Privacy disclaimer


Under Italian Legislative Decree 196/03 (the Italian Data Privacy Code, or the “Code”), Spafid Connect S.p.A. (the “Company”), with registered office in Foro Buonaparte 10, Milan, as the “Owner” of the data processing, is required to provide certain information regarding the use of personal data.


Source of personal data

Personal data of customers/market counterparties are acquired by the Company in the exercise of activities on a proprietary basis or on behalf of third parties (e.g. companies forming part of the Mediobanca Banking Group, other banks and financial intermediaries). If the Company acquires data from external companies for purposes of market research and direct offers of products or services, information will be provided as and when the data is recorded at the Company, and without prejudice to the foregoing, no later than the first contact.

All data is processed in accordance with the Code and the obligations to confidentiality on which the Company’s activity has always been based.


Purpose of data processing

Personal data are processed as part of the Company’s ordinary activity for the following purposes:

a)     purposes closely related and instrumental to handling relations with customers/market counterparties (e.g. acquiring preliminary information in order to complete a contract, execute transactions pursuant to obligations deriving from the contract thus completed, etc.);

b)     purposes related to obligations under law, regulations and EU directives and to regulations issued by authorities authorized to do so by law and by regulatory and supervisory bodies (e.g. central risk databases, laws on usury, anti-money-laundering, etc.);

c)      purposes functional to the Company’s activity for which the interested party is entitled to express or withhold his/her consent.

With reference to the purposes stated under a) and b) above, the processing and disclosure of your personal data by the Company does not require your consent in cases where such treatment or disclosure is required in order to comply with the foregoing obligations and requests. For the other purposes, each interested party is entitled to withhold their consent to the processing and/or disclosure of their personal data from the Company without thereby being prejudiced in any way.


Data processing methods

For the purposes listed above, personal data are processed according to criteria related to the said purposes, and without prejudice to the foregoing, in such a way as to guarantee the security and confidentiality of the said data.


Categories of individuals to whom the data may be disclosed or who may come into possession of the data by virtue of their position or appointment

For the purposes set forth above, the Company may disclose your personal data to third parties belonging to the following categories of individuals:

·         authorities and supervisory bodies, judicial authorities, and in general entities of public relevance (e.g. Bank of Italy and Consob);

·         other Mediobanca Banking Group companies.


Furthermore, in order to carry out its activities the Company uses a data processing services company (Mediobanca Innovation Services, 100%-owned by Mediobanca and part of the Mediobanca Banking Group) while retaining ownership of and liability for data processing.

Parties belonging to the categories of entity to which the data may be disclosed will treat the data as its “owners” as defined in the Code, in complete independence, being extraneous to the original data processing carried out by the Company.

A detailed list of such companies is available at the headquarters of Spafid Connect.

Certain categories of person, having been appointed to process data, are authorized to access your personal data in order to perform the duties with which they have been charged. In particular, the Company has designated members of its own staff, advisors and other collaborators to process your data.

Other individuals designated by the Company as responsible for data processing may also come to know your personal data.

A list of such persons is available at the headquarters of Spafid Connect.

With reference to digital recordings only, the data may also be transferred outside Italy by the platform manager, in accordance with the legal or regulatory provisions applicable to it.

No provision is made for any form of disclosure of processed data.


Interested parties’ rights

The interested parties’ rights versus the Owner of the processing are described in Article 7 of Italian Legislative Decree 196/03, transcribed in full hereunder:

1.       The interested party is entitled to receive confirmation of the existence or otherwise of personal data regarding them, even if said data has not yet been recorded, and to have such data communicated to them in intelligible form.

2.       The interested party is entitled to receive an indication:

a.      of the origin of the personal data;

b.      of the purposes and methods of processing;

c.      of the rationale applied in the case of processing using electronic instruments;

d.      of the identification details for the Owner, persons responsible and appointed representative pursuant to Article 5, paragraph 2 hereof;

e.      of the parties and categories of parties to which the personal data may be disclosed or which may come to know the personal data by virtue of their capacity as appointed representative in the national territory, as persons responsible or otherwise appointed.

3.       The interested party is entitled to obtain:

a.      update, amendment or, if they have an interest in so doing, addition to the data;

b.      deletion, rendering anonymous or blocking of data processed in breach of the law, including data which does not have to be st ored in relation to the purposes for which it was obtained or subsequently processed;

c.      statement that the operations contemplated under the foregoing letters a) and b) have been brought to the attention, including as regards their contents, of those to whom such data have been notified or disclosed, save in cases where such measure is impossible or involves a use of means which is manifestly disproportionate to the right thus safeguarded.

4.       The interested party is entitled to object, in part or in whole:

a.      on legitimate grounds, to the processing of personal data regarding them, even if relevant to the purpose for which the data was collected;

b.      to the processing of personal data regarding them for purposes of sending advertising or direct sales material or to carry out market research or for commercial communications.


Owner and person responsible for data processing

Further information may be requested from the head offices of Spafid Connect:

·         Spafid Connect S.p.A., Foro Buonaparte 10, Milan, Italy

·         Writing to the person responsible for data processing at the head offices of Spafid Connect S.p.A., Foro Buonaparte 10 – 20121 Milan, Italy.

Applications for exercise of the rights provided for under Article 7 of the Code may be sent in writing to the person responsible for data processing indicated above. Requests to know the identity of the other persons authorized to process data possibly appointed by the Company may also be made orally.