This Privacy Policy describes the purposes and methods by which COIMA SGR S.p.A., as a management company acting on behalf of the Porta Nuova Centrale fund, data controller (“Company”), collects and processes personal data relating to the user (“User”) who interacts with the website www.Iportali.portanuova.it and corresponding extensions (“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” or “GDPR”), and 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., acting on behalf of the Porta Nuova Centrale fund, Piazza Gae Aulenti 12, 20154 Milan

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 User’s data will be collected and processed for the following purposes:

1. Contacting the Company. The User can obtain more information about the services offered by using the contact details indicated on the Website. Personal data provided voluntarily by the User (e.g. e-mail address, telephone number, if any, and/or other information spontaneously provided by the User) will be processed in order to take charge of, manage and respond to communications and/or requests received from the User, including requests to be contacted, by the Company or, possibly, by brokers, appointed to provide support in managing the various requests. These parties will act as data controllers [. The legal basis of data processing is the performance of a service requested by the User (Art. 6(1)(b) GDPR), and any refusal to provide personal data will make it impossible to manage and acknowledge the communication or request for information
2. Request for information and/or visits. The User may ask for more information about the services offered, or request the scheduling of a visit or meeting by filling in a Contact Form on the Website. Personal data provided voluntarily by the User (e.g. first name, last name, e-mail address, telephone number, if any, Company) will be processed in order to take charge of, manage and respond to communications and/or requests received from the User. The legal basis of data processing is the performance of a service requested by the User (Art. 6(1)(b) GDPR), and any refusal to provide personal data will make it impossible to manage and acknowledge the request for information and/or an appointment.
3. Pursuing the legitimate interests of the Company and/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, 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 this data is closely connected and instrumental to the pursuit of those legitimate interests, which do not prevail over the User’s rights and fundamental freedoms (art. 6(1)(f) GDPR).
4. Fulfilling applicable legal or other obligations. The Company may use personal data provided by the User or acquired during the User’s interaction with the Website for purposes of compliance with legislative and regulatory obligations, national and EU legislation, as well as obligations deriving from measures issued by authorities who are legally authorised to do so, which represent the legal basis of data processing, without the need to obtain the User’s prior consent. (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 and anonymous information on the use of the Website for purposes strictly 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 the User as part of the services offered by the Website, for example, if the User contact the Company to report disservice or malfunctioning, to exercise its rights in relation to personal data processing, etc. Those data will be processed by the Company only for purposes strictly linked to the User’s 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 platform companies, for organisational purposes, internal control purposes, to pursue the Company or third-party legitimate interests and carry out the User services/requests (e.g., requests for information to the brokers indicated on the Website);
• companies, collaborators, consultants or freelancers used by the Company to carry out duties of a technical or organisational nature (for example, providers of IT and web services) or with which the Company collaborates (e.g. brokers), including the other COIMA Companies, for purposes of providing and ensuring the functioning of its services, 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. If the user writes directly to the press addresses of the project companies, they will process data as independent data controllers exclusively to reply to email requests. The list of entities to which the data are or may be disclosed can be requested from the Company by using the details indicated in the “Rights of Users and Contact Details” section.

6. Data retention

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 has the right to object, in whole or in part, for legitimate reasons, to the processing of their personal data. Those rights may be exercised directly by sending a communication by email. 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 via Cookies

8.1 What are cookies?
Cookies are small text strings sent by websites which the User visits to their computer browser, where they are stored for the User’s next visit to the website, for re-transmission. Cookies are used by the Company to operate the Website or improve its performance, assess the efficiency of services and provide information on the Website or on Users’ navigation
8.2Cookies used by the Website
The Website uses cookies for both technical and analytical purposes. While technical cookies are used as they are strictly necessary for the technical functioning of the Website and to provide the service expressly requested by the User (e.g. language setting, login, etc.), as described below, analytical cookies are used to carry out analyses and provide statistical information on Website usage, to improve its contents and assess Website effectiveness.
TECHNICAL COOKIES
They 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. If technical cookies are disabled, the Company may not be able to provide the user with all or part of the services or functionalities of the Website.

Cookie	Duration	Description
CookieConsent	6 mesi	Record the preference given regarding cookies
elementor	Persistent	Used in context with the website’s WordPress theme. The cookie allows the website owner to implement or change the website’s content in real-time.

  ANALYTICAL 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 choose whether to authorise or disable analytical cookies by clicking on the link in the banner or on the “Authorisation/deactivation modes” in the table below. 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 in the table below.

Cookie	Duration	Description	Activation/deactivation	Cookie Policy
Not currently present	–	–	–	–

8.3 Changing and managing cookie preferences
It is possible to change and manage cookie preferences through the Website or browser settings or third-party websites. 1) through the Website: third-party cookies can be enabled/disabled using the selections in the table in the paragraph above
2) through third party websites such as www.youronlinechoices.eu or www.aboutcookies.org 3) through the browser settings, cookies received from the Website or any other website can be blocked or deleted by changing the browser settings through the 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.
Cookies used by the Website are technical and analytics cookies, as listed in section 8 of this policy.
To get information on managing the analytics cookies and reject them, the user must click on the “Reject” button on the Banner or on “Cookie Settings” if the user wants to know the types of cookies and choose those to activate or reject, or on “Accept All” to accept all cookies.
We recommend that you consult the privacy policies of third parties and their cookie options at the links specified in the “cookie settings” table.

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 the User’s 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 updated on 2023/02/28