COIMA RES - Privacy and Cookie Policy

This Privacy Policy aims to describe the purposes and methods by which Coima RES S.p.A. SIIQ, in its capacity as Data Controller (“Company” or “Data Controller”), collects and processes the personal data of the user (“You/Your”) who interacts with the website https://www.coimares.com/en/ (“Website”) and with the various services offered by the same.
The information contained in this Privacy Policy is provided pursuant to Article 13 of Regulation (EU) 2016/679 of 27 April 2016 (“Regulation”), as well as pursuant to the Decisions issued by the Garante (Italian Data Protection Authority) and the Guidelines of European Authorities.
The information about the processing of personal data is disclosed exclusively for the Website and the processing carried out by the Company, but not for the processing operations carried out by third parties through other websites you may visit by opening a link. The Company shall take no responsibility for such additional processing operations, as you have to refer to the individual Privacy Policies of the third party websites you visit.

1. Controller and place of the processing

The Data Controller is Coima RES S.p.A. SIIQ, with registered office at Piazza Gae Aulenti 12, 20154, Milan (Italy).
The data are mainly processed at the headquarters of the Controller, by technical personnel of the Company appointed as persons in charge of the processing, within the Italian Stat.

2. Modalities to process the data

The Company shall process your data by adopting all the appropriate security measures intended to prevent any unauthorised access, as well as the unauthorised disclosure, modification, or destruction of the data. The data shall be processed both with manual and computer and/or telecommunication means, with organisational modalities and logics strictly connected with, and limited to, the specified purposes

3. Purposes and legal basis of data processing

The Company, through the Website, may process your data for the following purposes:

a. Recording and publication on the Website of the conference calls arranged to provide updates on financial results. The Company allows its investors, as well as any third parties concerned, to join - even only by listening - conference calls regularly organised by the Company in order to provide updates on the Company’s quarterly, half-yearly and annual financial results. Users can, in particular, join conference calls simply as listeners, or they may ask specific questions in the Q&A phase. The audio of such conference calls shall be recorded and published in a special audio file, on the Company’s Website for the purposes of transparency and filing, to allow those interested in the matter to hear the updates provided in the conference calls they have been unable to join. In this regard, when you request to join the conference call, at the beginning of the call, before connecting, you shall be informed of and, at the same time, may express your consent to, the recording and subsequent publication of the audio of the conference call you have requested to join. Therefore, the legal basis for the processing is represented by your express consent to the recording and publication of the audio of the conference calls the latter joins, and any refusal to provide personal data shall make it impossible for you to participate in the conference call or, alternatively, to ask specific questions during it.

b. Contacting the Company The Company shall give you the chance to send notices to the Company by email, in addition to questions and requests for information on the Company’s activities, initiatives, and services. To this subject, the personal data disclosed by you (for example, email address, possible telephone number and/or other information spontaneously provided to you) shall be processed by the Company to receive, correctly manage, and answer your communications. The legal basis for the processing is represented by the performance of the service expressly requested by you, and any refusal to provide the personal data shall cause the impossibility for the Company to manage and answer the communication or request for information.

c. Pursuance of the legitimate interests of the Company and/or third parties. Your data may also be used for the exercise of the rights and legitimate interests of the Company and/or third parties, for example, the right of defence in court, the management of complaints and situations of litigation, the recovery of receivables, fraud prevention and/or unlawful activities. In these cases, even if the disclosure of your personal data is not compulsory, it is in any case necessary in that such data are strictly connected and expedient to the pursuance of the said legitimate interests, which do not prevail on your fundamental rights and freedoms, and any refusal to disclose them could cause the impossibility to provide the services required (for example, requesting information to the Company).

d. Fulfilling legal obligations and/or applicable obligations. The Company may also use the personal data disclosed by you or otherwise acquired during your interaction with the Website for purposes related to the fulfilment of legal obligations, regulations, domestic and EU legislation, and purposes resulting from provisions issued by authorities empowered to do so by law, which represent the legal basis for the processing, without the need to obtain your prior consent.

d. Performing aggregate statistics on an anonymous basis in order to improve the performances and services offered by the Company through the Website. In this case, no consent shall be required of you, in that the processing specified shall be carried out exclusively on anonymous data.

4. Categories of data to be processed

The Company shall receive and collect, through the Website, information related to the users who visit the pages of the Website and use the web services available thereon. In particular, the Company shall acquire and process the following information.

4.1 Data collected through surfing and cookies

When you visit the Website, the latter shall collect some data such as the pages viewed, the links or the buttons you clicked, the date and time of access, your IP address, the surfing browser, and the operating system used (so-called “surfing data”). The surfing data could, by their very nature, enable your identification also through elaborations and associations with data stored by third parties. However, the Company shall use these data for the sole purpose of obtaining statistical and anonymous information on the use of the Website for purposes strictly connected with the operation thereof. The surfing data could also be used to ascertain liability in the case of computer crimes that damage the Website.
Secondly, in relation to the collection of your data through similar cookies and technologies, please read the Cookie Policy.

4.2 Data voluntarily supplied by You

The Company shall limit the collection of the information voluntarily provided by you to the information necessary to pursue the purposes illustrated in paragraph 3 above and the services expressly requested. Moreover, the Company may collect and process additional personal data, if the same have been voluntarily disclosed by you within the services offered by the Website, for example in the case in which you contact the Company to report failures or malfunctioning, exercise your rights on data processing, etc. Such data shall be processed by the Company exclusively for the purposes strictly connected to your request. The failure to disclose the data may cause the impossibility to obtain the service required.

5. Disclosure of data to third parties

The data supplied by you and those collected by the Website within the relevant services (for example, IP address) shall not be disclosed and may be notified, for the purposes and modalities illustrated in this Privacy Policy, to the categories of parties indicated below:

companies of the COIMA Group, for administrative-accounting purposes, for the pursuance of legitimate interests of the Company and/or third parties, and for the purpose of performing the services expressly requested by you;

companies, consultants, advisors or independent contractors of whom/which the Company avails itself for the performance of technical or organisational tasks (such as, for example, providers of IT services), or with whom/which the Company cooperates (including the other COIMA Companies), in order to provide and operate their services, or for any communication activities;

natural persons, companies, or professional firms that provide the Company with assistance and advisory services or activities, especially, but not exclusively, with reference to accounting, administrative, legal, tax, and financial issues;

parties whose right to access the data is provided for by legal provisions or orders of the relevant authorities.


The parties belonging to the categories indicated above shall use the data in their capacity as independent data controllers pursuant to law or as data processors duly appointed by the Company.

Such parties may be based in EU Member States or non-EU Countries. In particular, in the event that the said parties are based in non-EU Countries, the Company shall adopt the measures provided for by the Regulation to legitimize the transfer of personal data to the same.

The list of the persons to whom the data are or may be disclosed, as well as the details of the privacy measures adopted to legitimate data transfers outside the EU, may be requested to the Company by contacting the persons specified in the “Rights of Data Subjects and Contact Persons” section.

6. Storage of personal data

The Data shall be processed for as long as it is necessary for the performance of the activities indicated in paragraph 3 above, and they shall be erased when the purposes for which they have been collected and processed do not apply any longer.
In particular, the Company shall erase the personal data of those users who have asked for information or sent communications by contacting the Company through the Website 3 months after disclosure thereof. Secondly, the Company shall erase the personal data of those users who have sent their application in connection with jobs offered by the Company 3 months after disclosure thereof, in the case in which the applicant fails to enter into an employment/professional relationship with the Company.
Finally, the recordings of the relevant conference calls shall remain available on the Website, as part of a historical filing system, for 10 years after publication.

7. Your Rights and contact persons

You may exercise the rights provided for by the Regulation in the cases expressly provided for by law and where applicable. In particular, you shall have the right to:

request confirmation as to whether or not your personal data are being processed and, in this case, request from the controller access to the information related to the same processing (for example, purposes, categories of data processed, intended recipients, or categories of intended recipients of the data, storage period, etc.);

right to request from the controller the rectification of inaccurate or incomplete data;

request from the controller the erasure of the data (for example, if the personal data are no longer necessary for the purposes for which they have been collected, in the case of revocation of the consent on which the processing is based, etc.);

request the restriction of the processing (e.g., in the event that you challenge the accuracy of the data; if the processing is unlawful and you object to the erasure of personal data; if the data are necessary to exercise or defend in court one of your rights, even if the controller no longer needs them; in the event that the right to object is exercised, for the time necessary to verify the existence of legitimate grounds).

receive the data concerning you in a commonly used and machine-readable format (for example, PDF), and transmit them to another controller, or obtain the transmission of those data directly from one controller to another, if technically possible (so-called data portability).


Moreover, you shall have the right to object in whole or in part, on legitimate grounds, to the processing of the data regarding you.

Such rights may be exercised directly by sending a notice to the following email address: info@coimares.com.

Finally, if you deem that the processing of the data disclosed is in breach of data protection provisions, you shall have the right to file a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).

8. Collecting data through Cookies

A cookie is a small string of text that the websites visited send to the browser of your computer, where it is stored when you visit an Internet website, and are then re-transmitted to the same sites on the occasion of your next visit.

Cookies are used by the Company to operate the Website or improve its performance, and also to provide information about the Website or your browsing.

The Website uses cookies both for technical purposes and for further purposes: while technical cookies are used in that they are strictly necessary for the technical functioning of the Website and to provide the service expressly requested by you (e.g., setting the language, etc..), as better described below, cookies for further purposes (e.g., profiling cookies, analytical cookies) are used to carry out analyses of your behaviour on the Website, in order to improve its content and send advertising messages in line with the preferences expressed by you in the context of network browsing, as indicated below.

8.1 Technical cookies

Technical cookies are fundamental to enable you to surf the Website and use its functionalities, remember your preferences (for example, language, country of origin, etc.), distribute requests on more servers, remember when you consent to certain options (for example, by accepting the use of certain cookies to remove the informative banner), in order to enable you to view contents and videos through Adobe Flash Player. Such cookies shall last for no longer than 2 years and do not require your consent.

The technical cookies used are:

  • pll_language: allows the correct distribution of the contents in your selected language;
  • hypo-disclaimer: allows access to the Investor Relations area after you have confirmed to be able to access it by filling in the relative on-line form;
  • gat_gtag_UA_[xxx]: allows Google to distinguish users.

8.2 Performance and analytics cookies of the Company

These cookies may be session or permanent cookies, and their use is limited to the Website’s performance and improvement. These cookies enable us to identify, measure and track the Website’s visitors, thus allowing us to improve and perfect the Website, for example, by determining whether you can easily find the information desired, or by identifying which aspects of the Website are of greatest interest. These cookies are used by the Company to carry out statistical and anonymous analyses on how users navigate the Website, on the number of pages visited or the number of clicks made on a page during navigation. According to privacy regulations, these cookies are equated to technical cookies, therefore they do not require your consent.

8.3 Performance and Analytics Cookies of Third Parties

The Company may also use, on its Website, analytical and performance cookies of third parties, for the same purposes as those described above. In particular, the Company may use cookies of Google Analytics through the “_ga” cookie, in order to analyse how users navigate the Website, the number of pages visited or the number of clicks made on a page while browsing. The Company shall process the results of these analyses only if the third party uses the relevant cookies in connection with the browser installed on the computer or on other devices used by you to navigate the Website.
To activate these cookies, you can choose to give your consent (which therefore represents the legal basis for the processing) through the mechanism shown in the banner providing information on the Company’s cookies, which appears on the homepage/landing page of the Website when you access it.
For information on how to manage, or disable, the performance and analytics cookies installed by Google Analytics, we suggest reading Google’s Privacy Policy and cookies options at the following links: https://www.google.it/intl/it/policies/privacy/.

8.4 Profiling cookies installed by the Company

In the emails sent to you, the Company may insert web beacons and electronic images, so-called “one pixel GIFs”, “clear GIFs” or “pixel tags” that, if clicked, allow one to count the number of users who have visited the Website’s pages, or who have had access to the contents of communications; apart from obtaining statistical data, it is thus possible to identify also the characteristics and contents in which individual users are more interested, in order to provide more tailored information.

Click here if you want to refuse the use of these technologies

Finally, to learn more about the cookies on the Website and how to manage or disable those of third parties, you can visit www.youronlinechoices.com.

8.5 Disabling cookies through the browser

In addition to being able to choose whether to accept or reject all or part of the cookies used by the Website for further purposes through the mechanisms illustrated in this Privacy Policy, in future you may also, if you wish so, delete from your browser the cookies set by the Website also through the settings of the browser itself.
Most of surfing browsers are set to accept cookies. However, you may set your browser in such a way as to restrict the number of cookies accepted or block all the cookies, changing the browser settings as follows:

Microsoft Internet Explorer Click on the “Tools” icon in the top corner on the right and select “Internet Options”. Select “Privacy” in the pop-up window. Here you may change the cookies settings.

http://windows.microsoft.com/it-it/internet-explorer/delete-manage-cookies#ie=ie-11-win-7

Google Chrome Click on the “wrench” icon in the top corner on the right and select “Settings”. At this point, select “Show advanced settings” and change the “privacy” settings.

https://support.google.com/accounts/topic/2373959?hl=it&ref_topic=2373957

Mozilla Firefox From the menu button in the top corner on the left, select “Options”. Select “Privacy” in the pop-up window. Here you may change the cookies settings.

https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie#firefox:win7:fx38

Safari From the menu button in the top corner on the right, select “Preferences”. Select “Security” and there you may change the cookies settings.

https://support.apple.com/it-it/HT201265

However, it is pointed out that by disabling the use of all the cookies on the Website (including technical cookies), some functionalities will be compromised.

8.6 Additional information related to the cookies

The www.allaboutcookie.org website contains the instructions to manage the cookies on the most common browsers; alternatively, it is possible to consult the documentation attached to the software used on one’s own device.

The Company reserves the right to make changes to this Privacy Policy at any time, giving notice thereof through publication on the Website. We ask you to check such updates on the Website.

If the changes were particularly significant and/or their impact on your rights were substantial, the Company may notify you of such changes also through other modalities (for example, by sending an email).

Privacy and Cookie Policy as at 25 May 2018