Below you will find information on the processing of your personal data related to the use of We Wealth services for investors, including those accessible through www.we-wealth.com or other platforms that may be enabled to provide the same services as the site (hereinafter “Services”). In this notice you will also find the information necessary to exercise your rights under the GDPR, which è the main legislation on the processing of your personal data (EU Reg. 679/2016). Capitalized terms have the same meaning as è given to them in the terms and conditions of the Services.
1. Who is processing your data?
2. What data do we process?
Your contact and account information. We collect and store the personal and contact information you provide to us (first name, last name, e-mail) when you create an Account, when you activate a Service, when you provide details about yourself using the Services, or when you send us requests.
Data on your editorial interests. When you register to receive the newsletter or activate your Account you have the opportunity to indicate your areas of interest so that we have a content offering as close as possible to your needs. We will therefore associate with your Account the areas of interest that you wish to communicate to us. If you do not communicate any of this information to us you will receive We Wealth generalist newsletters and we will not associate any areas of interest with your Account.
Your Investor Profile.If you ask us to put you in contact with one of the Experts we will extract on your behalf, from public and professional databases, information about your real estate holdings, shareholdings and corporate offices so as to provide the Expert you wish to contact with a Profile of yours with information useful for the establishment of a possible professional relationship between you and the Expert. If you avail yourself of our Expert Contact service we will create and send to the Expert your Profile containing your contact information, age of birth, seniority of use of the Services, editorial interests the above, topics of interest to your investment profile, industry sector and company you belong to, type of corporate office held, estimate of your income, estimate of the value of your corporate holdings, type of We Wealth content in which you are interested, geography, type and estimate of the value of real estate properties.
Aggregate wealth and demographic information. After anonymizing personal information, we will use the resulting information to create aggregate analysis and statistics to be used to improve the Services.
Your direct messages. Certain features of the Site allow you to communicate directly with other users with short text messages. These communications are associated with your Account solely to allow you to send messages and read incoming messages.
Your payment and billing information.If you make purchases for products or services, we will use the transaction information to issue an invoice with respect to what you purchased from us and to send you any physical media materials you may have purchased. Your payment instrument or banking information will be processed by payment system operators and will not be disclosed to We Wealth.
Browsing Data. The systems and processes necessary for the operation of the Services acquire certain personal data that are then implicitly transmitted in the use of Internet communication protocols. This is information that is not collected in order to be associated with identified interested parties, but which by its very nature could, through processing and association with data held by us or by third parties, allow us to indirectly identify users (e.g. IP addresses, domain names of computers used by users who connect to the Site, time of the request, numeric code indicating the status of the response given by the server; the addresses in URI - Uniform Resource Identifier - notation of the resources requested, geographical URL encodings) and other parameters relating to the user's operating system and computer environment.
These data, which are not associated with directly identifiable users, are processed, for as long as strictly necessary, for the sole purpose of obtaining anonymous statistical information on the use of the Services and to monitor their regular operation.
Cookies. Cookies are strings of information used as a unique and anonymous identification method stored by your device when you browse the Site to be recognized when you return. They can serve several purposes: to speed up logging in, to recognize you as a registered user, to store your preferences, to make your browsing of the Site faster and more pleasant by storing certain non-personal information, to keep track of your tastes in order to offer you personalized advertisements.
3. Where we get your data and how we treat it
We get the data directly from you. When you access the Site, when you create an Account to access our Services, ask us a question by e-mail or through other communication channels, if you decide to participate in one of our initiatives through the Site. If you do not provide us with your information, we cannot allow you to create an Account, while any data that may be requested beyond what is strictly necessary to activate the Account is optional and failure to provide it will not prevent you from using the Site, but only those features that require you to provide additional data.
In some cases, we may take your data from third parties. With your consent, we will consult public and professional databases to extract the information needed to populate your Profile, as outlined above, in Section 2. This is information typically held by chamber of commerce systems and the land registry, which we query through service providers who specialize in business information. And again, if you choose to use functionality from other platforms (such as Facebook, Google, and LinkedIn) to create an Account, the third party site will transmit to us, with your consent, certain data about you, such as your name, country of origin, and e-mail address.
Your personal data will be processed in a predominantly automated form, through electronic means, with logic strictly related to the purposes indicated in section 4 and for the time strictly necessary to achieve them, through the use of instruments suitable to guarantee their security and confidentiality and in accordance with the GDPR.
4. Why and for how long we process your data
a) To provide you with Services.The processing of your information è necessary to give you access to the Site and its features, to provide all of our Services, to respond to your requests, and to provide you with assistance when you use our Services. Specifically, creating an Account allows you to access all content on the Site, receive Editorial Services and Personalized Content. In cases where it is not necessary to activate your Account to use the Service you have requested, we will need to process your personal information to provide you with such Services through means and channels other than the Site.
La legal basis of this processing is the provision of the Services provided for in the agreement we entered into when you accepted terms and conditions of the Services: it is necessary to process your data to fulfill this agreement and provide you with these Services and to process any pre-contractual requests you may have made prior to the activation of your Account. The period of retention of your data is equal to the period of activity of Your Account, which in any case will be deleted in case of inactivity for 24 months starting from Your last access or action on the Account. In cases where You do not need to activate Your Account to use the Service You have requested, the retention period is equal to the duration of the Service You have requested, where there are no other active Services.
b) To create your Profile to communicate to the Expert. If you wish, you can ask the Experts questions and then be put in touch with them. In order to locate the Expert and allow him or her to properly evaluate your position, we should send him or her your Profile, as explained above, in step 2. If you do not give us permission to collect this information and share it with the Expert, you will not be able to be put in touch with the Expert, but you can continue to browse the entire Site, use the Editorial Services, and browse the Personalized Content.
The legal basis of this processing is your consent, which we will ask you for at the time you request to be put in contact with the Expert. At that time we will ask your permission to create the Profile with the asset information indicated in point 2 and to enrich it with the data about your use of the Site and Editorial Services indicated in the following paragraph. The period of retention is equal to the time it takes to create the Profile and share it with your chosen Expert. We will not retain your Profile information beyond the time necessary to accomplish these activities (unless you give us express consent for additional, separate processing activities using the same information).
c) To track your browsing behavior on the Site and your use of the Editorial Services. If you wish, we may collect data about your browsing of the Site and Editorial Services (including Custom Content) and then aggregate it to your Profile when it is submitted to the Expert. This information is useful for making your Profile more accurate, but if you do not intend to give consent to its collection and sharing with the Expert, you can still be put in touch with the Expert (who will only have access to your Profile asset data, in this case) and continue to browse the entire Site, use the Editorial Services, and browse Personalized Content.
The legal basis of this processing è your consent, which we will ask you for at the time you activate your Account. Before we share this information with the Expert, we will ask you for the consent mentioned in the previous paragraph. The period of retention of this data of yours is 12 months from the time you gave consent (at the time you activate your Account or when we ask you for consent again).
d) To generate, analyze, and send essential information related to your Account. We use your e-mail to send you important information about the status of your Account (for example, whether your account is about to be deactivated in accordance with the terms and conditions of the Services that you have agreed to), the security of the Services, or changes made to the terms and conditions of the Services or this policy. If it is necessary to prevent, investigate, or address threats to the security of our systems, we may use information about your use of the Services, to the extent necessary for that purpose, to alert you to any issues detected and our efforts to resolve them.
The legal basis for this processing is We Wealth's legitimate interest in informing you about your account and its services that you have used and in protecting the integrity of its information systems against threats to their security. The period of data retention in connection with this processing is equal to the period of use necessary to carry out these communications.
e) To prevent or control illegal conduct or to protect and enforce rights. For example, we may use your data to prevent or prosecute torts, violations of our or third parties' intellectual/industrial property rights, or crimes (cyber or other) committed through telematic networks. The legal basis for such processing is We Wealth's legitimate interest in protecting its rights and preventing wrongdoing. The period of retention of your data is equal to the time reasonably necessary to enforce our rights from the time we become aware of the wrongdoing or its potential commission
The legal basis for such processing is the legitimate interest of We Wealth to protect its rights and prevent malfeasance. The period of retention of your data is equal to the time reasonably necessary to enforce our rights from the time we become aware of Of the wrongdoing or its potential commission.
f) To send you commercial communications from We Wealth. Subject to your consent, we may send you commercial communications related to We Wealth's business. For this purpose, we will process your personal data as the data controller.
The legal basis for this processing is your consent, which we will ask you for at the time you activate your Account or at a later time. The period of retention of this data of yours is 24 months from the time you gave consent. If you have also authorized the processing for marketing purposes of your economic, asset and company profile data extracted from public and professional databases, we will use this information to personalize the sending of commercial communications.
g) To send you commercial communications from third parties, particularly our partners. Subject to your consent, we may send you commercial communications related to the activities and services of our business partners identified in this link. For this purpose we will process your personal data, necessary for such sending, as joint data controller.
The legal basis of this processing è your consent, which we will ask you for at the time you activate your Account. The period of retention of this data of yours is 24 months from the time you gave consent. If you have also authorized the processing for marketing purposes of your economic, asset and company profile data extracted from public and professional databases, we will use this information to personalize the sending of commercial communications.
h) To properly manage your administrative position. When you purchase one of the Services for a fee, we will process your data for accounting, administrative and tax purposes, for purposes directly related to our business and required by applicable legal regulations.
The legal basis of this processing is compliance with legal obligations and the period of storage is equal to that required by regulations (particularly civil, tax, anti-money laundering, banking and public security security).
i) To give feedback to your requests collected Social Pages. We will use your data to give feedback to your requests received through our Social Pages, either as public comments and as private messages.
The legal basis for this processing is the performance of a contract to which the data subject is a party or the performance of pre-contractual obligations, and the period of retention is equal to the time necessary to comply with the data subject's requests. If the request is unrelated to the establishment of an Agreement with us, we will respond to such requests in pursuit of our legitimate interest in making We Wealth known to users of the Social Pages.
5. Where your data are processed
Your data is processed and stored with us, at the address above, and with our suppliers, with whom We Wealth has entered into data processing agreements that comply with Article 28 of the GDPR, which oblige all of these suppliers to process your data in a secure and appropriate manner, with the same level of security as we do for your data. All of our providers process in your data within the European Union. We Wealth does not transfer your data outside of the European Union unless we have the safeguards set forth in Articles 44-49 of the GDPR and the additional measures set forth by the European Data Protection Board.
If you would like to learn more about this information, you can contact us in the manner indicated in Section 7 below to ask for the details you deem necessary regarding where your data is processed.
Exclusively with regard to the data collected on our Social Pages, the same will be stored on the aforementioned platforms, according to the privacy policies of the latter, which we invite you to consult.
6. Who are the recipients of your personal data
Your information is accessible to We Wealth's employees, contractors and consultants. These persons have written authorization from We Wealth, which gives them necessary and appropriate instructions to process your personal data, which is accessible only to those who must necessarily process it in pursuit of the purposes set out above, in section 4.
Outside We Wealth, we may share your data:
With the Experts: these are professionals to whom we may send your personal contact information and Profile if you wish to be put in contact with them. Once we receive your data these experts may process it as autonomous data controllers.
With We Wealth Partners: these are companies that have commercial synergies with WeWealth and who, with your consent, may receive your contact details from us and then send you their proposals, in their capacity as autonomous data controllers.
With service providers. We Wealth uses third-party services for activities of storage, processing and protection of personal data and for activities to develop and update its own technologies or support of its customers, such as service providers cloud, connectivity;, maintenance, customer care or technical assistance.
These entities is all operating in the EU - come into possession only of the personal data necessary to the performance of their functions and may use it only for the purpose of performing such services on our behalf or to fulfill legal requirements. The updated list of third-party providers, operating as data processors pursuant to Article 28 GDPR, is available by contacting We Wealth by the methods; indicated in section 7 below.
Where necessary, solely to resolve issues of a technical nature, allow consultation of your information by entities located outside the EU, we will implement the safeguards set forth in Articles 44-49 of the GDPR and the additional measures set forth by the European Data Protection Board.
With judicial or administrative authorities. Where we believe we must do so to comply with an order of the court or an authority, or to comply with legal obligations or in order to protect judicially We Wealth, or third parties, we may disclose your data to the Judicial Authority or to an Administrative Authority.
7. Your rights
You can contact We Wealth to request access to your personal data, rectification,
deletion of the same or restriction of the processing (if you believe that the processing should be
suspended pending investigations), to object to processing (for example, in cases where we
we pursue a legitimate interest of ours) and to request portability of your data; you can also
withdraw consent at any time, in cases where there is processing based on the
consent (this will not affect processing based on consent given prior to this
When you exercise your right of access, you have the right to know whether there is ongoing processing of your data, what is the purpose of the processing, what categories of data are being processed, who are the recipients or the categories of recipients to whom your data are disclosed (and, if they reside in a third country, on the basis of what guarantees), the retention period of your data (or the criteria for determining the retention period), whether any automated processing is taking place (e.g. through profiling) and what the logic of such processing is, the origin of the data (if not collected initially by We Wealth).
You have the right to lodge a complaint with the Data Protection Authority and to request from We Wealth, at any time, information about the data controllers and the parties authorized by the data controller to process your data.
You can exercise your rights by contacting We Wealth at the above addresses or by writing to email@example.com.
8. What do we do if we change this policy
We may make changes to our notice: we will notify you in connection with such changes as required by the GDPR and we will also post an updated version on the Site. It will have a different date than indicated below. Please check the Site periodically for the updates.
Date updated: 05/10/22