Privacy Policy
Last updated: October 30, 2025
This policy describes how we process the personal data of users who visit and use the website [https://komplementasgr.com/] (hereinafter, the “Site”).
- Data controller
The Data Controller is
Komplementa Investment Partners SGR S.p.A.
with registered office at Via Camperio 9, 20123 Milan (MI)
Email: komplementainvestmentpartnerssgr@legalmail.it
- Types of data collected
The Site collects the following types of personal data:
a) Data provided voluntarily by the user
Contact form: first name, last name, email address, and any other information included in the message.
This data is used exclusively to respond to user requests.
Modulo di iscrizione alla newsletter: indirizzo email.
Il dato è utilizzato per inviare comunicazioni informative e promozionali, solo previo consenso esplicito dell’utente.
b) Browsing data
While browsing, some information is collected automatically (e.g., IP address, browser type, operating system, time spent on pages).
This data is used anonymously and in aggregate form for statistical purposes, without directly identifying the user.
- Purpose of the processing
Personal data are processed for the following purposes:
Respond to requests sent via the contact form;
Send the newsletter or promotional communications (with prior consent);
Perform anonymous statistical analyses to improve the functioning of the site;
Comply with any related legal obligations.
- Legal basis for processing
User consent (Article 6, paragraph 1, letter a) of the GDPR) for subscribing to the newsletter.
The implementation of pre-contractual measures at the request of the data subject (Article 6, paragraph 1, letter b GDPR) to respond to messages sent via the contact form.
The Data Controller’s legitimate interest in the proper functioning and security of the site.
- Data processing methods and security
The processing is carried out using IT and electronic tools, adopting appropriate security measures to guarantee the confidentiality and integrity of the data.
The data will never be disclosed publicly.
- Data retention
The data sent via the contact form is retained for the time necessary to process the request.
The data collected for the newsletter is retained until the user revokes their consent.
Browsing data is stored anonymously for statistical purposes for a limited period.
- Communication and data transfer
Personal data may be disclosed to service providers strictly necessary for managing the site (e.g., hosting providers, newsletter services).
These entities act as Data Processors and are bound by contractual agreements compliant with Article 28 of the GDPR.
The data is not transferred outside the European Union, unless specifically provided for by the service provider, in which case adequate protection measures are ensured.
- User rights
The user can exercise the following rights:
Access to your personal data;
Rectification or cancellation;
Restriction of processing;
Objection to processing;
Data portability;
Revoke consent at any time.
Requests should be sent to: komplementainvestmentpartnerssgr@legalmail.it
You can also lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).
- Cookie
The Site uses technical cookies necessary for its operation and, if applicable, anonymous analytics cookies.
Profiling cookies are not used.
For more details, see the Cookie Policy.
- Changes to this Policy
The Data Controller reserves the right to modify this policy at any time. Changes will take effect upon publication on the Site.
