Privacy and cookies

PRIVACY AND COOKIES INFORMATION

Personal data protection notice pursuant to articles 13 and 14 of European Regulation 2016/679- the General Data Protection Regulation (“GDPR”)

Kairos Partners SGR S.p.A. (the “company”) believes in the fundamental importance of safeguarding the confidentiality of its clients’ data. This is why it has always been careful to process and store the personal data disclosed to it with full transparency and in compliance with current regulations and the highest security standards.

In accordance with the GDPR, the company informs you that the personal data you provide shall be processed in compliance with the law and the principles of confidentiality.

The Data Controller is Kairos Partners SGR S.p.A., based in Milan, Via San Prospero 2, and legally represented by its CEO.

The Data Protection Officer, as defined in the GDPR, is Ecoconsult S.r.l., based in Milan, Via C. Goldoni 1 – email: dpo@kairospartners.com.

The Internal Data Treatment Officer for compliance issues and replies to data subjects is the Internal Audit Officer, domiciled for the purposes of this office with the Data Controller – email: privacy@kairospartners.com.

Purposes of data processing

The personal data indicated above shall be processed within the scope of the company’s normal operations and for the purposes indicated below:

a) legal purposes, i.e., to meet obligations under law, regulations, EU legislation or provisions of lawful Authorities;
b) contractual purposes, and, more generally, administrative/accounting purposes, i.e., to meet the obligations arising from contracts to which you are a party or to meet your specific requests, which may entail using methods of remote communication;
c) commercial purposes, i.e., to provide you with information and send you advertising material, which may entail using methods of remote communication, on the company’s or third parties’ products, services or initiatives, to promote the same, for direct sales campaigns, to conduct market research, to monitor the quality of products and services offered to you, to improve the same offer, to send commercial information, to conduct statistical research, to profile you in order to take appropriate commercial decisions, to disclose the data to third parties so they may carry out their own commercial initiatives.

Providing your personal data for the purposes indicated in points a) and b) above is necessary to enter into contracts and perform them. Failure to provide the data could make it impossible to enter into and perform the contracts or to fulfill your requests.

Providing your personal data for the purposes indicated in point c) is optional, and without your consent we will not be able to provide you with material and advertising information on the company’s or third parties’ products, services or initiatives indicated above.

The company may process your sensitive data solely to the extent necessary for the performance of the specific transactions that you have requested or to manage certain transactions between you and the company, exclusively with your consent and in compliance with the Personal Data Protection Authority’s authorization, except for the specific cases expressly provided for by law.

With respect to the purposes indicated, the personal data shall be processed using manual, automated and electronic instruments with methods and logic strictly related to the same purposes and, in any case, in such a way as to ensure that the data remain secure and confidential.

Profiling and similar forms of processing

The company shall not process the data using automated decision-making processes. If the company decides to use such forms of data processing, it shall issue a specific notice indicating the logic used and the importance and consequences of such processing.

Storage period

Based on the different purposes and aims for which the data were collected, the personal data shall be stored for the period of time provided for by the relevant legislation, i.e., the amount of time strictly necessary for the purposes and to protect the Data Controller’s rights in the event of legal disputes. However, the data shall be stored in accordance with the principles of necessity, purpose limitation, data minimisation and proportionality endorsed by the GDPR.

Data recipients

Within the company, your personal data could become known to employees and people working for the company in any capacity, assigned to services and offices, and to external and internal structures that perform technical, support and controlling duties on the company’s behalf.

To perform some of the activities related to the purposes for which the personal data are processed, as specified above, the company is assisted by external parties, including foreign entities, such as:

• banking and financial brokerage companies;
• data processing firms;
• service companies (e.g., envelope stuffing and customer notification);
• automated data management outsourcers;
• auditing firms;
• payment management outsourcers;
• legal and tax advisory firms for purposes closely related to the performance of our business activity;
• banks and bank branches;
• other subjects that have the right to access your personal data pursuant to the provisions of law or secondary or EU legislation.

In addition to meeting legal purposes, the data may be disclosed to meet anti-money laundering and anti-terrorism obligations pursuant to Italian Legislative Decree no. 90/2017, as amended and integrated, as well as to meet the company’s own contractual or commercial purposes and for the independent commercial purposes of the companies in the Kairos or Julius Baer group, or, in any case, parents, subsidiaries or associates.

The list of external and internal officers is updated continuously and stored at the company’s office where a free copy may be requested.

Transfer to third countries

Personal data may be transferred to third countries, as defined by the GDPR, where the European Commission has decided that the third country in question ensures an adequate level of protection, or in any case transferred to third countries with the appropriate safeguards (e.g., specific contractual clauses), pursuant to article 46 of the GDPR, or if there are binding corporate rules. Copies of the related documentation may be requested from the Internal Data Treatment Officer for compliance issues and replies to data subjects, including via email: privacy@kairospartners.com.

Data subject’s rights

Lastly, we inform you that articles 15 to 22 of the GDPR give the data subjects specific rights. In particular, data subjects shall have the right to obtain from the Controller confirmation as to whether or not personal data concerning them are being processed and, where that is the case, to access the personal data.

Data subjects may also request:
• the erasure, rectification or limited processing of the personal data concerning them;
• the restriction of data processing for legitimate reasons;
• to receive the personal data concerning them in a structured, commonly used and machine-readable format and have the data transmitted to another controller (the right to portability).

To exercise these rights, data subjects may write to the Internal Data Treatment Officer for compliance issues and replies to data subjects indicated above, by post or email: privacy@kairospartners.com.

Data subjects also have the right to withdraw any consent given at any time, without affecting the lawfulness of processing based on consent before its withdrawal, and they may lodge complaints with the Personal Data Protection Authority.

Browsing data

The computer systems and software that guarantee the functioning of this website acquire certain personal data in a way that is implicit in the browsing of websites.

This is information that is not collected in order to be associated with identified persons, but that by its very nature could, through processing and association with data held by third parties, done only at the explicit request of legal authorities, enable users to be identified.

This category of data includes IP addresses of domain names of computers used by users accessing the site, address in URI (Uniform Resource Identifier) notation of the resources requested, the time of the request, and parameters relating to the operating system and to the user’s IT platform. These data are used for the sole purpose of collecting anonymous statistical information on the use of the site and to check its correct functioning.

Cookie Policy

This page contains information about the technologies that allow this website to achieve the purposes described below. These technologies allow the owner to collect and save information (for example through the use of cookies) or to use resources (for example by running a script) on the user’s device when the latter interacts with this website.

In this document, the technologies are renamed as “tracking tools”.

Even if web cookies could be used in both browsers and mobile, it would be not correct talking about cookies in the context of mobile applications, since they are tracking tools that require the presence of a browser. For this reason, the term “cookie” is used only to specifically indicate that particular type of tracking tool.

Some tracking tools may request the user’s consent. If consent is given, it can be freely revoked in any time by clicking on the button at the end of this page.

This website uses tracking tools managed directly by the owner (commonly called “first party” tracking tools) and tracking tools that enable services provided by third parties (commonly called “third party” tracking tools). Unless otherwise stated within this page, these third parties have the access to their respective tracking tools.

Duration and expiration of cookies and other similar tracking tools may change depending on the rules set by the owner or by each third party supplier. Some of them expire at the end of the user session. In addition to what specified in the description of each of the categories listed below, users can get more detailed and updated information on the duration, as well as any other relevant information – such as the presence of other tracking tools – in the privacy policies of respective third party suppliers (through the available links ) or by contacting the data owner.

1. Functional Cookies
Functional cookies help to run certain functionalities, like sharing the content of the website on social media platforms, collect feedbacks, and other third-party features.

__atuvc – This cookie is set by Addthis to make sure user sees the updated count if he shares a page and returns to it before the website share count cache is updated.

__atuvs – This cookie is set by Addthis to make sure user sees the updated count if he shares a page and returns to it before website share count cache is updated.

2. Performance cookies
Performance cookies are used to understand and analyse the key performance indexes of the website which helps in delivering a better user experience for the visitors.

3. Analytics Cookies
Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics the number of visitors, bounce rate, traffic source, etc.

_ga – This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of website usage for the website analytics report. The cookies anonymously store information and assign a randomly generated number to identify unique visitors.

_gat_gtag_UA_119240533_1 – This cookie is set by Google and is used to distinguish users.

_gat_UA-119240533-1 – This is a pattern type cookie set by Google Analytics, where the pattern element on the name contains the unique identity number of the account or website it relates to. It appears to be a variation of the _gat cookie which is used to limit the amount of data recorded by Google on high traffic volume websites.

_gid – This cookie is installed by Google Analytics. The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the website is doing. The data collected including the number visitors, the source where they have come from, and the pages visited in an anonymous form.

CONSENT
 – These cookies are set via embedded YouTube videos. They register anonymous statistical data on for example how many times the video is displayed and what settings are used for playback. No sensitive data is collected unless user logs into his Google account, in that case choices are linked with user’s account, for example if clicking “like” on a video.

uvc – This cookie is set by Addthis.com to determine the usage of Addthis.com service.

4. Advertisement cookies
Advertisement cookies are used to provide visitors with relevant ads and marketing campaigns. These cookies track visitors across websites and collect information to provide customised ADS.

IDE – Used by Google DoubleClick and stores information about how the user navigates the website and any other advertisement before visiting the website. This is used to present users with ads that are relevant to them according to the user profile.

Loc – This cookie is set by Addthis. This is a geolocation cookie to understand where the users sharing the information are located.

test_cookie – This cookie is set by doubleclick.net. The purpose of the cookie is to determine if the user’s browser supports cookies.

VISITOR_INFO1_LIVE – This cookie is set by YouTube. Used to track the information of the embedded YouTube videos on a website.

YSC – This cookie is set by YouTube and is used to track the views of embedded videos.

yt-remote-connected-devices – These cookies are set via embedded YouTube videos.

yt-remote-device-id – These cookies are set via embedded YouTube videos.

5. Other cookies
Other uncategorised cookies are those that are being analysed and have not been classified into a category yet.

at-rand – No description available.

kairos_informa – No description available.

6. Necessary cookies
Necessary cookies are absolutely essential for this website to function properly. These cookies ensure basic functionalities and security features of the website, anonymously.

_wpfuuid – This cookie is used by the WPForms WordPress plugin. The cookie is used to allow the paid version of the plugin to connect entries by the same user and is used for some additional features like the Form Abandonment add-on.

ASP.NET_SessionId – This cookie is used in websites developed with Microsoft.Net. When a user starts browsing a unique session ID is created, which keeps track of all the information regarding that session. This information is stored in the web server and it is identified via a GUID. The GUID is essential for any ASP.NET website to function properly.

PHPSESSID – This cookie is native to PHP applications. The cookie is used to store and identify a users’ unique session ID for the purpose of managing user session on the website. The cookie is a session cookies and is deleted when all the browser windows are closed.

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