Privacy Policy
1. Introduction
- use our products or services;
- download documents from the Website (as defined below) and/or in connection with the services offered by Borsa Italiana or subscribe for alerts or newsletters from Borsa Italiana;
- apply for or carry out a regulated role for one of the companies listed on the markets managed by Borsa Italiana;
- by participating to one of our events ;
- visit or register to use https://www.borsaitaliana.it (the “Website”).
- You participate in a Euronext recruitment initiative
- You voluntarily submit your resume to a representative of Borsa Italiana on an ad hoc basis
- You apply for an advertised job
- A recruiter provides your resume or details to Borsa Italiana
- Borsa Italiana finds your CV / details in online searches e.g. LinkedIn
- You are referred to an open position by an employee as part of the Euronext Referral Program.
2. What personal data do we collect?
DEVICE INFORMATION |
We collect information about your computer/device browser via cookies used on Borsa Italiana websites. Please see section 4 and 10 of this Privacy Policy for further information. |
CONTACT AND COMPANY INFORMATION |
This may include general Personal Data about who you are such as your name, your contact details, identification number, your job title and position in a company. |
AML INFORMATION |
This may include your position as a director, officer or beneficial owner of a company, copy documentation confirming your identity (such as your passport or identity card) and copy documentation showing proof of your address and information collected through AML software and screening tools. |
INFORMATION COLLECTED IN CONNECTION WITH LISTING ON OUR MARKET |
This may include information about the issuer of the financial instruments, the board of directors, the management and the shareholders, collected from the documentation filed by the company or from other sources, such as information about criminal offences and convictions, as defined by the listing rules of the marketplace. |
MAR INFORMATION |
This may include general Personal Data about who you are such as your name, your contact details, your job title, identification number, position in a company and reason for being an insider as defined by law. |
MIFID II INFORMATION |
This includes all Personal Data this regulation requires Borsa Italiana to process. |
MIFIR INFORMATION |
This includes all Personal Data this regulation requires Borsa Italiana to process. |
CRM INFORMATION |
This may include your correspondence and communications with us and details of your connections with our staff and of your visits to our premises. |
PUBLICLY AVAILABLE INFORMATION |
This may include information available: (i) on the websites or promotional material of companies or organisations with which you are connected; (ii) in news articles; or (iii) from registries such as the companies registration offices. |
MARKET |
In connection with trading of financial instruments, we may collect your Personal Data from issuers, members, securities registers and public authorities in order to fulfil our legal duties to monitor market activity. |
INFORMATION IN |
We may collect specific information about you so that we may host you at our premises or at any event or seminar which we organise. We may also collect images (such as photographs and video footage) at IPO announcements and other Borsa Italianaevents and CCTV footage when you visit our premises. |
OTHER INFORMATION |
We may also process any Personal Data which you or the company with which you are connected choose to provide us. |
3. How will we use any personal data we collect and on which legal ground?
LEGAL BASIS |
PURPOSE |
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We obtain, collect and process your Personal Data: · to process contract or application between Borsa Italiana and you; · to process applications from the company with which you are connected to list financial instruments (including debt, funds and equities); · to process applications for financial products including Legal Entity Identifiers (LEI), International Securities Identification Numbers (ISIN) and Net Asset Valuations (NAVs); · to review and publish announcements; · to process your application to participate in the IPOready Program; · as part of the programs organized by Borsa Italiana related to the activity of the financial markets (notably Techshare, FamilyShare and issuance of attestations to the training courses attached to them); · provide you with access to Borsa Italiana websites and to enable you to use them; · test and improve the effectiveness of Borsa Italiana websites and to monitor metrics such as numbers of visitors, traffic data and demographic patterns; · to process your application to participate in dedicated programs organized by Borsa Italiana; and · for invoicing, billing and commercial purposes. |
LEGITIMATE INTERESTS We process certain of your Personal Data on the basis of our legitimate interests, such as in pursuit of our business or security interests or in the framework of the execution of a contract with a company with which you are connected. Where we process your Personal Data in pursuit of our legitimate interests we determine if such processing is necessary and we carefully consider the impact of our processing activities on your fundamental rights and freedoms. We will not process your Personal Data where our legitimate interests are outweighed by the impact on your rights and freedoms (unless otherwise required or permitted by law). |
· We obtain, collect and process your Personal Data in order to: · to process contract or application between Borsa Italiana and the company with which you are connected in order for Borsa Italiana to provide with the services subscribed such as but not limited to: o applications from a company with which you are connected to become a Member of Borsa Italiana; o applications from the company with which you are connected to list financial instruments (including debt, funds and equities) on Borsa Italiana; · to process compliance of the company with which you are connected to the provision of the contract signed; · provide you with access to Borsa Italiana websites and to enable you to use them; · test and improve the effectiveness of Borsa Italiana websites and to monitor metrics such as numbers of visitors, traffic data and demographic patterns; · provide you with information (e.g. newsletters, reports, statements and other material which you sign up to receive …); · respond to your enquiries; · conduct market research surveys linked to the services subscribed by the company with which you are connected; · maintain a list of our business contacts; · tailor our services to match your requirements; · create products or services that may meet your needs; · to process your job/candidate application including to contact you in relation to interviews and/or offer you a job after the interview stage or to process any references you provide to us in the context of recruitment; · maintain the security and integrity of our premises, infrastructure and systems, and the safety of our employees, by using security measures including CCTV cameras. |
LEGAL AND REGULATORY OBLIGATIONS |
As a regulated company, we obtain, collect and process your Personal Data to comply with legal and regulatory obligations applicable to Borsa Italiana.
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CONSENT
We may send you direct marketing communications. Where these are electronic communications (email or telephone) we will have obtained your prior consent. In limited circumstances, where we have obtained your explicit prior consent, we may send you marketing communications in relation to carefully selected and relevant third party partners, whose products and services may be of interest to you. You may opt out of certain kinds of marketing, or all forms of marketing, by emailing us at the following address: dpo@euronext.com. Alternatively, you can click on the "opt-out" link provided in all our marketing emails or follow the instructions in the My Account section of the Website.
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Where applicable, we obtain, collect and process your Personal Data on the basis of consent for some specific marketing purposes (i.e. proposal of products & services, invitation to events…). |
4. Analytics
5. Disclosure of your personal data
6. Cross-border transfers of your personal data
7. Modalities of processing of your personal data
8. Retention of your personal data
- Personal Data collected for the mandatory Purposes are retained for the period necessary to the provision of the required product or service, plus a maximum of 10 years from the termination of the account or the termination of the services;
- Personal Data collected for the marketing Purposes are retained for the period necessary to the provision of the required product or service and for the following 2 years;
9. Protection of your personal data
- Access control and network protection mechanism to prevent unauthorized access to our systems;
- SSL/TLS Encryption, hardening, backup and secure configuration of systems;
- Physical security controls on premises where Personal Data are stored
10. Our use of cookies and other tracking technologies
11. Your rights and how to exercise them
RIGHT |
FURTHER INFORMATION |
RIGHT TO BE |
You have the right to know your Personal Data is being processed by us, how we use your Personal Data and your rights in relation to your Personal Data. |
RIGHT OF |
You have the right to ascertain what type of Personal Data Euronext holds about you and to a copy of this Personal Data. |
RIGHT TO |
You have the right to have any inaccurate Personal Data which we hold about you updated or corrected. |
RIGHT TO ERASURE |
In certain circumstances you may request that we delete the Personal Data that we hold on you. You have also the right to give post-mortem instructions regarding your Personal Data. |
RIGHT TO |
You have the right to request that we stop using your Personal Data in certain circumstances including if you believe that the Personal Data we hold about you is inaccurate or that our use of your Personal Data is unlawful. If you validly exercise this right, we will store your Personal Data and will not carry out any other processing until the issue is resolved. |
RIGHT TO |
Where we rely on our legitimate interests to process your Personal Data, you have a right to object to this use. We will desist from processing your personal information unless we can demonstrate an overriding legitimate interest in the continued processing. |
RIGHT TO DATA PORTABILITY |
In case the processing is based on your consent or a contract conclude with you, you may request us to provide you with certain Personal Data which you have given us in a structured, commonly used and machine-readable format and you may request us to transmit your Personal Data directly to another controller where this is technically feasible. |
12. Applicants
- You participate in a Borsa Italiana recruitment initiative
- You voluntarily submit your resume to a representative of Borsa Italiana on an ad hoc basis
- You apply for an advertised job
- A recruiter provides your resume or details to Borsa Italiana
- Borsa Italiana finds your CV / details in online searches e.g. LinkedIn
- You are referred to an open position by an employee as part of the Euronext Referral Program.
- to any and all job applications submitted and recruitment initiatives co-ordinated by Borsa Italiana,
- up to the point at which we decide not to continue the recruitment process with you or when you start working for us (if applicable). On this latter case, the way we process your Personal Data will no longer be dealt with under this Privacy Policy, but will instead be governed by our Data Privacy Notice.
12.1 The personal data we process
PERSONAL DETAILS |
This may include general Personal Data such as your name, gender, residential address, email address, contact telephone numbers, nationality, marital status, etc. |
DETAILS ABOUT YOUR PREVIOUS EMPLOYMENT |
Such as the former company names, length of service, business titles and details on your previous roles. |
QUALIFICATIONS |
Such as your skills, education, the languages you speak (including your level of proficiency), your eligibility to work in a particular country (e.g. minimum legal age to work, citizenship or visa details), your experience in the job you apply for and other industries, etc. |
PREFERENCES |
Such as positions you may be interested in, information about when you may be available to interview and/or start date for Borsa Italiana or work on ongoing basis (e.g. full or part time or on weekends), whether you are open to relocation or working remotely, whether you are willing to travel for work and whether you have your own transport. |
PUBLICLY AVAILABLE INFORMATION |
Details about you which we gather from publicly available sources over the internet and your social media accounts where such searches are relevant to the job you have applied for within Borsa Italiana. |
MEDICAL RESULTS |
Where legally applicable (Italy, Portugal, United Kingdom and Ireland), results on aptitude and/or pre-employment medical tests which we may ask you to undergo after accepting our offer of employment. |
OTHER INFORMATION |
Details you may provide us in response to our queries or questions at interview stage (including information about you which we generate throughout the interview and/or recruitment process), at reference check stage, to complete psychometrics tests (where applicable) or details required where mandatory in the respect of local requirements laws. |
12.2 How and why we process your personal data
LEGAL BASIS |
PURPOSE |
LEGITIMATE INTERESTS
It is necessary to process your Personal Data where it is necessary for the purpose of initiate and facilitating the recruitment process. |
We obtain, collect and process your Personal Data: · to process your job application, including to contact you in relation to interviews and/or offer you a job after the interview stage ; · to assess your Personal Data against vacancies which we think may be suitable for you ; · to request information from third parties such as qualifications and references ; · to carry out background checks which aim to verify details you have provided to us, potentially using third party sources in UK & US. You will be notified in advance of the use of third parties for the background check. · to retain your information in order to contact you in relation to future vacancies within Borsa Italiana may be of interest to you; · to collect feedback on and evaluate the recruitment process ; · to promote internal and external recruitment events such as job fairs, campus events… ; · where legally applicable (Italy, Portugal, United Kingdom and Ireland), to assess if you are fit to work or not fit to work (e.g. where you suffer from a health condition which may affect your work capacity). |
COMPLIANCE WITH A LEGAL OBLIGATION
It is necessary to process your Personal Data in order to comply with legal obligations imposed on us as an employer under applicable Irish and European Union law. |
We obtain, collect and process your Personal Data in order to comply with legal obligations, which may include:
· to comply with European Union employment, equality and health & safety law ; · to comply with European Union Tax Law ; · to comply with other applicable European Union laws ; |
12.3 Disclosure of your personal data
- Internal business units such as Human Resources, IT, Finance/Payroll, Managers, system administrators, our trusted third party service providers and our IT service providers;
- Your previous employers when you have provided them as a reference third parties that may be contacted to provide additional information related to your previous work experiences;
- Recruitment agencies;
- Regulatory authorities;
- Outsourced service providers who assist Borsa Italiana with recruitment initiatives and campaigns such as recruitment agencies, technical test assessment, background check and health assessment companies (where applicable);etc.
- Professional advisors such as legal advisors, consultants and accountants.
12.4 Retention of your personal data
13. Changes to this policy
14. Links
15. Information about the data controller and contact details
- by sending a request to us at dpo@euronext.com
- By sending a letter to the following address:
- By submitting a request through the following form.