity to exercise specific rights; the data subject may obtain from the Data Controller: access, rectification, erasure, restricted processing, withdrawal of consent as well as the portability of the data that concern them.

The data subject also has the right of object to processing. In the event in which the right to object is exercised, CDPE reserves the option not to respond to the request, and therefore to continue with the processing, if there are legitimate mandatory reasons to proceed with the processing that supersede the data subject’s interests, rights and freedoms.

The above rights may be exercised by sending a request by post to CDP Equity S.p.A., via San Marco 21/A, 20121- Milan, for the attention of the Compliance Department, or by email to the following email address: privacy@cdpequity.it

The data subject also has the right to lodge a complaint with the Italian Data Protection Authority.