CDP Venture Capital SGR S.p.A. hereby provides information on processing of personal data, pursuant to Article 13 of Regulation (EU) 2016/679 (known as the "General Data Protection Requirement" or GDPR), with registered office in Rome, Via Arduino, no. 22, VAT no. 08480100018 ("CDP Venture Capital SGR"). In its capacity as Data Controller, CDP intends to explain the purposes and methods it uses to collect and process your personal data, what categories of data are processed, what rights are granted to you as “data subject,” and how those rights may be exercised.
The information provided regards only this website, accessible via https://www.cdpventurecapital.it ("the Site"). CDP Venture Capital SGR therefore assumes no responsibility for any other websites that users may visit or end up on via hyperlinks on the Site.
The data collected through the Site may be communicated by CDP Venture Capital SGR to the companies in its group and thereby to CDP S.p.A. and its subsidiaries [or affiliates] and to third parties in accordance with legal requirements.
In using the Site, users accept this policy and are invited to read it before providing any personal information.
1. DATA CONTROLLER
CDP Venture Capital SGR is the controller of personal data (“data controller”) collected through the Site. CDP Venture Capital SGR is a collective management organization focused on asset management. Its purpose is to manage closed-ended alternative reserve funds to invest in the Venture Capital industry, particularly funds that fall within the scope of the "Italian innovation fund " mentioned in the 2019 budgetary law (the "Funds"). Along with its fund management operations, CDP Venture Capital SGR aims, through various initiatives and events, to become a cornerstone of the Italian Venture Capital network by connecting and creating synergies among all market stakeholders.
An up-to-date list of data processors and persons in charge is maintained in the Data Controller's registered office.
2. CATEGORIES OF PERSONAL DATA
CDP Venture Capital SGR processes the personal data it collects ("Data") when innovation-focused SMEs (small and medium-sized enterprises) submit funding applications for their projects, with the aim of obtaining investments from the Funds, or apply to participate in Venture Capital events organized by CDP Venture Capital SGR. The Data Controller will obtain the following types of personal data from individuals (“data subjects”):
- personal data, such as first name and last name, place and date of birth, Italian tax code, gender, marital status, and residential address;
- contact information, such as a shipping address, telephone number and e-mail address;
- bank details, if provided (IBAN or, in the case of foreign accounts, BIC codes);
- other financial data, if provided, including information about the user’s familiarity and experience in terms of investment in financial schemes, as well as the frequency and sum of such transactions;
- education and employment-related data, if provided (such as education level and professional experience, both current and within the last twelve months);
- data collected purely for statistical purposes or for insight on navigation experience (IP address, time of access to the site, and/or registration on the platform), methods of access to the server, and numerical codes indicating the server’s successful or unsuccessful responses;
Through the Site, the Data Controller will not acquire any sensitive data (specifically, no data protected by the special categories referred to in art. 9 of the GDPR, nor data related to criminal convictions or offenses).
Your Data will be processed by CDP Venture Capital SGR exclusively for the purposes and within the limits indicated in the following section.
3. PURPOSES AND LEGAL BASIS OF DATA PROCESSING
CDP Venture Capital SGR will use your Data for the following purposes:
a) for compilation of the Site’s "submit your application" form
CDP Venture Capital SGR will process the data indicated in paragraph 2, no. 1-5, in order for you to successfully fill out the Site’s application form.
Providing this Data is necessary for successful management of the working relationship; without it, we will not be able to consider your application.
b) for event organization purposes
CDP Venture Capital SGR will process the data indicated in paragraph 2, no. 1-2, if and when it is necessary for organizing events (stakeholders in the Venture Capital sector, institutional bodies, and the press may be involved in such events).
This Data is needed if we are to present users’ projects and initiatives at such events.
c) For marketing purposes
Direct marketing. When indicated on the Site (and subject to your express consent), CDP Venture Capital SGR may process your Data for the delivery of advertising materials or commercial communications. Such communications may be related to specific promotions or may be for market research purposes. Communications may be sent via automated systems (e.g. e-mail, SMS, app notifications) or traditional systems (e.g. postal mail).
The Data referred to in paragraph 2, nos. 1 and 2 will be processed for this purpose.
Your consent may be revoked at any time, even if only to deactivate automated communications. Simply write to firstname.lastname@example.org.
Newsletter. Data indicated in paragraph 2, no. 2 must be provided when subscribing to our newsletter. CDP Venture Capital SGR will process this data for the sole purpose of delivering you the newsletter. This means Data will only be processed for the purpose of providing a service specifically requested to the Data Controller. At any time, you may unsubscribe from the newsletter by following the directions periodically given in communications made for the purposes laid out in this statement.
Soft spam. Data referred to in paragraph 2, no. 2, obtained to successfully implement the services offered via CDP Venture Capital SGR's Site, may be used to send commercial communications relating to services similar to the ones offered. Pursuant to Article 130 of Legislative Decree 196 of June 30, 2003, this data processing does not require your express consent. However, you may object to this processing at any time by following the directions periodically given in communications made for the purposes laid out in this statement.
d) for the communication of your data to third parties
When indicated on the Site (and subject to your express consent), CDP Venture Capital SGR may communicate your Data to third parties. These third parties may process your data in order to send out their own commercial communications, including by SMS/MMS/VMS and/or e-mail.
CDP Venture Capital SGR may communicate your Data to entities working in the commercial sectors indicated below, as examples:
- Clothing, fashion, accessories, footwear, optics, costume/fashion jewelry, jewelry, watches;
- Leather goods (bags and suitcases);
- Event planning companies, weddings, parties, concerts;
- Children and early childhood, goods and services, toys, articles and services for pregnant women and new mothers;
- Education, culture;
- Real estate listings, buying and selling, rentals, mortgages;
- Home/domestic services;
- Personal services;
- Culture and educational courses, specialization courses, masters;
- Financial products, banking, social security, loans and debt consolidation, investments, home banking, investment platforms;
- Employee recruitment and selection, job offers, internships and training programs;
- Prevention and personal safety devices;
- Food, organic products, agriculture;
- Beverages and soft drinks, wines and spirits;
- Energy drinks and dietary supplements (healthy nutrition and fitness);
- Specialist medical services;
- Climate control and living environment management;
- Vegetable- and plant- gardening, floriculture;
- Bricolage and DIY projects;
- Electrical, burglar alarm, telephonic, data, satellite, digital, and similar systems;
- Recreation and entertainment, video games;
- Cinema and theatres;
- Athletics, gyms, sports centers, sporting events and competitions;
- Technology, computers, tablets, cameras, telephony, TV;
- Household appliances;
- Interior blueprints, furniture and interior design;
- Data connection, ADSL, fiber, fixed telephony, satellite, new connectivity technologies, internet providers, internet services, web design, social networks and Internet-based services;
- Development of: webpages, websites, and applications for computers and mobile devices;
- Mobile telephones, phone operators, fares and promotions, services and initiatives;
- Volunteering associations, social engagement;
- Electronic printing and publishing, e-books;
- Automotive, car buying and selling, car rentals, spare parts, automotive and motorcycle maintenance and services;
The data referred to in paragraph 2, no. 1 and 2 will be processed for this purpose.
You may revoke your consent at any time by writing to email@example.com.
Your Data may also be communicated to individuals, entities or authorities when we are legally bound to do so, according to legal provisions or orders by judicial authorities.
4. METHODS OF DATA PROCESSING
Personal data processing is carried out using a combination of manual, computerized and telematic tools, using logical steps expressly related to the stated ends, and guaranteeing security and confidentiality. CDP Venture Capital SGR has also implemented innovative tools to ensure your protection.
5. PLACE, LENGTH OF DATA RETENTION, AND DURATION OF PROCESSING
Your Personal Data will be stored mainly on the servers of our parent company CDP S.p.A., to which CDP Venture Capital SGR has outsourced IT services. CDP S.p.A. is headquartered in Rome (00185), via Goito 4.
Your Data will be stored for the duration of your relationship with CDP Venture Capital SGR. Upon termination of the relationship, your Data will be retained for a period of 10 years, solely as a means of protecting the Data Controller's rights and fulfilling legal obligations.
Regarding the data processing for marketing purposes described in paragraph 3, letter b), users should be aware that Data will be processed for the entire duration of the contract, unless you revoke your consent or exercise your right to object.
Regarding the communication of your data to third parties for marketing purposes, users should be aware that the Data may continue to be communicated until your consent is revoked.
6. DEFENSE IN COURT
CDP Venture Capital SGR may use your data for defense purposes in court or in the initial stages of preparation for a court case.
7. CREDIT CARD DATA
Your credit card details may be requested but will not be stored nor processed by CDP Venture Capital SGR. They are processed and/or stored directly by the banking circuit.
9. TRANSFER OF YOUR DATA TO COUNTRIES OUTSIDE THE EU
Regarding the possible transfer of your data to third-party countries, CDP Venture Capital SGR will process data in the manner currently permitted by law, which requires: consent from the data subject; adoption of Standard Clauses approved by the European Commission; and relevant parties’ involvement in international programs for the free movement of data, or operating in countries deemed safe by the European Commission.
10. RIGHTS OF THE INTERESTED PARTIES
In compliance with the current regulations, you have the following rights:
- You may request and obtain information about the presence of your data in CDP Venture Capital SGR’s systems, and be granted access to this data;
- for data processed by automated systems, you may request transfer to another data controller;
- if you find your personal data to be inaccurate or incomplete, you may request and make modifications and/or corrections to it;
- If your data or information is not necessary (or no longer necessary) to carry out the purposes specified above, you may request and obtain deletion (and/or processing restrictions) of your personal data. This may be done after the storage period indicated in the previous paragraph.
The data subject also has the right to object to data processing. If this right is exercised, CDP Venture Capital SGR reserves the right not to comply with the request. This means the data may continue to be processed if there are legitimate, compelling reasons that take precedence over the interests, rights and freedoms of the data subject.
Relevant requests may be sent to the Data Controller by writing to firstname.lastname@example.org or by registered postal mail with return receipt addressed to CDP Venture Capital SGR S.p.A., Via Arduino, 22- 00162 Rome (RM).
Additionally, pursuant to current regulations, users may submit complaints about the processing of personal data to the Data Protection Authority.
11. MODIFICATIONS TO THIS POLICY