Our Policies

LEGAL INFORMATION

This website is provided by Generali Investments and is considered as a marketing communication and financial promotion related to the products and services of the following companies belonging to the Generali group: Generali Asset Management S.p.A. Società di gestione del risparmio, Generali Investments Luxembourg S.A. and Generali Investments Holding S.p.A. (hereinafter jointly, Generali Investments).

Generali Asset Management S.p.A. Società di gestione del risparmio, is one of the asset management companies 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..

Generali Investments Luxembourg S.A., is one of the asset management companies of Generali Group with its registered office at 4, rue Jean Monnet, L-2180 Luxembourg and subject to the direction and coordination of Generali Investments Holding S.p.A..

Generali Investments Holding S.p.A. is the holding company of the abovementioned asset management companies of the Generali Group with its registered office at 34132, Trieste, 4, via Machiavelli, Italy.

By accessing this Site (the ‘Site‘), you agree to be bound by the following terms and conditions (the ‘Terms‘). Before using this Site, you should read carefully the Terms and also our ‘Privacy and Cookie Policy’.

COOKIES POLICY 

Effective from 30/06/2023

Generali Investments Holding S.p.A. (hereinafter referred to as "Generali Investments" or "Company"), with registered office in Trieste, at Via Machiavelli 4, intends to provide, as the data controller, information to users (hereinafter referred to as "you" or "your") of the website www.generali-investments.com (hereinafter, the "Site") regarding the use of cookies on the Site.

If you wish to contact the Company or to exercise a right regarding the processing of your personal data,, you can use:

  • the postal address: Generali Investments Holding S.p.A., Via Machiavelli 4, 34132 Trieste, or

  • the email address: privacy.GIH@generali.com.

For any questions or to exercise a right regarding the processing of your personal data, you can contact our Data Protection Officer at the following contacts:

  • by regular mail at the address: Generali Investments Holding S.p.A., Via Machiavelli n. 4, 34132 Trieste, attention to the Data Protection Officer, or

  • by email at the address: DPO.GIH@generali.com.

Generali Investments may change this cookie policy from time to time, also following any changes to the applicable regulations. The latest updated version of the document will always be available for consultation on the Site.

 

Definitions

Cookies are typically text strings that websites (so-called publishers or "first parties") visited by the user, or different websites or web servers (so-called "third parties"), place and store within a user's terminal device (so-called "active identifiers"). On each subsequent visit, the browser sends these cookies to the site that originated them or to a different site.

Storing certain information through cookies enables users to navigate online easily and quickly and constitutes the processing of personal data.

Cookies have different characteristics and are used for different purposes. They can be distinguished based on the following three criteria:

 

A. The entity that installs them:

·       First-party cookies: Installed directly by the company that owns the visited website, through the website itself.

·       Third-party cookies: Installed, through the visited website, by third parties other than the company that owns the website.

B. The duration of the period they remain active:

·       Session cookies: Cookies that store necessary information during the browsing session and are deleted when the browser is closed.

·       Persistent cookies: Cookies stored on the user's hard drive, and the website reads them each time the user reconnects to the site. A persistent cookie has a specific expiration date, after which it stops functioning.

C. The purposes pursued:

·       Technical cookies: Used solely for "the transmission of a communication over an electronic communications network, or insofar as this is strictly necessary for the provider of an information society service explicitly requested by the subscriber or user to provide this service" (cf. Article 122, paragraph 1 of Legislative Decree 196/2003 and subsequent amendments). To be installed, they do not require consent as they are strictly necessary for the functioning of the sites.

·       Analytical cookies: Used to obtain statistical information, generally in non-aggregated form, about the number of users accessing one or more sites or using them. To be installed, they require consent as they are not strictly necessary for the functioning of the sites.

·       Profiling cookies: Used to track the profiles of site users to display advertisements on visited sites that may be of interest due to alignment with the tastes and consumption habits of different users. To be installed, they require consent as they are not strictly necessary for the functioning of the sites.

Similar functions can be performed by other tools that, while using a different technology (so-called "passive identifiers"), allow for treatments similar to those carried out through cookies.

Types of Cookies Used by the Site

Generali Investments' website uses both technical cookies and analytical cookies from both first and third parties.

Generali Investments does not aim to track individual users or identify them, but primarily uses cookies to obtain useful information about the ways in which the site is used, with the goal of constantly improving user experience.

In any case, it is possible to avoid the installation of cookies by modifying the settings of the browser in use, as explained in the relevant menu, which is different for each browser. To understand how to set cookies, it is recommended to consult the instructions of the most commonly used browser providers, available at the following links:

Alternatively, you can visit the website www.aboutcookie.org for a comprehensive guide on setting cookies in a wide range of desktop browsers.

A. Technical Cookies

Generali Investments uses technical cookies solely for the purpose of allowing you to visit the site and use its various functions. Specifically, the company uses:

  • Navigation cookies: Ensure the normal use of the site and are generally session cookies that are automatically deleted when the browser is closed.

  • Functionality cookies: Allow you to navigate the site based on a set of selected criteria (such as language or country of origin) to improve the use of the services offered by the site. These are persistent cookies that remain on your computer even after the browser is closed until their expiration date (typically ranging from two months to two years) or until you delete them.

Technical cookies are used exclusively for the purposes described in this paragraph. The site uses the technical cookies listed below.

Cookie table

The installation of technical cookies does not require your prior consent because it is strictly necessary to ensure the correct functioning of the Site.

B. Third-Party Analytical Cookies

The Site uses analytical cookies from Google Analytics, allowing the Company to collect statistical information, exclusively in aggregated form, about the usage of the Site, such as the number of users accessing it and the most frequently visited pages.

The analytical cookies from Google in use do not allow the identification of users since the IP address associated with the cookie is anonymized before being sent to Google. The entire IP address is never collected or stored on either Google's systems or ours.

Below is a list of the analytical cookies currently used by the Site.

Cookie table

The installation of third-party analytical cookies requires your prior consent. To this end, when you access the Site, a banner is displayed informing you that the Site uses third-party analytical cookies. By clicking "Accept," you are providing your free and informed consent to the installation of these cookies. The Company will track your consent through a specific technical cookie, ensuring that consent is not requested again on each subsequent visit to the Site.

You can block the storage of analytical cookies at any time without affecting your ability to visit the Site. To learn how to block the storage of analytical cookies, you can read information about third-party cookies by clicking on the links provided in the table above.

C. Marketing Cookies

The Site uses marketing cookies (also known as targeting cookies) to track users visiting the Site, aiming to present relevant and engaging advertising to individual users, which consequently holds more value for publishers and third-party advertisers.

Below is a list of marketing cookies currently used by the Site.

Cookie table

The installation of marketing cookies requires your explicit consent. To this end, when you access the Site, a banner is displayed, informing you that the Site uses marketing cookies. By clicking "Accept," you are freely and knowingly giving your consent to the installation of these cookies. The Company tracks your consent through a specific technical cookie to avoid asking for your consent again during each subsequent visit to the Site.

You can block the storage of marketing cookies at any time without affecting your ability to visit the Site. To learn how to block the storage of marketing cookies, you can refer to the information on marketing cookies by clicking on the links provided in the table above.

Exercise of Rights:

Even concerning the processing of personal data through the installation of cookies, you can exercise the following rights:

  • Right of Access: You can ask the Company to access your personal data to find out, for example, which data the Company is currently processing.

  • Right of Rectification: You can ask the Company to correct personal data that is inaccurate or incomplete.

  • Right to Erasure: You can request the deletion of personal data under specific circumstances.

You can request the Company to delete your personal data in the following circumstances:

  • Personal data is no longer necessary for the purposes for which it was collected or otherwise processed.

  • You have revoked consent to the processing, or there are no other legal grounds for the processing.

  • You object to the automated processing of your personal data, and there are no other legal grounds for the processing.

  • Personal data has been processed unlawfully.

  • Personal data must be erased in compliance with a legal obligation of the European Union or Italy to which the Company is subject.

  • Personal data has been collected in relation to the offer of information society services.

Right to Restriction: You can request the Company to limit the processing of your personal data in the following circumstances:

  • You have contested the accuracy of personal data, and you request the Company to limit the processing for the period necessary to verify the accuracy of your personal data.

  • The processing is unlawful, and instead of deleting the personal data, you request the Company to limit the processing of personal data.

  • The Company no longer needs to process your personal data for the above purposes, but such data is necessary for the establishment, exercise, or defense of a legal claim.

Right to Data Portability: You can request the Company to transfer the personal data you provided to another company or organization and/or receive your personal data in a structured, commonly used, and machine-readable format.

Finally, if your personal data has been transferred outside the European Economic Area, you have the right to obtain a copy of such data or information about where it has been made available.

These rights can be exercised by contacting the Data Protection Officer at the above-mentioned contacts. The Company will not charge any fees for tasks resulting from your request unless the request is manifestly unfounded or excessive.

 

Right to Lodge a Complaint:

If you detect irregularities in the processing of your personal data, you have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali). You can find the procedures for submitting a complaint on the Authority's website: https://www.garanteprivacy.it/diritti/come-agire-per-tutelare-i-tuoi-dati-personali/reclamo.

Additionally, you have the right to lodge a complaint with the supervisory authority of the European Union member state where you reside, work, or where the alleged violation is assumed to have occurred. The contact details for the supervisory authorities of the European Union member states can be found at the following link: https://edpb.europa.eu/about-edpb/board/members_en.

PRIVACY POLICY

IN ACCORDANCE WITH ARTICLES 13 AND 14 OF REGULATION (EU) 2016/679

1. Which company of the Generali Group will process Your personal data*?

Generali Investments Holding S.p.A., Generali Asset Management S.p.A. Società di gestione del risparmio and Generali Investments Luxembourg S.A. (hereinafter “Generali Investments” or “We”), with registered office in Trieste, Via Machiavelli n. 4, will process* Your personal data as Data Controller* in accordance with Regulation (EU) 2016/679 (hereinafter the “GDPR”).

If You wish to contact Us or exercise a right regarding the processing of Your personal data, You can use the following contact details:

  • Generali Investments Holding S.p.A., Via Machiavelli 4, 34132 Trieste or Piazza Tre Torri 1, 20145 Milan; Privacy.GIH@generali.com.

  • Generali Asset Management S.p.A. Società di gestione del risparmio, Via Machiavelli 4, 34132 Trieste or Piazza Tre Torri 1, 20145 Milan; Privacy.Genam@generali.com.

If You wish to submit any questions on the processing of your personal data to the Data Protection Officer or exercise a right, You can use the following contact details:

  • Generali Investments Holding S.p.A., Via Machiavelli 4, 34132 Trieste or Piazza Tre Torri 1, 20145 Milan, to the attention of the Data Protection Officer; DPO.GIH@generali.com.

  • Generali Asset Management S.p.A. Società di gestione del risparmio, Via Machiavelli 4, 34132 Trieste or Piazza Tre Torri 1, 20145 Milan, to the attention of the Data Protection Officer; DPO.Genam@generali.com.

Effective as from 01/01/2024 

This Privacy Policy provides users (hereinafter “You” or “Your”) of the website www.generali-investments.com (hereinafter the “Website”) with the information on the processing of their personal data, collected by means of the Website, in the context of Your use of the Website and the services available on the Website, under Articles 13 and 14 of the GDPR.

Unless otherwise specified herein, this Privacy Policy does not apply to any other data referred to You, collected by Generali Investments by or through any other means, such as information collected offline and on other websites of the entities of the Generali group that You might access via any link found on the Website.

Generali Investments may provide You with further specific information on the processing of Your personal data, along with the relevant request of consent, if needed. This information may also be provided within other webpages of the Website, in case You should make specific requests to Generali Investments, by providing the latter with Your personal data. Those privacy information notices and consents will be respectively provided and obtained prior to the processing of these further categories of personal data. 

Generali Investments cares about the confidentiality, protection and safety of Your personal data. In order to help You in understanding this Privacy Policy, You can find a glossary on the last page of this Privacy Policy, which includes the definitions of the main terms used herein.

We strongly recommend You to carefully read this Privacy Policy before browsing through the pages of the Website.

We may amend this Privacy Policy, from time to time, also as a consequence of any legal or regulatory changes. However, the updated version of this Privacy Policy will always be available on the Website, to be consulted by You. 

2. How do We process Your personal data and what is the legal basis for the processing of this data?

Generali Investments will process Your personal data (as better identified in Section 4 below) to pursue the following purposes:

a) Ensuring the browsing of the Website, after having selected the criteria for navigation (e.g., investor typology and language) and accepted the relevant terms and conditions, and using the services offered through the Website, including the possibility of obtaining answers to the requests for information or assistance that You should submit to us (hereinafter "Contractual Purposes");

b) Complying with the obligations set forth by applicable laws, including responding to possible requests submitted to us by governmental authorities and supervisory bodies (hereinafter "Legal Purposes");

c) Based on legitimate interest, developing and improving the services offered through the Website, by carrying out statistics on the use of the Website (e.g., analyzing the most visited pages, etc.) and checking its functioning; and

d) Based on legitimate interest, establishing, exercising or defending of legal claims;

e) Based on legitimate interest, management and maintenance of the security of assets, also in order to prevent possible prejudices for Generali AM deriving from abusive access or illicit data processing, commission of crimes, etc., including checks, inspections and internal audits;

f) Based on legitimate interest, assessing the opportunity to proceed with any legal or structural changes to GenAM, mergers, demergers and other extraordinary transactions that may involve GenAM as a whole or partially (the purposes from let. c) to let. F) above are hereinafter jointly referred to as “Legitimate Interest Purposes”);

g) Based on your consent, inviting you to events, meetings, workshops, roundtables, congresses (including professional training), identified as of specific interest to you, organised and managed by the Italian entities of the Generali Investments Network, independently or in cooperation with other entities identified from time to time in the invitations (brochures and/or presentations) that will be previously mailed or delivered to you to allow you to register for the event (hereinafter, respectively, the “Event(s)” and the "Partner(s) in the Event”); executing complementary activities following your registration for the Event, such as, for example, activities related to the organisation and management of the Event itself; if you attend, using your personal images that may have been collected in the course of the Event for possible publication on different (paper, tape and/or digital) supports, or through other means of communication or media, including websites, portals and social networks present on the internet;

h) Based on your consent, sending you newsletters, publications, studies, survey results, market analyses or analyses of specific industries or businesses, and any other type of professional information material, identified as of specific interest to you, prepared or published by the Italian (and, in certain circumstances, foreign) entities of the Generali Investments Network, independently or in cooperation with other entities identified from time to time in the specific document (hereinafter, the “Publications” and “Publication Partners”, respectively).

Moreover, also on the basis of the legitimate interests, your personal data shall be processed for the following purposes:

i) carrying out customer relationship management, consisting mainly in tracing and managing the relationships and interactions that Italian and foreign legal entities of the Generali Investments Network, through the professionals belonging to it, develop with the ‘contacts’ of current and prospective clients, and any other persons/entities with whom/which Generali Investments Network professionals have developed business relationships, for the purpose of understanding their needs and expectations, improving services offered, developing new services based on the market’s requirements, as well as growing the business. For those purposes the personal information of ‘contacts’, including your personal information, will be entered into special data bases owned by or available to Generali Investments and will thus be made accessible to the other Italian and foreign entities of the Generali Investments Network. Where specific obligations of confidentiality or professional secrecy exist, as well as when there are particular reasons of expediency, your personal information will be made available, depending on the circumstances, solely to professionals of the Italian legal entities of the Generali Investments Network (excluding foreign entities), or solely to Generali Investments, i.e. solely to the members of the team of Generali Investments assigned to the specific professional engagement. In any case, it is agreed that you may be contacted, for customer relationship management purposes, only through the professionals who operate within the Italian legal entity of Generali Investments with which you have established the main relationship.

In case Generali Investments wishes to process Your personal data for purposes other than the ones listed above, Generali Investments will prior provide You with any required information under the GDPR, and collect Your consent, where needed. 

Generali Investments does not process Your personal data only based on automated decision-making processes. 

3. Why do We ask You to provide Your personal data?

a) The processing of Your personal data for Contractual Purposes (please see Section 2, let. a), above) is carried out to ensure your navigation, pursuant to art. 6.1, let. b) of the GDPR; it is mandatory, given that otherwise We would not be able to allow You to browse the Website or assist You in relation to Your requests. If you don’t want us to process Your Identification Data (as defined under Section 4, letter a), below), please do not send us a request of information.

b) The processing of Your personal data for Legal Purposes (please see Section 2, let. b) above) is performed to comply with legal and regulatory obligations to which Generali Investments is subject, pursuant to art. 6.1, let. c) of the GDPR; it is mandatory, as it is necessary to enable us to comply with applicable laws.

c) The processing of Your personal data for Legitimate Interest Purposes (please see Section 2, letters from c) to f) above) is based on our legitimate interests, pursuant to Article 6.1, let. f) of the GDPR, which have been adequately balanced with Your interests and rights, as the processing of Your personal data is carried out only to the extent it is strictly necessary to pursue such purposes. However, You may object to the processing of Your personal data, by following the instructions specified under Section 6 below, unless We have an overriding interest on further processing Your personal data or in case the processing of Your data is necessary to establish, exercise or defend of legal claims. 4. Categories of personal data processed

We will process Your personal data only to the extent necessary to achieve the above-mentioned purposes. In particular, We will process the following categories of personal data referred to You: 

a) Data voluntarily provided by You, by submitting to Us any requests for information or assistance by means of the Website or using Our contact details available on the Website. This data might include Your name, surname, address, occupation, job title, employer/associated company, phone number and email address, as well as any other information referred to You that You should provide to Us by requesting information or assistance; (hereinafter jointly referred to as “Identification Data”);

b) Browsing data relating to the use of the services on the Website made by You, such as Your IP addresses or domain names of Your devices, URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the server and other parameters relating to Your operating system and computer environment (hereinafter jointly referred to as "Browsing Data"). This data is automatically collected by means of the cookies* installed on the Website, in accordance with Our cookie policy, which is available at the following link. The collection of the Browsing Data does not aim at matching this data with You and We process this data in aggregate form.

5. With whom do We share Your personal data?

Generali Investments will process Your personal data only to the extent that it is adequate, relevant and limited to what is necessary in relation to the purposes indicated under Section 2 above, by means of electronical and telematic tools as well as hard copies, in such a way as to ensure the security, protection and confidentiality of Your personal data.

In pursuing the purposes referred to in Section 2 above, We may disclose Your personal data to the following categories of recipients:

a) Third party suppliers and companies of the Generali group, to the extent that such entities provide assistance or consultancy services to Generali Investments, including but not limited to technological, accounting, administrative, legal and insurance services;

b) Governmental authorities and supervisory bodies whose right to access to Your personal data is set forth by applicable laws; and

c) To possible purchasers of Generali Investments and other entities resulting from mergers or any other operations affecting Generali Investments.

Your personal data will not be disseminated.

6. Where do We transfer Your personal data?

Where this is necessary to pursue the purposes indicated above (see Section 2 above), Your personal data may also be transferred abroad, both within and outside the European Economic Area.

In particular, Generali Investments’ activities may be supported by a computer network, cloud-based servers and other information infrastructures and technologies also provided by third parties.

In the event that, for technical and operational reasons, our suppliers are located in countries outside the European Economic Area which may not guarantee a level of protection of personal data equivalent to that provided within the European Economic Area, We will verify that the level of protection of personal data is adequately guaranteed through other measures, such as binding corporate rules, standard data protection clauses adopted by the European Commission or on the basis of specific exemptions provided for by the GDPR. Further information on the countries to which personal data are transferred and on the safeguards adopted can be requested by writing to DPO.GIH@generali.com.  

7. The rights You can exercise regarding the processing of Your personal data

According to Articles 15 et seq. of the GDPR, You have the following rights that You can exercise by contacting Our Data Protection Officer:

-        Right of access 

You may ask Generali Investments to access Your personal data in order to know, for example, which personal data referred to You Generali Investments is currently processing.

-        Right to rectification 

You may ask Generali Investments to rectify any personal data referred to You which should be inaccurate or incomplete. 

-        Right to erasure

You may ask Generali Investments to erase Your personal data when one of the following circumstances occurs:

  • Personal data is no longer necessary with respect to the purposes for which it was collected or otherwise processed;

  • You withdrew Your consent on the processing of Your personal data and Generali Investments cannot rely on other legal grounds to process Your data;

  • You have objected to automated decision-making and there are no overriding legitimate grounds for the processing of Your data, or You have objected to the processing of Your data for direct marketing purposes;

  • Personal data has been unlawfully processed by Generali Investments;

  • Personal data has to be erased for compliance with a legal obligation in Union or Member State law to which Generali Investments is subject; and

  • Personal data has been collected in connection with the provision of information society services, referred to in Article 8, paragraph 1, of the GDPR. 

-        Right to restriction 

You may ask Generali Investments to restrict how it processes Your personal data, and requesting only its storage, where one of the following applies:

·       You contest the accuracy of Your personal data, for a period enabling Generali Investments to verify the accuracy of Your personal data;

·       The processing is unlawful and You oppose the erasure of Your personal data and request the restriction of its use instead;

·       Generali Investments no longer needs Your personal data for the purposes of the processing, but this data is required by You for the establishment, exercise or defense of legal claims; 

·       You have objected to processing pursuant to the right to object and automated decision-making, pending the verification whether the legitimate grounds of Generali Investments override Yours. 

-        Right to data portability and Consent withdrawal

You may ask Generali Investments to transfer Your personal data to another company or organization and/or to receive Your personal data in a structured, commonly used and machine-readable format.

If You have granted your consent to the processing of Your data, You may withdraw such consent at any time, without prejudice to the validity of the processing carried out before the withdrawal of Your consent.

If Your personal data has been transferred outside the European Economic Area, You have also the right to obtain a copy of such data or the indication of where it has been made available.

Your rights can be exercised by contacting Generali Investments and/or the Data Protection Officer, by using the contact details indicated above (see Section 1 above). We will not charge You any cost for the tasks resulting from Your request, unless this request is manifestly unfounded or excessive, in which case We might charge you the related costs.

When You exercise Your rights, we might request personal information referred to You, in order to verify Your identity.

8. The right to object to the processing of Your personal data

You have the right to object to the processing of Your personal data and request the stop of the processing operations in relation to the processing of Your personal data that is based on Generali Investments’s legitimate interests (please see Section 2, letters from c) to f) above), by contacting Generali Investments and/or the Data Protection Officer.

9. The possibility to lodge a complaint with the competent Supervisory Authority

In case you noticed any irregularities in the processing of Your personal data, You have the right to lodge a complaint with the Garante per la Protezione dei Dati Personali, based on the modalities indicated at the following website:

https://www.garanteprivacy.it/home/diritti/come-agire-per-tutelare-i-tuoi-dati-personali.

You also have the right to lodge a complaint with the supervisory authority, of the Member State of Your habitual residence, place of work or place of the alleged infringements.

You can find Your national supervisory authority at the following website:*

 https://edpb.europa.eu/about-edpb/board/members_en

 10. How long do we retain Your personal data?

Your personal data will be retained only for the time necessary to pursue the specific purposes for which it was collected, as indicated within this Privacy Policy. In particular:

a) Your Browsing Data will be retained for no longer than seven days and will be erased immediately after being aggregated, except where governmental authorities and/or supervisory bodies should need such data to perform their duties;

b) Your user choices that allow you to browse the Website on the basis of selected criteria (e.g., language or country of origin), to improve the services provided on the Website, will be retained for no more than 2 years or until they are erased by you;

c) Your Identification Data will be retained for no more than 2 years, unless its retention for a longer period is required under applicable laws or to establish, exercise or defend legal claims.

***

GLOSSARY

To help You in understanding our Privacy Policy, please find below the meaning of the main terms contained therein:

Processing means any operation or set of operations which is performed on personal data or on sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction, whether or not by automated means.

Personal data means any information relating, directly or indirectly, to a person (such as, for example, name, an identification number, location data, an online identifier, one or more elements able to identify the physical, physiological, genetic, mental, economic, cultural or social identity, etc.).

Special categories of data means the personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership as well as genetic data, biometric data where they uniquely identify a person, data concerning health or data concerning a person’s sex life or sexual orientation.

Data subject means the person whose personal data are processed.

Data Controller means the individual or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data (for example, the employer is the data controller in respect of its employees’ personal data since, with reference to the employment relationship, it decides the purposes and means of such processing). 

Data Processor means the individual or legal person, public authority, agency or other body which processes personal data on behalf of the data controller (for example, the company which provides the service of employees’ salaries calculation may be considered a data processor since it processes personal data on behalf of another company, the employer). 

Data Protection Officer means a person in charge for performing support activities for the company functions and control activities in respect of the processing of personal data. It is also in charge for cooperating with the Supervisory Authority and it represents the contact point, also for the data subjects, for any matters connected with the processing of personal data 

Garante per la Protezione dei Dati Personali is the Italian data protection supervisory authority.

Cookies are small text files that are sent to Your device (e.g. computer, smartphone, tablet), when You visit a website, where they are stored to be re-transmitted to the same website at Your next visit. If You wish to have more information about cookies, You can consult Our cookies policy.

TERMS AND CONDITIONS

These Terms cover your use of this Site. All products and services provided by members of the Generali Group have their own terms and conditions (the ‘Product Terms’). You must read both the Product Terms and these Terms. To the extent that the Product Terms conflict with these Terms or any local sites’ terms and conditions then the Product Terms will prevail.

Please make sure you read carefully all applicable terms, conditions and disclaimers relevant to your use of the products, services or information that may be offered to you from time to time.

If any part of these Terms is found by any court or other competent authority to be invalid, unlawful or unenforceable then such part shall be severed from the rest of the Terms which shall continue to be valid and enforceable to the fullest extent permitted by law.

CHANGES TO OUR TERMS

The information on this Site is regularly updated. The validity of the information provided on this Site is restricted to the point in time in which it was published and to our assessment at that point in time. Generali Investments does not assume any liability for the correctness, accuracy, suitability, completeness or availability of this Site or the information contained therein. Generali Investments does not assume any responsibility for any loss or damage resulting from the use of the information contained on this Site for any other than its intended purpose. Generali Investments reserves the right to amend or supplement the information on this Site at any time without advance notice.

ABSENCE OF ADVICE

The information contained on this Site does not constitute a recommendation or an offer to persons in countries in which a corresponding offer is not permissible, nor an offer to persons to whom a corresponding offer must not be made or who must not be solicited to buy Units/Shares. Nothing contained on the Site constitutes investment, legal, tax or other advice nor is to be relied on in making an investment or other decision.

INVESTMENT SUITABILITY

A Fund may not be suitable or appropriate for all investors. The information does not take into account individual circumstances, investment objectives, financial situation or specific needs of the investors. The Site does not refer to any particular tax treatment. Tax regimes depend on each potential client’s own circumstances and may be subject to change in the future.

Only investors can decide if the transactions they might engage in are suitable to their own financial situation. The fiscal treatment resulting from an investment in Units/Shares of UCITS depends on the situation of each investor. We recommend that investors consult their usual tax advisor.

Changes in the economic, legal or tax conditions or other events may influence the future development of the market or individual products at any time in a manner other than as described in the information provided on this Site.

ACCESS TO FUND DOCUMENTS

The sole binding basis for the acquisition of Units is the prospectus as amended from time to time and the key investor information and the relevant annual and half-yearly reports (if available) and/or the statutorily required documents, which are made available before an investment decision.

All Fund documents (Prospectus, KIIDs, annual and semi-annual reports) are available in the language required by the country/-ies where the relevant product is registered at www.generali-investments.com .

Paper copies of any Fund documents may be requested from the local agents of your country of residence, free of charge. The list of all local agents is available in any of our Fund prospectuses.

PERFORMANCE FIGURES

Past performances displayed on the Site are not a reliable indicator of future performance and may be misleading. There could have been a fluctuation in returns since the posting of information on this Site.

RISK CONSIDERATIONS

The value of the shares may fall as well as rise and you may not get back the amount initially invested. Investing in a Fund involves multiple risks including the loss of capital.

The net asset value of some classes is subject to a high volatility, which may result in major latent short-term losses.

For more information about the inherent risks of any Fund or sub-fund, please read the latest version in force of the prospectus, the articles of incorporation, the Key Investor Information Documents (KIIDs) and the latest annual and semi-annual report. Please pay attention to the sections of the prospectus related to risks.

COSTS

Please also pay attention to the costs and fees of each Fund, sub-fund and class presented in the KIIDs and in the prospectus.

COPYRIGHT

The User acknowledges explicitly that the given information remains property of Generali Investments and he accepts not to alter it. No part of this website may be reproduced or transmitted for any purpose, in any form or by any means without the express written permission of the copyright owner or its legal representatives. By continuing to browse this website, you are agreeing to the terms set forth in this legal notice.

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.

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© Generali Investments, all rights reserved. This website is provided by Generali Investments and is considered as a marketing communication and financial promotion related to the products and services of the following companies belonging to the Generali group: Generali Asset Management S.p.A. Società di gestione del risparmio, Generali Investments Luxembourg S.A. and Generali Investments Holding S.p.A. (hereinafter jointly, Generali Investments). Moreover, the website may contain marketing communication and financial promotion of products and services of companies part of the multi-boutique platform coordinated by Generali Asset Management S.p.A. Società di gestione del risparmio, and in particular of Infranity, Sycomore Asset Management, Aperture Investors LLC., Plenisfer Investments SGR, Lumyna Investments, Sosteneo Infrastructure Partners SGR and Generali Real Estate S.p.A. Società di Gestione del Risparmio