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PRIVACY POLICY

  1. Purpose of processing and consequences if you refuse to provide your personal data
  2. Methods and Legal bases for processing
  3. Disclosure of your personal data to third parties
  4. Transfer of personal data outside the European Union
  5. Maintaining of personal data
  6. Data Controller and Compliance Officer
  7. Your rights

Welcome to our website www.viteos.com (the Website). Your privacy and the security of your personal data are very important to Viteos Fund Services LLC .. That is why we are collecting and managing your personal data with the utmost attention and are adopting specific measures to keep it secure. Below you will find the main information about Viteos’s processing of your personal data in relation to your navigation of www.viteos.com and to the use of the services offered. For detailed information on how Viteos Fund Services LLC manages your personal data, we ask that you carefully read this document. Some services may be subject to specific legal terms, in which case we will give you all the appropriate information in each instance. 

WHO IS THE CONTROLLER?

The Website www.viteos.com is powered by HubSpot, Inc., with head office at 25 First Street, 2nd Floor Cambridge, MA 02141, United States ("Hubspot"), which acts as an independent processor of personal data for all marketing-related activities. Viteos Fund Services LLC., with registered office at 80 Cottontail Lane, Suite 430 Somerset, NJ 08873 (Viteos Fund Services LLC .) acts as an independent data controller for the purposes of marketing, profiling and sharing your data, whenever you provide your consent to such processing. Below is the main information regarding how Viteos Fund Services LLC processes your personal data. For any clarification, request or requirement related to your privacy and to the processing of your personal data, you may contact us at any time by sending a request to our Customer Care or by writing to the address of the registered office of Viteos Fund Services LLC.. If you wish to do so, you may also contact our Compliance Officer (CO), by writing to the aforementioned address, or via email to compliance@viteos.com. 

WHAT DATA DO WE PROCESS AND WHY?

The personal data that Hubspot processes is the information that you provide when you complete the a form or request information, and the information that we collect while you navigate or when you use the services offered on www.viteos.com and related websites. Hubspot may thus collect data concerning you, for example, contact information such as first and last name, company name, email address, IP address, phone number and navigation data. Viteos Fund Services LLC processes, with your consent, the data that you provide to us when you wish to receive promotional information or communications from Viteos Fund Services LLC or from other group companies. Viteos Fund Services LLC also processes data related to your interests, when you provide your express consent to record your interests and preferences so they can be used to create group and individual profiles ("profiling") which are used to send personalised communications, and to conduct market research and statistical research with anonymous data, organised in aggregate form. Your personal data is processed for the following purposes:

In the aforementioned cases, the processing of your personal data is lawful to the extent needed to provide you with the service/materials you have specifically requested. However, we will only process your personal data with your express consent for:
WHO WILL PROCESS YOUR DATA?

Your personal data is processed by personnel who have been duly instructed by us and by other companies in the Viteos Group and, for organisational and functional requirements related to the provision of services on www.viteos.com, by our providers. The latter have been evaluated and selected by Viteos Fund Services LLC and by Hubspot for their proven expertise and reliability. Some of these parties may also be based in non-EU countries and, in these cases, the transfer of your personal data in these countries is carried out in compliance with the guarantees provided by law.

FOR WHAT PERIOD OF TIME DO WE KEEP YOUR DATA?

We keep your personal data for a limited period of time, which depends on the purposes for which it was collected; after such period, your personal data will be deleted or nevertheless rendered irreversibly anonymous. The retention period for the data used to send you our materials until you request that we stop sending it to you is nevertheless kept for a period of no more than 60 months.

WHAT ARE YOUR RIGHTS?

At any time, depending on the specific processing, you may: revoke your consent to processing, find out what personal data is in our possession, its source and how it is used, ask that the data be updated, corrected or supplemented as well as, in the cases provided for by the current provisions, have it deleted, limit its processing, or oppose it. If you wish, you may ask to receive the personal data in the possession of Viteos Fund Services LLC in a form that can be read by electronic devices and, where technically feasible, we can transfer your data directly to a third party you have indicated. If you believe that the processing of your personal data has been carried out illegally, you can submit a claim to one of the supervisory authorities responsible for compliance with the rules on personal data protection.

PRIVACY POLICY- GENERAL REGULATIONS ON PERSONAL DATA PROTECTION - "REGULATIONS"

Viteos Fund Services LLC (“Viteos ") as data controller informs you as follows regarding the processing of your personal data pursuant to Art. 13 of EU Regulation 2016/679 on personal data protection ("Regulations"). 

1. PURPOSES OF PROCESSING AND CONSEQUENCES SHOULD YOU REFUSE TO PROVIDE YOUR PERSONAL DATA

Purposes that require data processing to perform marketing - profiling - sharing of data with the Viteos Group companies, with your consent (which is optional), Viteos uses your personal data for marketing purposes, i.e. to send you promotional newsletters, sales, or advertising communications on events, promotional and sales initiatives of Viteos , market research and satisfaction surveys, in addition to performing statistical analyses with anonymous data that has been organised in aggregate format. The marketing activities are completed by e-mail, newsletter, telephone call via operator, sms, chat, social networks and traditional mail, including the sending of invitations to events organised by Viteos or in which Viteos participates. You may at any time indicate the contact method you prefer of those noted above, or may oppose receiving promotional communications through all or just some of the aforementioned communication methods. With your consent (which is optional), Viteos, at its websites or Viteos accounts on social media, collects information relating to your preferences, practices, interests, in order to use it to create group and individual profiles ("profiling") which are used to send personalised communications and to perform market research and statistical research with anonymous data, which is organised in aggregate form. The personalised marketing activities are completed by e-mail (newsletter), phone, sms, chat, social network and traditional mail, including invitations to events. You may at any time indicate the contact method you prefer from among those noted above, and you may oppose receiving promotional communications through any or all of the communications methods listed above. With your consent (which is optional), Viteos uses your personal data for the purposes of sharing it with the companies of the Viteos group, in order to conduct marketing activities on their behalf, i.e. to send you promotional newsletters, sales or advertising communications about events, promotional and sales initiatives for companies in the Viteos group, market research and satisfaction surveys, in addition to performing statistical analyses with anonymous data, organised in aggregate form. Marketing activities are carried out by e-mail, newsletter, telephone calls through operators, sms, chat, social networks, and traditional mail, including sending invitations to events organised by companies in the Viteos Group or in which the companies of the Viteos Group participate. You may indicate at any time the contact method you prefer from among those noted above and you may oppose receipt of the promotional communications through all or some of the communication channels noted above. For the marketing, profiling and data sharing activities Viteos uses data such as your title, first and last name, e-mail address, company name, IP address, phone number, participation in events organised by Viteos, or in which Viteos participates. It is optional to provide your personal data for the aforementioned purposes of marketing, profiling and data sharing, and any refusal to do so shall have no effect on your registration with the website. 

2. METHODS AND LEGAL BASES FOR THE PROCESSING

Viteos processes your personal data with or without the aid of electronic instruments, based on logic and procedures that are consistent with the purposes indicated below and in accordance with the Regulations, including the confidentiality and security terms. You may provide the data when registering with the website www.viteos.com or when you interact with our digital initiatives (websites, social media), or during events that are organised by Viteos Group or in which Viteos Group participates. In accordance with the Regulations, the personal data concerning you that is acquired from you in each instance or from authorised third parties is used to update and correct the information that was previously collected. Viteos processes your personal data based on the following criteria of legitimacy:

3. COMMUNICATION OF YOUR PERSONAL DATA TO THIRD PARTIES

The personal data is accessible to our duly authorised personnel based on criteria of need and is communicated to third parties in the following cases:  (i) when the communication is required by law and applicable regulations with respect to legitimate third parties who receive the data, such as public entities and authorities for the respective institutional purposes; (ii) communication to third parties in case of extraordinary operations (eg. mergers, purchases, disposal of business, etc.) Your personal data is also shared with our service providers, e.g. for services of a technical and organisational nature which are functional for the purposes indicated above, such as independent associates, including partners, e.g. companies that manage our website, companies specialised in market research or data processing, advertising companies, etc. We provide these parties with the data needed to perform the services agreed to and they act as Data Processors, based on the instructions they receive from Viteos. Viteos does not disclose your data to third parties for them to be able to use it for their own marketing or profiling purposes. 

4. TRANSFER OF PERSONAL DATA OUTSIDE THE EUROPEAN UNION

Aforementioned parties are established outside the European Union, in countries that may not provide an adequate level of personal data protection according to the standards established by the Regulations. Viteos takes the necessary precautions for data to be lawfully transferred (e.g. through implementation of the Standard Contractual Clauses approved by the European Commission). You may request information regarding the transfer abroad of your personal data at any time by contacting Viteos or Viteos 's Compliance Officer at the addressed indicated below. 

5. MAINTAINING OF PERSONAL DATA

The personal data processed for the purposes of marketing, profiling and sharing data with companies of the Viteos Group the data is kept for the period of time that is strictly necessary to achieve the aforementioned purposes, within the limits granted by the Regulations. In particular, your data will be processed for a period of 60 months for marketing purposes. You may request that your data be deleted for such purposes and oppose the processing of data for marketing purposes at any time. 

6. DATA CONTROLLER AND DATA PROTECTION OFFICER

The Data Controller is Viteos Fund Services LLC ., with registered office at 80 Cottontail Lane, Suite 430 Somerset, NJ 08873, United States. The Data Protection Officer is domiciled at the registered office of the Controller and may be contacted at the following e-mail address: compliance@viteos.com 

7. YOUR RIGHTS

You may contact Viteos in its capacity as Data Controller or the Compliance Officer at the addresses indicated above for an updated list of our data processors (i.e. our service providers), the parties to whom the data is disclosed and to exercise your rights per Art. 15 et seq. of the Regulations at any time; to obtain confirmation of whether or not your data exists, to check its content, source, accuracy, to request that it be supplemented, updated, corrected, deleted, anonymised, to request that it be transferred, that processing be limited, to oppose processing for legitimate reasons, e.g. opposing marketing activities, or to submit a claim to the Supervisory Authority (the Personal Data Protection Authority).


PDF of the VITEOS Policy for Prevention and Redress of Sexual Harassment at workplace