Privacy

Privacy Policy pursuant to Article 13 of the General Data Protection Regulation EU 2016/679 (GDPR) 

Value Partners S.p.A., with registered office at Piazza San Marco 1 - Milan (hereinafter "Company" or "Controller"), is committed to continuously protecting the online privacy of its users. 

 
A) Source of Personal Data and Data Controller 

This document has been prepared pursuant to Article 13 of EU Regulation 2016/679 (hereinafter: "Regulation") to inform you about our privacy policy. It describes the general methods of processing personal data of users of the site and how your personal information is managed when you use our website www.valuepartners.com (hereinafter "Site").  

The information and data you provide or otherwise acquire while using the Company's services—such as access to the reserved area of the Site, newsletters, etc. (hereinafter "Services")—will be processed in compliance with the provisions of the Regulation and the confidentiality obligations that guide the Company's activities.  

According to the rules of the Regulation, the processing carried out by the Company will be based on the principles of lawfulness, fairness, transparency, purpose limitation and storage limitation, data minimization, accuracy, integrity, and confidentiality.  

The data controller for the processing carried out through the Site is Value Partners S.p.A., with registered office at Piazza San Marco 1 - Milan, as defined above, to whom you can write for any information regarding the processing of personal data.  

This notice is provided only for this Site and not for other websites that the user may consult through links. Please refer to any specific sections of the Site where you can find specific notices and any requests for consent for individual processing activities. 

B) Types of Data 

Following your navigation of the Site, we inform you that the Company will process personal data (Article 4(1) of the Regulation), hereinafter referred to as "Personal Data." In particular, the Personal Data processed through the Site are as follows: 

1. Navigation Data 
   The IT systems and software procedures used to operate the Site acquire, during their normal operation, certain Personal Data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified data subjects, but by its very nature could, through processing and associations with data held by third parties, allow for the identification of users. This category of data includes IP addresses or domain names of computers used by users connecting to the Site, URI (Uniform Resource Identifier) addresses of the requested resources, 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 (successful, error, etc.), and other parameters related to the user's operating system and IT environment. This data is used solely to obtain anonymous statistical information on the use of the Site and to check its proper functioning (see the Cookie Policy), to identify anomalies and/or abuses, and is deleted immediately after processing. The data may be used by competent authorities to ascertain responsibility in the event of hypothetical cybercrimes against the site. 
2. Data Provided Voluntarily by the Data Subject 
   Apart from what is specified for navigation data, the user is free to provide personal data included in any request forms available on the website (e.g., to activate newsletters, free registration, purchases, etc.). Failure to provide such data may result in the inability to deliver the related service. In these cases, only the necessary information for the requested service will be required (please refer to the specific notices for details). 
   When using certain Services of the Site, there may be processing of Personal Data of third parties that you send to the Company. In such cases, you act as an independent data controller, assuming all legal obligations and responsibilities. In this regard, you provide the broadest indemnity against any dispute, claim, request for damages from processing, etc., that may be made to the Company by third parties whose Personal Data have been processed through your use of the Site's functions in violation of applicable data protection laws. In any case, if you provide or otherwise process Personal Data of third parties while using the Site, you guarantee from now on—assuming all related responsibilities—that this particular processing is based on an appropriate legal basis pursuant to Article 6 of the Regulation that legitimizes the processing of the information in question. 

3. Social Plug-ins 
   These "social buttons" are visible on our website to allow sharing of content through social networks, including Facebook, Twitter, LinkedIn, and YouTube. Cookies are placed by these platforms on our site to enable them to collect information about your browsing. 
   For more information on cookie management and the privacy policy of: 
   LinkedIn click here. 

   More details are available in our Cookie Policy. 

C) Purposes of Processing and Legal Bases  

• The processing of personal data that we intend to carry out, with your specific consent where necessary, has the following purposes: 
• To enable the provision of the Services of the Site; 
  The legal basis for processing is the execution of a contract to which the data subject is a party or the execution of pre-contractual measures taken at the request of the data subject (Article 6(1)(b) of the Regulation). 
  The provision of Personal Data for these purposes is optional, but failure to provide it would result in the inability to activate certain Services provided by the Site. 

D) Recipients of Personal Data  

• Your Personal Data may be shared, for the purposes mentioned above, with: 
• Individuals authorized by the Company to process Personal Data necessary to carry out activities strictly related to the provision of Services, who have committed to confidentiality or have an adequate legal obligation of confidentiality (e.g., employees and system administrators). 
• Third parties possibly responsible for managing the Site who typically act as Data Processors. 
• Entities, bodies, or authorities to whom it is mandatory to communicate your Personal Data under legal provisions or orders from authorities. 

 E) Transfers of Personal Data 

Some of your Personal Data may be shared with Recipients who may be located outside the European Economic Area. The Company ensures that the processing of your Personal Data by these Recipients is carried out in compliance with the Regulation. In fact, transfers may be based on an adequacy decision, on Standard Contractual Clauses approved by the European Commission, or on another appropriate legal basis. 

F) Retention of Personal Data 

Your Personal Data will be retained only for the time necessary for the purposes for which they were collected, in compliance with the principle of minimization set forth in Article 5.1.c) of the Regulation. In any case, your personal data will be retained for the time necessary to fulfill the obligations related to the services of the Site. For the retention periods of data related to the various data processing activities collected in the forms present on the site, please refer to the relevant notices. 

G) Your Privacy Rights pursuant to Articles 15 et seq. of the Regulation 

Pursuant to Articles 15 and following of the Regulation, you have the right to request from the Company, at any time, access to your Personal Data, rectification or deletion of the same, the right to object to processing, the right to request the limitation of processing in the cases provided for by Article 18 of the Regulation, as well as the right to obtain in a structured, commonly used, and machine-readable format the data concerning you, in the cases provided for by Article 20 of the Regulation. 

Requests should be addressed in writing to the Controller at the following address: privacy@valuepartners.com. 

In any case, you always have the right to lodge a complaint with the competent Supervisory Authority (Data Protection Authority), pursuant to Article 77 of the Regulation, if you believe that the processing of your Personal Data is contrary to the applicable regulations. 

 
H) Changes 

This privacy policy is effective as of 01/12/2023. The Company reserves the right to modify or simply update its content, in whole or in part, also due to changes in applicable regulations. The Company will inform you of such changes as soon as they are introduced, and they will be binding as soon as they are published on the Site. 

The Company therefore invites you to regularly visit this section to become aware of the most recent and updated version of the privacy policy so that you are always informed about the data collected and how the Company uses it.