Privacy

The Code on the protection of personal data, adopted with the Legislative Decree no. 196 of June 30th, 2003 (hereinafter indicated also as the "Code" or the “Law”), obliges the persons defined as "Data controllers" for the processing of personal data, pursuant to art. 4 of the same Law, to provide all Data Subjects with precise information on the processing, if any, of their personal data.

Monte Titoli S.p.A. (“Monte Titoli”) in his capacity as Data controller for the processing of personal data, intends to give details regarding the information requested on the processing of the relevant data (hereinafter the “Data”).

Monte Titoli is a part of the London Stock Exchange Group plc, with registered office in London (UK) (hereinafter indicated also as “LSE Group or “LSEG”) and is acting under the direction and coordination of London Stock Exchange Group Holdings – (Italy) Ltd (hereinafter also “LSGH(I)”), along with the italian companies of the Group: BIt Systems S.p.A., Borsa Italiana S.p.A., Cassa di Compensazione e Garanzia S.p.A., MTS S.p.A., Piazza Affari Gestione e Servizi S.p.A. and Servizio Titoli S.p.A.

The Data gathered directly by the Data subject or by a third party or otherwise acquired by the companies of the LSE Group within their business could be processed in compliance with the above Law and with the confidentiality duties.

1. to gather preliminary or subsequent information to the conclusion of an agreement, including the economic and financial rating of connected risks or of other juridical relationships; to fulfil obligations deriving from contractual relationship with the companies of the LSEG; to fulfil the correct conduct of contractual relationships and relevant obligations, to manage finance and accounting administration data and correspondence, also via fax and via e-mail, as well as to fulfil activities strictly connected to the compliance of reciprocal obligations;
2. to comply with obligations set forth by laws, by regulations, by EU laws or to comply with requirements of the Stock Exchange supervisory bodies or as laid down by administrative practice;
3. to perform functional purposes connected to the activities carried out by the Companies of LSEG, such as the performance of:
   • customer surveys, carried out by means of personal or telephone interviews, questionnaires, etc., regarding the quality of the services rendered;
   • market research surveys and studies;
   • informative, statistical or scientific activities;
   • marketing, promotion and sale of products and services of LSEG, also using Data subject's name for publicity;
   • public relations activities, carried out by any means.

It is not obligatory to provide personal data for the purposes stated in point c) and failure to provide them does not involve any consequence whatsoever. However, failure to provide them would make it impossible for LSE Group to keep Data Subjects up-to-date on events, conventions, promotion of new products and services or to provide the same with publications and with other informative material.

Data is made available only to the personnel who needs it for the activities and tasks carried out, by way of example without limitation, within LSE Group, such as: external relations and commercial officers, accountants, secretaries, managers and officers of the LSE Group. These persons, whose number will be limited to the minimum required, process the data in their capacity as “Persons in charge of the Processing”; they are specially appointed for such purpose and are duly instructed in order to avoid loss, destruction, unauthorized access or forbidden processing of such data.

Monte Titoli, with registered office in Milan, via Mantegna, 6, is Data Controller.

Data Processor for Monte Titoli is Alessandro Perugini, who, for these purposes, is domiciled at the company’s registered office.. He has the task to answer to all queries connected to the processing of personal data and he can also make available the updated list of all other internal Data Processors, as well as the external ones.

2.COMMUNICATION OF DATA TO THIRD PARTIES

In addition to communicating personal data of Data Subjects inside the LSE Group, Monte Titoli may communicate personal data to:

1. supervisory bodies, or to other designated subjects, in accordance with their own requirements or set forth by local or EU laws, by regulations and by administrative procedures;
2. third parties that support Monte Titoli for the purposes mentioned in point 1, letter a) namely:
   • banks and financial companies, professionals, external service companies, including persons in charge of debit collection;
   companies that print, pack and deliver communications to Data Subjects;
   • companies that provide technological services. and/or data processing systems.
   Names and address of these companies will be made available at the request of Data Subjects.
3. third parties carrying out support activities for Monte Titoli, such as:
   • third parties that carry out customer surveys regarding the quality of the services rendered;
   • third parties that carry out information systems, statistical and scientific activities;
   • third parties that promote and/or sell products and services;
   • third parties that carry out market research and surveys;
   • third parties that carry out public relations activities;
   • companies or entities that manage Italian or foreign markets with whom companies of LSE Group may enter into alliances and/or co-operate with, and also third parties that support such entities or companies.

3.TRANSFER OF PERSONAL DATA ABROAD

Personal data of Data Subjects may be transferred abroad, even outside the European Community, for the same purposes stated in point 1 above, either by or without electronic or alternatively automated means.

Consent for transferring personal data abroad is optional for the purposes stated in point 1 letter c) above and failure to provide it does not involve any consequence whatsoever. However, failure to provide it would make it impossible for Monte Titoli and for the other companies of LSE Group to keep Data Subjects up-to-date on events, conventions, promotion of new products and services or to provide the same with publications and with other informative material.

4.METHOD OF PROCESSING DATA

Monte Titoli processes personal data of Data Subjects in a lawful and professional manner, so as to ensure the confidentiality and security of the information. The processing of personal data - which shall mean any operation provided for in the definitions under article 4 , letter a) of the Code – is carried out by manual, electronic or computerized means with organisational methods and logic strictly related to the purposes mentioned above. In view of the fact that Monte Titoli belongs to LSE Group, personal data of Data Subject may be held on information devices at the LSE plc and at its controlled or associated companies, in compliance with the above conditions. Data is kept for no longer than is necessary for the purpose for which they were collected or subsequently processed., in compliance with general principles and with provisions issued by the “Garante”.

5.RIGHTS OF DATA SUBJECTS

In compliance with the Law, Data Subjects are entitled to the rights mentioned in art. 7 of the same Law. Besides, in compliance with the said article Data Subjects may ask for the access to their personal data, obtain a copy of the data processed, ask for their updating, rectification, integration, erasure or termination, where conditions occur or may object, on legitimate grounds, to the processing of personal data concerning them.

Data Subjects may assert their rights by writing to Monte Titoli S.p.A., via Mantegna, 6, 20154, Milan, for the attention of the Data Controller or Data Processor.