This Privacy Policy describes the purposes and methods by which COIMA SGR (“Company”, “Data Controller” or “Controller”), collects and processes personal data relating to the user (“User”) who interacts with the website www.coima.com (“Website”) and with the various services it offers. The Website provides an overview of Coima Group Companies’ business, and allows users to interact with individual companies, through their dedicated pages, in their capacity as controllers. The information contained in this Privacy Policy is provided under Art. 13 of Regulation EU of 27 April 2016 no. 679 (“Regulation” or “GDPR”), and the Measures issued by the Data Protection Supervisory Authority and the Guidelines of the European authorities. Information on the processing of data is provided only for the Website and for data processing operations carried out by the Company and it does not extend to processing carried out by third parties on other websites that may be consulted by Users via links. The Company does not accept any liability for this further processing; the User should refer to the individual Privacy Policies of the third party websites.
1.Data Controller and place of the data processing
The Data Controller is the Company COIMA SGR S.p.A., based in Milan (Italy), Piazza Gae Aulenti no. 12, 20154.
2. Data processing methods
The Company processes the User’s data while adopting all appropriate data security measures to prevent unauthorised access, unauthorised disclosure, modification or destruction of the data. The processing is carried out using both manual and/or electronic tools, using organisational methods and logics strictly related and limited to the indicated purposes.
3.Data processing purpose and legal basis
The Company, through the Website, may process the User’s data for the following purposes:
Contacts. The User may communicate with the Coima Group Companies’ contact persons to request information using the details specified on the Website. Each company follows the user's requests for information as an independent data controller. Information on the processing of the data provided can be consulted by accessing the privacy policies on each company's website. Personal data provided voluntarily by the User (e.g. email address, telephone number if any or other information freely provided to the User) will be processed by the Coima Group Companies contacted by the User, to manage and respond to their communications or requests. The processing legal basis is the performance of the service requested by the User (Art. 6(1)(b) GDPR), and any refusal to provide personal data will make it impossible for the Company to manage and acknowledge the communication or request for information.
Pursuing the legitimate interests of the Company or third parties. The User’s data may be used to exercise the rights and legitimate interests of the Company or third parties, for example, handling claims, fraud prevention or prevention of unlawful activities. In these cases, although the provision of the User's personal data is not mandatory, it is necessary as this data is closely connected and instrumental to the pursuit of those legitimate interests, which do not prevail over the User’s rights and fundamental freedoms (art. 6(1)(f) GDPR)
Fulfilling applicable legal or other obligations The Company may use personal data provided by the User or acquired during the User’s interaction with the Website for purposes of compliance with legislative and regulatory obligations, national and EU legislation, as well as obligations deriving from measures issued by authorities who are legally authorised to do so, which represent the legal basis of data processing, without the need to obtain the User’s prior consent. (art. 6(1) (c) GDPR)
4. Data categories
The Company receives and collects information through the Website relating to the User who visits the pages of the Website and who uses the web services available on the Website. The Company acquires and processes the following information.
4.1 Data collected from browsing and cookies
When the User visits the Website, the latter collects certain data, such as pages viewed, connections or buttons clicked by the User, date and time of access, IP address, browser and operating system used (known as “navigation data”). The Company uses this data for the sole purpose of obtaining statistical and anonymous information on the use of the Website for purposes strictly related to its operation and assess the effectiveness of the services offered by the Website. Navigation data could be used to ascertain responsibility in the event of any computer crimes being committed against the Website. For the collection of the User’s data through cookies and similar technologies, please visit the Cookie Policy.
4.2 Data provided voluntarily by the User
The Company limits the gathering of voluntarily provided information to data necessary to achieve the purposes described in paragraph 3 above and receive the services requested. Additional personal data may be collected and processed by the Company, if the same are provided voluntarily by you as part of the services offered by the Website, for example, if you contact the Company to report disservice or malfunctioning, to exercise your rights in relation to personal data processing, etc. Those data will be processed by the Company only for purposes strictly linked to your request. Any failure to provide the data may make it impossible to obtain the requested service.
5. Disclosure of data to third parties
The data provided by the User as well as those collected by the Website as part of the relevant services (e.g. IP address) will not be disseminated and may be communicated - for the purposes and using the methods illustrated in this Privacy Policy - to the categories of persons/entities listed below:
COIMA platform companies, for organisational purposes, internal control purposes, pursue the Company or third-party legitimate interests and carry out the User services/requests (e.g., contact requests);
companies, co-workers, consultants or freelancers that the Company uses in order to implement technical or organisational tasks (e.g. IT and web service providers), or with whom the Company collaborates (including other COIMA Companies) to provide and operate its own services, or for any communication activities;
persons, companies or professional firms that provide assistance and advice to the Company, particularly (but not exclusively) in accounting, administrative, legal, tax and financial matters;
persons/entities entitled by law or by order of a public authority to access the data.
The persons/entities belonging to the categories indicated above will use the data as independent data controllers pursuant to law or as data processors properly appointed by the Company.
The list of entities to which the data are or may be disclosed, can be requested from the Company by using the contact details indicated in the “Rights of Users and Contact Details” section.
6. Data retention
The data are processed for the period of time necessary to carry out the activities indicated in paragraph 3 above, and are erased when the purposes for which they were collected and processed no longer apply. The Company will provide feedback to email requests without further processing the personal data. It may hold the data for longer periods to meet the user’s request. The information collected through cookies will be stored for the periods specified in each table in section 8 below.
7. User rights and contact details
The User may exercise the rights provided for by the Regulation in the cases expressly envisaged by law and where applicable. The User has the right to:
obtain confirmation of whether or not the processing of his/her personal data is in progress and, in that case, to request from the Controller access to information relating to that processing (e.g. purposes, categories of data processed, recipients or categories of recipients of data, retention period, etc.);
request the rectification of inaccurate or incomplete data;
request the Controller to erase the data (e.g. if the personal data are no longer necessary in relation to the purposes for which they were collected, or if the consent on which the data processing is based is withdrawn, etc.);
request the data processing limitation (e.g. if the User disputes the accuracy of the data; if the data processing is unlawful and they object to the erasure of personal data; if data is required to exercise or defend the User's rights in court, even where the Controller no longer requires it; when the User exercises their right to oppose data processing, for the time required to verify whether legitimate reasons exists).
receive personal data relating to him/her in a commonly-used and machine-readable format (e.g. pdf) and to send them to a different data controller, or to obtain direct transmission from one controller to the other, if technically possible (known as data portability).
The User also has the right to object, in whole or in part, for legitimate reasons, to the processing of their personal data.
Those rights may be exercised by sending a communication to the following email address: privacy@coimasgr.com .
Finally, if the User considers that the processing of data provided violates personal data protection rules, he/she has the right to lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).
8. Data collection using Cookies
Cookies are small text strings sent by websites which the User visits to their computer browser, where they are stored for the User's next visit to the website, for re-transmission. Cookies are used by the Company to operate the Website or improve its performance, assess the efficiency of services and provide information on the Website or on the User’s navigation. The Website uses cookies for technical, analytical and profiling purposes: while technical cookies are used as they are strictly necessary for the technical functioning of the Website and to provide the service expressly requested by the User (e.g. language setting, login, etc.), as described below, analytical and performance cookies analyse the Use of the Website, to improve its contents and assess Website effectiveness.
8.1 Technical cookies
Technical cookies are essential to enable the User to navigate the Website and use its features, to record the User's choices (e.g. language, country of origin, etc.), to distribute requests on multiple servers, to record when the User consents to certain options (e.g. by accepting the use of certain cookies as a result of having viewed the information banner), to enable the User to view content and videos using the Adobe Flash Player. These cookies do not require the User's consent. The technical cookies used, and their features are set out in the table below.
| Party installing the cookie | Cookie name | Purpose | Retention period |
|---|---|---|---|
| Coima | lang | Allows the correct distribution of content in the User's selected language | Maximum two years |
| Coima | XSRF-TOKEN | It ensures browsing security for visitors by preventing requests from being falsified. This cookie is essential for website and visitor security. | Two hours |
| Coima | coima_welcome_session | Allows the PHP session to be maintained | Two hours |
| _gat_gtag_UA_99071980_8 | Enables Google to distinguish between users | Maximum two years |
8.2 Performance and Analytics Cookies
The Company may also use third-party analytics and performance cookies on the Website, for the same purposes described above, and in particular of Google Analytics, by means of the “_ga” cookie, to analyse how Users navigate the Website, the number of pages visited or the number of clicks made on a page during a browsing session. The Company processes the results of these analyses only if the third party uses cookies for the browser installed on the computer or on other devices which the User uses in order to navigate the Website. To activate these cookies, the User may give their consent (the legal processing basis) through the mechanism shown in the Company's cookie information banner, which the User displays on the Website homepage/landing page. For information on managing performance and analytics cookies installed by Google Analytics and to refuse them, you will need to click on the "Refuse" button on the Banner or on "More Options" if you are interested in learning about the types of cookies and choose whether to enable or refuse them We recommend that you consult Google's Privacy Policy and cookie options using the links below. The Company is not responsible for the possible use of information collected by third parties using the cookies specified in the table below, analytics cookies section (third-party) as the Company does not directly control these cookies.
| Party installing the cookie | Cookie name | Purpose | Retention period | How to activate/deactivate and Cookie policy |
|---|---|---|---|---|
| _ga | Records a unique ID that is used to generate statistical data on how the visitor uses the website. | Two years | https://policies.google.com/privacy | |
| _gat | Used by Google Analytics to limit the frequency of requests. | One day | https://policies.google.com/privacy | |
| _gid | Records a unique ID that is used to generate statistical data on how the visitor uses the website. | One day | https://policies.google.com/privacy |
8.4 Changing and managing cookie preferences
It is possible to change and manage cookie preferences through the Website or browser settings or by using third party websites
through the Website: you can enable/disable third-party cookies using the selections in the table in the paragraph above
through the Websites www.youronlinechoices.org oppure www.aboutcookies.org or www.aboutcookies.org
through your browser settings you can block or delete cookies received from the Website or any other website by changing your browser settings through your browser function.
Below are links to the instructions for the following browsers:
Internet Explorer - http://windows.microsoft.com/en-gb/windows-vista/block-or-allow-cookies
Chrome - https://support.google.com/chrome/answer/95647
Firefox - https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Opera - http://www.opera.com/help/tutorials/security/privacy/
Safari - http://support.apple.com/kb/PH17191
Please note that disabling cookies - including strictly necessary cookies - could cause issues with browsing the Website and prevent certain features of the Website from functioning properly.
9. Third Party Plugins
The Website may also incorporate plugins and/or buttons for social networks in order to make it easier for the user to share content on their preferred social networks. These plugins do not set a cookie, but if one is already present on the user’s computer, they can read it and use it within the limits of its settings. The collection and use of information by these third parties is regulated by the relevant privacy policies, which the user is recommended to read.
10. Use of other websites
The user is recommended to read the privacy and cookie policies of any websites that they visit through the links present on the Website. Please note that the cookie preferences applicable to this Website will not be active on the websites of other companies.
11. Transfer to non-EU countries
The Company will not transfer your data to entities established outside the European Union. For information on the possible transfer of personal data collected through third-party cookies established in non-EU countries, please refer to the third-party privacy policy on its website.
12. Changes to the Privacy and Cookie Policy
The Company reserves the right to make changes to this Privacy Policy at any time, giving notice of this by publication on the Website. We invite the User to check these updates on the Website. Should the changes be particularly significant and/or notably impact the User's rights, the Company may also communicate them to the User in a different manner (e.g. by sending an email).
Privacy and Cookie Policy updated on 24 June 2022