This cookie policy (the “Cookie Policy”) describes the different types of cookies and similar technologies that may be used by Koinos Capital SGR S.p.A., with registered office at Via Fatebenefratelli Saffi No. 9, 20121 Milan, Italy, Tax Code and VAT No. 09900230963, registered with the Companies Register of Milan-Monza Brianza-Lodi, share capital €400,000 fully paid-in, listed under No. 164 of the Register of Asset Management Companies – Section FIA Managers (the “Controller”), on its website (the “Website”).
Koinos Capital SGR S.p.A., with registered office at Via Fatebenefratelli Saffi No. 9, 20121 Milan, Italy, Tax Code and VAT No. 09900230963, registered with the Companies Register of Milan- Monza Brianza-Lodi, share capital €400,000 fully paid-in, registered under No. 164 in the Register of Asset Management Companies – FIA Managers Section (hereinafter also referred to as the “Controller”), in its capacity as controller, is concerned with the confidentiality of your personal data and ensures that it is provided with the necessary protection against any event that may put it at risk of breach.
To this end, the Controller implements policies and practices regarding the collection and use of personal data and the exercise of the rights recognized by the applicable legislation. The Controller takes care to update the policies and practices adopted for the protection of personal data whenever necessary and, in any case, in the event of regulatory or organizational changes that may affect the processing of personal data of data subjects.
A “cookie” is a small text file created by certain websites on the user’s computer when the user accesses a specific site, for the purpose of storing and transmitting information. Cookies are sent by a web server (which is the computer running the visited website) to the user’s browser (Internet Explorer, Mozilla Firefox, Google Chrome, etc.) and stored on the user’s computer; they are then sent back to the website during subsequent visits.
Some operations could not be carried out without the use of cookies, which, in certain cases, are therefore technically necessary. In other cases, the website uses cookies to facilitate and enhance the user’s browsing experience or to allow the user to benefit from specifically requested services.
Cookies can remain in the system for extended periods and may also contain a unique identification code. This allows websites that use them to track the user’s navigation within the website itself, for statistical or advertising purposes, namely to create a personalized profile of the user based on the pages visited and thus display and/or send targeted advertising to the user (so-called Behavioural Advertising).
With the introduction of HTML5, several forms of local storage and similar technologies, such as web beacons, tracking pixels, and transparent GIFs, are available, which can be used to collect information on the user’s behavior, preferences, and use of services.
The cookies used can be divided into four categories:
technical cookies: aimed at managing the website. They allow the website to function and be navigated securely and efficiently;
functionality cookies: facilitate browsing and the service provided to the user based on a series of criteria selected by the latter;
analytics cookies: collect aggregated information on users’ browsing activity in order to optimize the browsing experience and the services themselves;
profiling cookies: create user profiles to send advertising messages in line with the preferences expressed by the same during browsing.
Furthermore, there are additional types of cookies, which can be classified as follows:
Based on duration:
Session cookies: are deleted immediately when the browser is closed;
Persistent cookies: remain stored in the browser for a determined period of time. They are used, for example, to recognize the device connecting to the website, thereby facilitating user authentication.
Based on origin:
First-party cookies: cookies generated and managed directly by the operator of the website on which the user is browsing;
Third-party cookies: are generated and managed by entities other than the operator of the website on which the user is browsing.
For more details, please visit: www.allaboutcookies.org
The Controller provides below the specific categories of cookies used on the Website, their purpose, and the consequence of their de-selection. We constantly update this Cookie Policy to ensure maximum transparency regarding our use of cookies.
This Website also uses third-party cookies, i.e., cookies created by a website other than the one the user is currently visiting. These include cookies resulting from the presence of portions of the visited page that are directly generated by said third-party websites and integrated into the Website, containing content from social networks (Facebook, Instagram, etc.). This occurs because a website may include elements (images, maps, sounds, specific links to web pages of other domains, etc.) that reside on servers different from that of the site being visited.
To view the complete and constantly updated list of third-party cookies, and to enable or disable them, please refer to the "cookie preferences" page.
The processing of information collected by third parties is governed by their respective privacy and cookie policies, to which express reference is made by consulting the aforementioned page.
We invite you to review the consequences resulting from the de-selection of individual cookies, as indicated in the table above.
The processing of personal data is carried out through computerized procedures by specifically authorized and trained internal personnel. These individuals are allowed access to your personal data only to the extent necessary to carry out the processing activities related to you.
The Controller periodically verifies the tools through which your data are processed and the security measures in place, which are regularly updated. The Controller also ensures—also through the individuals authorized for the processing—that no personal data are collected, processed, stored, or retained when not necessary. The data are stored with guarantees of integrity, authenticity, and use for the actual purposes of the processing activities performed.
Where we process your dataDove trattiamo i tuoi dati
Data are stored in digital and electronic archives located within the European Economic Area on servers of third-party companies duly appointed as Data Processors.
How long we process your data
We invite you to review the data retention periods as indicated in the table above.
At any time, free of charge and without any particular formalities for your request, you may:
obtain confirmation of the processing carried out by the Controller;
access your personal data and learn their origin (when the data have not been obtained directly from you), the purposes and objectives of the processing, the data of the subjects to whom they are communicated, the storage period of your data or the criteria used to determine it;
update or rectify your personal data so that they are always accurate and correct;
erase your personal data from the Controller’s databases and/or backup archives, if, among other reasons, they are no longer necessary for the purposes for which they were collected, or if the processing is deemed unlawful, provided that the legal conditions are met; and in any case, if the processing is not justified by another equally legitimate reason;
restrict the processing of your personal data in certain circumstances, for example where you have contested their accuracy, for the time necessary for the Controller to verify their accuracy. You must be informed, within a reasonable time, when the suspension period has expired or the reason for the restriction no longer exists, and thus when the restriction is lifted;
receive your personal data, if provided to or processed by the Controller with your consent and/or if the processing is based on a contract and carried out by automated means, in a structured, commonly used, and machine-readable format, also for the purpose of transmitting them to another controller.
The Controller shall proceed without undue delay and, in any case, no later than one month from receipt of your request. This period may be extended by two months if necessary, considering the complexity and number of requests received. In such cases, the Controller shall inform you within one month of receipt of your request and explain the reasons for the extension. To exercise your rights, please write to: info@koinoscapital.com
How and when can you object to the processing of your personal data?
For reasons related to your particular situation, you may object at any time to the processing of your personal data if it is based on legitimate interest, by sending your request to the Controller at info@koinoscapital.com
You also have the right to request the erasure of your personal data if there is no overriding legitimate reason prevailing over the reason that gave rise to your request.
To whom can you lodge a complaint?
Without prejudice to any other administrative or judicial remedy, you may lodge a complaint with the competent supervisory authority, i.e., the authority that performs its duties and exercises its powers in Italy where you have your habitual residence, place of work, or, if different, in the EU Member State where the alleged violation of Regulation (EU) 2016/679 (GDPR) occurred.
The Controller reserves the right to update this Cookie Policy at any time to reflect, for example,
changes to the cookies we use or for other operational, legal, or regulatory reasons, and invites the
Data Subject to check the latest version available for consultation.
Last update date: August 2025