Privacy Notice for website pursuant to Article 13 of EU Regulation 2016/679 ("GDPR")


In accordance with Regulation (EU) 2016/679 (hereinafter "GDPR"), this page describes the methods of personal data processing. This is a notice provided pursuant to Article 13 of the GDPR. This notice is not valid for other third-party websites that may be accessed through links on this website, for which no responsibility is assumed.

Personal data processed


Personal data: any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person (Recitals 26, 27, 30 GDPR).

Navigation data: the computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This category of data includes IP addresses or domain names of the computers and terminals used by users, URI/URL (Uniform Resource Identifier/Locator) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.), and other parameters relating to the user's operating system and computer environment.


Voluntarily communicated data: the optional, explicit, and voluntary sending of messages to the contact addresses indicated on this website and/or the completion of data collection forms entails the subsequent acquisition of the sender's address, necessary to respond to requests, as well as any other personal data entered.


Specific information: specific information may be provided on the pages of the Website regarding particular services or data processing activities.


Cookies and other tracking systems. What are they? What are they for?

For Cookies and other tracking systems, please refer to the cookies policy provided in the website footer and at the following link.


1. Data Controller and contact details

The Data Controller of the data is FinLabo Investments Sicav, with registered office at 2, Rue d’Alsace L-1122 Luxembourg, Grand Duchy of Luxembourg, represented by its Legal Representative pro tempore, who can be contacted at the email address:


2. Purposes of processing, legal bases, data retention period, and nature of provision.


Purpose a) possible contact request or information request via the "information request" form


  • Legal basis: Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; Article 6(1)(b) of the GDPR

  • Data retention period: maximum 12 months.

  • Nature of provision: Provision is necessary. Failure to provide the necessary data will result in the inability to be contacted and receive information.


Purpose b) receipt of informational material

  • Legal basis: Processing is based on consent to the processing of personal data (Recitals 42, 43) Article 6(1)(a) of the GDPR.

  • Data retention period: Until consent is revoked (or opt-out)

  • Natura del conferimento: Provision is optional. Failure to provide the necessary data will result in the inability to receive direct marketing communications.



3. Communication to third parties

Personal data provided will be shared with entities who will process the data as data processors (Article 28 of EU Regulation 2016/679) and/or as individuals acting under the authority of the Controller and the Processor (Article 29 of EU Regulation 2016/679), for the purposes listed above.

Specifically, the data will be shared with:

  • AcomeA SGR S.p.A., management company of Finlabo Sicav;

  • sentities providing services for the management of the information system used by the Controller and telecommunications networks, including email, newsletters, and website management, freelance professionals, firms or companies providing assistance and consultancy services;

  • competent authorities for compliance with legal obligations and/or orders from public authorities, upon request.

The list of Data Processors is constantly updated and available by writing to or using the other contact details provided above.


4. Transfer of data to countries outside the EEA

Personal data collected for the purposes described in this Notice will not be transferred to countries outside the EEA.


5. Automated process

Personal data will be subject to traditional manual, electronic, and automated processing. It is noted that no fully automated decision-making processes are carried out.


6. Rights of the Data Subject

Current legislation recognizes numerous rights to the Data Subject, which we invite you to carefully consider. Among these, we remind you of the rights to:

  1. Access the following information:

    1. the purposes of the processing,

    2. the categories of personal data concerned,

    3. the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations,

    4. the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject;

  2. Rectification, meaning:

    1. correction of inaccurate personal data concerning you without undue delay,

    2. completion of incomplete personal data, including by means of a supplementary statement;

  3. Erasure of data concerning you without undue delay if:

    1. the data are no longer necessary in relation to the purposes for which they were collected or otherwise processed,

    2. consent is withdrawn, and there is no other legal basis for processing,

    3. you object to the processing, and there are no overriding legitimate grounds for the processing,

    4. the personal data have been unlawfully processed,

    5. the personal data have to be erased for compliance with a legal obligation,

    6. the personal data have been collected in relation to the offer of information society services;

  4. Restriction of processing:

    1. where you contest the accuracy of the personal data, for a period enabling the controller to verify the accuracy of the personal data

    2. when the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead,

    3. when the personal data are no longer needed for the purposes of processing, but are required by you for the establishment, exercise or defense of legal claims,

    4. when you have objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject;

  5. Receive notification regarding rectification or erasure of personal data or restriction of processing;

  6. Data portability, meaning the right to receive the personal data concerning you, which you have provided to a controller, in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller, where:

    1. the processing is based on consent or on a contract and

    2. the processing is carried out by automated means;

  7. Object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you.


You have the right to lodge a complaint with a supervisory authority if you believe that your rights as described here have not been recognized.


To exercise the aforementioned rights, you may contact the Data Controller by sending a registered letter with return receipt requested to the address provided or an email to


7. Changes to the notice

The Controller reserves the right to modify, update, add, or remove parts of this notice. In order to facilitate verification and modification of the text, the notice will contain the update date.



Date of update: September 13, 2023