Data Privacy and Personal Data Protection Policy

Personal data protection
Generali Investments, družba za upravljanje, d.o.o. (Generali Investments – Management company LLC) pays particular attention to data protection, and handles them with due care, responsibility and in compliance with applicable regulations. We respect your right to privacy and therefore process data in a manner protecting your interests, fundamental rights and freedoms. We process personal data lawfully, fairly and in a transparent manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures. Before processing your personal data, we carefully assess the proportionality of the intended processing and any positive or negative impact on you or your rights in terms of personal data protection.

Legal basis
The legal basis for personal data processing is:
– Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation),
– Personal Data Protection Act,
– Investment Funds and Management Companies Act,
– Electronic Communications Act,
– Prevention of Money Laundering and Terrorist Financing Act,
– tax regulations, and
– any other regulations governing personal data processing and/or protection.

The Controller
The Controller is Generali Investments – Management company LLC, Dunajska cesta 63, 1000 Ljubljana (hereinafter: Generali Investments). Access to your personal data and the right to their processing for specified purposes is granted only to authorised employees of Generali Investments and carefully selected contractual processors that provide sufficient guarantees, including the security of processing, and have signed an agreement on personal data processing committing to the same standards of personal data protection as applied by us.
Generali Investments designated a data protection officer, with the following contact: dpo@generali-investments.si.

Personal data
Personal data means any information relating to a natural person, i.e. name, surname, tax number, e-mail, and any other data based on which a person can be identified or to whom personal data refer.
You are obliged to provide to us true, correct and complete personal data as well as any changes to your personal data.

Purposes of personal data processing
We process your personal data on the basis of our business relationship with you (subscription form, agreement), on the basis of the law, on the basis of our legitimate interest and on the basis of your consent.
The processing of personal data for purposes other than those for which the personal data were initially collected is allowed only where the processing is compatible with the purposes for which the personal data were initially collected, or where required by applicable regulations.
We will not transmit your personal data, except in cases required by the law, to any third party without your written consent. As a rule, we process your personal data within the EU and the European Economic Area (“EEA”). In certain cases, we also transmit your data to users outside the EU and the EEA, in which case the same level of personal data protection will be ensured as if the processing were carried out by yourself, and all regulatory requirements relating to the transfer of personal data to third countries will be respected.

Processing based on a contract
We process your personal data in connection with conducting our services (management of the Generali Umbrella Fund subfunds), with the purpose of meeting our obligations arising form our business relationship with you.
Upon entering into a business relationship (by signing a subscription form or an agreement), we request from you all data we are legally obliged to obtain from you. Unless you transmit to us all necessary data, we will request you to do so, and if you decline we reserve the right to not enter into or to terminate a business relationship with you. Upon concluding a business relationship or subsequently, you can provide to as on a voluntary basis any other data not specifically required when we enter into a business relationship. In certain cases, we can obtain certain data from third parties or from public records and in accordance with the regulations.
Before entering into a business relationship, we can process the data you transmit to us to set up contact with respect to advisory services, to determine your financial profile, to advise you on appropriate products, or to inform you about our offer.

Processing on the basis of the law
We process personal data on the basis of various laws for the purpose of meeting legal obligations, for purposes imposed by regulations (e.g. in the area of tax, prevention of money laundering and terrorist financing, etc.).

Processing on the basis of legitimate interest
We can process your personal data where this is necessary for the purpose of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. Legitimate interests are our interests connected with the conduct of our activities in a friendly and safe manner, and in compliance with legal requirements. Processing on the basis of legitimate interest is grounded on impact assessment, by which we define our legitimate eligible interest and assess any overriding interest of the data subjects over the legitimate interests of the Company.
The legitimate interests pursued by the Company are development, advertising and offering of savings products and services, business process improvement, compliance, business and data processing security, better tailoring of our offer, and improved user experience.

Processing on the basis of consent
Personal data may be processed on the basis of your freely given consent. By giving consent, you consent that your personal and other data collected in the framework of performing our services and in other forms of interaction (e.g. including information collected via web browsers) are collected, stored and used for specified purposes. We obtain data directly from you or from other sources (social networks, websites or other public sources), or data are transmitted to us by our contractors commissioned by us to collect personal data or to perform surveys or market surveys. If your consent is incomplete, you allow us to enter into our database the missing data available to us from other subscription, transaction or sales documentation.
By way of your consent, you can specify one or several of the following purposes of personal data processing:
– direct marketing (e.g. information about promotional activities and targeted (segmented) marketing, e.g. sending news, articles, our own magazines, event invitations, offers, promotional material, cards, newspapers and prize competitions),
– surveys and market research for our needs,
– statistical processing,
– profiling, monitoring of customer’s purchase behaviour (including in past periods) on the basis of past activities, processing and receipt of messages and benefits intended and specifically individualised for you.

Consent is in particular intended for the purpose of our product and service development, tailoring of our offer, improvement of user experience, receipt of communications from the Company, and assistance in financial decisions. Your consent does not affect any previously given approval or consent we might have obtained from you before, unless they are contradictory. Notifications on the basis of consent are carried out through communication channels you selected when giving consent

Processing in the framework of the Generali Bonus Club
If you are a Generali Bonus Club member, we process your personal data together with the co-founder, GENERALI zavarovalnica d. d., in accordance with the Generali Bonus Club rules.

Storage period
Storage periods for personal data differ depending on the type and purpose of personal data processing. Certain data are stored for 10 years or longer after the termination of a business relationship or transaction completion. Data based on free consent are stored until withdrawal. A longer period of storage may be prescribed by the law.
We store personal data processed for one-off events (conferences, meetings, lectures, prize competitions, visits and trips) in accordance with applicable laws and rules of specific events, or until withdrawal of consent.
If we receive a request to delete data, we will execute the request by restricting data processing only to purposes arising from applicable regulations or our internal rules.
If personal data are anonymised, i.e. they can no longer be related to an identified person, such data may be stored and processed without a fixed storage period.

The rights of the data subject
We exercise your rights regarding personal data processing without undue delay, and no later than within one month of receipt of your request. We can extend the deadline to exercise your rights by two further months, of which we will inform you within one month of receipt of your request, together with the reasons for the delay.
You have the following rights with regard to your personal data:
– the right to consultation or the right to access to your data,
– the right to rectification of inaccurate data. We reserve the right to request from you documentation showing the relevant changes;
– the right to a transcript and a copy your data. You have the right to one free copy of your personal data in electronic or printed form. For any further copies, we may charge a reasonable fee based on administrative costs;
– the right to restriction of processing due to reasons of law,
– the right to object to processing and the right to erasure of data,
– the right to be informed about rectification, erasure and restriction of processing,
– the right to the provision of a list of users to whom, when, on what basis and for what purpose your personal data were transmitted,
– the right to information about the purpose of processing and the type of personal data processed, and all necessary explanations in this respect, including all relevant information about the source when personal data are not collected from the data subject,
– the right to obtain an explanation in case of automated decision-making with personal data processing,
– the right to lodge a complaint with a supervisory authority if you think the processing violates applicable laws.
If you have given your consent freely, you can always withdraw or modify your consent, without the withdrawal impacting the lawfulness of processing carried out on the basis of consent prior to its withdrawal. You can arrange this at our headquarters or offices, or by sending an e-mail to nasvet@generali-investments.si. We are available for any further explanations at 080 80 24.
If you are an Generali Bonus Club member and withdraw the consent you have given freely for the purpose of direct marketing, your withdrawal will automatically mean you have ceased to be an Generali Bonus Club member.
Generali Investments is not liable for any disclosure of personal data or identity fraud as a consequence of insufficient protection of your own personal data or hardware and other equipment where your personal data is stored, by you or any third party.

The right to lodge a complaint
If you consider that your rights have been infringed with respect to your personal data processing, you may lodge a complaint by sending it to Generali Investments, d.o.o., Dunajska cesta 63, 1000 Ljubljana, or by e-mail to dpo@generali-investments.si.

If you consider that data processing is an infringement of the applicable laws, you also have the right to lodge a complaint with the supervisory authority. The supervisory authority is the Information Commissioner of the Republic of Slovenia, https://www.ip-rs.si.

Members of the Generali Bonus Club
You can find provisions on personal data processing for members of the Generali Bonus Club here: https://www.generali-klub.si/sl/informacije-o-obdelavi-osebnih-podatkov.

Amendments to the Privacy Policy
This Privacy Policy may be amended or supplemented at any time. You will be informed about any amendments on this website, and by e-mail in the event of substantial amendments with an impact on personal data processing.