Privacy
Privacy Policy
Intermonte considers the protection of personal data a fundamental principle to be guaranteed in the provision of its investment services. It undertakes to ensure the protection and confidentiality of personal data, defining and implementing privacy policies in accordance with the principles dictated by Regulation (EU) 2016/679 on the protection of personal data ("GDPR"), by Legislative Decree no. 196 of 30 June 2003, containing the Italian Data Protection Code, as well as by the measures of the competent domestic and European authorities.
Data Controller
The data controller is INTERMONTE SIM S.p.A.
• registered office and operational & administrative headquarters: Galleria De Cristoforis, 7/8 – CAP 20122 a Milan (MI)
• website: https://www.intermonte.it/it/index.html
• contact details: Tel +39 02 771151, e-mail compliance@intermonte.it
Data Protection Officer
Intermonte has appointed Dr. Virginia G. Basiricò as "Data Protection Officer (DPO)", as required by art. 37 of EU Regulation 2016/679.
The role of the DPO is to monitor compliance with privacy policies, assessing the risks to data subjects (customers, potential customers, employees, suppliers) from any processing of personal data carried out by Intermonte. The DPO helps Intermonte inform employees of their obligations according to data protection policies and other associated provisions.
The DPO also cooperates with the Italian Data Protection Authority and is the point of contact, within Intermonte, on any matter related to the processing of personal data.
The Data Protection Officer can be contacted through the following channels:
• tel. +39 02 771151
• e-mail: dpo@intermonte.it
Type of data processed and legal basis of the processing
Intermonte processes personal data that falls into the following legal categories:
• personal data of a standard nature relating to job candidates and employees
• special categories of personal data relating to employees
• standard personal data relating to clients
• special categories of personal data relating to clients and suppliers
The personal data processed by the Company belong to the following categories of subjects (databases):
• potential clients
• potential suppliers/ outsourcers
• clients
• suppliers/ outsourcers
• commercial partners/ counterparties
• candidates to be considered for job opportunities
• employees
• freelancers/ independent workers
• company representatives
For more information on how data is processed using cookies, please consult the Cookie Policy in the appropriate section of the website.
Means of data processing
Intermonte has adopted a data protection policy in line with the GDPR. In particular, the data processing methods take into account the following principles:
• lawfulness, fairness and transparency: the data must be processed in a lawful, fair and transparent manner.
• purpose limitation: personal data must only be collected for specified, explicit and legitimate purposes, and subsequent processing must be compatible with these purposes.
• data minimisation: the personal data collected must be adequate, relevant and limited to what is necessary in light of the purpose envisaged.
• accuracy: the data must be kept accurate and, if necessary, up to date. All reasonable steps must be taken to ensure that inaccurate data is promptly rectified or erased.
• storage limitation: the data must be stored in a way that allows identification of the data subjects for no longer than the time needed for the purposes of the processing.
• integrity and confidentiality: data must be processed in such a way as to ensure adequate security, including protection against unauthorised or unlawful processing and accidental loss, destruction or damage, by means of appropriate technical and organisational measures.
Data storage times
The data provided by the user will be held for the time period necessary for fulfilling the purposes indicated above. Once the purposes that dictated the collection of personal data have been achieved, according to internal procedures, any copies of the documentation used will be promptly traced and securely deleted.
If, for any reason, the Data Subject considers that the purpose of processing has been exhausted, the Data Subject may inform Intermonte of this in writing, and Intermonte will immediately erase the information, providing that the request does not conflict with the law.
Rights of the Data Subject
The data subject may exercise all the rights provided for by art. 15 et seq. of Regulation (EU) 2016/679, namely:
• right of access;
• right to rectification;
• right to erasure (right to be forgotten);
• right to restriction of processing;
• right to data portability;
• right to object to data processing;
• right to withdraw consent, where envisaged;
• right to lodge a complaint with the Italian Data Protection Authority.
The Data Subject also has the right to ask Intermonte at any time to access their personal data, as well as to obtain said data in a format that is structured, in common use, and legible by automatic device (art. 15 et seq. of EU Regulation 2016/679). Any request from a Data Subject to exercise their rights will be responded to within 30 days (potentially extendible for a further 30 days, pursuant to law).
Should processing take place in breach of the aforementioned Regulation or related national provisions, the Data Subject also has the right to file a complaint with the Italian Data Protection Authority or to take appropriate action through the courts.
To exercise their rights the Data Subject may contact Intermonte using the contact details provided on this page.
Enforcement methods
These rights can be exercised in several ways: through direct oral or written request to the Company, through a lawyer holding specific power of attorney or proxy that must be attached to the application or through appropriate tools (e.g. web platforms) where previously expressed consent can be withdrawn. The exercise of these rights is assessed taking into account:
• fulfilment of legal obligations,
• the need to protect the privacy of any counterparties,
• other relevant matters of public interest to be balanced against the right to privacy.
In order to exercise these rights, the interested party, depending on the relationship that binds them to Intermonte, can directly contact:
• the Legal & Administration department if the interested party works or has worked as an employee;
• the Operations department if the interested party operates or has operated as a customer or as a supplier;
• the Digital and Advisory department if the interested party operates or has operated as a customer of the Digital Division.
The data subject may also submit a complaint (a written statement challenging a specific offence by Intermonte in relation to the processing of the complainant's personal data) if he/she considers that his/her right to privacy has been violated. In this case, please refer to the Complaints section of the website.