Privacy Policy

Dear user, Le Fonti Srl (hereinafter “Le Fonti”) is constantly committed to protecting your online privacy.

This Privacy Notice (“Notice”) will allow you to learn about our privacy policy in order to understand how your personal information will be managed using the Le Fonti web services accessible from this site (“Site”).

Definitions

1.1 Cookies: Cookies are text files (letters and/or numbers) which contain packets of information which are stored on the User’s computer or mobile device every time they visit a website through a browser. At each subsequent visit, the browser sends cookies to the website that originated them. Cookies can be stored only for the time a particular site is used (i.e. session cookies), or for a longer period of time independent of the session (i.e. persistent cookies).

1.2 Personal Data: Personal Data means any information relating to a natural person, identified or identifiable, directly or indirectly, by reference to the name, an identification number, location data, an online identifier or elements characteristic of its physical identity (for example, but not limited to images), physiological, genetic, psychic, economic, cultural or social.

1.3 Disclosure: this document.

1.4 Newsletter: these are the daily e-mail communications that Le Fonti sends to the Financial Advisors who have requested it expressing their consent on Le Fonti Awards. The Newsletters, standard for all recipients, contain information that generally concerns the world of finance and the economy and may have a specific focus on the savings sector.

1.5 Registration: is the action by which the user creates his own personal profile on the site, by entering his Personal Data in the appropriate online form, in order to make use of additional services.

1.6 Regulation: EU Regulation 2016/679 of 27 April 2016.

1.7 Service: this is the service that Le Fonti provides to Financial Advisors who have registered and wish to stay updated on the news published. The Service includes the use of Le Fonti Awards as well as the receipt of newsletters.

1.8 Terms of use of the Service: terms that regulate the use of the Service, which includes the use of Le Fonti Awards and the receipt of the Newsletter which constitutes an essential part of the Service itself requested by the Financial Advisors.

1.9 Owner: is the company Le Fonti S.r.l., as specified in point 2 of this Information.

1.10 Processing: any operation or set of operations concerning Personal Data, such as, by way of example, the collection, organization, structuring, conservation, modification, extraction, consultation, use, communication, interconnection, limitation, cancellation and destruction.

1.11 Users: users of Le Fonti Awards who visit Le Fonti Awards but who have not registered.

Data Controller

The Data Controller referred to in this Information is Le Fonti S.r.l., VAT number 04496930969, with registered office in Via Dante 4, 20121, Milan.

The User can send the Owner any request relating to the Processing of his Personal Data, including the possible exercise of the rights referred to in point 8 of this Information, either by registered letter with return receipt. at the registered office of the Data Controller, or by email at the following address: info@lefonti.it.

Purpose and legal basis of the Processing

The Owner collects and uses the Personal Data of Users for the following purposes:

a) Allow navigation of Le Fonti Awards, essentially through the use of Cookies.

The collection of Personal Data for this purpose is governed in the information relating to Cookies, available at the following link which the Data Controller recommends reading.

b) Allow users to use the Service through Registration.

The collection of Personal Data for this purpose is aimed at allowing users to register and, therefore, use the Service. By registering, the user can manage their Personal Data, the use of Le Fonti Awards, as well as receive newsletters.

The Processing of Personal Data for this purpose is necessary to use the Service and is based on the Terms of Use which are accepted by the user through a declaration or affirmative action (e.g. flag), at the time of Registration.

The user can exercise the withdrawal of consent at any time by following the instructions referred to in point 8 lett. a) of this Information. The revocation prevents the user from continuing to use the Service and does not affect the lawfulness of the Processing carried out before the revocation itself.

c) Allow Users to receive Newsletters.

The Processing of Personal Data for this purpose is necessary to allow Users to receive the Newsletter and is based on the consent, free, specific, informed and unequivocal, expressed by the User through a declaration or positive action (e.g. non-preselected flag).

The User can exercise the withdrawal of consent at any time by following the instructions referred to in point 8 lett. a) of this Information. The revocation prevents the User from continuing to receive the Newsletters and does not affect the lawfulness of the Processing carried out before the revocation itself.

d) Send Users occasional email invitations to events and/or greeting cards.

The collection of Personal Data for this purpose is aimed at sending Users and Financial Advisors, on a completely occasional basis, some e-mails concerning invitations to events promoted by the Data Controller or of which the Data Controller has become aware and believes to be of particular interest with respect to the topics dealt with in Le Fonti Awards, as well as greeting e-mails sent (for example, but not only) around the Christmas holidays.

The Processing referred to in this purpose is optional and is based on the legitimate interest of the Data Controller to promote its business and maintain relations with Users. The Owner has struck a balance between this legitimate interest and the User’s right to privacy, and, from this balance, it resulted that the former could be considered prevalent over the latter, above all by virtue of the fact that the communications sent following this Processing have a minimum frequency that does not have a relevant impact in the sphere of the interested party; do not contain information or commercial proposals; relate to events in any case inherent to the world of finance and the economic sector; with specific reference to communications of greetings, they intend to establish and maintain a relationship of cordiality and closeness between the Owner and the User.

The User can oppose the Processing in question at any time by following the indications referred to in point 8 lett. g) of this Information.

e) Carry out statistical analyzes and market research to improve the performance of the Le Fonti Awards Service.

The Processing referred to in this purpose is optional and is aimed at improving the Service, as well as Le Fonti Awards, and is based on the legitimate interest of the Data Controller in wanting to improve its business. The Owner has struck a balance between this legitimate interest and the User’s right to privacy, and, from this balance, it resulted that the first could be considered prevalent over the second above all by virtue of the fact that the improvement of the Service, of Le Fonti Awards, also contributes to the benefit for Users.

In any case, the Data Controller ensures that, where possible, anonymous or aggregated Personal Data are used to achieve this purpose which, therefore, do not identify, nor can they make Users and Financial Advisors identifiable.

In all cases where Personal Data should not be used in anonymous or aggregate form, Users can oppose the Processing in question by following the indications referred to in point 8 lett. g) of this Information.

Types of Personal Data collected and methods of collection

a) The Data Controller collects the following types of Personal Data:

a.1) Common Personal Data of Users, such as, for example, the name, e-mail address and personal qualification;

b) The Data Controller collects Personal Data in the following ways:

b.1) Directly by the User, for Personal Data that is released during Registration or when subscribing to the Newsletter;

b.2) Automatically by Le Fonti Awards through, but not limited to, Cookies (for further information on Cookies, the Owner recommends reading the Cookies information available at the following link https://lefontiawards.com/cookie -policy/

Possible recipients of Personal Data

The Owner undertakes to personally process the Personal Data of Users.

However, in the event that this becomes necessary (for example, but not limited to, to send the Newsletter), the Data Controller guarantees that the Personal Data will be communicated to third parties belonging to the European Union, selected for reliability and competence, which are required to process them according to the indications provided by the Data Controller and exclusively for the purposes indicated in point 3 of this Information.

In such cases, Personal Data may be processed by:

a) employees and/or collaborators of the Data Controller for the provision of the Service, as well as for administrative and accounting purposes;

b) third party suppliers of services necessary to ensure the functioning of Le Fonti Awards (for example, the company that deals with hosting services);

c) third parties who provide the Owner with consultancy and assistance services (for example, the tax consultant).

Retention period of Personal Data and criteria for determining this period

The Data Controller keeps the Personal Data of Users and Financial Advisors for the time strictly necessary to achieve the purposes for which they were collected, indicated in point 3 of this Information, and in particular:

a) for the purposes of Navigation of Le Fonti Awards (referred to in point 3 letter a) of this Information) and the related retention of Personal Data, it is recommended to read the information relating to Cookies available at the following link

b) The user’s Personal Data collected for the use of the Service (purpose indicated in letter b) of point 3 of this Information) are kept for the entire period in which the user intends to keep the Service active.

c) The User’s Personal Data collected for receiving the Newsletter (purpose indicated in letter c) of point 3 of this Information) are kept for a maximum period of 24 months from the last User interaction, i.e. from the last action of the User that is suitable to confirm the interest in the Newsletter (for example, consultation of the content of the Newsletter via link or opening of the same). In the event of exercise of the right of cancellation by the User, or inactivity of the User for a continuous period of 24 months, the Owner will eliminate the User’s Personal Data from the Newsletter within 36 hours, as well as cancel or return them irreversibly anonymous within 30 days of exercising the right or of the expiry of the aforementioned term. In any case of cancellation or irreversible anonymisation, the Personal Data can no longer be used to send the Newsletter, nor can they be traced back to the individual User.

d) Users’ Personal Data collected for sending invitations to events and/or greeting cards (purpose indicated in letter d) of point 3 of this Information Notice), as well as those collected to perform market analyzes and to improve Le Fonti Awards and the Service (purpose indicated in letter e) of point 3 of this Information), if not collected in anonymous or aggregate form, are kept for a period of time equal to that indicated in letters b) and c) of this point 6 of the ‘Information.

Possible transfer of Personal Data to organizations in non-EU countries

The Personal Data of Users are transmitted, pursuant to art. 45 of the Regulation, to organizations residing in non-EU countries only if necessary to achieve the purposes referred to in point 3 of this Information (for example, but not limited to, to use software owned by third parties which in order to send the Newsletters to Users and/or Financial Advisors more quickly).

The Users’ Personal Data is transmitted by the Data Controller to third parties or organizations belonging to countries outside the European Economic Area only if necessary to achieve the purposes referred to in point 3 of this Information (for example, but not only, to use a property of third parties that in order to send the Newsletters to Registered Users more quickly), pursuant to articles 44 et seq. of the Regulation as well as by virtue of adequate guarantees to ensure the protection of Personal Data.

The third parties, companies incorporated under US law, that the Data Controller has selected for the possible transfer of Users’ Personal Data are the following:

a) Google LLC, including YouTube;

b) MailUp;

c) Facebook, Inc;

d) LinkedIn Corporation;

e) Twitter, Inc.

User rights

Pursuant to and for the purposes of the Regulation, for the entire period referred to in point 6 of this Information, each User has the right to:

a) revoke the consent given for the Processing of Personal Data, at any time without prejudice to the lawfulness of the Processing carried out before the revocation. The revocation of consent can be communicated by registered communication to the registered office of the Data Controller or by e-mail to the Data Controller, at the addresses indicated in point 2 of this Information, or by exercising the opt-out at the bottom of all communications and – email from the Data Controller (see Article 7, paragraph 3 of the Regulation).

b) ask the Data Controller to access their Personal Data and information on the related Processing, obtaining a copy in electronic format (see Article 15 of the Regulation);

c) ask the Data Controller to correct and/or supplement their Personal Data, without unjustified delay (see Article 16 of the Regulation);

d) for specific reasons (for example, unlawful processing, withdrawal of consent, non-existence of the purpose of the Processing), ask the Data Controller to cancel the Personal Data, without unjustified delay (see Article 17 of the Regulation);

e) upon the occurrence of specific hypotheses (for example, inaccuracy of the Personal Data, unlawfulness of the Processing, exercise of a right in court), ask the Data Controller to limit the Processing of your Personal Data (see Article 18 of the Regulation);

f) in the event of automated Processing, receive the Personal Data in a readable format, for the purpose of the relative communication to a third party, or, where technically feasible, request the transmission of the Personal Data by DG directly to this third party (so-called right to the portability of Personal Data – see Article 20 of the Regulation);

g) oppose the processing of your Personal Data that is carried out on the basis of the legitimate interest of the Data Controller, by registered communication to the Data Controller’s registered office or by e-mail to the Data Controller, at the addresses indicated in point 2 of this Information (see art. 21 of the Regulation);

h) be informed by the Data Controller, without unjustified delay, of any violations or unauthorized access by third parties to their systems containing Personal Data (so-called data breach – see Article 34 of the Regulation);

i) lodge a complaint with the supervisory authority of the EU country in which he resides, works or in which he believes the violation of his rights has occurred (see Article 77 of the Regulation); For further information on the terms and conditions for the exercise of the rights recognized by the Regulation, it is possible to consult the text of the Regulation itself published at the following link http://eur-lex.europa.eu/legal-content/IT/TXT/PDF/?uri=CELEX: 32016R0679&from=IT, or contact the Data Controller in the forms provided for in point 2 of this Information.