Privacy Policy

PRIVACY NOTICE PURSUANT TO ARTICLE 13 OF REGULATION (EU) 2016/679

October 2026

Pursuant to Regulation (EU) 2016/679, the General Data Protection Regulation (the “GDPR”), Anima Alternative SGR S.p.A. (hereinafter the “Company”), in its capacity as Data Controller, is required to provide you with information on the processing of your personal data as a user of the aforementioned websites (hereinafter jointly referred to as the “Website”).

The Company has appointed a Data Protection Officer (“DPO”) in accordance with the GDPR, who can be contacted at dpo@animaalternative.it.

This Privacy Notice also covers processing carried out by parties performing the technical and organisational tasks described in Section 1 on behalf of the Company.

CONTENTS

  1. Purposes and methods of processing. Whether provision of data is mandatory.
  2. Categories of personal data processed.
  3. Categories of recipients to whom personal data may be disclosed or who may access them as processors or authorised persons.
  4. Rights of data subjects under Articles 15 et seq. of Regulation (EU) 2016/679.
  5. Data Controller and Data Processors.
  6. Amendments.

1. Purposes and methods of processing. Whether provision of data is mandatory.

The personal data held by the Company are obtained from the person to whom they relate (the “Data Subject”), either indirectly through technical means (e.g. the user’s IP address when accessing the Website) or through voluntary provision (e.g. by submitting an information request to the Company’s contact addresses).

Personal data are processed in the course of the Company’s ordinary business activities for the following purposes:

a) to provide users with the technical ability to browse the Website and access its services and content, on the basis of the overriding legitimate interest of the Data Controller, including improving the Website through anonymous, aggregated statistical analysis of its use.

The provision of personal data required for these purposes is not mandatory. However, refusal to provide such data may prevent the Company from granting access to the Website or ensuring its proper operation. Processing does not require your consent; the data will be processed for as long as necessary to use the Website.

b) to respond to any requests from the Data Subject (for information or otherwise) concerning the activities and content of the Website or the Company, on the basis of the Data Subject’s pre-contractual/contractual requests or the Company’s legitimate interest.

The provision of personal data required for these purposes is not mandatory. However, refusal to provide such data would prevent the Company, depending on the request made by the Data Subject, from responding or providing the requested information. Processing does not require your consent; the data will be processed for as long as necessary to assess and respond to your requests.

c) to comply with obligations imposed by laws, regulations or European Union legislation (e.g. the retention of corporate correspondence pursuant to Article 2220 of the Italian Civil Code).

The provision of personal data required for these purposes is mandatory and the related processing does not require your consent; the data will be processed for the periods prescribed by applicable law.

d) other purposes based on the legitimate interests of the Company or third parties, such as:

    • Fraud prevention (Recital 47 of Regulation (EU) 2016/679).
    • Network and information system security (Recital 49 of Regulation (EU) 2016/679).
    • The establishment, exercise or defence of legal claims, where applicable.

The provision of the necessary data is mandatory when using the Website, as otherwise the Company would be unable to protect these legitimate interests. The related processing does not require your consent. Data will be retained for up to six months for fraud prevention and security purposes, and for as long as necessary to establish, exercise or defend legal claims, including any applicable limitation period (e.g. ten years for contractual liability).

For the purposes described above, personal data are processed manually or by electronic or other automated means, according to procedures strictly connected with those purposes and in a manner designed to ensure the confidentiality and security of personal data (particularly where remote communication technologies are used).

Use of tracking technologies in email marketing communications.

When sending promotional communications by email, the Company may use tracking technologies (so-called “tracking pixels”), i.e. technical elements embedded in messages which, when displayed, may allow the Company to detect whether the communication has been opened, the date and time of opening and, depending on the technology used, technical information such as the IP address and characteristics of the device or email software used. Where associated with a recipient, these data may be processed to measure campaign effectiveness and improve promotional communications.

The use of these technologies for the purposes described above is covered by any consent given by the Data Subject for direct marketing activities, on the basis of the information provided in this Privacy Notice. Consent is optional, and withholding it does not affect access to the Company’s services.

The Data Subject may, at any time, withdraw consent for direct marketing activities or selectively withdraw consent solely to the use of tracking technologies (so-called “tracking pixels”), while continuing, in the latter case, to receive promotional communications without such tracking. To this end, the Data Subject may manage their preferences through the dedicated link at the bottom of each promotional email, which allows them either to withdraw consent to marketing or to disable tracking technologies only. Withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal.

For information on the use of cookies on the Website, please refer to the relevant Cookie Policy: https://www.iubenda.com/privacy-policy/28202039/cookie-policy. For the use of social networks, please refer to the privacy notices of the relevant platforms. Exchanges of information with users are governed by this Privacy Notice, while the publication of communications and information exchanged between the Company and users is subject to the specific terms of the relevant social network, including those concerning retention of published data.

2. Categories of personal data processed

The Company and the other parties carrying out the tasks described in Section 1 on its behalf or for its benefit process personal data observed while you browse the Website (IP address, pages visited, etc.) or provided directly by you (e.g. when requesting information or contacting the Company).

In providing the services and activities referred to in this Privacy Notice, the Company does not need to process the “special categories” of personal data referred to in Article 9 of the GDPR (such as data revealing health status, political opinions, trade union membership, religious beliefs, etc.). You are therefore requested not to disclose such data to the Company; otherwise, they will be promptly deleted. However, should the Company need to process special-category data for operational purposes, it will provide you with a new, specific privacy notice together with a request for specific consent to the processing of such data.

3. Categories of recipients to whom personal data may be disclosed or who may access them as processors or authorised persons

To pursue the purposes described in Section 1, the Company needs to disclose your personal data to third parties belonging to the following categories:

  • parties performing the technical or organisational tasks referred to in Section 1 on behalf of the Company;
  • external companies and/or professionals engaged by the Company to provide assistance and consultancy services;
  • intermediaries responsible for distribution, as well as any other parties identified in the contractual documentation;
  • banking and financial intermediaries, in order to execute your instructions and settle the amounts payable under contracts entered into by you;
  • regulatory and supervisory authorities, judicial authorities and, more generally, public or private entities performing functions of public importance (such as the Bank of Italy, CONSOB and the Italian Financial Intelligence Unit (UIF));
  • national and international organisations responsible for the coordination, supervision and management of the Internet and telecommunications networks;
  • public administration bodies (e.g. public entities or State authorities), where necessary for the Company’s activities or where required by law, for the purposes described above.

The recipients of disclosures described in this Privacy Notice act independently as separate data controllers or, in certain cases, have been appointed by the Company as data processors. An up-to-date list is available from the Company.

Certain categories of persons authorised to process data may access your personal data in carrying out their assigned duties. In particular, the Company has authorised its employees, including system administrators, temporary agency workers and interns, to process client personal data as necessary to perform their duties.

Persons appointed by the Company as Data Processors may also become aware of your personal data in performing the tasks entrusted to them. Information on the identity of the Data Processors appointed by the Company may be obtained as described in Section 5 below.

Personal data processed by the Company and by parties performing the technical and organisational tasks described in Section 1 on its behalf are not made publicly available.

Unless otherwise expressly stated, data will not be transferred to or processed outside the European Community or in any other location not considered to afford an adequate level of protection under EU law. Where such transfers occur, they may generally be based on the European Commission’s standard contractual clauses or another appropriate safeguard (Article 46 GDPR), or on one of the derogations under Article 49 GDPR.

4. Rights of Data Subjects under Articles 15 et seq. of Regulation (EU) 2016/679

Data protection legislation grants Data Subjects a number of specific rights. In particular, each Data Subject has:

a) the right of access under Article 15 GDPR, namely the right to access personal information concerning them;

b) the right to rectification under Article 16 GDPR, namely the right to have inaccurate personal data concerning them corrected without undue delay;

c) the right to erasure (“right to be forgotten”) under Article 17 GDPR, namely the right to obtain erasure of personal data concerning them;

d) the right to restriction of processing where one of the circumstances set out in Article 18 GDPR applies;

e) the right to data portability under Article 20 GDPR, namely the right to receive their personal data in an interoperable format and/or have those data transmitted to another controller without hindrance from the Company;

f) the right to withdraw consent at any time under Article 7 GDPR. With regard to promotional communications sent by email, the Data Subject may at any time selectively withdraw consent to the use of tracking technologies (so-called “tracking pixels”) without affecting their consent to receive marketing communications, through the dedicated link at the bottom of each email, which allows the relevant preferences to be managed separately;

g) the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) in the event of a breach concerning the processing of their data, pursuant to Article 77 GDPR;

h) the right to seek a judicial remedy in the event of unlawful processing of personal data, including against decisions of the Data Protection Authority, pursuant to Article 78 GDPR;

i) THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF THEIR PERSONAL DATA ON GROUNDS RELATING TO THEIR PARTICULAR SITUATION WHERE: (I) THE PROCESSING IS NECESSARY FOR THE PERFORMANCE OF A TASK CARRIED OUT IN THE PUBLIC INTEREST OR IN THE EXERCISE OF OFFICIAL AUTHORITY; OR (II) THE PROCESSING IS BASED ON THE LEGITIMATE INTERESTS OF THE DATA CONTROLLER.

5. Data Controller and Data Processors

The Data Controller for the personal data covered by this Privacy Notice is Anima Alternative SGR S.p.A., registered with the Bank of Italy under No. 8 in the register of UCITS management companies and No. 6 in the register of alternative investment fund managers, and a member of the National Guarantee Fund, with registered office at Corso Garibaldi 99, 20121 Milan, Italy – Toll-free number: 800.388.876.

Requests to exercise the rights referred to above may be submitted in writing or by email to privacy@animaalternative.it.

Requests concerning the identity of Data Processors appointed by Anima Alternative SGR S.p.A., as well as the requests referred to in Section 5 above, may also be made orally. The complete list of processors appointed by the Company may be requested by email at privacy@animaalternative.it.

6. Amendments

This Privacy Notice may be amended or updated if changes are made to the way we process your data or to other information provided herein. Any amendments will, in all cases, ensure full protection of your rights. As this Privacy Notice concerns the Website and browsing activities, any changes will be communicated simply by publication on the Website, which should be consulted periodically for updates.