VAM Investments Group S.p.a.

Management of investments through an online platform

The controller has developed an online portal, accessible as a reserved area to its clients/investors by means of authentication credentials and not open to the public, which allows them to monitor the status of their investments and to take part in consultations relating to the companies in which they are invested. The portal is also accessible to the internal staff of VAM Investments, who can monitor the status of all the investments managed and the data of the related investors, the invoices issued for the payment of fees, and the data, including personal data, contained in company register extracts. Through the portal, it is also possible to send and receive signed documents relating to consultations and to votes at shareholders' meetings.

Why we process the data and on what legal basis

Managing relationships with investors.Legal basis: Performance of a contract (or pre-contractual measures) (Art. 6(1)(b) GDPR)
Allowing investors to monitor their investments.Legal basis: Performance of a contract (or pre-contractual measures) (Art. 6(1)(b) GDPR)
Allowing investors to take part in corporate consultations and to share documentation relating to votes at shareholders' meetings.Legal basis: Performance of a contract (or pre-contractual measures) (Art. 6(1)(b) GDPR)

Categories of data subjects

Clients / investors (natural persons)
Contact persons and legal representatives of investors that are legal persons

Data subjects requiring greater protection: B2B customers and/or suppliers

Categories of personal data

Identification and personal details (e.g. first name, surname, date and place of birth, tax code)
Economic, financial and asset data (e.g. current and past investments in the companies managed by VAM, holding of Participating Financial Instruments - SFP)
Accounting and tax data (e.g. invoices issued for the payment of fees, amounts due, payments)
Data relating to corporate roles, offices and shareholdings (e.g. corporate offices, membership of clubs with investment privileges)
Data relating to corporate consultations and votes (e.g. corporate consultations, signed documents relating to votes at shareholders' meetings)
Authentication and access data (e.g. credentials for access to the platform)

Processors

Blumerstudio S.a.g.l. (IT services)
Hostinger International Ltd (Hosting Provider)

Retention period

Administrative data relating to investments and investors are retained for 10 years pursuant to Art. 2220 of the Italian Civil Code.

Consequences of not providing the data

Providing the data is necessary for the performance of the investment relationship and for access to the reserved area of the portal. Without the data requested, VAM will not be able to allow the investor to monitor their investments through the portal or to manage the related relationship properly.