Privacy Policy

  1. Data Controller

1.1 The website www.2331eurcenter.com (the "Website") is owned and managed by UBS Asset Management (Italy) SGR S.p.A. (hereinafter "UBS"), Data Controller pursuant to the applicable regulations, with registered office in Milan, Via del Vecchio Politecnico 3, Tel. +39-02-764141, Fax. +39-02-7641588, PEC ubsglam@actalispec.it

1.2 UBS has appointed a Data Protection Officer who can be reached at dpo-it@ubs.com.

1.3 This "Privacy Policy" describes the methods and purposes with which UBS processes the personal data of users/visitors of its Website.

  1. Data Processing covered by this Privacy Policy

2.1 This Privacy Policy applies to any information obtained by UBS through your use of the Website. It is not applicable to any Internet websites controlled by third parties not affiliated with UBS that the UBS Website may link to ("Third Party Sites"). Please review the privacy statements of Third Party Sites as UBS is not responsible for and has no influence on the content or the privacy practices of Third Party Sites.

2.2 In the event of the Website user intentionally sending e-mails to a third party e-mail address mentioned at the bottom of the Website, the sender's address and any other information contained in the message shall be collected and processed exclusively by the relevant independent data controller, who shall process such personal data in accordance with its own privacy policy to which the user shall refer, and UBS declines all responsibility in this matter.

  1. Types of Data Processed

3.1 Navigation data. While browsing the Website, its standard software procedures acquire certain personal data whose transmission is inherent to the use of Internet communication protocols. This information is not intended to be associated with identified users but, where associated with other data held by third parties, could allow the identification of the Website users. Navigation data includes IP addresses or domain names of the computer used by the user accessing the website, the URL (Uniform Resource Locator) notation addresses of the requested resources, the time of the request, the modalities used to submit the request to the server, the size of the file obtained in response, the numerical code identifying the status of the server response (successful, error, etc.) and other parameters related to the user's operating system.

3.2 The collection of user navigation data is automated (therefore, mandatory) upon access to the Website.

3.3 This Website does not use cookies.

  1. Purpose and Legal Basis of the Data Processing

4.1 Your navigation data above are processed in order to verify the correct functionality and security of the Website, therefore on the legal basis of the Data Controller’s legitimate interest in the proper and safe management of its business activity.

  1. Security measures.

5.1 UBS has implemented reasonable technical and organisational security measures to protect your personal data collected by UBS via the UBS Website against unauthorized access, misuse, loss or destruction.

  1. Recipients of Personal Data

6.1 The data will be processed by employees or collaborators acting under the authority of the Data Controller and other subjects (IT service providers and hosting) as independent data controllers or data processors.

6.2 The data will not be communicated to third parties unless required by law or judicial authority and will not be disclosed in any way.

  1. Data Retention

7.1 The Data Controller stores your personal data as long as it is required to achieve the purpose for which they were collected or if this is required by law or judicial authority.

7.2 The navigation data will be stored for no longer than 12 months, subject to any need to detect crimes by the judicial authorities.

7.3 Personal data will be stored in electronic form on servers located within the European Union.

  1. Rights of the Data Subject

8.1 Within the limits of the applicable law or regulation, you may:

by sending an e-mail to ubs-asset-management-italia@ubs.com.

8.2 You also have the right to lodge a complaint with the Italian Data Protection Authority if you deem that the processing of your personal data is in breach of GDPR or applicable law.

  1. Policy Modification

Last update in November 2020.

This Policy may be subject to modification due to regulatory changes or new Internet developments and innovations. UBS reserves the right to make such changes at its sole discretion; in this case UBS will proceed to inform you about the update by appropriate means.