Privacy and Cookie Policy

Privacy Policy
This Privacy Policy is intended to describe the purposes and methods by which Fondo Porta Nuova Isola and Fondo Porta Nuova Varesine, Data Controllers (“Fondo” or “Controller”) by way of Residenze Porta Nuova S.r.l. (“RPN”), in the capacity of Processor which deals with marketing the properties, process your personal data collected via the website (“Website”) when you interact with the Website and with the different services offered by the same.

The information contained in this Privacy Policy is provided in accordance with Art. 13 of Regulation EU 2016/679 (“Regulation”), as well as the Measures issued by the Data Protection Supervisory Authority and the Guidelines of the European Data Protection Board.
The information on data processing is provided only for the Website and does not extend to processing carried out by third parties on other websites that may be consulted by you via links. With respect to that additional processing, the Controller does not accept any liability; your must refer in that regard to the individual Privacy Policies of the third party websites.

1. Controller and place of processing
The Data Controllers, each in relation to the personal data connected to the properties and services under its remit, are Fondo Porta Nuova Isola and Fondo Porta Nuova Varesine, both based in Piazza Gae Aulenti 12, 20154, Milan. The data are mainly processed by RPN in the capacity of Processor and by entities authorised within the territory of the European Union.

2. Data processing methods
Your data are processed adopting all appropriate security measures to prevent unauthorised accesses, as well as the unauthorised disclosure, modification or destruction of the data. The processing is carried out using both IT and/or electronic tools, with organisational methods and logics strictly related and limited to the indicated purposes.

3. Purpose of data processing and legal basis of processing
RPN, through the Website and on behalf of the Controllers, may process your data for the following purposes:

a. Contact the Company. You may contact RPN to request information and advice on the Residences, using the contact details indicated on the Website, and to ask to make an appointment even by way of the specific pages. In this regard, the personal data provided voluntarily by you (e.g. email address, any telephone number and/or other information provided spontaneously by you) will be processed by RPN, as Processor, and by the Controller of reference to accept, manage correctly and respond to communications and/or requests received from you, including requests to be recontacted to make an appointment. The legal basis of processing is represented by the execution of the service expressly requested by you, and any refusal to provide the personal data involves the impossibility for RPN and the Controller to manage and respond to communications or requests for information.

b. Receive information and notifications on properties of the Funds. You may choose to be informed of the properties in which you are interested by email. To that end, your consent to receive communications will be requested; that consent may be freely provided by affixing a specific and optional flag.

c. Pursuit of the legitimate interests of the Controllers and/or third parties. Your data may also be used to exercise the rights and legitimate interests of the Controllers and/or third parties (including RPN), for example, the right of defence in court, the handling of claims and litigation, credit recovery, prevention of fraud and/or unlawful activities. In these cases, although the provision of your personal data is not mandatory, it is, however, necessary as those data are closely connected and instrumental to the pursuit of those legitimate interests, which do not prevail over your rights and fundamental freedoms, and any refusal to provide them could involve the impossibility of carrying out the requested services (e.g. requesting information).

d. Fulfilment of legal obligations and/or applicable obligations. The personal data provided by you or otherwise acquired during your interaction with the Website may be used for purposes related to the execution of obligations of laws, regulations, and national and Community legislation, as well as deriving from provisions imparted by authorities legitimated to do so by law, which represent the legal basis of processing, without the need to obtain your prior consent.

e. Carry out aggregate statistical analyses on an anonymous basis to improve the performances and services offered by the Controllers and by RPN via the Website. In this case, no consent will be requested from you, as the processing will only be carried out on anonymous data.

f. Sending of informative and commercial communications by RPN as autonomous Controller. Subject to your consent, the Controllers may communicate your personal data and contact details to RPN for the implementation, by the same and in the capacity of autonomous data controller, of marketing activities such as sending, by email, informative and promotional material on properties not owned by the Funds. In this case, the legal basis of processing is your specific consent, which may be freely provided by affixing a specific and optional flag; any failure to provide the data will not in any way prevent you from using the services offered by the Website.

4. Categories of data subject to processing
The Website may collect information relating to you if you visit the pages of the Website and use the web services available on the same. In particular, the following information may be collected and processed.

4.1 Data collected by browsing and by cookies
When you visit the Website, it collects some data, such as pages viewed, connections or buttons clicked by you, date and time of access, IP address, browser and operating system used (known as “browsing data”). The browsing data may, by their very nature, allow for you to be identified also by way of processing and association with data held by third parties. However, these data are used for the sole purpose of obtaining anonymous statistical information on use of the Website for purposes strictly related to the functioning of the same. The browsing data may also be used to assess liability in the event of any IT crimes in detriment to the Website.
Secondly, in relation to the collection of your data through cookies and similar technologies, please visit the Cookie Policy.

4.2 Data provided voluntarily by you
The collection of data is limited to information provided voluntarily by you and those necessary to pursue the purposes illustrated in paragraph 3 above and the services expressly requested. In addition, additional personal data may be collected and processed, if the same are provided voluntarily by you as part of the services offered by the Website, for example, if you contact the Controllers and/or RPN to report disservice or malfunctioning, to exercise your rights in relation to personal data processing, etc. Those data will be processed only for purposes strictly linked to your request. Any failure to provide the data may involve the impossibility of obtaining the requested service.

5. Communication of data to third parties
The data provided by you as well as those collected by the Website as part of the respective services (e.g. IP address) will not be disseminated and may be communicated, for the purposes and by the methods illustrated in this Privacy Policy, to the categories of entities listed below:

• companies assigned to manage the properties of the controllers and which act on behalf of them, including companies forming part of the Coima platform, for administrative-accounting purposes, to pursue the legitimate interests of the Controllers and/or third parties, and for purposes of executing the services expressly requested by you;

• companies, collaborators, consultants or freelance professionals used by the Controllers and/or RPN to carry out duties of technical or organisational nature (for example, providers of IT services), or with which they collaborate (including the other Coima Companies), for purposes of providing and ensuring the functioning of its services, or for any communication activities;

• persons, companies or professionals firms that provide assistance and consulting activity to the Controllers and/or to RPN, with particular but not exclusive reference to accounting, administrative, legal, tax and financial matters;

• entities to which the right to access the data is recognised by legal provisions or orders of the authorities.
The entities belonging to the categories indicated above will use the data in the capacity of autonomous controllers in accordance with the law or processors duly appointed on behalf of the Controllers.
The list of entities to which the data are or may be disclosed can be requested from the Company by using the details indicated in the “Rights of Users and Contact Details” section.

6. Data retention
The data are processed for the time necessary to carry out the activities indicated in paragraph 3 above, and are erased at the conclusion of the purposes for which they were collected and processed.
In particular, if you have requested information or sent communications via the Website, your personal data will be erased after 3 years from provision of the same, subject to your possibility to object at any time. At the end of the indicated period, the Company reserves the right to inform you, allowing your to choose whether or not to remain in the Company database or to be deleted.

7. Rights of Users and Contact Details
You may exercise, in the cases expressly envisaged by law and where applicable, the rights provided by the Regulation. In particular, you have the right to:

• obtain confirmation of whether or not your personal data is being processed and, in that case, to request from the controller access to information concerning that processing (e.g. purposes, categories of data processed, recipients or categories of recipients of data, retention period, etc.);

• request the rectification of inaccurate or incomplete data;

• request from the controller the erasure of the data (e.g. if the personal data are no longer necessary with respect to the purposes for which they were collected, in the case of withdrawal of consent on which the processing is based, etc.);

• request the restriction of processing (e.g. if you dispute the accuracy of the data; if the processing is unlawful and you object to the erasure of personal data; if the data are necessary to exercise or defend your rights in court, even where the controller no longer requires them; in the case of exercising the right of objection, for the time necessary to verify the existence of the legitimate reasons);

• receive in a commonly-used and machine-readable format (e.g. pdf) the personal data relating to you and send them to another controller, or obtain the direct transmission from one controller to the other, if technically feasible (known as data portability).
You also have the right to object, in whole or in part, for legitimate reasons, to the processing of personal data relating to you.
Those rights may be exercised directly by sending a communication to RPN at the following email address:
Finally, if you believe that the processing of the data provided violates the personal data protection regulation, you have the right to lodge a complaint with the Data Protection Supervisory Authority (

Cookie Policy
Cookies are small text strings sent by the websites that you visit to your computer, where they are stored when you a website, only then to be retransmitted to the same websites on the next visit.
Cookies are used by the Controllers and by any third parties, as indicated below, to allow the Website to operate or to improve its performances, but also to provide information on the Website or on browsing by you.
The Website uses cookies both for technical purposes and for additional purposes: while technical cookies are used as they are strictly necessary for the functioning of the Website as well as to provide the service expressly requested by you (e.g. language setting, etc.), as illustrated in more detail below, cookies for additional purposes (e.g. profiling cookies, analytics cookies) are used to carry out behavioural analyses of you on the Website, in order to improve its contents and to send advertising messages in line with the preferences shown by you while browsing on the internet, as indicated below.

Privacy and Cookie Policy as at 6 August 2020