INFORMATION NOTICE

Who is the Data Controller and who to contact?
Purpose of the processing and legal basis for the processing
Cookie
Duration of the Personal Data processing
Methods of processing and disclosure of Personal Data
Transfer of Data outside Europe
Minor
Rights of the Data Subject
Business vicissitudes

European Regulation 2016/679 (hereinafter "GDPR" or “Regulation”) requires Azimut Holding S.p.A. in its quality of controller[1] (hereinafter "Azimut", “We” or “Us”), to inform the users (hereinafter, also, "Data Subject" or “you”) about personal data processing[2] methods and purposes (hereinafter "Personal Data[3]").

This information notice is provided solely for the website www.azimut-group.com, (hereinafter “Website”) and it does not concern other websites accessible by the user browsing through the links contained within the Website. Please check information notices provided by third-party websites accessible through the Website and identify the applicable terms and conditions concerning the processing of your Personal Data.

1. Who is the Data Controller and who to contact?

The company that will carry out the processing of your personal data according to the purposes and methods listed below is Azimut Holding S.p.A. in its quality of controller.

You will be able to reach Us out and obtain more information about our role and responsibilities by sending an email to: privacy@azimut.it

Azimut has appointed a Data Protection Officer (DPO) that you may reach out to by sending an e-mail to: privacy@azimut.it

Azimut may collect and process your Personal Data for the purposes listed within section 2 of this notice.

2. Purpose of the processing and legal basis for the processing

PURPOSES OF THE PROCESSING	LEGAL BASIS
Provide feedback to the media / journalists about the requests submitted by filling out the "Contact us for Media" form in the "Media" section	The processing carried out for these purposes is carried out with your preventive, specific and informed consent provided to the Data Controller individually for each of the purposes listed, pursuant to the provisions of Article 6, paragraph 1, letter a) of the Regulation. In any case, you can always revoke every single consent given by sending an e-mail to: privacy@azimut.it
Upon subscription to the mailing list, sending reports and figures directly in your inbox relating to the financial category of your interest (Subscribe form)
Provide feedback to requests submitted by filling out the "Contact us"form
Prevent threats to the integrity, availability and confidentiality of personal data, contrast spam or other malware and, in general, detect, prevent and mitigate security risks (Information security purposes)	The processing activity carried out for these purposes is necessary for the pursuit of the legitimate interest of the Data Controller, pursuant to the provisions of art. 6, par. 1, lett. f) of the Regulation.

2.1 Personal data processed

Below you will find a detail of the personal data processed for each purpose described in paragraph 2

Personal Data voluntarily provided by filling in the “Contact us for Media” form within the “Media” section

	Contact us for Media
Personal Data	name, surname, e-mail address, content of the message

The provision of Personal Data for the aforementioned purpose is optional and Azimut will process your Personal Data only if expressly and specifically authorised by you. However, any refusal to communicate such Personal Data and any incorrect information given, will make impossible to carry out the aforementioned activity.

Personal Data voluntarily provided by filling in the Subscribe form

	Subscribe form
Personal Data	name, surname, e-mail address, company, country, financial category of interest

Personal Data voluntarily provided by filling in the “Contact us”

	Contact us form
Personal Data	name, surname, e-mail address, content of the message

Personal Data processed for information security purposes

When you use the Website, we may automatically collect certain information for the purpose outlined under paragraph 2, lett. D).

	Information security
Personal Data	Technical information (such as: response times of the pages of the Website, download errors, duration of visits to certain pages of the Website, information on interaction with certain pages of the Website, such as scrolling, click, etc.)

3. Cookie

We only use technical and statistical "cookies" to improve your browsing experience, provide our services, understand, in an anonymous way, how users use our services in order to make improvements to the Website. For more information about cookies and how we use them, please see our Cookie Policy.

You can at any time manage your preferences regarding cookies at the following link.

4. Duration of the Personal Data processing

Personal Data processed for the purposes under paragraph 2 lett. A) and C) will be stored for a period of time strictly and related to the time necessary for providing an answer to your request.

Personal Data processed for the purposes under paragraph 2 lett. B) will be stored for a period of time of 24 months.

Personal Data processed for the purposes under paragraph 2 lett. D) will be stored in accordance with the provisions of the applicable regulations, for a period of time not exceeding that necessary to achieve the purposes for which they are processed.

In any case the criteria used to determine the aforementioned storage period of Personal Data is based on the respect of the data storage periods stated by law and by principles stated by article 5 of GDPR.

At the end the retention period, personal data will be erased or anonymised.

5. Methods of processing and disclosure of Personal Data

The processing of your Personal Data will be carried out using appropriate tools to ensure security and confidentiality and may be carried out through manual, computerized and electronic means for storing, managing and transmitting Personal Data.

Your Personal Data will be made accessible only to authorized persons, who are expressly in charge and instructed by Azimut to the Personal Data Processing, pursuant to Article 29 of the GDPR.

Furthermore, other trusted companies will carry out the processing of your Personal Data. These companies perform technical and organizational tasks on behalf of Azimut (e.g. companies operating for the technical management and maintenance of the Website, third parties with whom Azimut collaborates for business services, etc.). Azimut has appointed the aforementioned companies as external data processors pursuant to Article 28 of the GDPR.

An updated list of the appointed data processor is available by sending an email to: privacy@azimut.it

6. Transfer of Data outside Europe

Your Personal Data is processed by Azimut within the territory of the European Union and, if necessary, for technical or operational reasons Azimut reserves the right to transfer your Personal Data to countries outside the European Union subject to the existence of European Commission "adequacy" decisions, or on the basis of adequate guarantees, or on the specific exceptions provided for by GDPR. In case We transfer your Personal Data to countries outside the European Union, We will promptly inform you about the safeguards adopted to guarantee the protection of your Personal Data as set out in Chapter V of GDPR.

7. Minor

The Website is not directed to individuals under the age of 16, and we do not knowingly collect personal data belonging to such subjects. However, despite Azimut is committed to control and prevent the processing of personal data from subjects under the age of 16, it is not possible to guarantee the total avoidance of such processing.

If a user under the age of 16 has provided personal information without the prior consent of the parental responsibility, the latter may request at any time the deletion of the personal data provided by the minor by sending an e-mail to the following address: privacy@azimut.it

8. Rights of the Data Subject

Each Data Subject has:

a) a right to access to his/her personal information processed by or on behalf of Azimut;

b) a right to have his/her Personal Data rectified by Azimut if they are incorrect or incomplete;

c) a right to request the erasure of his/her Personal Data as provided for by article 17 of the GDPR including in the following situations (i) where the Personal Data is no longer necessary in relation to the above described purposes, (ii) the Data Subject objects to the processing of its data and there are not overriding legitimate grounds for the processing, and (iii) the data has been unlawfully processed;

d) a right to obtain a limitation of the processing of his/her data in accordance with the provisions of article 18 of GDPR;

e) a right to object to the processing of his/her data;

f) a right to lodge a complaint with the Data Protection in accordance with the provisions of article 77 of the GDPR;

g) a right to receive the Personal Data concerning him or her or to request that it be transmitted to another data controller, when feasible, in accordance with the provisions of article 20 of GDPR.

At any time, you will be able to exercise your rights by sending an email to: privacy@azimut.it

9. Business vicissitudes

If Azimut is acquired or merges with another company, transfers part or all of its assets to a third party, or in the event of bankruptcy or dissolution of the business, Personal Data may be transferred to the purchasing company or a third party, also to enable the prior due diligence required for such commercial transactions, according to the limits and guarantees provided by applicable laws. In any case, you will be promptly informed about any business vicissitudes so that you can decide whether to continue to use the features of the Website.

We may amend this information notice from time to time. Please, visit the Website to ensure that you are always up to date about all processing activities and our compliance with applicable data protection legislation.

[1] For the purpose of this notice “Controller” shall mean the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

[2] For the purposes of this notice, “Personal Data Processing” shall mean 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, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction (article 4, 2), of GDPR).

[3] For the purposes of this notice, "Personal Data" shall mean any information concerning an identified or identifiable natural person (article 4, 1), of GDPR).