DISCLAIMER

Introduction – Please read this notice carefully. By accessing this site, you agree to be bound by the following terms and any materials contained herein.

Liability Disclaimer – The information published on this web site (the “Web Site”) may include inaccuracies or typographical errors. Changes are periodically added to the information herein. DeA CAPITAL ALTERNATIVE FUNDS SGR (the “Company”) and/or its respective suppliers may make improvements and/or changes in the Web Site at any time. The Web Site may be temporarily unavailable from time to time due to required maintenance, telecommunications interruptions, or other disruptions. The Company and/or its respective suppliers make no representations about the suitability of the information contained on the Web Site for any purpose. All such information, are provided ‘as is’ without warranty of any kind. The Company and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title, non-infringement, and availability. In no event shall the Company and/or its suppliers be liable for any direct, indirect, punitive, incidental, special or consequential damages arising out of or in any way connected with the use of the Web Site or with the delay or inability to use the Web Site, or for any information, products, and services obtained through the Web Site, or otherwise arising out of the use of the Web Site, whether based on contract, tort, strict liability, or otherwise, even if the Company or any of its suppliers has been advised of the possibility of damages. In case some States/Jurisdictions do not allow the exclusion or limitation of liability for consequential or incidental damages, however, the above limitation may not apply to you.

No lawful or prohibited use – As a condition of your use of the Web Site, you warrant to the Company that you will not use the Web Site, and/or any content therein, for any purpose that is unlawful or prohibited by these terms, conditions, and notices.

Links to third-party sites – The Web Site may contain hyperlinks to web sites operated by parties other than the Company. Such hyperlinks are provided for your reference only. The Company does not control such web sites, and is not responsible for their contents. The Company’s inclusion of hyperlinks to such web sites does not imply any endorsement at any time of the material on such web sites or any association with their operators.

Modification of the terms and conditions – The Company reserves the right to change the terms, conditions, and notices under which the Web Site is offered.

General – Use of the Web Site is unauthorized in any jurisdiction that does not give effect to all provisions of these terms and conditions, including without limitation, this paragraph. You agree that no joint venture, partnership, employment, or agency relationship exists between you and the Company as a result of this agreement or use of the Web Site. The Company’s performance of this agreement is subject to existing Italian laws and legal process, and nothing contained in this agreement is in derogation of the company’s right to comply with law enforcement requests or requirements relating to your use of the Web Site or information provided to or gathered by the Company with respect to such use. If any part of this agreement is determined to be invalid or unenforceable pursuant to applicable law including, but not limited to, the warranty disclaimers and liability limitations set forth above, then the invalid or unenforceable provision will be deemed superseded by a valid, enforceable provision that most closely matches the intent of the original provision and the remainder of the agreement shall continue in effect. This agreement constitutes the entire agreement between the user and the Company with respect to the Web Site and it supersedes all prior or contemporaneous communications and proposals, whether electronic, oral, or written, between the user and the Company with respect to the Web Site. A printed version of this agreement and of any notice given in electronic form shall be admissible in judicial or administrative proceedings based upon or relating to this agreement to the same extent and subject to the same conditions as other business documents and records originally generated and maintained in printed form. Any rights not expressly granted herein are reserved.

Agreement between user and the Company – The Web Site is offered to you, the user, conditioned on your acceptance without modification of the terms, conditions, and notices contained herein. Your use of the Web Site constitutes your agreement to all such terms, conditions, and notices.

Personal and non-commercial use limitations – The Web Site is for your personal and non-commercial use, and for your reference. You may not modify, copy, distribute, transmit, display, perform, reproduce, publish, license, create derivative works from, transfer, or sell any information, products, or services obtained from the Web Site.

Photocopy or reprint permission – Reproduction, transmission, or storage in a data retrieval system, in whole or in part, for other than personal use or internal reference is prohibited without advance written permission from DeA CAPITAL ALTERNATIVE FUNDS SGR.

No security offering – No information published on the Web Site constitutes a solicitation or offer, or recommendation, to buy or sell any investment instruments, to effect any transactions, or to conclude any legal act of any kind whatsoever. All that is provided in the Web Site is for information purposes only. No data or statement herein is intended as, and should be construed as, investment advice or a recommendation to purchase or sell a particular security.

Privacy Information – DeA Capital Alternative Funds SGR S.p.A. (“DeA Capital AF” or “Company”), belonging to De Agostini group and acting as data controller, would like to share with its users (“Users“) of the website www.deacapitalaf.com (“strong>Website”) about how their data collected by DeA Capital AF, according to the new European Regulation n. 679/2016 on the processing of personal data (“European Privacy Regulation“), applicable from May 25th 2018.

1. Data collector and data processors
DeA Capital Alternative Funds SGR S.p.A. with registered office in Via Brera 21, 20121 Milan is the data controller and can be contacted at the following email address: privacy-af@deacapital.com.
A complete list of the data processors can be requested through the above-mentioned email address.

2. Personal data collected
According to this policy, DeA Capital AF will process personal data collected from its Users; these data may include:
a) personal data and contact details provided by the User through the Website;
b) browsing data related to services offered through the Website and collected through cookies, according to the Cookie Policy available at this link: https://deacapitalaf.com/it-privacy;
c) data provided when requesting information or assistance.
DeA Capital AF will not process health data or in general other special categories of data defined in article 9 of the European Privacy Regulation. The Website is not dedicated to subjects under 18. If the User is minor, he cannot enjoy the services offered by the Website.
The above-mentioned categories of data will be processed only to the extent that is necessary to the purposes described in paragraph 4 of this policy.

3. Processing of personal data
Personal data of the Users will be processed using automated instruments or other means and will be protected through the implementation of adequate security measures to ensure safety and confidentiality of the personal data. Specifically, DeA Capital AF implements proper technical and organizational measures aiming at ensuring that collected personal data are protected against loss, theft, unauthorised alteration, disclosure of, or access to, personal data transmitted, stored or otherwise processed.
Personal data are only processed for as long as is necessary for the purpose for which they were collected; therefore, at the expiry of the retention period (further explained in paragraph 9), DeA Capital AF will anonymize personal data and will remove identifiers.

4. Purposes of data processing
DeA Capital AF will require its Users to provide their personal data for the following purposes:
a) to allow Users to enjoy all the services offered through the Website and to establish, exercise or defend a claim toward the User or others (jointly defined as: “Contractual Purposes“);
b) to comply with legal and regulatory obligations (defined as: “Legal Purposes“);
c) upon User’s consent, to send via email newsletters and commercial communications about the Company and its funds (defined as “Purposes of DeA Capital AF“);

5. Legal basis for data processing
Processing of personal data for Contractual Purposes is mandatory since it is necessary to enjoy specific services offered through the Website.
Processing of personal data for Legal Purposes is mandatory since it is required by the applicable laws. If the User does not wish his personal data to be processed for these purposes, he will not be able to register to the Website, nor to enjoy the services offered through the Website.
Processing of personal data for Purposes of DeA Capital AF is not mandatory and subject to User’s consent. Should the User not give his consent, DeA Capital AF will not be able to keep the User updated about new product or services.

6. Communication of personal data
For the Purposes explained in paragraph 4, DeA Capital AF might communicate Users’ personal data, strictly necessary to each type of processing, to the following categories of subjects:
a) employees, collaborators and suppliers of DeA Capital AF, for the purpose of performing their tasks and/or contractual obligation and in relation to the commercial relations with the Users, for the purposes stated in this policy;
b) sub suppliers and/or subcontractors within the activities connected to the performance of services and products offered by DeA Capital AF;
c) other companies of De Agostini group, as explained in the following paragraph 7.
Personal data of the Users shall not be disclosed.

7. Transfer of personal data across international borders
Personal data of the Users can be freely transferred outside the national territory to other EU Countries.

8. Rights of the Users
In relation to his personal data, the User will be able to exercise, with no additional charge and at any time, the following rights: (a) to obtain confirmation as to whether or not his personal data are being processed, and, in case, to be informed of; (b) to know the origin of the data, the processing purposes and procedures and the criteria applied to processing by automated means; (c) to ask for the update, rectification or – if he is interested – the integration of the data; (d) to ask for the erasure, the anonymization or the blocking of data unlawfully processed or to object to the processing for legitimate reasons; (e) to fully or partially object to the processing of data for purposes of direct marketing carried out either through automated or more traditional ways; (f) to withdraw his consent to data processing at any time, without affecting the lawfulness of processing based on his consent prior to withdrawal.
In addition to the above-mentioned rights, Users will also enjoy the rights enshrined in the following paragraph 9 b).
Users will be able, at any time, to exercise their right, to modify their contact details, to notify DeA Capital AF changes and updates regarding their data, to obtain further information on the processing of their personal data carried out by DeA Capital AF, by writing an email to: privacy-af@deacapital.com.

9. Further provisions of the European Privacy Regulation
The following provisions are fully effective starting from May 25th 2018, when the European Privacy Regulation has come into force.
a) Retention period of personal data: DeA Capital RE will retain personal data for no longer that is necessary to fulfil the purpose for which data have been collected, according to paragraph 2 of this privacy policy. In any case, the following retention periods will apply for these specific purposes:
➢ Personal data collected for Contractual Purposes (par. 4.a) shall be retained for the duration of the contract and for 10 years after its termination, for DeA Capital AF to exercise/defend a right, both for judicial and extrajudicial settings, should a claim arise in relation to the contract;
➢ Personal data collected for Legal Purposes (par. 4.b) shall be retained in accordance with the specific limitation periods defined by law;
➢ Personal data collected for Purposes of DeA Capital AF (par. 4.c) shall be retained the duration of the contract and for 2 years after its termination;
➢ Users’ personal data will be deleted/anonymized and/or aggregated.
b) Additional rights: the User, at any time and as per previous paragraph 8, is entitled to, (a) ask for the restriction of the processing of personal data when (i) he questions the accuracy of his personal data, for as long as is necessary for the data controller to verify the accuracy of the personal data; (ii) the processing is unlawful and the User opposes the erasure of the personal data and instead requests the restriction of their use; (iii) DeA Capital AF no longer needs the personal data to be processed, but they are required by the User for the establishment, exercise or defence of legal claims; (iv) the User has objected to processing pursuant to Article 21.1 of the European Privacy Regulation, pending the verification whether the legitimate grounds of the data controller override those of the User; (b) to object at any time to processing, unless DeA Capital AF is entitled to a prevailing lawful right; (c) to ask for the erasure of personal data without undue delay; (d) to ask for the portability of his personal data; (e) to file a grounded claim before the National Authorities for the Protection of Personal Data.

10. Updates
This policy will be effective from the date indicated in the heading.
DeA Capital AF might change and/or integrate this policy, also as a consequence of further modifications and/or integration of the European Privacy Regulation and/ or of the national law. Updates and modifications will be notified in advance and Users will always be able to view the update statement at the following link: https://deacapitalaf.com/it-privacy/.
In case of doubts, questions or complaints with regard to the collection and processing of personal data, the User may contact DeA Capital AF at the email address: privacy-af@deacapital.com

Cookies Policy – Our website uses cookies. By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
About cookies: a cookie is a small file, typically of letters and numbers, downloaded on to a device when the user accesses certain websites. Cookies allow a website to recognise a user’s device and track users as they navigate different pages on a website and to identify users returning to a website. Cookies do not contain any information that personally identifies you, but personal information that we store about you may be linked, by us, to the information stored in and obtained from cookies. For more information see: http://www.allaboutcookies.org
Blocking/Managing cookies: you may configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. For example:
(1) in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector;
(2) in Firefox you can block all cookies by clicking “Tools”, “Options”, and un-checking “Accept cookies from sites” in the “Privacy” box.
Blocking all cookies will, however, negatively affect the usability of many websites. If you block cookies, you will not be able to use login/account and facet application featured on websites you may browse and it will affect some of features available on this website.
Deleting cookies: you can also delete cookies already stored on your computer, check the “Help” menu of your browser. For example:
(1) in Internet Explorer, you must manually delete cookie files (you can find instructions for doing so at http://support.microsoft.com/kb/278835);
(2) in Firefox, you can delete cookies by clicking “Tools”, “Options” and “Privacy” and then choosing “Use Custom Settings for History” from the History drop down menu settings, the clicking “Clear cookies” when the menu “Show cookies” appears with the list.