Dear Interested Party,
Zest Group (defined below) has great respect for the privacy of Users.
The data that may be communicated through the Site (described below) will be treated with the utmost care and with all the tools necessary to ensure their security, in full compliance with the current legislation placed to protect the confidentiality of data. We wish to inform you that the "European Regulation 2016/679 on the Protection of Individuals with regard to the Processing of Personal Data and on the free movement of such data" (henceforth "Regulation" or "GDPR") provides for the protection of individuals with regard to the processing of data of a personal nature as a fundamental right. Therefore, pursuant to Article 13 of the GDPR, we would like to inform you of the following.
1. WHAT’S ZEST?
Zest S.p.A. (“Zest”) is a company listed on the Italian Stock Exchange's Euronext Growth Milan that invests in innovative startups and offers open innovation services through its subsidiaries Zest Investments S.r.l. and Zest Innovation S.r.l. (the "Subsidiaries") (hereinafter Zest and the Subsidiaries are collectively defined “Zest Group” or “Joint Controllers”).
In particular, the Zest Group provide structural and technical services to support corporations and startups by helping them in their growth and development process. Zest and the Subsidiaries, in accordance with the GDPR Regulations, act as Joint Controllers with respect to the data communicated by Users when browsing the Site.
By accepting the following privacy policy, the User declares that he/she is aware that his/her personal data may also be disclosed to third parties, again for purposes related to the provision of services.
2. GLOSSARY
"Personal Data" any information relating to an identified or identifiable natural person, with particular reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more features of his or her physical, physiological, genetic, mental, economic, cultural, or social identity.
"Zest" is the company Zest S.p.A. - Rome (RM) Via Marsala 29/h, CAP 00185 P.IVA 01932500026 C.F. 81020000022 e-mail: privacy@zestgroup.vc.
"Zest Investments" is the company Zest Investments S.r.l. - Milan (MI) Via Bernardo Quaranta 40, VAT 13467090968, e-mail: privacy@zestgroup.vc.
"Zest Innovation" is the company Zest Innovation S.r.l. - Turin (TO) Corso Giacomo Matteotti, 29 bis, VAT 10766230014, e-mail: privacy@zestgroup.vc.
"Zest Group" refers to the corporate group formed by Zest, Zest Investments, and Zest Innovation acting as Joint Controllers.
"Processor" the natural person, legal entity, public administration and any other entity that processes personal data on behalf of the Zest Group.
"Site" is this website under Zest.
"User(s)" and/or "Data Subject(s)" the individual making use of this Site to whom the Personal Data relate.
3. CATEGORIES OF DATA
Zest Group collects directly from its Users, Personal Data and other information as part of the contact process on the Site (this includes, but is not limited to: e-mail address, first and last name).
The subject of processing may be personal data of Users such as:
a. Data provided in Contact
Zest Group will process personal data that the User provides in order to directly contact one or more of the Joint Controllers. This data is provided directly by the Data Subject and may include contact data, including but not limited to first name, last name, profession, e-mail address and other data voluntarily provided by the User. If the User authorizes it, or even through the use of cookies, Zest Group may store data released by the User. It is understood that the Interested Party will have the right to request the deletion of personal data provided during contact.
b. Automatically collected data
The computer systems and applications dedicated to the operation of the Site detect, in the course of their normal operation, certain data (the transmission of which is implicit in the use of Internet communication protocols) potentially associated with identifiable Users. The data collected include the IP addresses and domain names of the computers used by Users connecting to the Site, the addresses in URI (Uniform Resource Identifier) notation of the resources requested, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc..) and other parameters regarding the operating system, browser and computer environment used by the User, name of the internet service provider (ISP), date and time of visit, web page of the visitor's origin (referral) and exit.
c. Data voluntarily provided by the User
The voluntary and explicit sending of electronic mail to the addresses indicated in the different channels of the Site, does not imply a request for consent and involves the acquisition of the address and data of the sender, necessary to respond to requests, as well as any other personal data included in the message. Such data is understood to be voluntarily provided. By entering a comment or other information, the User expressly accepts this document.
d. Data voluntarily provided by the User to be subscribed to the Newsletter
Within the Site, if the User agrees, Group Zest may collect the User's Personal Data in order to i) keep newsletter subscribers updated about developments on the Site and new services offered by the Group; ii) monitor the interest of subscribers in order to improve the focus of updates; iii) share articles and news related and/or otherwise connected to the world of Venture Capital; iv) learn about any updates related to Zest Group's official partners.
e. Cookie
The Site uses cookies. The data collected through cookies may be used to access parts of the Site or for statistical purposes or to make the browsing experience more pleasant and more efficient in the future, trying to evaluate the behavior of users and to modify the proposition of offering content according to their behavior.
f. Third-party providers
The Site makes use of third party service providers in order to extend the functionality of the Site. It should be noted, as of now by then, that the use of such providers may result in the transmission of Personal Data to a third country. For this reason, the User has the possibility to perform a check on the use of the provider's Personal Data through the following links: i) Mailchimp, https://mailchimp.com/it/ ; ii) Google, https://policies.google.com/privacy?hl=en-US.
4. SOURCE OF PERSONAL DATA
Personal data held by Zest Group are collected directly from the Data Subject through voluntary completion of specific requests in Contact.
5. PURPOSE OF DATA PROCESSING AND LEGAL BASIS
The processing of Users' data has the following purposes and legal basis:
1. Data provided in Contact
Purpose: User request
Legal basis: legitimate interest of the User.
2. Newsletter
Purpose: To send e-mail about news and topics of interest.
Legal basis: consent of the User.
Provider: Mailchimp
3. Site maintenance and improvement
Purpose: Use of aggregated and anonymous data to improve the Site.
Legal basis: legitimate interest of the Joint Controllers.
4. Detect or prevent fraudulent activities
Purpose: To detect, prevent, or stop fraudulent activity on the Site.
Legal basis: legitimate interest of the Joint Controllers and legal obligation.
5. Compliance with court orders
Purpose: To comply with legal obligations.
Legal basis: legal obligation.
6. Automatically collected data
Purpose: To ensure and improve the service experience.
Legal basis: the legitimate interest of the Joint Controllers.
7. Data voluntarily provided by the User,
Purpose: is the purpose inherent in the request for that data entry.
Legal Basis: User Consent.
The provision of Personal Data, for the purposes mentioned in point 1 of this article, is necessary to allow the User direct contact with one or more companies of Zest Group. Therefore, in the absence of the aforementioned data, it will not be possible to take advantage of our collaboration. Consent for the purposes is optional. does not result in any negative consequences for Users' experience.
6. RECIPIENTS OF THE DATA
To the extent relevant to the stated processing purposes, Users' data may be disclosed to Subsidiaries, Third Party Providers, consulting companies, third party technical service providers, hosting providers and IT companies.
If suppliers process personal data on behalf of the Joint Controllers, they will be appointed as data controllers under Art. 28 GDPR.
7. DATA TRANSFER TO A THIRD COUNTRY
Zest Group may share some of the data collected with services located outside the European Union area. In particular, it may take place through social plug-ins and Third Party Provider service. The transfer is authorized and strictly regulated by Article 45(1) of the EU Regulation 2016/679, so it does not require specific authorizations.
8. RETENTION PERIOD
According to the principle of retention limitation (Art.5, GDPR), verification of the obsolescence of retained data in relation to the purposes for which they were collected is carried out periodically.
In particular:
a) automatically collected data are processed, for the time strictly necessary, for the sole purpose of obtaining statistical information on the use of the platform and to check its regular operation, including for security purposes or according to the deadlines provided by the Italian law;
b) the data voluntarily provided by the User will be kept for a period of time not exceeding the achievement of the purposes for which they are processed or in accordance with the deadlines stipulated by Italian law.
9. RIGHTS OF THE DATA SUBJECT
The Data Subject always has the right to request from Zest Group access to his/her data, rectification or erasure of data, restriction of processing or the possibility to object to processing, to request data portability, to revoke consent to processing by asserting these and other rights under the GDPR by simple communication to Zest Group. The Data Subject may in any case also lodge a complaint with a supervisory authority.
The Data Subject may submit the above requests to the following e-mail address: privacy@zestgroup.vc.
10. DATA PROCESSING METHODS
The Personal Data provided by Users will be subject to processing operations in compliance with the aforementioned regulations and the confidentiality obligations that inspire Joint Controllers activity. The data will be processed both with computer tools and on paper media as well as on any other type of suitable media, in compliance with the adequate security measures pursuant to Article 5 par. 1 letter F of the GDPR.
11. FINAL NOTES AND HOW TO UPDATE
The policy is made only for the Site and not also for other websites and/or mobile apps that may be consulted by the User through links contained in this Site. The policy may be subject to change due to the introduction of new regulations in this regard, provided that Users will be promptly informed in such case, the User is invited to periodically check the Privacy Policy to stay updated.
Last updated 28.11.2024