1. INTRODUCTION

This Privacy Policy explains how the Associazione Intermediari Mercati Finanziari – ASSOSIM (“ASSOSIM”) and ICSA (jointly “we”, “us” or “our”) collect information from you when you:

• use our products or services;
• download documents from us or subscribe for alerts or newsletters;
• attend one of our events, or an event hosted at our premises;
• visit or register to https://events.assosim.it (the “Website”)

Please read this Privacy Policy carefully and re-visit this page from time to time to review any changes/updates that may have been made.

Your joint-controller will be ASSOSIM and ICSA which collected your Personal Data. We will process any Personal Data we collect about you in accordance with applicable data protection laws, and where required, we will maintain appropriate registrations as joint-controllers with the local regulatory bodies.

Effective Date: 26th February 2019

2. WHAT PERSONAL DATA DO WE COLLECT?

   1. 2.1 “Personal Data” refers to information which does or is capable of identifying you as an individual. We process Personal Data on the products or services you receive from us, including information on the following:
      • your name;
      • email address;
      • other personal contact details (including telephone number and postal address);
      • job title;
      • employer;
      • corporate contact details (including business “direct dial” or office address);
      • your photograph (on demand).
   2. 2.2 We may in limited circumstances collect certain types of sensitive Personal Data which are protected more strictly by law. These include:
      • disability information (where you choose to share this with us in relation to accessing to our services or our physical premises); and
      • any type of dietary requirements for an event hosted by us.
   3. 2.3 We will only collect information that is necessary for us to provide you with the product or service that you have requested. The type of information that we may collect will depend upon the nature of that service or product.

3. HOW WILL WE USE ANY PERSONAL DATA THAT WE COLLECT?

   1. 3.1 The following is an overview of our purposes for processing Personal Data. Please remember that additional information may be provided to you in a separate notice.
   2. 3.2 We process your Personal Data for the following applies:
      • providing you with specific services and products in accordance with a contract you are entering, or have entered into with us;
      • making
      • a list of participants (ICSA delegates) published online after the event.
      • photographs and audio-visual recordings Assosim, ICSA and other third parties (including media reporters and other event participants) may take photographs and digital audio/visual recordings during the event.
      • official reports prepared by ASSOSIM and ICSA, including in their annual reports.
      • carrying out regulatory reporting;
      • processing for compliance with a legal obligation to which the controller is subject;
      • processing for the purposes of the legitimate interests pursued by the controller or by a third party

      (the bullets above are jointly referred to as the “Mandatory purposes”)

      • provide you with newsletters or alerts where you have signed-up for these on the Website;
      • provide you with informational or promotional material pertaining to products, services, organizational of events or workshops;
      • conduct market research surveys, where you choose to participate in these;

      (the three bullets above are jointly referred to as the “Marketing purposes”)

      Your Personal Data may be processed either electronically or in hard copy form, inside and/or outside the EU and the EEA, in accordance with paragraph 5.

   3. 3.3 We may send you direct marketing communications. Where these are electronic communications (email or telephone) we will have obtained your prior consent. In limited circumstances, where we have obtained your explicit prior consent, we may send you marketing communications in relation to carefully selected and relevant third party partners, whose products and services may be of interest to you. You may opt out of certain kinds of marketing, or all forms of marketing, by emailing us at the following address: assosim@assosim.it and peisenhardt@iiac.ca. Alternatively, you can click on the “opt-out” link provided in all our marketing emails.

4. DISCLOSURE OF YOUR PERSONAL DATA

   1. 4.1 We may share your Personal Data in order to provide you with our products or services. Access to your Personal Data is limited to those employees, agents and contractors of ASSOSIM and ICSA who need access to it in order to provide you with our services and products; to communicate with you (including, with your consent, to send you marketing communications); and to carry out legal or regulatory obligations.
   2. 4.2 We may also employ the services of third party service providers to help us in certain areas, such as website hosting, physical security, marketing and market research. Where third party service providers receive your information we will remain responsible for the use of your Personal Data. We take appropriate steps to ensure that such third parties treat your Personal Data with the same consideration that we do.
   3. 4.3 We may from time to time be required to disclose your Personal Data to law enforcement bodies, regulators, agencies or third parties under a legal requirement or court order. We act responsibly and take account of your interests when responding to any such requests.

5. CROSS-BORDER TRANSFERS OF YOUR PERSONAL DATA

Any transfer of data to non-EU countries, we will take place in accordance with the provisions of Chapter V GDPR (Article 44 et seq.)

6. RETENTION OF YOUR PERSONAL DATA

   1. 6.1 ASSOSIM and ICSA will store your Personal Data as long as necessary to accomplish the purposes referred to in Section 3 above. In particular:
      • Personal Data collected for Mandatory purposes is stored as long as necessary to provide you with the requested services and for a further 10 years from the termination of the services;
      • Personal Data collected for Marketing purposes is stored as long as necessary to provide you with the requested services and for a further 2 years.
   2. 6.2 In some circumstances we may store Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, tax or accounting obligations. In specific circumstances we may also store your Personal Data for longer periods of time so that we have an accurate record of your dealings with us in event of any claims.

7. PROTECTION OF YOUR PERSONAL DATA

   1. 7.1 We take the security of our physical premises, our servers and the Website very seriously and we will take all appropriate technical measures using recognized security procedures and tools in accordance with good industry practice to protect your Personal Data.
   2. 7.2 Whilst we use all reasonable endeavors to protect your security in the manner described above, we consider that it is only appropriate to advise you that data transmission over the Internet and the World Wide Web cannot always be guaranteed as 100% secure, and therefore that you use the Website at your own risk.

8. YOUR RIGHTS

   1. 8.1 Subject to applicable law, you may have some or all of the following rights in respect of your Personal Data:
      • to obtain a copy of your Personal Data together with information about how and on what basis that Personal Data is processed;
      • to rectify inaccurate Personal Data (including the right to have incomplete Personal Data completed);
      • to erase your Personal Data (in limited circumstances, where it is no longer necessary in relation to the purposes for which it was collected or processed);
      • to restrict processing of your Personal Data where:
        • the accuracy of the Personal Data is contested;
        • the processing is unlawful but you object to the erasure of the Personal Data;
        • we no longer require the Personal Data but it is still required for the establishment, exercise or defense of a legal claim
      • to challenge processing which we have justified on the basis of a legitimate interest (as opposed to your consent, or to perform a contract with you);
      • to prevent us from sending you direct marketing;
      • to withdraw your consent to our processing of your Personal Data (where that processing is based on your consent);
      • to object to decisions which are based solely on automated processing or profiling.

      In addition to the above, you have the right to submit a claim to Italian Data Protection Authority (Garante per la protezione dei dati personali), Piazza Venezia 11– 00187, Roma or to call the UK Information Commissioner’s Office at the following number: +44 (0)303 123 1113.

      If you wish to access Personal Data about you or exercise any of the rights listed above, you should apply in writing to the following contact details:Associazione Intermediari Mercati Finanziari – ASSOSIM

      Via Alberto da Giussano, 8 – 20145 Milano

      assosim@assosim.it

      assosim@legalmail.it

      International Council of Securities Associations

      c/o ICMA

      23 College Hill, London EC4R 2RP

      peisenhardt@iiac.ca

9. CHANGES TO THIS PRIVACY POLICY

   1. 9.1 Any changes we make to this Privacy Policy will be detailed on this page in order to ensure that you are fully aware of what Personal Data is collected, how it is used and under what circumstances it will be disclosed.