VAM Investments Group S.p.a.

Administrative management of investors

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Administrative management of investors

The controller processes investors' personal data in the administrative activities relating to the raising and management of investments. In particular, it carries out the following activities: recording master data; managing the investor database; managing payments made and the payment of Management Fees; managing communications with clients through the available contact channels (ordinary post, email, telephone).

Why we process the data and on what legal basis

  • Managing relationships with clients.Legal basis: Performance of a contract (or pre-contractual measures) (Art. 6(1)(b) GDPR)
  • Service communications.Legal basis: Performance of a contract (or pre-contractual measures) (Art. 6(1)(b) GDPR)
  • Managing incoming payments.Legal basis: Performance of a contract (or pre-contractual measures) (Art. 6(1)(b) GDPR)
  • Managing investments.Legal basis: Performance of a contract (or pre-contractual measures) (Art. 6(1)(b) GDPR)

Categories of data subjects

  • Investors who are natural persons
  • Legal representatives and contact persons of investors that are legal persons

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

Categories of personal data

  • Identification data (e.g. first name, surname, nationality, age, date of birth, facial image)
  • Contact data (e.g. residential address, professional address, email, telephone number)
  • Tax data (e.g. tax code, VAT number)
  • Economic, financial and bank data (e.g. bank details, means of payment, information relating to investments)
  • Data relating to identity documents (e.g. copy of identity documents)
  • Data relating to investments (e.g. investment history, transactions carried out, financial instruments held)

Categories of recipients

  • Insurance companies
  • Lawyers
  • Banks

Processors

  • XION Informatica S.a.s. di Cattivelli & C. (IT services)
  • TLA Studio Tributario e Legale (Accountants and tax advisers)
  • Datev Koinos S.r.l. (Software services)
  • Microsoft Ireland Ltd. (Software services)

Transfers to third countries

Some personal data are transferred to countries outside the European Economic Area (EEA). Below you will find, for each transfer, the party involved, the destination country and the safeguard that makes it lawful:

  • Microsoft Ireland Ltd. (Software services) — United States (safeguard: EU-US Data Privacy Framework)

Microsoft has obtained certification under the EU-US DPF, which is covered by an adequacy decision of the European Commission.

Retention period

The data are retained for the duration of the contractual relationship and, thereafter, for the period needed for administrative obligations and the protection of rights (as a rule 10 years from the end of the relationship), unless there is litigation.

Consequences of not providing the data

Providing the data is mandatory. Without the personal data requested, VAM cannot perform the mandate it has received or manage the investments administratively.