Privacy Policy

Below you will find information on the processing of your personal data related to the use of We Wealth services for investors and professionals, 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 you need to exercise your rights under the GDPR, which is the main legislation on the processing of your personal data (EU Reg. 679/2016). Capitalized terms have the same meaning as given to them in the terms and conditions of the Services.

1. WHO IS PROCESSING YOUR DATA?

We, Voices Of Wealth s.r.l. (“We Wealth”) collect and process your personal data to provide you with the Services and for the other purposes you see in Section 4. We do this as a data controller (or co-processor, as noted in Section 4) and are located at Via Vincenzo Monti, 52, 20123 Milan: you can contact us here or by writing to [email protected]. The Data Protection Officer (“DPO”) can be contacted at [email protected]. Limited to the data collected through our pages on X, Facebook, Instagram, YouTube and LinkedIn (“Social Pages“) we are co-owners of the processing of your personal data, as published within these platforms, with the operators of these platforms. Please review their privacy policy for more information.

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, email) 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 about your professional characteristics. In the case of a professional user, we collect and use information about your professional profile, your work experience, your current and potential areas of specialization and expertise, your membership in professional registers or particular categories of professionals, when you register on our Site, when you request activation of one or more Services, and when you use these Services.

Data about your editorial interests. When you register to receive editorial updates/newsletters or activate your Account, or again when your Commercial Offer includes Editorial Services you have the option of indicating 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 touch with one of the Experts (e.g., by filling out the Your Advisor form with your information such as your first name, last name, telephone, city, e-mail address, and information in the message you send us). If you make use 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 i mentioned in the previous point,.

Aggregate wealth and demographic information. After anonymizing your personal information, we will use the resulting information to create aggregate analysis and statistics to be used to improve the Services.

Your personal 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 some personal data that is 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 the time strictly necessary, for the sole purpose of obtaining anonymous statistical information on the use of the Services and to check 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 in order to be recognized when you return. Find more information about cookies in the cookie policy.

3. WHERE WE GET YOUR DATA AND HOW WE PROCESS IT

We take data directly from you. When you log in to 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, or even when you join one of our campaigns to, for example, obtain informational materials, download a topic guide, sign up for an event. If you do not provide us with your data, we cannot allow you to create an Account or to provide you with any of the various services requested, while any data that may be requested beyond those strictly necessary to activate your Account are optional and failure to provide them will not prevent you from using the Site, but only those features that require you to provide additional data.

Your personal data will be processed in a predominantly automated form, through electronic means, with logic strictly related to the purposes indicated in point 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 editorial content. The processing of your contact information, Account and editorial interests is 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/newsletters/editorial content. In cases where it is not necessary to activate your Account in order to use the Service you have requested, we will need to process your personal data to provide you with such Services, possibly through means and channels other than the Site. 

The legal basis for this processing is the provision of the Services provided by the agreement we entered into when you agreed to the terms and conditions of the Services: we need to process your data to fulfill this agreement and provide you with these Services and to fulfill any pre-contractual requests you may have made prior to activating your Account. The retention period 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 36 months starting from Your last access or action on the account. 

We may also provide You with the aforementioned content if You log in through one of the Social Media and exclusively request said content or even if You fill out a form to request informational material/download a subject guide or to sign up for one of our events and consequently to receive editorial content and/or informational material and/or editorial content and/or newsletters. In such cases we will only use the information necessary to make such content available to you, i.e. your name and e-mail address or other information you provide to us. The legal basis for such processing is your request to stay updated, through filling out the dedicated form, as well as to enable you to obtain the requested content/topic guide or to be registered for an event. 

The retention period of your data is equal to the time necessary to provide you with the requested service, for example, to enable you to attend the event you have registered for or to provide you with the requested topic guide. On the other hand, with regard to the provision of editorial content, the retention period of your related data is equal to 36 months from the time you gave your consent or from your last interaction with us and/or with the email communication you received containing said editorial content.

(b) To get in touch with the Experts. If you wish, you can ask questions of the Experts and then be put in contact with them. We will process your personal contact information and information contained in your questions on the Site – or in contact requests otherwise provided by our Services – to locate the Expert. In order for the Expert to properly assess your position and tailor his or her advice, we will need to send him or her your Profile, as explained above, in Step 2.

The legal basis for this processing is the provision of the Services provided for in the agreement we entered into when you agreed to the 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 requests you may have related to Expert Contact. The retention period for this data of yours 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 create aggregate analytics and statistics. After removing the association between your personal information and the demographic, economic and statistical data we need, we will create aggregate analysis documents to improve our Services.

The legal basis for this processing is We Wealth’s legitimate interest in improving the quality of its Services. The retention period of this data from you for this purpose is as long as necessary to anonymize the information we need to create the above analysis and statistics.

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, if we detect problems in the registration process or your account is about to be deactivated in accordance with the terms and conditions of the Services that you have agreed to), about the security of the Services, or about changes made to the terms and conditions of the Services or to this policy. If it is necessary to prevent, investigate, or address security threats to our systems, we may use information about your use of the Services, to the extent necessary for that purpose, to notify you of 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 data retention period in connection with this processing is equal to the duration of your Account.

(e) To prevent or control unlawful conduct or to protect and enforce rights. For example, we may use your data to prevent or prosecute torts, violations of our own 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 retention period for your data is equal to the time reasonably necessary to enforce our rights from the time we learn of the wrongdoing or its potential commission.

(f) To properly manage your administrative position. When you purchase any of the Optional Services, we will process your data for accounting, administrative and tax purposes, for purposes directly related to our business and required by applicable law. The legal basis for this processing is to comply with legal obligations and the retention period is as long as required by the regulations (particularly civil, tax, anti-money laundering, banking and public safety regulations).g) To acknowledge your requests collected Social Pages. We will use your data to acknowledge your requests received through our Social Pages, either as public comments or 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 retention period is equal to the time necessary to fulfill the data subject’s requests. If the request is unrelated to the establishment of an Agreement with us, we will respond to such requests to pursue our legitimate interest in introducing WeWealth to users of the Social Pages.

(h) To send you commercial communications about the WeWealth world. Subject to your consent, we may send you commercial communications about the activities of WeWealth and its partners. For this purpose, we will process your personal data as 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, for example when filling in dedicated forms/registering for an event. The retention period for this data of yours is 36 months from the time you gave consent or from your last interaction with us, your Account and/or the marketing communication you received. 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.

(i) To send our Partners your personal data. If you authorize us to do so, we will send your personal data (in particular, first name, last name, email address and in some cases also your corporate role and the company to which you belong) to the Partners specifically identified at this link, from time to time, so that they can send you commercial communications in accordance with the terms of the privacy policy that these Partners will make available to you. The consent we will ask you for, in the case, will relate exclusively to the sending of your personal data to our Partner. The legal basis for this processing is your consent, which we will ask you for when we propose to share your information. The retention period of this data of yours for this processing purpose is the time strictly necessary to send it to our Partner.

(j) To send you our daily/weekly newsletter. Subject to your consent, we may send you our daily/weekly newsletter. 

The legal basis for this processing is your consent, which you can give by entering your email address in the appropriate banner. The storage period for this data of yours is 36 months from the time you gave your consent

K) To enable you to request registration for our events and related participation. Within the dedicated section of the Site available here https://landing.we-wealth.com/eventi-we-wealth/ , upon creation of an Account, you can request participation in one of the events organized by us. Subject to the additional purposes, related legal bases and additional retention periods related to Account creation and explained in this policy, your data will be processed in order to enable you to participate in the event and allow your registration. The retention period of your personal data is equal to the time necessary to enable acceptance of your registration and related participation in the event.

In addition, with your consent, we may publish your name among the participants of the event, with the possibility of being contacted and contacting other participants of the event within a restricted area dedicated only to the participants of the individual event. The retention period for such further processing is limited to the duration of the event itself. You may revoke your consent at any time by contacting WeWealth, but this will in no way affect the processing carried out by WeWealth prior to such revocation.

Finally, where a catering service is also organized as part of the event, we may collect information about your food intolerances and/or allergies in order to offer you a dedicated menu. The legal basis for such processing is your consent, which will be deemed given at the time you provide us with such information. The storage period is for the duration of the event. You may revoke your consent at any time by contacting WeWealth, but this will in no way affect the processing carried out by WeWealth prior to such revocation.

5. NATURE OF THE PROVISION OF PERSONAL DATA

For the purposes a) to g) in the previous paragraph, the provision of data is necessary. 

For the purposes from h) to j), the provision of data is optional in nature; a refusal will not be prejudicial. You may revoke your consent at any time by contacting WeWealth or by following the instructions in the e-mail you receive, but this will in no way affect the processing carried out by WeWealth prior to such revocation.

6. WHERE YOUR DATA IS PROCESSED

Your data is processed and stored with us, at the address above, and with our suppliers, with whom We We Wealth has entered into personal data processing agreements that comply with Article 28 of the GDPR, which oblige all such suppliers to process your data in a secure and adequate 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 the European Union, except under the safeguards of Articles 44-49 of the GDPR and the additional measures provided by the European Data Protection Board. If you want to learn more about this information, you can contact us in the manner set out in Section 7 below to ask for the details you feel are 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.

7. WHO ARE THE RECIPIENTS OF YOUR PERSONAL DATA

Your data is accessible to We Wealth’s employees, contractors and consultants. These persons have written authorization from We Wealth, which gives them the necessary and appropriate instructions to process your personal data, which are accessible only to those who must necessarily process it in pursuit of the purposes set out above, in point 4.

Outside of We Wealth, we may share your data:

With 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, subject to your consent. Once these experts receive your data they may process it as autonomous data controllers.

With We Wealth Partners: these are companies that have business synergies with WeWealth and, with your consent, may receive your contact information from us and then send you their proposals, as autonomous data controllers.

With service providers: We Wealth uses third-party services for personal data storage, processing and protection activities and for activities to develop and update its own technologies or support its customers, such as cloud service providers, connectivity, maintenance, customer care or technical support.

These parties come into possession only of the personal data necessary for the performance of their functions and may use it only in order to perform such services on our behalf or to comply with legal regulations. The updated list of third-party providers, operating as data controllers under Article 28 GDPR, is available by contacting We Wealth in the manner indicated in Section 7 below.

Where it is necessary, solely to resolve issues of a technical nature, to allow your information to be accessed 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 in order to comply with a court order or authority, or to comply with legal obligations or in order to judicially protect We Wealth, or third parties, we may disclose your information to the Judicial Authority or an Administrative Authority.

8. YOUR RIGHTS.

You can address We Wealth to request access to your personal data, rectification, deletion of your personal data or restriction of processing (if you believe that processing should be suspended pending investigation), to object to processing (for example, in cases where we pursue a legitimate interest of ours) and to request portabilitỳ of your data; you can also withdraw consent at any time, in cases where there is processing based on consent (this will not affect processing based on consent given prior to this withdrawal). When you exercise your right of access, you have the right to know whether your data are being processed, what the purpose of the processing is, what categories of data are being processed, who the recipients or categories of recipients are 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. by profiling) and what the logic of such processing is, the origin of the data (if not initially collected by We Wealth). You have the right to lodge a complaint with the Data Protection Authority. You can exercise your rights by contacting We Wealth at the above addresses or by writing to [email protected] 

You can also exercise your rights, in relation to the processing of personal data carried out through our Social Pages, by contacting them directly in accordance with their respective privacy policies.

9. WHAT 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 also post an updated version on the Site. It will have a different date than the one shown below. Please check the Site periodically for updates.

Last Updated: April 17, 2026