Privacy Policy

1.     The Types of Information We Collect About You

When you enter and browse the Site, we may collect two different types of information about you: information you provide to us, and information we collect through technology.

Information You Provide to Us.  To obtain access to certain information or materials provided via the Site, you may have to provide information that we collect and store in a way that allows us to identify you personally, including your name, e-mail address, company name, and title. We refer to such information as personally identifiable information. Additionally, we may collect and retain a record of all communications with you.

Information We Collect Through Technology. We may collect information about you through technology. For example, we may collect your IP address each time you request a page during a visit to the Site. (An IP address is often associated with the portal through which you enter the Internet.) At times, we may also use IP addresses to collect information regarding the frequency with which users browse various parts of the Site.

The Site may also use other technical methods to track and analyze the traffic patterns on the Site, such as the frequency with which our users visit various parts of the Site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML e-mails that we send to our Site users to determine whether such users have opened those e-mails and/or clicked on links in those e-mails. We may collect the information from use of these technical methods in a form that identifies you personally.

We use software tools such as Google Analytics to measure and collect session information about your Site visits, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse overs), and methods used to browse away from the page. We may use this information to measure Site activity, to develop ideas for improving our websites and for any other purpose to the extent permitted by applicable law.

2.    Cookies and How We Use Them

Cookies are small text files that may be placed on your browser when you visit our Site. Cookies are used primarily for administrative purposes, to improve your experience with our Site. For instance, when you return to the Site after logging in, cookies provide information to the Site, including personal information, so that the Site will remember who you are.

The Equity Club S.r.l Site uses cookies primarily to capture anonymous analytics to improve your experience with the Site and its performance. This includes compiling statistical information concerning, among other things, the frequency of use of our site, the pages visited, and the length of each visit, as well as information about your computer, operating system, browser, language, and country. We do not use cookies to store any personal information that could be read or understood by others.

Using the settings of your Internet browser, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. Consult your browser’s Help menu to learn the correct way to modify your cookies. If you choose to turn off cookies, you may not have access to many features that make your browsing of our Site smoother, and some of our services may not function properly. You may at any time delete any cookies set by us by using the relevant option of your Internet browser or by deleting the cookies on your hard drive. If you would like to modify your browser to notify you when you receive a new cookie or to disable cookies altogether, please refer to https://www.aboutcookies.org. If you continue without changing your settings, we’ll assume that you accept receipt of all cookies on the Site.

As mentioned above, we use Google Analytics to collect information about your use of the Site. Google Analytics collects information such as how often users visit the Site, what pages users visit, and what other sites they visited prior to or after coming to the Site. More information on how Google Analytics uses your data can be found at www.google.com/policies/privacy/partners/. By using the Site with your browser set to accepting cookies, you consent to our and Google Analytics’ use of cookies on the Site.

3.    How We Use Your Personally Identifiable Information

The Equity Club S.r.l does not use or disclose any nonpublic personally identifiable information about its Site users to any nonaffiliated third party, except as set forth below.

We may use or disclose certain personally identifiable information we collect about you when you visit and browse the Site as part of our normal business operations, or to send you administrative communications either about your interactions with us or about features of the Site, including any future changes to this Privacy Policy.

We may also store your personally identifiable information and share it among our affiliates. We may use or disclose this information for marketing, research and other business purposes, and we may associate your personally identifiable information with other information we collect about you, such as details about your usage patterns and interests, but we will not sell this information or disclose it to third parties.

We may also use service providers to facilitate our services or platform functions on our behalf. These companies and individuals may have access to your personally identifiable information, as needed to perform their functions, but may not use it for another purpose.

We will use or disclose personally identifiable information when we believe that such disclosures are required by law, regulation, legal process, subpoena, document request or governmental request. For example it may be necessary, under anti-money laundering and similar laws, to disclose information about investors in order to accept subscriptions from them. We may also do so to help enforce our Terms of Use or to protect the safety or security of our websites and other assets, our users (including you) and their property and the rights of third parties. Also, in the event that The Equity Club S.r.l or any of its assets or businesses are acquired or merged with another entity, whether an affiliate or a third party, user information (including personally identifiable information) may be one of the transferred assets.

4.    Your data protection rights

Under data protection law, you have rights we need to make you aware of. The rights available to you depend on our reason for processing your information. Right of access. You have the right to ask us for copies of your personal information. This right always applies. Right to rectification. You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. Right to erasure. You have the right to ask us to erase your personal information. Right to restriction of processing. You have the right to ask us to restrict the processing of your information. Right to object to processing. You have the right to object to processing if we are able to process your information because the process is in our legitimate interests. Right to data portability. This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated. If we are processing your information for criminal law enforcement purposes, your rights are slightly different.

Please contact us at direzione@equityclub.eu if you wish to make a request.

For further requests or in case you have not received a reply, you can also contact The Equity Club S.r.l’s Data Protection Officer (DPO). Our Data Protection Officer is Gianmarco Gandolfi. You can contact him at direzione@equityclub.eu. Please mark the envelope “Data Protection Officer”. 

5. Purpose and legal basis for processing

Processing is carried out:

a) to maintain and monitor the performance of the Site and to constantly look to improve the Site and the services it offers to our users, the legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests;

b) to obtain access to certain information or materials provided via the Site, the legal basis we rely on to process your personal data is article 6(1)(a) of the GDPR, which allows us to process personal data when you gave us consent;

c) for marketing, research and other business purposes, the legal basis we rely on to process your personal data is article 6(1)(a) of the GDPR, which allows us to process personal data when you gave us consent or article 6(1)(f) of the GDPR, which allows us to process personal data for direct marketing purposes (legitimate interests), as long as the marketing is carried out in compliance with e-privacy laws and other legal and industry standards. Given that you have the absolute right to object, at any time, to direct marketing.

 Last updated: April 30th, 2019