(IN ACCORDANCE WITH ART.13 OF REGULATION (EU) OF 2016/679)

This brief has been drawn up by Oltre Venture SGR S.p.A. – Gestore EuVECA (henceforth referred to also as “Company”) and relates to the way the company manages data on-line through its company website and therefore also relates to data included in the “Submit Project” section of the site.

Oltre Venture SGR S.p.A. – Gestore EuVECA ,VAT No. 1127344096, with registered offices in Via Bernardino Zenale 8 – 20123 Milan, Italy, attaches the utmost importance to the right to personal data privacy as well as to its legal responsibilities.

1. Nature of data handled

With reference to objectives in point 2) of this document, we collect personal data that includes:

• Personal contact details (that is to say name, date of birth, e-mail address, postal address, telephone number) provided directly by you when you fill in the form on our website;
• Other personal details you may have provided on the form or in attachments.

2. How this information will be used

In the majority of cases, your personal details will be used based on the following criteria:

• The information is necessary in order to conclude a contract or to follow up initiatives required with a view to completing a contract;
• The information is necessary in order to fulfil our legal obbligations;
• The processing of data is done on the basis of your prior explicit consent, for example in the case of marketing activities (for sending newsletters) and in the case of compilation and transmission of the website page called “Submission Form – Startup”

3. How this data is managed

Data is managed using tools and procedures set in place to guarantee security and privacy and this can be in either paper or electronic format.

4. Mandatory provision

We need to receive your personal details in order to carry out the requests you send to us. By refusing to provide these details for the purposes mentioned above, you could make it impossible for us to fulfill your requests or to comply with legal or other regulatory obbligations.

Providing additional personal details, other than those mentioned above that are necessary to comply with legal or contractual obbligations or for the effective consultation of our services with the necessary navigation data, is not compulsory and will have no affect on the use of the site and its services.

5. Disclosure and communication of your personal data

The data we collect from our users will not be “disseminated” by us, with this term we mean giving information to undetermined persons in any way, even by making them available or for consultation.Personal data may however be “communicated” by us, and by this we mean informing one or more specific parties, in the following way:

1. persons appointed within the company to process the data;
2. commercial partners of the Company for the purposes of contract execution;
3. persons who can legally access the data, or via EU legislation, within the limits set down by law;
4. persons who need to access the data for purposes auxiliary to the existing relationship, within the limits strictly necessary to carry out the auxiliary tasks entrusted to them;
5. our consultants, to the extent it is necessary to carry out their duties on our behalf, subject to our letter of appointment which imposes on them the duty of confidentiality and security in the processing of data.

6. Conservation of personal data

Generally, we keep your personal data only for the period necessary to achieve the purposes for which it was collected and for a limited period fruther to the end of our relationship or from our last contact, unless otherwise required by law. However, under certain circumstances, we may retain personal data for a longer period, for example if we are required to comply with legal, tax and financial requirements.
Furthermore, in specific circumstances, we can keep your personal data for a longer period, in accordance with the appropriate regulations, so that we can keep an accurate record of your transactions with us in the event of any complaint or recourse.

7. Rights of interested parties

Pursuant to articles 15-22 of the GDPR the interested party can exercise the following rights towards us:

• right of access for the interested party (pursuant to Article 15 of the GDPR);
• right of correction (pursuant to art. 16 of the GDPR);
• right to be forgotten (pursuant to Article 17 of the GDPR);
• right to limited treatment (pursuant to art. 18 of the GDPR);
• right to request the holder to communicate corrections or deletions of personal data transmitted to the recipients (pursuant to Article 19 of the GDPR);
• right to data portability (pursuant to art. 20 of the GDPR);
• right to object (pursuant to Article 21 of the GDPR);
• right not to be subjected to a decision based on automated processing (pursuant to Article 22 of the GDPR).

8. Exercise of rights

In order to exercise rights stipulated in point 7, the User may make a written request directly to the Data Controller by e-mail at the following PEC address: oltreimpactsgr@legalmail.it or by post to this address: Via Bernardino Zenale 8 – Milan, Italy.