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TERMS AND CONDITIONS

You are connected to the website of Generali Investments Europe S.p.A. Società di gestione del risparmio, the Asset Management company of Generali Group with its registered office at 34132, Trieste, 4, via Machiavelli, Italy, registered at the Albo delle Società di Gestione del Risparmio in the UCITS Section, under no. 18 and in the AIF section, under no. 22 and subject to the direction and coordination of Generali Investments Holding S.p.A..

ACCESS TO THE WEBSITE

Visitors of this website shall read carefully the present notice before going any further. Visitors consulting Generali Investments Europe S.p.A. Società di gestione del risparmio Internet website pages agree having read, understood and accepted the content of the present disclaimer. Visitors that do not agree with this disclaimer are required to leave this website.

By accessing this website, Visitors acknowledge having the skills and competence to use this website. The site is available in several languages, however English is the official language.

It is the responsibility of any person connecting to this website to comply with the law of the country in which he/she is resident. That person will bear any direct or indirect consequences resulting from non-compliance with the legal and regulatory requirement. Generali Investments Europe S.p.A. Società di gestione del risparmio cannot under any circumstances be held liable for such violation.

INFORMATION

All material information disseminated on this website is provided solely for purposes of information. This information is published without any guarantee of completeness or accuracy and has no legal, accounting or fiscal value as such.

This website aims to present the activity of asset management of Generali Investments Europe S.p.A. Società di gestione del risparmio. The information provided herein does not constitute in any manner an offer or solicitation to buy or sell any financial instrument.

The various information available on this website, particularly in relation to undertakings for collective investment in transferable securities (UCITS) managed by Generali Investments Europe S.p.A. Società di gestione del risparmio, shall in no way constitute an offer to subscribe or redeem Units of UCITS.

The information available on this website stems from sources considered reliable by Generali Investments Europe S.p.A. Società di gestione del risparmio. However, Generali Investments Europe S.p.A. Società di gestione del risparmio cannot be held responsible for the use of this information and any financial consequences that would arise therefrom.

In no way does this website claim to be a substitute neither for the reader’s personal deliberations nor for his technical and professional knowledge. Hyperlinks to other Internet resources are used at the visitor’s own risk.

PRIVACY AND COOKIES POLICY

The asset manager Generali Investments Europe S.p.A. (hereinafter “Generali Investments”) has always attached the greatest importance to the privacy, protection and security of information, in particular of the personal data of its clients and of parties who come into contact with Generali Investments.

This section sets out the methods used to manage this website (www.generali-investments.com) with regard to processing of users’ personal data. In compliance with art. 13 of Regulation 679/2016 (EU) (“GDPR”), this information is also supplied to parties that interact with the services provided via the internet by Generali Investments (Data controllers).

The information is provided solely for and applies only to the Generali Investments website www.generali-investments.com. It is not applicable to other websites linked to the Generali Investments site. Users who browse our website are not required to provide personal data.

Users are required to provide personal data only if they wish to contact us or request information. In such cases, on a completely voluntary basis, users are required to read the disclosure provided as established by law and to supply only the data strictly required for the processing of their requests.

In compliance with current privacy laws, Generali Investments has adopted a specific policy, which is illustrated below.

Useful information is set out below on active and passive collection of information relating to parties/devices that interact with this website, and on the security measures adopted by Generali Investments.

When a user browses an internet site, it is technically possible to collect information without explicit registration by the user or without the user taking an active role. This type of information collection is known as “passive collection”. Specifically, the section below describes how IP addresses, cookies and other session identifiers, internet tags, and navigation data are used, as well as their possible exclusion and related implications.

With regard to passive information collection, the services offered on this website:

• Do not use IP addresses (internet protocol addresses) to collect information. Nevertheless, the IP addresses are stored among the browsing data.
• Use browsing data only for statistical purposes, in the form of aggregate data.
• Use cookies and other session identifiers only in order to enable browsing. Cookies are not used for statistical purposes. Use of cookies may be disabled, depending on the user’s browser. However, this could make browsing difficult.
• Do not use internet tags.

With regard to active information collection, the services offered on www.generali-investments.com are based on the following guidelines:

• E-Mail: data reaching the website via e-mail are used solely to reply to enquiries from users. They are stored solely for statistical purposes and to check the existence of any previous data. Names may be inserted in specific Mailing Lists only if this is expressly requested by users and only after users have given their consent, in order to receive particular documents on a regular basis (press releases, financial reports, etc.).
• Registration: to access a range of services, users must fill out a specific form. The information is used to reply to requests from the sender and only to supply the services requested.
• Forum(s): If the site includes forum(s), specific rules of conduct will be set out. Data will not be used for other purposes.
• Access to the site: in order to access the internet site, users must indicate their country of residence, the type of investor represented and subsequently accept the related legal notices. The activity is necessary in order to browse the site.
• Data provided voluntarily: data provided voluntarily by the user, for example, name, surname, date of birth, address, etc.

Purposes of processing

The purpose of the processing to be performed is to enable the services requested by the user to be provided.

Processing procedures and nature of conferment

Users’ personal data will be processed by the Company and its designated parties with IT (and manual) systems, in accordance with the principles of correctness, fairness and transparency contemplated by data privacy laws and safeguarding the privacy and rights of the data subject by implementing suitable technical and organisational measures to guarantee a level of security appropriate to the risk.

Data will be processed to pursue the legitimate interest of the Data Controller as envisaged by art.6.f of the Regulation.

Data communication, dissemination and transfer

Data may be transferred inside the European Union where other offices and/or servers of Generali Investments or the Generali Group are present.

Rights of the data subject

In connection with the processing of the data described in this document, the data subject may exercise their rights as contemplated by the Regulation (arts.15-21), including:

• receive confirmation of the existence of their personal data and have access to their content (access rights);
• update, amend and/or correct their personal data (rectification right);
• request erasure of data or limit processing of data processed in breach of the law, including data whose storage is not necessary for the purposes for which the data were collected or otherwise processed (right to be forgotten and right of limitation);
• object to processing (right of opposition);
• revoke consent, where given, without prejudice to the lawfulness of processing based on consent given prior to revocation;
• lodge a complaint with the supervisory authority in the event of breaches of data privacy laws;
• receive a copy of the data relating to them in electronic format and request that said data be transmitted to another data controller (right to data portability).

To exercise these rights, the user may apply to the DPO by sending an email to the following address: PrivacySGR@generali.com

Storage of data

The Data Controller shall process users’ personal data using manual and IT tools, with procedures strictly related to the purposes and, in any case, in a manner that guarantees the security and privacy of the data.

The personal data of users of the website shall be stored for the length of time strictly necessary to complete the illustrated primary purposes or in any case the length of time needed to protect the interests of both the users and the Data Controller under civil law.

If at any time the data subject deems that the purpose of processing by the company is no longer necessary or useful, they may notify the company accordingly so that the data may be immediately erased.

To exercise this right, the data subject may apply to the DPO by sending an email to the following address: PrivacySGR@generali.com

Privacy Data Processors

Privacy Data Processors

This website is available in several languages, however English is the official one. Then visitors accept the delivery of this website in English if other languages are not available.

MIFID INVESTMENT PROFILES

For the purpose of this web-site, Institutional Investor indicates the MiFID category of Eligible Counterparties (ECP). This category receives the lowest level of protection under MiFID and it refers to an entity to which a credit institution or an investment firm provides the services of reception and transmission of orders on behalf of clients and/or execution of such orders and/or dealing on own account:

a. Investment Firms or other investment firms;
b. Credit institutions;
c. Insurance companies;
d. UCITS and UCITS management companies;
e. Pension funds and their management companies;
f. Other financial institutions authorized by a Member State or regulated under Community legislation or the national law of a Member State;
g. Commodity dealers and ‘locals’ on exchanges;
h. National governments and their corresponding offices, including public bodies that deal with public debt;
i. Central banks and supranational institutions.

If such clients are provided with investment advice, they will be treated as Professional clients instead.

It is the responsibility to the subject that enters in the area of the web-site denominated “Institutional Investors” to verify its own quality and the belonging to such category.

For the purpose of this web-site, Professional Investor refers to the entities that are not classified as an Eligible counterparty according to MiFID but who possesses the experience, knowledge and expertise to make its own investment decisions and properly assess the risks.

In order to be considered as a Professional Investor, the client or prospective client shall be:

(i) an entity authorized or regulated to operate in the financial markets, such as:

(a) Credit institutions;
(b) Investment Firms;
(c) Other authorized or regulated financial institutions;
(d) Insurance undertakings;
(e) Collective investment schemes and management companies of such schemes;
(f) Pension funds and management companies of such funds;
(g) Commodity and commodity derivatives dealers;
(h) Locals;
(i) Other institutional investors.

(ii) Large undertakings can also qualify as Professional Investors if they meet at least two of following size requirements on company basis:

1. A balance sheet total of at least EUR 20 million;
2. Net turnover of at least EUR 40 million;
3. Own capital of at least EUR 2 million.

(iii) National and regional governments, public bodies that manage public debt, central banks, international and supranational institutions such as the World Bank, the International Monetary Fund, the European Central Bank, the European Investment Bank and other similar international organizations.

(iv) Other institutional investors whose main activity is to invest in financial instruments, including entities dedicated to the securitization of assets or other financial transactions. The entities mentioned above are considered to be professionals.

This category receives a lower level of protection than Retail clients

It is the responsibility to the subject that enters in the area of the web-site denominated “Professional Investors” to verify its own quality and the belonging to such category.

For the purpose of this web-site, Private Investor indicates the MiFID category of Retail clients. All the clients or prospective clients that do not fall under the classification of Professional Investors or Institutional Investors have to be considered as Private Investors according to this web-site.

This is the classification that offers the most protection and imposes the most requirements in terms of communication, disclosure and transparency.

It is the responsibility to the subject that enters in the area of the web-site denominated “Private Investor” to verify its own quality and the belonging to such category.