Privacy and Data Protection

1. Introduction

Sempione Sim, in its capacity as Data Controller, acknowledges the importance of maintaining the confidentiality, integrity and availability of personal data and, in accordance with Art. 13 of Regulation (EU) 2016/679, sets out on this page the methods of processing the personal data of users who consult this Website – https://www.sempionesim.it/ – in full compliance with current European legislation on privacy. This information does not apply to other websites, pages or online services that can be reached via hypertext links that may be published within the Site but refer to resources outside the Sempione SIM domain.

2. Contact Details

SEMPIONE SIM S.p.A.  Data Protection Officer  with registered office at Via M. Gonzaga, 2 CAP 20123 a Miano, e-mail: amministrazione@sempionesim.it

Data Protection Officer: Dott.ssa Virginia G. Basiricò

Via M. Gonzaga, 2 20123 Milano Italia

E-mail: dpo@sempionesim.it

3. Categories of data processed

Data provided by the User The Data Controller collects and processes the personal data directly and knowingly provided by the User through the “Contact” section of the Website. This means of communication involves filling in a form for the collection of the following personal data: first name and last name, telephone number, e-mail address. The voluntary sending of communications via the “Contact” form, but also by sending messages to the Company’s contact addresses, or by means of private messages sent by users to Sempione Sim profiles/pages on social media (where this option is available) involve the acquisition of the sender’s contact details, required to respond to requests, in addition to any other personal data contained in the message sent. Redirection to external sites The “Financial Info Links” section of the Website includes direct links to websites dealing with issues relating to wealth management, financial management and the stock exchange. For information on the purposes, type and methods of collection, processing, use and retention of personal data by these sites, and on how to exercise your rights, please consult the privacy policy adopted by the individual domain.

4. Purpose and legal basis of the processing

Personal data are processed without the express consent of the data subject, in accordance with Art. 6(1b) of Regulation (EU) 2016/679, as the processing is necessary for the execution of precontractual measures or for the execution of a contract to which the data subject is a party, for the following purposes:

• to enable users to contact Sempione Sim directly to obtain information regarding the services offered;
• to respond to and fulfill any of your requests;
• to enable clients to access their dedicated area, “e-Banking” section, using an authentication username and password.
  
  

5. Period of data retention

The User’s personal data will be retained for as long as necessary to fulfill the purposes set out above. If the data subject believes, for any reason, that the purpose of the processing no longer exists, s/he must notify Sempione SIM in writing, which will immediately delete the data, if not in conflict with the law.

6. Sources

The data subject to processing can be acquired through the Sempione SIM website.

7. Recipients

Personal data will not be “disseminated”, i.e. they will not be made known to unspecified entities; instead, such data will be “communicated”, i.e. they will be made known to one or more entities, as set out below. Specifically, the data may be made accessible:

• to employees and associates of the Data Controller, in their capacity as processors and/or system administrators;
• to third-party companies carrying out services of various kinds, such as: the hosting of the Site, companies tasked
• with the management service of the company’s social media channels, IT companies that deal with the maintenance of the IT system, in their capacity as external data processors.

8. Transfer of personal data to Third Countries

Users’ personal data may be transferred outside the EU, with reference to the hosting of the Site, specifically to Switzerland, in consideration of the fact that the servers are located in that country and that the Parent Company, Banca del Sempione, has its registered office in Lugano. However, it is clarified that Switzerland is one of the third countries that guarantee an adequate level of protection, as per the European Commission Decision of October 17, 2001. (Official Journal no. 275 of November 26, 2001 – Ordinary Supplement no. 250).
For other activities, the processing is carried out by the Data Controller in Italy.

9. Nature of the conferral of data and consequences in the event of refusal

The provision of data is necessary to pursue the purposes set out in section 3 of this Privacy Policy. Any refusal to respond, at the time of collection of the data, may make it objectively impossible for the Data Controller to fulfill the purposes set out above.
With regard to the “Contact” form, if the User wishes to receive information on the services offered, or to make a contact request, s/he must fill in all the fields indicated as mandatory in the relevant personal data collection form in the section (e-mail address).

10. Rights of the data subject

Within the limits of the applicable regulations, the data subject is entitled to request from Sempione Sim, at any time, access to his/her personal data, for the correction or erasure thereof, to object to or limit the processing and/or to obtain the data concerning him/her in a structured, commonly used and machine-readable format (Articles 15 et seq. of Regulation (EU) 2016/679). The request made by the data subject to exercise his/her rights will be answered within 30 days, with the option to extend for a further 30 days, in accordance with the law. In the event that the processing takes place in violation of the above-mentioned Regulation and related national provisions, the data subject is also entitled to lodge a complaint with the Italian Data Protection Authority or to take legal action. To exercise their rights, data subjects can write to the contact details set out in section 1 of this Policy.

Year of update: 2023