Privacy notes


Generali Real Estate SpA, like its parent company Assicurazioni Generali SpA, has always paid maximum attention to confidentiality, protection and safety of the information it processes, especially when they relate to personal data of clients and counterparties the company interacts with.
 
This website’s User is therefore invited to consult the Privacy notes in advance. They illustrate the company’s guidelines with regard to personal data protection.
 
The website management as far as the treatment of users’ personal data is concerned is analyzed hereafter. This information is given in accordance with art. 13, Legislative Decree 196/2003 (Codice in materia di protezione dei dati personali, Personal Data Protection Code) to whomever interacts with the services provided via internet by Assicurazioni Generali, owner of the treatment.
 
The information is given and valid for the Generali Real Estate SpA’s website only. It does not apply to other websites the user might access via link.
 
Navigation through this website for consultation purposes does not require the submission of any personal data. Nevertheless, technologies are used to archive certain data relating to instruments available to the User. The said technologies are described hereafter.
 
The User is asked for personal data only if He/She wants to contact Generali Real Estate SpA or take advantage of its advice. In such occasions – which are by all means discretionary – the User, after having consulted the information required by law, might provide the data that are necessary to fulfil the task(s) He/She has requested.
 
In order to ensure that the in-force privacy laws are fully complied with, Generali Real Estate SpA has set up a specific governance which is described hereafter.
 
Information on the modalities of active and passive collection of information relating to individuals and instruments interacting with this site, as well as on the safety measures, are disclosed hereafter.
 
When navigating through the internet website, it is technically possible that – even without explicit registration by the User and/or His/Her active role – information is collected. This collection is therefore defined ‘passive’. In particular, the ways in which IP addresses, Cookies and other session IDs, Internet Tags and navigation data are processed are described hereafter along with the possibility to exclude them and relating implications.
 
As regards the passive collection of information, the website:
  • Does not utilize IP addresses to collect information although memorizes them within navigation data;
  • Utilizes navigation data for statistical purposes as aggregates;
  • Utilizes cookies and other session IDs with the sole purpose to enable navigation or to the extent they are necessary to provide the service requested by the User in accordance with Legislative Decree 69/012 and the European law on personal data protection in electronic communications services available to public. To these ends, no agreement is required. Cookies are not used for statistical purposes. Depending on the User’s browser, cookies might be disabled. In such case, navigation might be impaired;
  • Does not utilize Internet Tags.
As regards the active collection of information, what follows applies to the services offered on www.generalirealestate.com:
  • E-mails: Data provided via e-mail contacts included in the website are used with the sole aim of replying to the User’s enquiries; those data are archived for statistical purposes only and to verify the existence of any precedent;
  • Single names might be included in specific mailing lists only upon explicit request by the User willing to receive certain documents (e.g. news) on a regular basis;
  • Registration: To access certain services, the website requires data acquisition through a dedicated form. These data are used with the sole aim of replying to the User’s enquiries or providing the requested services;
  • Discussion forums: Should the website include forums, specific participation rules must be defined; data shared within forums won’t be used for other purposes.
For institutional reasons, Generali Real Estate SpA manages third parties’ personal data and, in doing so, adopts every necessary measure to ensure confidentiality and safety of the managed data, in line with the guidelines of the parent company Assicurazioni Generali SpA, the technological progress in general and the IT progress in particular.
 
Generali Real Estate SpA complies with the in-force law on personal data protection and, accordingly, has set up the following governance.
 
What follows applies to the passive collection of information.
 
The Company is the owner of the treatments. Its Managing Director is in charge of the application of the corporate privacy law.
 
The Human Resources & Organization function has been nominated as ‘Responsible for replying to whomever expresses interest in exercising the rights as per article 7’ with the task of serving as the inbound and outbound privacy interface. Anyone interested in exercising their rights to access and obtain any further information on privacy can contact the Human Resources & Organization function at ‘Ufficio Risorse e Organizzazione – Generali Real Estate SpA – Piazza Duca degli Abruzzi 1 – 34132 Trieste – Fax 0039.040.6799500’.
 
To ensure the compliance with the law and the guidelines spread across all the organization’s functions, the following areas of Privacy Responsibility have been identified:
  • Human Resources & Organization
  • Real Estate Services Procurement
  • Administration and IT Services
  • Property
  • Facility
  • Building
The officers who manage personal data have been nominated as Appointees for the treatment; they’ve been given specific instructions and a continuous training and learning project is dedicated to them.
Due to specific technical and organization needs, the Company relies on third parties to carry out parts of its process. Those subjects might assume the role of Appointees or Responsible for the Company’s treatments. Alternatively, they might operate autonomously as separate Owners of subsequent treatments with the same purposes of the Company.
 
The Company acquires data only if and when they are strictly necessary to provide the requested services or fulfil the tasks they were collected for. Sensitive data are managed with particular care – they are managed only when anonymous treatment is made impossible following a case-by-case evaluation.
 
The Company manages personal data and, in doing so, adopts the necessary physical and digital safety measures in accordance with the Privacy Code and the Technical Procedural Document attached.
 
After the treatments’ completion, the Company deletes the managed data or renders them anonymous unless it is required to hold them by law.
 
The above-mentioned Human Resources & Organization function can be contacted by anyone who is interested in personal data and, in particular, in order to:
  • Know if any personal data relating to Him/Her exist and, if so, get the intelligible communication of the said data;
  • Be informed about the origin of any personal data, the purposes and modalities of their treatment as well as the approach adopted in case of electronic instrument-aided treatment;
  • Get the list of recipients or categories of recipients which receive communication of the data or might get in contact with the data in their capacity as Responsible or Appointees;
  • Request the update or correction of the managed data and, in case of law-infringing treatments, their deletion, transformation into anonymous data or ban;
  • Deny, in part or in full, the treatments of their personal data for legit and commercial purposes. 
GLOSSARY
 
  • IP Address: ID code that identifies the User’s computer and is assigned by the internet provider. It is not considered as personal data because it is often dynamically assigned – it changes from time to time depending on the connection. It is used for diagnosis and optimization purposes by the provider.
  • Cookies: Short strings of IT records. They are sent by the service provider’s server to the User’s computer attached to an ID that enables future activation. Thanks to cookies, the User’s computer and navigation preferences can be identified when the User accesses the website again. Cookies can be temporary (they are cancelled when the session terminates and are used to optimize navigation) or permanent (they are archived in the User’s hard disk unless the User deletes them; they can record a wide range of information which can be retrieved later by the service provider for several purposes). By adequately setting the browser, the User can control how to use cookies (e.g. Internet Explorer allows Users to opt for full activation, activation with pre-emptive alert and User’s consent, or cancellation).
  • Internet Tags: Strings shorter than cookies which are mainly used to record technical data such as the IP and the User’s browser. They are also known as ‘invisible GIFs’, ‘clear GIFs’, ‘1-by-1 GIFs’, ‘single-pixel GIFs’.
  • Navigation data: Files archived in the provider’s server, also known as ‘log files’, ‘clickstream data’, ‘server logs’. They can automatically record data relating to the connection for purposes such as accounting and administrative activities and the User’s profile analysis (e.g. system management, browser type, date and time of visit, images and texts the User clicked on, purchases, file downloads, screen settings) with the aim to improve website content.
  • Registration: Users are asked to fill a form with several personal data, which can be mandatory or discretionary, to fulfil a specific task. Depending on the services provided, the registration can entail contractual obligations. A specific disclaimer must be provided to the User when registering. If necessary, the User’s consent must be asked for.
 

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