Identity and Contact Details of the Data Controller
21 Invest S.p.A. (hereinafter also referred to as “21” or the “Data Controller”), with its registered office at Borgo Camillo Benso Conte di Cavour 38, 31100 Treviso (TV), Italy, may be contacted at the following email address: privacy@21invest.com or by telephone at +39 0422 316611.

Purposes and Legal Bases of the Processing
A. To verify the proper functioning of the services and thereby enable website browsing
The computer systems and software procedures used to operate this website acquire, during their normal operation, certain personal data whose transmission is inherent in the use of Internet communication protocols.
This category of data includes IP addresses or domain names of the computers and devices used by users, the URI/URL (Uniform Resource Identifier/Locator) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's response (successful, error, etc.), and other parameters relating to the user’s operating system and IT environment.

B. Statistics
Information is collected to understand how visitors interact with the website in order to generate statistical analyses and improve the performance and usability of the site.

C. To respond to communications submitted through the published contact details
When a visitor contacts the Data Controller using one of the contact details made available on the website, the information voluntarily provided by the visitor is collected and processed for the purpose of handling and responding to the request.

D. Defence Purposes
The Data Controller may need to process personal data for the establishment, exercise or defence of legal claims, including the management of disputes, complaints, and judicial or extrajudicial proceedings.

Legal Basis for Processing (General Personal Data)

Purposes	Legal Basis
A	Performance of a contract
B	Consent
C	Performance of pre-contractual measures; The Data Controller’s legitimate interest in responding to requests received.
D	The Data Controller’s legitimate interest in establishing, exercising or defending legal claims.

Cookie
Some of the purposes listed above may be pursued through the use of tracking technologies (cookies). For further information, visitors may consult the dedicated section: “Cookie Policy".

Retention Period

Purposes	Retention Period
A	Please refer to the information provided in the Cookie Policy section.
B	Please refer to the information provided in the Cookie Policy section.
C	For the time necessary to process the requests received and any subsequent communications related thereto.
D	10 years from the final resolution of the dispute.

Nature of the Provision of Data and Consequences of Refusal

Purposes	Nature	Consequences
A	Mandatory	Inability to access and use the website.
B	Optional	Inability for the Data Controller to carry out statistical analyses.
C	Mandatory	Inability to receive the requested information.
D	Mandatory	Inability to manage the dispute or legal proceedings.

Categories of Recipients
All data collected and processed may be disclosed to authorised internal personnel, to the extent necessary for the performance of their respective duties, as well as to the following categories of external recipients, in connection with the specific purposes of processing described above

Purposes	Categories of External Recipients
A	Third parties other than the Data Controller as specified in the “Cookie Policy” section
B	Third parties other than the Data Controller as specified in the “Cookie Policy” section.
C	Related platforms and software providers; companies belonging to the same corporate group.
D	Law firms; Judicial Authorities.

As personal data are also processed through IT systems and electronic tools, they may be accessible to individuals responsible for the maintenance and support of such systems, to the extent strictly necessary for the performance of their activities.

Transfer of Personal Data to a Third Country or an International Organisation

Purposes	Country	Legal Basis for the Transfer
A	Please refer to the information provided in the Cookie Policy section.
B
C	NO
D	NO

Rights of Data Subjects
The individual to whom the personal data relates is entitled to exercise the following rights:

• Access: You have the right to obtain confirmation as to whether or not your personal data are being processed and, where that is the case, to access such data and request a copy thereof.
• Rectification: You have the right to request the updating of your personal data, the correction of inaccurate data, and the completion of incomplete data.
• Erasure: You have the right to obtain the erasure of your personal data where the relevant legal conditions are met (for further information, please contact the Data Controller).
• Restriction of Processing: You have the right to request that your personal data be marked and its processing restricted where the relevant legal conditions are met (for further information, please contact the Data Controller).
• Objection: You have the right to object to the processing of your personal data, on grounds relating to your particular situation, where the processing is based on the Data Controller’s legitimate interest or is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller.
• Data Portability: You have the right to receive the personal data provided to the Data Controller in a structured, commonly used and machine-readable format and to transmit those data to another data controller, where the processing is based on consent or on a contract and is carried out by automated means.
• Withdrawal of Consent: Where processing is based on consent, you have the right to withdraw your consent at any time. Such withdrawal shall not affect the lawfulness of processing carried out prior to the withdrawal.

The rights that may be exercised in relation to the specific processing activities carried out are as follows:

purposes	Access	Rectification	Erasure	Restriction of Procesing	Objection	Data Portability	Withdrawal od Consent
A	X	X	X	X		X
B	X	X	X	X		X	X
C	X	X	X	X	X
D	X	X	X	X	X

To exercise the rights described above, Data Subjects may use the form available at:
https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/1089924
and submit it to the following contact details: privacy@21invest.com or 21partners@legalmail.it.

Data Subjects may also use the same contact details to request further information regarding the processing activities described above (e.g., the legitimate interest balancing test or the list of Data Processors).

Data Subjects also have the right to lodge a complaint with a supervisory authority. In Italy, the competent supervisory authority is the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali) (www.garanteprivacy.it).