DeA Capital Real Estate SGR S.p.A. (“DeA Capital RE
” or “Company
”), belonging to De Agostini group and acting as data controller, would like to share with its users (“Users
“) of the website http://www.themedelan.com
“) about how their data collected by DeA Capital RE, according to the new European Regulation n. 679/2016 on the processing of personal data (“European Privacy Regulation
“), applicable from May 25th 2018.
Data collector and data processors
DeA Capital Real Estate SGR S.p.A. with registered office in Via Mercadante 18, 00198 Rome is the data controller and can be contacted at the following email address: privacy-RE@deacapital.com
A complete list of the data processors can be requested through the above-mentioned email address.Personal data collected
According to this policy, DeA Capital RE will process personal data collected from its Users; these data may include:
- personal data and contact details provided by the User through the Website;
- data provided when requesting information or assistance.
DeA Capital RE will not process health data or in general other special categories of data defined in article 9 of the European Privacy Regulation. Personal data of minors will be processed as per following paragraph 8 of this policy.
The above-mentioned categories of data will be processed only to the extent that is necessary to the purposes described in paragraph 4 of this policy.
Processing of personal data
Personal data of the Users will be processed using automated instruments or other means and will be protected through the implementation of adequate security measures to ensure safety and confidentiality of the personal data. Specifically, DeA Capital RE implements proper technical and organizational measures aiming at ensuring that collected personal data are protected against loss, theft, unauthorised alteration, disclosure of, or access to, personal data transmitted, stored or otherwise processed.
Personal data are only processed for as long as is necessary for the purpose for which they were collected; therefore, at the expiry of the retention period (further explained in paragraph 10), DeA Capital RE will anonymize personal data and will remove identifiers.
Purposes of data processing
DeA Capital RE will require its Users to provide their personal data for the following purposes:
- to allow Users to enjoy all the services offered through the Website and to establish, exercise or defend a claim toward the User or others (jointly defined as: “Contractual Purposes“);
- to comply with legal and regulatory obligations (defined as: “Legal Purposes“);
- upon User’s consent, to send via email newsletters and commercial communications about the Company and its funds (defined as “Purposes of DeA Capital RE“)
Legal basis for data processing
Processing of personal data for Contractual Purposes is mandatory since it is necessary to enjoy specific services offered through the Website.
Processing of personal data for Legal Purposes is mandatory since it is required by the applicable laws. If the User does not wish his personal data to be processed for these purposes, he will not be able to register to the Website, nor to enjoy the services offered through the Website.
Communication of personal data
For the Purposes explained in paragraph 4, DeA Capital RE might communicate Users’ personal data, strictly necessary to each type of processing, to the following categories of subjects:
- employees, collaborators, suppliers, professional advisors and outsourcers of DeA Capital, for the purpose of performing their tasks and/or contractual obligation and in relation to the commercial relations with the Users, for the purposes stated in this policy;
- sub suppliers and/or subcontractors within the activities connected to the performance of services and products offered by DeA Capital RE;
- other companies of De Agostini group, as explained in the following paragraph 7.
Personal data of the Users shall not be disclosed.Transfer of personal data across international borders
Personal data of the Users can be freely transferred outside the national territory to other EU Countries.Data of subjects under 18
The Website is not dedicated to subjects under 18. If the User is minor, he cannot enjoy the services offered by the Website.Rights of the Users
In relation to his personal data, the User will be able to exercise, with no additional charge and at any time, the following rights: (a) to obtain confirmation as to whether or not his personal data are being processed, and, in case, to be informed of; (b) to know the origin of the data, the processing purposes and procedures and the criteria applied to processing by automated means; (c) to ask for the update, rectification or – if he is interested – the integration of the data; (d) to ask for the erasure, the anonymization or the blocking of data unlawfully processed or to object to the processing for legitimate reasons; (e) to fully or partially object to the processing of data for purposes of direct marketing carried out either through automated or more traditional ways; (f) To withdraw his consent to data processing at any time, without affecting the lawfulness of processing based on his consent prior to withdrawal.
In addition to the above-mentioned rights, Users will also enjoy the rights enshrined in the following paragraph 10 b).
Users will be able, at any time, to exercise their right, to modify their contact details, to notify DeA Capital RE changes and updates regarding their data, to obtain further information on the processing of their personal data carried out by DeA Capital RE, by writing an email to: privacy-RE@deacapital.com
.Further provisions of the European Privacy Regulation
The following provisions are fully effective starting from May 25th 2018, when the European Privacy Regulation has come into force.
- Personal data collected for Contractual Purposes (par. 4.a) shall be retained for the duration of the contract and for 10 years after its termination, for DeA Capital RE to exercise/defend a right, both for judicial and extrajudicial settings, should a claim arise in relation to the contract;
- Personal data collected for Legal Purposes (par. 4.b) shall be retained in accordance with the specific limitation periods defined by law;
- Users’ personal data will be deleted/anonymized and/or aggregated.
- Additional rights: the User, at any time and as per previous paragraph 9, is entitled to, (a) ask for the restriction of the processing of personal data when (i) he questions the accuracy of his personal data, for as long as is necessary for the data controller to verify the accuracy of the personal data; (ii) the processing is unlawful and the User opposes the erasure of the personal data and instead requests the restriction of their use instead; (iii) DeA Capital RE no longer needs the personal data to be processed, but they are required by the User for the establishment, exercise or defence of legal claims; (iv) the User has objected to processing pursuant to Article 21.1 of the European Privacy Regulation, pending the verification whether the legitimate grounds of the data controller override those of the User; ( to object at any time to processing, unless DeA Capital RE is entitled to a prevailing lawful right; (c) to ask for the erasure of personal data without undue delay; (d) to ask for the portability of his personal data; (e) to file a grounded claim before the National Authorities for the Protection of Personal Data.
This policy will be effective from the date indicated in the heading.
DeA Capital RE might change and/or integrate this policy, also as a consequence of further modifications and/or integration of the European Privacy Regulation and/ or of the national law. Updates and modifications will be notified in advance and Users will always be able to view the update statement at the following link: http://www.themedelan.com/legal-notices
In case of doubts, questions or complaints with regard to the collection and processing of personal data, the User may contact DeA Capital RE at the email address: privacy-RE@deacapital.com