Privacy policy according to Art. 13 and 14 of the EU General Data Protection Regulation No. 679/2016

Dear customer, within the meaning of Art. 13 and 14 of the EU General Data Protection Regulation No. 679/2016 (henceforth GDPR) and with reference to the personal data the Company Kinvest has been provided with by you or has otherwise acquired, we inform you about the following: The personal data and information which is made available to us from your side or has been otherwise acquired by using the services on our website, will be processed in accordance with the provisions of the Regulation and in conformity with the confidentiality obligations of the responsible person. In accordance with the provision of the Regulation, the handling of the data by the Company Kinvest will be characterized by the principles of rightfulness, fair and lawful processing, transparency, limitation of storage, minimization of data, correctness, integrity and confidentiality.

1) Name and address of the responsible person.

The person responsible for the processing of the personal data within the meaning of the GDPR is the Company Kinvest, with its registered office in 39040 Vahrn, Forch 1. The responsible person can be contacted at the telephone number +39 0472 055 277 and by the email-address

2) Subject-matter of processing operations.

We inform you that, due to the navigation on our website, the person responsible for the data-processing can process personal data that may consist in your name, an identification number, online identification data, a postal address, an email-address, a telephone number or any other element of your physical, physiological, psychical, economic, cultural or social identity that allows the responsible person to identify the person in question or makes that person identifiable (henceforth “personal data”). The personal data processed on or via the website of the Company Kinvest are the following:

a) Navigation data:

The computer system and software procedures used to operate within this website acquire, during their normal operation some personal data, whose transmission is implicit in the operation of the Internet communication protocols. This information is not collected to be associated with identified persons, but by their very nature could allow, through processing and association with data held by third parties, to identify users. This category of data includes IP addresses or domain names of computers used by users connecting to the site.

b) Data voluntarily supplied by the user:

If you use specific services on our website (such as the request or contact form), we can process the personal data that you supplied to us. This category of data includes your name and your email-address.

c) Cookies:

The website uses technical cookies that are relevant for the full functionality of the website. Cookies are small text files which are automatically transferred to the hard disk of your computer via our website or by a user’s Web browser, in order to store small amounts of information of the website for a certain period of time.

3) Scope of data processing.

The personal data is processed exclusively for the purpose of enabling the services requested by the users and for the scope of executing the order correctly and completely. Furthermore, the personal data is collected and processed for the purpose of fulfilling fiscal and accounting obligations. After a prior explicit and specific consent, the data supplied by the user can be processed for marketing and promotion communications, including the sending of newsletters and market research surveys. The legal basis for the processing of data for this purpose is Art. 6, para. 1, lit. a of the Regulation.

4) Modalities of data processing.

a) The processing of data refers to any kind of processing operation respectively any set of operations that are described in Art. 4, para. 1, lit. a) of the Italian Privacy Codex: Elicitation, storage, organization, retention, query, elaboration, modification, selection, retrieval, comparison, utilization, interconnection, blocking, communication, dissemination, erasure and destruction of data. b) The processing operation can be carried out with or without the help of electronic or automated means. c) The personal data of the users is processed by the entitled person and/or by persons in charge of the processing.

5) Legal basis for the data processing

The legal basis for the data processing is Art. 6, para. 1, lit. b of the GDPR (completion of a contract), as the processing of the personal data is necessary for the performance of the services requested by the users and the fulfillment of the contracts. Insofar as processing of personal data is required to fulfill a legal obligation that the Company Kinvest is subject to, Art. 6 para. 1 lit. c GDPR is the legal basis. The legal basis for advertising efforts and marketing communications is Art. 6, para. 1, lit. a) of the GDPR (consent of the user).

6) Refusal to disclose personal data.

If the user should refuse to provide the personal data according to paragraph 2, it will be impossible for the Company Kinvest to prosecute the services indicated in paragraph 3.

7) Transmission of the data.

The personal data can be transmitted to the persons in charge of the processing and can be made accessible to external employees, persons, companies or office communities that offer accounting, administrative, legal, fiscal, financial, advertising and marketing assistance and consultation to the responsible company Kinvest and essentially to all entities (including Hosting-Provider and entities, that are charged with technical maintenance operations), to whom or which the data must be communicated in order to guarantee the fulfillment of the purposes according to paragraph 3.

8) Dissemination of the data and profiling.

The personal data will not be disseminated and will not be part of any processing operation, which is based solely on automated processing of data, including profiling.

9) Transfer of data to a foreign country.

The personal data can be transferred to member countries of the European Union and to third countries according to the purposes indicated in paragraph 3.

10) Duration of storage.

The personal data, which is processed for the purposes indicated in paragraph 3, will be stored for the duration of the order or the contract and by all means for as long as required by legal regulations and ordinances, to which the Company Kinvest is subject. Personal data that is processed for advertising efforts and marketing communications will be stored until withdrawal of the consent by the person concerned or, if such withdrawal has not been communicated, for a specified maximum period that is considered to be appropriate.

11) Rights of the persons concerned

Within in the meaning of the GDPR, the persons concerned have several rights, including the right to be informed by the responsible person of the data and its processing according to Art. 15 of the GDPR and the right to obtain such information in an intelligible form. According to Art. 16, the persons concerned are entitled to obtain the immediate rectification of data concerning them; the user has furthermore the right to obtain the cancellation of the data (Art. 17 GDPR) and to demand the restriction of the data processing (Art. 18 GDPR). Moreover, the person concerned is entitled to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided (Art 20 GDPR). The user has furthermore the right pursuant to Art. 21 GDPR to object at any time to processing of personal data. The data subject has the right to revoke the consent at any time; the revocation of consent does not affect the legality of the processing carried out on the basis of the consent until the revocation. In addition, there is a right of appeal to the data protection supervisory authority (Autorità Garante per la protezione dei dati personali – according to Art. 77 GDPR. For questions about the collection, processing or use of your personal data, information, correction, blocking or deletion of data as well as revocation of any given consent or objection to a particular use of data, please contact the responsible person mentioned in the imprint on our website