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PRIVACY POLICY

 

Wise Equity SGR S.p.A. (“Wise”) Privacy Policy

This privacy policy (hereinafter the “Policy”), drafted in accordance with Regulation (EU) 2016/679 (“GDPR”) and Legislative Decree 196/2003, as supplemented and amended (together with the GDPR, the “Applicable Privacy Law”), describes how and when Wise collects, uses and shares the information generated or actively provided by you when using the website www.wisesgr.com and the other contact channels (e.g. e-mail address info@wisesgr.com) available on the website (jointly, the “Services”). The data controller and service provider is Wise SGR, with registered office in Milan, Italy, Foro Buonaparte no. 76 and Tax Code and VAT no. 13142090151 (the “Data Controller”). When you use any of our Services, you are aware that it implies the collection, transfer, storage, organization, consultation, processing, modification, selection, retrieval, comparison, use, interconnection, blocking, communication, dissemination, deletion and other uses of your information as described in this Policy, and we therefore recommend that you read it with due care.

 

Collection and use of information

Information you provide. You may provide us with personally identifiable information (“Personal Data.”) when using our Services, by entering your name and other personally identifiable information or by sending us materials and information that identify you.

Automatically Collected Information. We automatically collect your personal information when you use the Services. This may include your IP address, software configurations, smartphone ID numbers, the address of websites you visited before visiting our website, and other similar data.

Login Information. We collect the information you provide (username, email, password) to login to the private area of the site.

 

Cookies and other similar tracking tools

Like many other websites, we use “Cookies” technology to collect data about the website’s use and to improve our Services.

Cookies may be stored on your device and transmitted back to you when you use the Services a second time. Through Cookies, websites record the actions and preferences of users (such as, for example, the chosen language, the font size, other settings regarding the layout of the site, etc.), in such a way as to avoid the user having to enter them again when they return to the site a second time or when navigating to another page of the same site. Cookies are also used to ensure user login, to monitor browsing sessions, to store information related to users who have access to the site and may contain a unique identification code that allows tracking of the user's browsing session on the site, for statistical and advertising purposes. Users may also download on their devices Cookies owned by websites and servers different from the site they are visiting at that moment (“Third Party Cookies”). Some Cookies are necessary for the technical functioning of the site; if you do not accept this type of Cookies, some functionalities and features of the site may not be accessible.

There are different types of cookies, depending on their characteristics and functions, and may be stored on your devices for different periods of time: session cookies are deleted at the end of each browsing session; persistent cookies may persist until the date predetermined by their owner.

On the basis of the current legislation on Cookies, the user’s consent to the use of Cookies on the site www.wisesgr.com is not necessary, as the site uses only the so-called “technical cookies”, exclusively for the purpose of transmitting a communication over electronic communication networks, or when it is strictly necessary for the provision of a service expressly requested by the user. This type of cookie is essential for the proper functioning of the site and to perform the activities specifically requested by users.

Among the technical Cookies, which do not require explicit consent from the user to be used, the regulations include the following:

• “analytical Cookies” to the extent that they are used directly by the website manager to collect aggregate information and information about visits to the website,

• “browsing” or “session Cookies” (to log in to the site),

• “Functional cookies,” which allow users to navigate based on certain predetermined criteria, such as language or products to purchase, in order to improve the quality of the service.

There are also profiling cookies, ie those aimed at creating user profiles and used to send advertising messages in line with the preferences shown by the user during navigation, for which the prior consent of the user shall be required. The website www.wisesgr.com does not use these cookies.


Types of Cookies used by the site

The site only uses proprietary cookies, which are as follows:

• Technical browsing or session cookies, strictly necessary for the operation of the site and to provide users with the services they have expressly requested;

• Technical and analytical cookies, used by the site manager to collect aggregated information on the number of visitors and information about visits to the site. This type of cookies does not collect Personal Data. The information collected is processed anonymously and in aggregate form. The data controller may use such aggregated information to analyze market trends, manage the site, track user movements, and collect a wide range of demographic information for aggregate use;

• Functional technical cookies, which allow users to navigate based on certain predetermined criteria, such as language, in order to improve the quality of the service offered.

• Tracking cookies, which allow us to verify the origin of a user from another site.

Please note that if you choose to disable technical/functional cookies, including through your browser as described below, the website may not function properly, and some website features may not be available or may not function properly.

 

How to view and change Cookies settings through the browser used

Users can select the cookies they wish to enable, disable or delete (totally or partially) using the tools offered by the browser used. In any case, it should be noted that the disabling of technical/functional cookies could lead to a deterioration in the use of the site and that some services offered or some features of the site may not function properly or not be available, and that it may be required to modify or manually enter certain information or preferences each time you visit the site.

To learn more about how to set your cookies preferences through your browser, please read the information available at the following links (Wise does not control third party browsing sites or their instructions on how to enable and disable cookies; these pages may be updated, modified or removed from third party browsers at their sole discretion):

• Internet Explorer

• Firefox

• Safari

• Chrome

For more information about cookies, please refer to our Cookie Policy, as set out in Annex A to this Policy


Sharing of information

We may communicate your personal information to the following parties:

 

Subjects predetermined by law or when necessary to protect our Services. There may be cases of communication of your information to other parties (e.g. public and/or private organizations authorized by law to receive it and to persons, companies, associations or professional firms providing services or activities of assistance and advice to the Data Controller), in order to:

 

• protect the rights of Wise and its Service users;• protect the security of users of the Services;

• prevent fraud (or for risk management purposes); or

• to comply with what is required by law or by judicial proceedings or in case of a request for cooperation from a government entity, whether or not required by law.

 

Other Subjects in aggregate form. We may also share your information with third parties in aggregate or non-personally identifiable form.

 

Safety and security

We use physical, technical and administrative measures to safeguard the information in our possession against loss, theft and unauthorized use, communication or modification of Personal Data. Please note that, in any case, no transmission or storage of Personal Data can be guaranteed to be 100% secure. Consequently, while we strive to protect the information we hold about you, we cannot guarantee or ensure the complete security of any information you transmit to us.

 

Policy for the processing of data relating to minors

Our Services are not intended for persons under 18 years of age. If you become aware that a child under the age of 18 has provided us with his or her personal data, please contact us at info@wisesgr.com. We do not knowingly collect personal information from children under 16 years of age. If we become aware that a child under the age of 16 has provided us with his or her personal data, we will take the necessary steps to remove that information.

 

Policy for the processing of data relating to applicants to job positions at Wise

If you use our Services (i.e. interaction via email) to submit, voluntarily or upon request, your application for an open position with the Holder, the latter will process your common Personal Data, contained in your curriculum vitae and all those provided by you concerning relevant aspects for the assessment of your professional suitability such as, by way of example and not limited to, educational qualifications, certificates of previous professional experiences, your economic or organizational requests related to the employment relationship for which you are applying. Resumes or other documents containing special categories of data, as referred to in art. 9 of the GDPR (i.e. suitable to reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, etc.), will not be accepted, unless such data processing is necessary to fulfill obligations and exercise specific rights of the data subject in labor law, social security, and social protection under the Applicable Privacy Regulations. Where information related to such special categories of data, as referred to in art. 9 of the GDPR, is provided in any way, the Holder will proceed to deletion. Please note that your Personal Data

common data will be processed for research, evaluation, and selection of personnel, as well as for administrative-accounting purposes and to comply with legal obligations. The execution of pre-contractual measures adopted based on a request and the fulfillment of legal obligations constitute the legal basis for processing. The Personal Data transmitted in the context of your application or a personnel selection process initiated by the Data Controller will be retained for 24 months following the closure of the selection process or the date of spontaneous submission of the curriculum vitae, in order to facilitate re-contact by both parties in case of new job opportunities.

 

Policy for the processing of data relating to professional contacts relevant to Wise

If your professional profile is of particular interest for the purposes of the activities carried out by the Data Controller, the latter may, also through the Services, process your common Personal Data, contained in your curriculum vitae, and all those provided by you concerning aspects relevant to the assessment of your professional aptitude and of your specific qualifications and/or professional experience relevant to the areas of activity of the Data Controller, such as, by way of example but not limited to, degrees, certificates of previous professional experience, your economic or organizational requests regarding your previous employment relationships with previous business partners, suppliers, subscribers or investors of the Data Controller. Curricula or other documents containing particular categories of data, as per art. 9 of the GDPR (i.e. disclosing racial or ethnic origin, political opinions, religious or philosophical beliefs, etc.), will not be processed, unless it is necessary to fulfil the obligations and exercise the specific rights of the data subjects with regard to labour law, social security and social protection under the Applicable Privacy Law. If the candidate provides information on these special categories of data, as referred to in Art. 9 of the GDPR, the Data Controller will delete them. Please note that your Personal Data will be processed to send you updates and information in relation to the availability of job opportunities in senior positions at Wise or third parties, for which you may be interested because of your professional profile. Your Personal Data will be kept for a period of 5 years from the time it was first transmitted by you, or for 2 years from the date of closure of a selection process in which you may have taken part, in order to facilitate contact by both parties in the event of new employment opportunities. Longer retention periods may be necessary to protect the rights or interests of the Data Controller in court or in a preliminary phase thereof, as well as to fulfill regulatory and/or legal obligations incumbent upon the Data Controller. Please note that the Controller does not bear any responsibility for the retention periods of personal data autonomously applied by third parties (e.g., providers of artificial intelligence systems used by the Controller). For further information in this regard, data subjects may contact the Controller using the contact details provided in this Policy.. Your Personal Data will be processed to provide a service you have requested or for which you have expressed an interest by sending or leaving your CV or other contact details to the Data Controller, pursuant to Article 6 paragraph 1 letter b) of the GDPR; for this reason, you will not be asked for your consent. Your personal data will also be processed using technical and organizational solutions such as Customer Relationship Management software (hereinafter referred to as “CRM”), which will allow the Data Controller to record and analyze interactions with you in order to refine its commercial and organizational strategy. Such processing will be carried out by the Company on the basis of its legitimate interest in improving business processes and selecting relevant professional contacts, in accordance with Article 6, paragraph 1, letter. f) of the GDPR.

The processing of your Personal Data is carried out using IT and/or manual systems with the application of appropriate technical and organizational measures in accordance with Article 32 of the GDPR.

The Data Controller has decided to adopt artificial intelligence systems (including, for example, one of the most advanced the artificial intelligence language model offered one the market) and to use them as workplace tools. However, please note that, unless necessary to meet specific business needs, the Data Controller will not process your Personal Data through artificial intelligence systems; in particular, where processing involves documents that may contain your Personal Data, the Data Controller will, where possible, ensure that such data is anonymized. You may exercise the rights referred to in the following paragraph also with reference to the processing that the Data Controller may carry out through such systems. In order to ensure that the use of artificial intelligence systems by its employees and collaborators is carried out in a correct and responsible manner and in compliance with the Applicable Privacy Law, the Data Controller has adopted an Acceptable Use Policy for artificial intelligence systems.

 

Policy for the processing of data related to potential subscribers

 If you are a professional who, personally or on behalf of companies, entities, associations, or legal persons in general, expresses an interest in receiving proposals for potential subscriptions to shares of funds managed by the Data Controller, following a preliminary meeting with the Data Controller, the latter will process your common Personal Data (such as, by way of example and not limited to, name, surname, email address, and, if applicable, the position or title held). The processing of special data referred to in Article 9 of the GDPR is not provided for, and where such information has been provided in any way, the Data Controller will proceed with deletion. Your Personal Data will be processed on the basis of the legitimate interest of the Data Controller, pursuant to Article 6, paragraph 1, letter f) of the GDPR and considering no. 47 of the GDPR, to analyze and map the interactions between you, the Data Controller, the advisors and the community of professionals connected to wealth management, as well as to send you informational material regarding activities and investment projects of your potential interest, also through the use of software dedicated CRM. Your Personal Data may also be processed through artificial intelligence systems, in compliance with the acceptable use policy adopted by the Data Controller. Your Personal Data may be communicated to individuals, companies, associations, or professional firms that provide assistance and consulting services to the Data Controller, appointed, where necessary, as processors under Article 28 of the GDPR. Your Personal Data will not be subject to dissemination but may be transferred to outside the European Economic Area to the CRM service provider and to the providers of artificial intelligence systems, based on the standard contractual clauses adopted by the European Commission and appropriate supplementary measures. Your Personal Data related to a completed investment will be retained for 25 years following their entry into the Data Controller's database; Personal Data processed through the CRM will be retained for 5 years following their collection or last update, subject to any legal obligations or judicial protection needs of the Data Controller. You may exercise the rights referred to in the paragraph “Your rights” of this Policy also with reference to the treatments described above.

 

Policy for the processing of data related to subscribers and purchasers of shares in the Funds

 If you, personally or on behalf of legal entities, propose the subscription and/or purchase of shares in the funds (the “Funds”) managed by the Data Controller, or if your Personal Data is acquired for the fulfillment of legal or regulatory obligations related to such subscription or purchase, the Data Controller will process your common Personal Data (first name, last name, email address, position or title held), as well as, where necessary, data related to criminal convictions and offenses pursuant to art. 10 of the GDPR, within the limits provided by the Applicable Privacy Regulations. The processing of special data as per art. 9 of the GDPR is not foreseen and, if provided, the Data Controller will proceed with deletion. Your Personal Data will be processed for the following purposes and legal bases: (a) execution of the subscription and/or purchase of shares of the Funds and fulfillment of related contractual obligations, pursuant to art. 6, paragraph 1, letter b) of the GDPR; (b) fulfillment of legal obligations, including those arising from the TUF and anti-money laundering regulations, as well as reporting obligations to supervisory or fiscal authorities, pursuant to art. 6, paragraph 1, letter c) of the GDPR; (c) legitimate interest of the Data Controller to keep its contact base updated and to send you informational material, also via the CRM, as well as to use artificial intelligence systems, pursuant to art. 6, paragraph 1, letter f) of the GDPR. Your Personal Data may be communicated to entities that provide assistance and consulting services to the Data Controller, as well as transmitted to any Placement agents used by the company and to the companies controlled by it for consulting activities in the structuring and placement of the Funds. Your Personal Data may be transferred to the tax authorities of third countries pursuant to FATCA regulations, as well as outside the European Economic Area, in compliance with arts. 45 and following of the GDPR, based on adequacy decisions or the standard contractual clauses of the European Commission. Your Personal Data will be retained for 10 years following their entry into the Data Controller's database; the Personal Data processed in the CRM will be retained for 5 years from entry or the last update, subject to any legal obligations or judicial protection needs of the Data Controller. You may exercise the rights referred to in the paragraph “Your rights” of this Policy also with respect to the processing described above, including those carried out through the systems of artificial intelligence.

 

Policy for the processing of data related to co-investors

 If you are a co-investor natural person of the Holder, or a natural person with powers of representation or who carries out activities with co-investors legal entities, or a family member or a third party on behalf of whom the co-investors act (together, the “Interested Co-investor Subjects”), the Holder will process your Personal Data contained in the documentation related to the co-investment (the “Co-investment Contractual Documentation”), limited to the strictly necessary data, including name, surname, and contact details, as well as, potentially, data referred to in art. 10 of the GDPR, within the limits set by the Applicable Privacy Regulations. The processing of special data referred to in art. 9 of the GDPR is not provided for and, if provided, the Holder will proceed to deletion. Your Personal Data will be processed for the following purposes and legal bases: (a) execution and management of the contractual relationship and fulfillment of pre-contractual obligations, pursuant to art. 6, paragraph 1, letter b) of the GDPR; (b) fulfillment of obligations arising from laws and regulations, including mandatory communications provided for by the TUF and by CONSOB, pursuant to art. 6, paragraph 1, letter c) of the GDPR; (c) legitimate interest of the Holder, pursuant to art. 6, paragraph 1, letter f) of the GDPR, to the protection of its rights in court, to the conclusion of financial and corporate transactions, to the use of artificial intelligence systems, as well as to the sending of communications and updates related to the investment or to similar services, without the need for prior consent, remaining the right to object at any time by sending an email to wiseadministrationfunds@wisesgr.com. The processing is carried out by manual and/or electronic means, suitable to guarantee its security and confidentiality. Your Personal Data may be communicated to third parties, public administrations, and professionals who provide assistance and consultancy services to the Holder, appointed, where necessary, as data processors pursuant to art. 28 of the GDPR. Your Personal Data will not be subject to dissemination but may be transferred outside the European Economic Area to the CRM service provider and to the suppliers of artificial intelligence systems, based on the standard contractual clauses of the European Commission and appropriate supplementary measures. Personal Data will be retained for 10 years following the expiration of the term provided by the Co-investment Contractual Documentation, without prejudice to any legal obligations or needs for judicial protection of the Holder. You may exercise the rights referred to in the paragraph “Your rights” of this Policy also with reference to the treatments described above, including those carried out through artificial intelligence systems.

 

Policy for the processing of data related to subscribers

If you are a natural person who has subscribed to shares of funds managed by the Data Controller, or a natural person with powers of representation of companies, entities, associations, or legal persons who have subscribed to shares of funds, or a natural person whose Personal Data is held by the Data Controller by virtue of the role performed with respect to the subscribers, and possibly the family members and third parties on behalf of whom the subscribers act (collectively, the “Interested Subscribers”), the Data Controller will process your Personal Data collected in relation to the subscription of the subscription contract and the related documentation (the “Subscription Contract Documentation”), limited to the strictly necessary data. The processing of special categories of data as per art. 9 of the GDPR is not provided for and, if provided, the Data Controller will proceed with deletion. The processing of judicial Personal Data will be carried out within the limits set by the Applicable Privacy Regulations. Your Personal Data will be processed for the following purposes and legal bases: (a) execution and management of the contractual relationship and fulfillment of pre-contractual obligations, in accordance with art. 6, paragraph 1, letter b) of the GDPR; (b) fulfillment of obligations arising from laws and regulations, including mandatory communications provided for by the TUF, by CONSOB, and by anti-money laundering regulations (Legislative Decree no. 231/2007 and subsequent amendments), in accordance with art. 6, paragraph 1, letter c) of the GDPR; (c) legitimate interest of the Data Controller, in accordance with art. 6, paragraph 1, letter f) of the GDPR, for the use of artificial intelligence systems, as well as for sending information about the activities and investment projects of the funds managed by the Data Controller and for analyzing interactions with the Interested Parties Subscribers, also through the use of dedicated CRM software. The processing is carried out by manual and/or electronic means, suitable to ensure security and confidentiality. Your Personal Data may be communicated to third parties, public administrations, and professionals who provide assistance and consultancy services to the Data Controller, appointed, where necessary, as data processors pursuant to art. 28 of the GDPR. Your Personal Data will not be subject to dissemination but may be transferred outside the European Economic Area to the CRM service provider and to the suppliers of artificial intelligence systems, based on the standard contractual clauses of the European Commission and appropriate supplementary measures. The Personal Data of the Interested Parties Subscribers natural persons will be retained for 10 years following the expiration of the term provided by the Subscription Contract Documentation; the Personal Data relating to Interested Parties Subscribers legal entities will be retained for 25 years from their entry into database of the Owner; the Personal Data processed through the CRM will be kept for 5 years from the collection or the last update, without prejudice to any legal obligations or judicial protection needs of the Owner. You may exercise the rights referred to in the paragraph “Your rights” of this Policy also with reference to the treatments described above, including those carried out through artificial intelligence systems.

 

Your rights

Wise does not share your Personal Data with third parties for direct marketing purposes. Your Personal Data will not be subject to dissemination. Wise has adopted the suite of Cloud services, in which the email boxes with the Wise domain as well as the Owner's database will be transferred. Cloud is a service of Microsoft Ireland Operations Limited (“Microsoft”), purchased by the Owner through an external provider. The Owner also uses artificial intelligence systems. Microsoft and the provider have been designated as processors under Article 28 of the GDPR, and will process the Personal Data on behalf of Wise in accordance with its instructions and the highest standards of security provided by the GDPR. The Owner has instructed the two processors to process and store the Personal Data within the European Union; where, by virtue of Microsoft's security and backup policies, the Personal Data were transferred outside the European Union, such transfer would occur on the basis of standard clauses of the European Commission in force from time to time.

Wise has also purchased from the company Project Affinity, Inc. (“ Affinity”), located at 170 Columbus Avenue Floor 3, San Francisco, CA, USA 94133, a CRM solution that involves the transfer of Your personal data to the United States of America and that Affinity will process as the data controller; such transfer takes place based on the standard contractual clauses of the European Commission in effect at the time, in the controller-processor format, and is supported by additional safeguards agreed upon between Wise and Affinity through a specific Data Processing Addendum.

We inform you that, regarding Your Personal Data in our possession, you can exercise all the rights provided by the Applicable Privacy Regulations and in particular: (i) request from the Data Controller confirmation of the existence of your Personal Data, the origin of such data, the logic and purposes of the processing, the categories of subjects to whom the data may be communicated, as well as the identifying information of the controller and the processors; (ii) request access to the Personal Data, transformation into anonymous form, blocking, rectification, integration or deletion of the same, or limitation of processing; (iii) opposing the processing in cases provided by the Applicable Privacy Regulations especially with reference to processing carried out with the aid of artificial intelligence systems; (iv) exercise the right to portability, within the limits provided by art. 20 of the GDPR; (v) revoke the consent (where this is the necessary legal basis for the processing) at any time without affecting the lawfulness of the processing based on the consent given before the revocation; (vi) be informed of the existence of an automated decision-making process, including profiling as referred to in art. 22 paragraphs 1 and 4, and, at least in such cases, significant information on the logic used, as well as the importance and expected consequences of such processing for the Data Subject; (vii) lodge a complaint with the Data Protection Authority, following the procedures and guidelines published on the official website of the Authority on www.garanteprivacy.it.

 

Exercise of users’ rights

You can contact Wise via email at info@wisesgr.com, in order to assert your rights. With reference to the processing related to the subscription and/or purchase of shares of the Funds, you can also contact the Data Controller at wiseadministrationfunds@wisesgr.com.

 

Amendments to this Policy

We may review this Privacy Policy over time. The most recent version of the Policy will govern Wise’s use of your Personal Data and will be available on the website www.wisesgr.com. We may make changes to this Policy at our sole discretion. By continuing to access or use our Services after any changes have become effective, you agree to the terms of the revised Privacy Policy.

 

Questions

If you have any questions about this Policy or your privacy in using our Services, please contact info@wisesgr.com.