| privacy policy | 

Last update: 05/25/2018

 

PRIVACY POLICY NOTICE PURSUANT TO ARTICLE 13 OF EU REGULATION 2016/679

 

By this Privacy Policy, Tamburi Investment Partners S.p.A., pursuant to Article 24 of EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the ‘EU Regulation’), would like to inform all those visiting this website how their personal data will be used and processed.

Regulation
http://eur-lex.europa.eu/legal-content/IT/TXT/HTML/?uri=CELEX:32016R0679&from=IT

 


 

Definitions

‘Personal data’ (as per Article 4, No. 1 of EU Regulation 2016/679): Any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

‘Processing’ (as per Article 4, No. 2 of EU Regulation 2016/679): Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

 


 

Who is the Data Controller? And how can I contact the Data Controller?

 

Company name: Tamburi Investment Partners S.p.A.

Registered office: Via Pontaccio 10, 20121, Milan (MI), Italy

Telephone: (+39) 02 8858801

Email: tip@tamburi.it

This website is managed by Sequel S.r.l.

Tamburi Investment Partners S.p.A. can be contacted at the above addresses.

 


 

Data Protection Officer (DPO) Contact Details

 

Name and surname: Vera Cantoni, Esq.

Address: Via Turati 26, 20121 Milan (MI), Italy

Telephone: (+39) 02 70039991

Email: dpo@tamburi.it

 


 

Data processing purposes

 

Personal data collected

Tamburi Investment Partners S.p.A. collects and processes personal data provided by data subjects, such as identification data (for example, name, surname and email address).

 

Processing purpose

Tamburi Investment Partners S.p.A. processes the data of data subjects through electronic, and potentially paper, means, for the purposes indicated in the following table along with respective data categories and retention periods:

 

TABLE 1

Purposes of the processing of the personal data Legal basis of the processing Categories of personal data processed Retention period of the personal data Recipient categories
Management of requests for information Consent Identifying data

Personal data

Until completion of the request *
Management of subscriptions to the newsletter and informative email service Consent Identifying data

Personal data

Until withdrawal of consent *
Management of job applications (curricula vitae) Consent Identifying data

Personal data

12 months *

 

* Recipient categories

In relation to the indicated purposes, the data may be disclosed to the following persons and/or categories of persons, or may be disclosed to companies and/or persons, both in Italy and abroad, who provide services, also on a consulting basis, on behalf of the Data Controller, including**, as indicated for greater clarity, by way of example and not limited to, according to different type:

  • IT services companies;
  • Control and supervisory bodies

(**) The list of External Recipients/Officers, with additional data useful for identification purposes, is available from the Data Controller.

 

Transfer of data to non-EU countries

Tamburi Investment Partners S.p.A. does not transfer personal data to non-EU territories.

 

Retention period

Personal data will be kept until deactivation of the service is requested.

 

Rights of the data subject

  • The data subject, in relation to the personal data referred to in this notice, may exercise the following rights as provided for by the EU Regulation:
  • Right of access to one’s own personal data [Article 15 of the EU Regulation];
  • Right of rectification of one’s own personal data [Article 16 of the EU Regulation];
  • Right of erasure of one’s own personal data without undue delay (‘right to be forgotten’) [Article 17 of the EU Regulation];
  • Right to restriction of the processing of one’s own personal data [Article 18 of the EU Regulation];
  • Right to data portability of one’s own personal data [Article 20 of the EU Regulation];
  • Right to object to the processing of one’s own personal data [Article 21 of the EU Regulation];
  • Right not to be subjected to automated decision-making processes [Article 22 of the EU Regulation].

The aforementioned rights may be exercised according to the provisions of the EU Regulation via the transmission of an email to TIP@tamburi.it and dpo@tamburi.it.

Tamburi Investment Partners S.p.A., in compliance with Article 19 of the EU Regulation, informs recipients to whom the personal data has been communicated of any requested rectifications, erasure or processing restrictions where possible.

When the processing purpose pursued by Tamburi Investment Partners S.p.A. has as a legal basis consent, the data subject has the right to proceed, at any time, with the withdrawal of consent via the transmission of an email to tip@tamburi.it. As per Article 7 of the EU Regulation, the withdrawal of consent does not affect the lawfulness of the processing based on consent made prior to the withdrawal.

If the data subject believes his/her rights have been compromised in any way, he/she has the right to lodge a complaint with the Privacy Guarantor.

For more information on the aforementioned rights and the exercise of such rights, please refer to Articles 15-22 of the EU Regulation

 

Tamburi Investment Partners S.p.A. does not make use of any automated decision-making process.

 

Processing method

Personal data is processed electronically and in computerized form, and entered in relevant databases (e.g. potential customers, customers, users) accessed by processors expressly appointed by the Data Controller to manage the processing of the data. In relation to the personal data, such processors may perform operations of consultation, use, processing, comparison and any other appropriate automated or un-automated operation in compliance with the provisions of law necessary to ensure, inter alia, the confidentiality and security of the data, and its accuracy, updating and relevance with respect to the stated purposes.

 


 

Data processing for browsing purposes

 

The computer systems and software procedures used to operate this website acquire, during normal operation, some personal data whose transmission is essential to the use of internet communication protocols.
This is information which is not collected for purposes of association with identifiable data subjects, but which, by its very nature, might allow users to be identified via processing and association with data held by third parties.

Information that may be collected may include IP addresses, browser type and operating system used, addresses in URI notation (uniform resource identifier), the domain name and addresses of referring and exit website pages, server connection times, connection methods used and information on server responses, further information on the user’s navigation of the website (see also the related section on cookies) and other parameters relating to the operating system and the user’s computer environment.

Such data may also be used to identify and ascertain responsibility in case of any computer crimes committed against the website.

 


 

Use of cookies

 

The following information is made available to the user in compliance with the provision of the Privacy Guarantor concerning the protection of personal data of 8th May 2014, entitled ‘Simplified procedures for disclosure and acquisition of consent for the use of cookies’.

WHAT ARE COOKIES?

Cookies are small text strings that a website can send to your device (be it a PC, notebook computer, smartphone, tablet, etc.) while browsing and that are generally stored directly in the browser used for navigation. The same website that transmitted them can then read and write to them on the same device in order to obtain various kinds of information. Each type of cookie has a well-defined role.

HOW MANY TYPES OF COOKIES EXIST?

Esistono due macro-categorie fondamentali, con caratteristiche diverse: cookie tecnici e cookie di profilazione.

 
There are two main categories with different essential characteristics: technical cookies and profiling cookies. Technical cookies are necessary for the proper functioning of the website and allow basic browsing features. Without such technical cookies, the user may not be able to view web pages correctly or use some services. For example, a particular type of technical cookie is essential in keeping the user connected throughout his/her visit to a website, another in storing language or display preferences, and so on.
Cookies can be further subdivided in:

  • Navigation cookies, which guarantee normal navigation and use of the website (allowing, for example, to make purchases or authenticate access to restricted areas);
  • Analytics cookies used directly by the site operator to collect information, in aggregate form, on the number of users and how they visit the website.
  • Functional cookies, which allow the user to navigate according to set of selected preferences (for example, language, products selected for purchase) in order to improve the service provided.

Profiling cookies are a more sophisticated type of cookie. Such cookies have the task of profiling the user and are used in order to send advertising messages in line with preferences expressed by the user during browsing activities.

Cookies can also be subdivided in:

  • Session cookies, which are deleted immediately when the browser is closed;
  • Persistent cookies, which, unlike session cookies, remain in the browser for a certain period of time. They are used, for example, to recognize the device connecting to the site in order to facilitate authentication operations for the user.
  • First-party cookies, which are cookies generated and managed directly by the operator of the website the user is browsing.
  • Third-party cookies, which are generated and managed by parties other than the operator of the website the user is browsing (generally forming part of a contract between the owner of the website and the third party).

 

WHAT TYPES OF COOKIES DOES TAMBURI INVESTMENT PARTNERS S.P.A. USE

Necessary (2)

The necessary cookies help to help make a website usable by enabling basic functions such as page navigation and access to protected areas of the site. The website can not function properly without these cookies.

Name Duration Type of cookies Purposes
ASP.NET_SessionId Session HTTP Cookie Preserve user status on the different pages of the site.
CookieConsent 1 anno HTTP Cookie< It stores the status of the user's cookie consent for the current domain

 

Statistics * (6)

Statistical cookies help website owners to understand how visitors interact with sites by collecting and transmitting information in an anonymous form.

Name Duration Type of cookies Purposes
__utm.gif Session Pixel Tracker Google Analytics Tracking Code that logs details about the visitor's browser and computer.
__utma 2 anno HTTP Cookie It collects data on the number of times a user has visited the website, as well as data for the first visit and the most recent visit. Used by Google Analytics.
__utmb Session HTTP Cookie Register a timestamp with the exact time of access to the site by the user. Used by Google Analytics to calculate the duration of a visit to the site.

__utmc

Session

HTTP Cookie

Register a timestamp with the exact time of exit from the site by the user. Used by Google Analytics to calculate the duration of a visit to the site.

__utmt

Session

HTTP Cookie

Used to limit the speed of requests to the site.

__utmz

6 mesi

HTTP Cookie

It collects data on the user's provenance, the search engine used, the link clicked and the search term used. Used by Google Analytics.

* This website uses tools that reduce the identifying power of cookies, such as anonymisation of users' IP addresses before processing or storage by Google inc.

 

Marketing (1)

Cookies for marketing are used to monitor visitors on websites. The intent is to display relevant and engaging ads for the individual user and therefore the most valuable ads for publishers and third party advertisers.

Name Duration Type of cookies Purposes
NID 6 mesi HTTP Cookie Register a unique ID that identifies the user's device that returns to the site. The ID is used for targeted advertising.

 

ILinks to information on how to disable the use of cookies or delete existing cookies stored in some of the most popular browsers are given below:

 


 

Notice concerning children under 14 years of age

Children under the age of 14 may not provide personal data. Tamburi Investment Partners S.p.A. may not be held liable in relation to the collection of personal data or false statements provided by legal minors. If Tamburi Investment Partners S.p.A. should become aware of the provision of such data, it shall facilitate rights of access and erasure forwarded by legal guardians or by those exercising parental authority.

 


 

Exercise of data subject rights

 

The data subject, in relation to the personal data referred to in this notice, may exercise the following rights as provided for by the EU Regulation:

  • Right of access [Article 15 of the EU Regulation]: The data subject has the right to obtain from the data controller confirmation as to whether or not personal data concerning him/her is being processed, and, where that is the case, access to the personal data and the information expressly provided for in the indicated article, including, by way of example and without limitation, the purposes of the processing, the categories of personal data and recipients, the retention period, the existence of the right of erasure, correction or restriction of processing, the right to lodge a complaint, all available information on the origin of the data and the use of any automated decision-making processes, as per Article 22 of the Regulation, as well as a copy of his/her personal data.
  • Right of rectification [Article 16 of the EU Regulation]: The data subject has the right to obtain from the data controller, without undue delay, the rectification of inaccurate personal data or the completion of incomplete personal data concerning him/her;
  • Right to erasure (‘right to be forgotten’) [Article 17 of the EU Regulation]: The data subject has the right to obtain from the data controller the erasure of personal data concerning him/her, without unjustified delay, for any of the grounds expressly provided for by the indicated article, including, by way of example and without limitation, the data is no longer necessary for the purposes for which it was collected, the data subject withdraws consent for the processing, the data subject objects to the processing and there are no overriding legitimate grounds for such processing, the data has been unlawfully processed, the data has to be erased for compliance with a legal obligation, the data relates to minors processed in the absence of the application of the conditions provided by Article 8 of the Regulation;
  • Right to restriction [Article 18 of the EU Regulation]: In the cases provided for by Article 18, including unlawful processing, contestation of the accuracy of the data, objection of the data subject to processing and the lack of the data controller’s need of the data, the personal data shall, with the exception of storage, only be processed with the data subject’s consent or under the other conditions expressly provided for by the indicated article;
  • Right to data portability [Article 20 of the EU Regulation]: The data subject, in cases in which the processing is based on consent, contract or automated means, has the right to receive his/her personal data in a structured, commonly used and machine-readable format, and to transmit that data to another controller;
  • Right to object [Article 21 of the EU Regulation]: The data subject has the right to object to the processing of his/her personal data in the event that the processing is not based on overriding legitimate interests or is carried out for direct marketing purposes;
  • Right not to be subject to automated decision-making processes [Article 22 of the EU Regulation]: The data subject has the right not to be subject to a decision, including profiling, based solely on automated processing (for example carried out exclusively through electronic tools or computer programs).
  • The above descriptions are not intended, in any way, to replace the text of the articles cited and are referred to here under their broadest consideration. For full reading of said articles, refer to Articles 15-22, see below

Right to lodge a complaint

If the data subject believes his/her rights have been compromised in any way, he/she has the right to lodge a complaint with the Privacy Guarantor, according to the methods indicated by the same authority at the following Internet address:

http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524.

For more information on data subject rights provided for by the Guarantor, please refer to the link.

 


 

Changes and updates

This Privacy Policy Notice bears the date of its last update in its header.
Tamburi Investment Partners S.p.A. may make amendments or supplements to this Privacy Policy also as a consequence of any subsequent regulatory amendments or supplements.

 


 

Regulatory references concerning the rights of the data subject

Article 15

Right of access by the data subject

1. The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:

a) the purposes of the processing;

b) the categories of personal data concerned;

c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;

d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;

f) the right to lodge a complaint with a supervisory authority;

g) where the personal data are not collected from the data subject, any available information as to their source;

h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

2. Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.

3. The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.

4. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.

 

Article 16

Right to rectification

The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

 

Article 17

Right to erasure (‘right to be forgotten’)

1. The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;

c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);

d) the personal data have been unlawfully processed;

e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;

f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).

2. Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:

a) for exercising the right of freedom of expression and information;

b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);

d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or

e) for the establishment, exercise or defence of legal claims.

 

Article 18

Right to restriction of processing

1. The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;

b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;

c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;

d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.


2. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
3. A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.

 

Article 19

Notification obligation regarding rectification or erasure of personal data or restriction of processing

The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it.

 

Articolo 20

Diritto alla portabilità dei dati

1. L'interessato ha il diritto di ricevere in un formato strutturato, di uso comune e leggibile da dispositivo automatico i dati personali che lo riguardano forniti a un titolare del trattamento e ha il diritto di trasmettere tali dati a un altro titolare del trattamento senza impedimenti da parte del titolare del trattamento cui li ha forniti qualora:

a) il trattamento si basi sul consenso ai sensi dell'articolo 6, paragrafo 1, lettera a), o dell'articolo 9, paragrafo 2, lettera a), o su un contratto ai sensi dell'articolo 6, paragrafo 1, lettera b): e

b) il trattamento sia effettuato con mezzi automatizzati.

2. Nell'esercitare i propri diritti relativamente alla portabilità dei dati a norma del paragrafo 1, l'interessato ha il diritto di ottenere la trasmissione diretta dei dati personali da un titolare del trattamento all'altro, se tecnicamente fattibile.

3. L'esercizio del diritto di cui al paragrafo 1 del presente articolo lascia impregiudicato l'articolo 17, Tale diritto non si applica al trattamento necessario per l'esecuzione di un compito di interesse pubblico o connesso all'esercizio di pubblici poteri di cui e investito il titolare del trattamento.

4. ll diritto di cui al paragrafo 1 non deve ledere i diritti e le libertà altrui.

 

Article 20

Right to data portability

1. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:

a) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and

b) the processing is carried out by automated means.

2. In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

3. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

4. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

 

Article 21

Right to object

1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.

3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.

5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.

6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

 

Article 22

Automated individual decision-making, including profiling

1. The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

2. Paragraph 1 shall not apply if the decision:

a) is necessary for entering into, or performance of, a contract between the data subject and a data controller;

b) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or

c) is based on the data subject’s explicit consent.

3. In the cases referred to in points (a) and (c) of paragraph 2, the data controller shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.

4. Decisions referred to in paragraph 2 shall not be based on special categories of personal data referred to in Article 9(2)1), unless point (a) or (g) of Article 9(2) applies and suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests are in place.