Data Privacy and Personal Data Protection Policy

Personal data protection

Generali Investments AD Skopje  pays particular attention to data protection, and handles them with due care, responsibility and in compliance with applicable regulations. We respect your right to privacy and therefore process data in a manner protecting your interests, fundamental rights and freedoms. We process personal data lawfully, fairly and in a transparent manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures. Before processing your personal data, we carefully assess the proportionality of the intended processing and any positive or negative impact on you or your rights in terms of personal data protection.

Legal basis

The legal basis for personal data processing is:

– Personal Data Protection Act,

– Investment Funds Act,

– Electronic Communications Act,

– Prevention of Money Laundering and Terrorist Financing Act,

– tax regulations, and

– any other regulations governing personal data processing and/or protection.

The Controller

The Controller is Generali Investments AD Skopje, Bld. Partizanski odredi 14A, 1000 Skopje (hereinafter: Generali Investments). Access to your personal data and the right to their processing for specified purposes is granted only to authorized employees of Generali Investments and carefully selected contractual processors that provide sufficient guarantees, including the security of processing, and have signed an agreement on personal data processing committing to the same standards of personal data protection as applied by us.

Generali Investments designated a data protection officer, with the following contact: marija.lozevska@generali-investments.mk

Personal data

“Personal data” means any information relating to an identified natural person or a person who can be identified. A person who can be identified is a person whose identity can be ascertained directly or indirectly on the basis of a citizen’s identification number or on the basis of one or more features specific to his physical, physiological, mental, economic, cultural or social identity.

You are obliged to provide to us true, correct and complete personal data as well as any changes to your personal data.

Purposes of personal data processing

We process your personal data on the basis of our business relationship with you (subscription form, agreement), on the basis of the law, on the basis of our legitimate interest and on the basis of your consent.

The processing of personal data for purposes other than those for which the personal data were initially collected is allowed only where the processing is compatible with the purposes for which the personal data were initially collected, or where required by applicable regulations.

We will not transmit your personal data, except in cases required by the law, to any third party without your written consent. Personal data are not transmitted to third countries.

Processing based on a contract

We process your personal data in connection with the purpose of meeting our obligations arising from our business relationship with you.

Upon entering into a business relationship (by signing a subscription form or an agreement), we request from you all data we are legally obliged to obtain from you. Unless you transmit to us all necessary data, we will request you to do so, and if you decline we reserve the right to not enter into or to terminate a business relationship with you. Upon concluding a business relationship or subsequently, you can provide to as on a voluntary basis any other data not specifically required when we enter into a business relationship. In certain cases, we can obtain certain data from third parties or from public records and in accordance with the regulations.

Before entering into a business relationship, we can process the data you transmit to us to set up contact with respect to advisory services, to determine your financial profile, to advise you on appropriate products, or to inform you about our offer.

Processing on the basis of the law

We process personal data on the basis of various laws for the purpose of meeting legal obligations, for purposes imposed by regulations (e.g. in the area of tax, prevention of money laundering and terrorist financing, etc.).

Processing on the basis of legitimate interest

We can process your personal data where this is necessary for the purpose of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. Legitimate interests are our interests connected with the conduct of our activities in a friendly and safe manner, and in compliance with legal requirements. Processing on the basis of legitimate interest is grounded on impact assessment, by which we define our legitimate eligible interest and assess any overriding interest of the data subjects over the legitimate interests of the Company.

The legitimate interests pursued by the Company are development, advertising and offering of savings products and services, business process improvement, compliance, business and data processing security, better tailoring of our offer, and improved user experience.

Processing on the basis of consent

Personal data may be processed on the basis of your freely given consent. By giving consent, you consent that your personal and other data collected in the framework of performing our services and in other forms of interaction (e.g. including information collected via web browsers) are collected, stored and used for specified purposes. We obtain data directly from you or from other sources (social networks, websites or other public sources), or data are transmitted to us by our contractors commissioned by us to collect personal data or to perform surveys or market surveys. If your consent is incomplete, you allow us to enter into our database the missing data available to us from other subscription, transaction or sales documentation.

By way of your consent, you can specify one or several of the following purposes of personal data processing:

– direct marketing (e.g. information about promotional activities and targeted (segmented) marketing, e.g. sending news, articles, our own magazines, event invitations, offers, promotional material, cards, newspapers and prize competitions),

– surveys and market research for our needs,

– statistical processing,

– profiling, monitoring of customer’s purchase behavior (including in past periods) on the basis of past activities, processing and receipt of messages and benefits intended and specifically individualized for you.

Consent is in particular intended for the purpose of our product and service development, tailoring of our offer, improvement of user experience, receipt of communications form the Company, and assistance in financial decisions. Your consent does not affect any previously given approval or consent we might have obtained from you before, unless they are contradictory. Notifications on the basis of consent are carried out through communication channels you selected when giving consent

Storage period

Storage periods for personal data differ depending on the type and purpose of personal data processing. Certain data are stored for 10 years or longer after the termination of a business relationship or transaction completion. Data based on free consent are stored until withdrawal. A longer period of storage may be prescribed by the law.

We store personal data processed for one-off events (conferences, meetings, lectures, prize competitions, visits and trips) in accordance with applicable laws and rules of specific events, or until withdrawal of consent.

If we receive a request to delete data, we will execute the request by restricting data processing only to purposes arising from applicable regulations or our internal rules.

If personal data are anonymized, i.e. they can no longer be related to an identified person, such data may be stored and processed without a fixed storage period.

 The rights of data subjects

• To be informed about the processing of your personal data

For the purpose of transparency, the controller is obliged to inform the personal data subjects for the aims and the legal basis of the processing of their personal data.

• Request access to the data

The request for data access must be submitted in written form and contain additional data and information necessary to locate required data.

The controller is obliged to respond to the entities within 15 days of receipt of the request, with no obligation to respond again to the same or similar request of a particular entity, if in the meantime there hasn’t been changes in personal data, unless six months have passed from the date of submission of the previous to the new request.

• Request to amend, modify, delete or stop data processing

At the request of the subjects, the controller shall be obliged to amend, modify, and delete personal data or to stop the processing of data, if they are incomplete, incorrect or out of date, or if their processing is not in accordance with the law.

Regardless of whether the entity has made such a request, if the controller determines that the personal data is incomplete, incorrect or out of date, it is obliged to amend, modify or delete. We are available for any further explanations at 02 60 90 300.

Preventing the use of personal data

Each subject has the right to request the Company stop processing personal data relating to it. If you consider that your rights have been infringed with respect to your personal data processing, you may lodge a complaint by sending it to Generali Investments AD Skopje, Bld. Partizanski odredi 14A, 1000 Skopje.

There is no strict form what the request should contain and how it will look like, but it is preferable to contain the following information:

Your identity and the personal data you are referring to;

When you considered that the processing of personal data is illegal;

When the personal data is used for other purposes, different from that which you have consented to;

The possible harmful consequence of such processing;

Time frame you want the processing of your personal data to stop (this should be a reasonable time frame).

The right to lodge a complaint

If you think that your rights have been violated in relation to the processing of your personal information, you may file a complaint by sending it to Generali Investments AD Skopje, Bld. Partizanski odredi 14A, entrance 1, floor 2/2, 1000 Skopje, or by e-mail at info@generali-investments.mk. If you think that the processing of data is a violation of applicable law, you have the right to file a complaint to the supervisory authority. The supervisory authority is the Directorate for Personal Data Protection, https://dzlp.mk.

Amendments to the Privacy Policy

This Privacy Policy may be amended or supplemented at any time. You will be informed about any amendments on this website, and by e-mail in the event of substantial amendments with an impact on personal data processing.

Cookies

Rules on use of cookies and similar technologies for information storage and access to information stored on a user’s computer or mobile devices are governed by the Electronic Communications Act.

What are cookies?

Cookies are small text files that are, upon your prior agreement, copied from onto your computer when you visit a website, and normally include:

• the name of the server from which a cookie was sent;
• cookie duration;
• the value – usually a randomly generated anonymous unique code.

The cookie itself does not contain or collect information. However, if it is read by a server together with a web browser it can help the web site provide user friendly services. A cookie can only be read and used by the server that generated it.

Which cookies are used by website www.generali-investments.mk?

Cookie manager

Generali Investments AD Skopje
Bld. Partizanski odredi 14A
1000 Skopje

What cookies do not do?

• They do not transfer data from your computer to any server other than back to the sender.
• They do not transfer any data to our server apart from the ones that the server itself sent to the user and are returned at every visit (unique code).
• They do not contain your name, address, etc.
• They cannot infect your computer with a virus or harm it in any other way.
• They do not enable the company to find out what you, apart from visiting our server, do on- or offline.
• They do not enable us to recognize your personal data unless you yourself have shared it with us.

If you do not wish to use cookies or do not answer the question about their use, cookies will not be stored. You will still be able to use most of the contents on our server.