Privacy and Cookie Policy

The objective of UCapital24 S.p.A. ("UCapital24", the "Owner", or "we") is to connect all economic and financial operators, both retail and institutional, by acting as an "aggregator" between supply and demand and by offering through various WebApps and websites financial services and content.

In this context, this Privacy Policy describes the procedures followed by UCapital24 in relation to the processing of personal data collected or processed through the site ucapitalintellinge.com (the "Site") which, specifically, is a site through which Users can view the services offered by the Market UCapital Intelligence WebApp, with the possibility of purchasing subscription licences to access the aforementioned services (by way of example, market analysis, live signals, market call, world economic tv).

Where not otherwise specified, this Policy applies as information - pursuant to Articles 13 and 14 of Regulation (EU) No. 2016/679 (hereinafter the "GDPR") - provided to those who interact with the website ("Users", "Interested Parties", or "you"), including those who intend to take advantage of the services that can be purchased and subsequently used through the Market UCapital Intelligence WebApp, as governed by the Terms and Conditions of Service.

1. Data controller. Data Processors.
The data controller is UCapital24 S.p.A., with registered office at Via dei Piatti 11, 20123, Milan (MI), Tax Code and VAT no. 10144280962, e-mail: privacy@ucapital24.com. The updated list of any data processors is available, upon request, at the Data Controller's registered office.

2. Data Protection Officer.
The Data Controller has appointed a Data Protection Officer ('DPO' or 'RDP'), pursuant to Article 37 of the GDPR, who can be contacted for any needs concerning the processing of personal data by writing to the following e-mail address: dpo@ucapital24.com.

3. Categories of personal data processed. Sources from which they originate.
Through the site, the Data Controller may collect and process the following categories of data:
common personal data, including data voluntarily provided by the User by filling in forms on the Site (name, surname, e-mail, telephone number);
Browsing data: During normal operation, the computer systems and software procedures used to operate this site acquire certain personal data, the transmission of which is implicit in the use of Internet communication protocols. This category of data includes the IP addresses or domain names of the computers and terminals used by users, the URI/URL (Uniform Resource Identifier/Locator) notation addresses of the resources requested, 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 given by the server (successful, error, etc.) and other parameters relating to the user's operating system and IT environment;
payment and billing data in the case of the purchase of paid services;

4. Purpose and legal basis of the processing. Legitimate interests pursued.
The personal data collected will be processed:
a) to respond to requests for information made by Users through forms within the App;
b) for activities related to specific pages or functionalities of the site, and to the use of related services; this includes activities aimed at the purchase and use of paid services (licences);
c) to fulfil legal obligations to which the Controller is subject (e.g. accounting, tax, administrative);
d) for the sending, by UCapital24, of promotional communications regarding services similar or related to those already purchased or for which the User has registered (so-called "soft spam");
e) to send notices concerning the availability of the services, service messages on the use of the services and security, legal notices;
f) for the establishment, exercise or defence of a right of UCapital24, including in court;
g) for activities related to the functioning and operation of the site.


The processing of data for the purposes under a) and b) does not require the consent of the Data Subjects as it is necessary to fulfil specific requests made by them to UCapital24, or for the performance of a contract to which the Data Subject is a party pursuant to Article 6, c. 1, lett b) of the GDPR (with particular reference to the Terms and Conditions of Service and the General Terms and Conditions of Sale).
The processing of data for the purpose sub c) does not require the consent of the Data Subjects as it is necessary to fulfil the legal obligations to which the Data Controller is subject, pursuant to Article 6, c. 1, lett. c) of the GDPR.
The processing of data for the purposes sub d), e), f) and g), does not require the consent of the Data Subjects as it is necessary for the pursuit of the legitimate interest of the Data Controller, pursuant to Article 6, c. 1, lett. f) of the GDPR.
It will be possible to receive updates and information content by e-mail depending on the service, in accordance with the Terms and Conditions of Service and the General Terms and Conditions of Sale.

5. Provision of data and consequences in the event of non-provision.
The provision of personal data for the purposes under a), b) and c) is optional, but necessary to manage and process Users' requests, as well as to fulfil UCapital24's legal and contractual obligations. The provision of personal data for the purposes d), e), f), and g) is optional, but necessary for the pursuit of the legitimate interests of the Data Controller indicated in the section above. In all these cases, failure to provide the data will make it impossible to fulfil the User's requests, establish contractual relations with the same and carry out the activities indicated above.

6. Recipients and possible categories of recipients of personal data.
Personal data may be made accessible to, brought to the attention of or communicated to the following entities, which will be appointed by UCapital24, as the case may be, as data processors or persons authorised to process the data, or will act as autonomous data controllers:
employees and/or collaborators in any capacity whatsoever of the Controller;
employees and/or collaborators in any capacity whatsoever of companies in the group to which the Controller belongs;
suppliers and partners of the Controller who provide services and all activities related to the Site, suppliers of IT services for platform maintenance, etc;
freelancers and consultants for the purposes of the legal, financial and accounting management of the Controller's activities (e.g. accountants, administrators, etc.);
public authorities or police forces, in cases provided for by law.

7. Transfer of data to countries outside the European Union
In the event that the recipients referred to in point 6 above are established or process data in a country outside the European Union, the transfer of data to such entities will be carried out, alternatively: i) in the presence of an adequacy decision by the European Commission, pursuant to Art. 45 of the GDPR, which has verified that such third country, or more specific sectors within the third country, ensure an adequate level of protection of your rights; ii) following the stipulation of standard data protection clauses, approved by the European Commission, pursuant to Article 46, c. 2, of the GDPR; iii) in the presence of binding corporate rules approved by the supervisory authority in accordance with Article 47 of the GDPR.
In the absence of an adequacy decision or the adequate safeguards identified above, the Controller will only transfer personal data to a third country or an international organisation for the purpose of the performance of a contract with the data subject or for the performance of contractual measures taken at the data subject's request, or in order to establish, exercise or defend a right in court, or where the data subject has explicitly consented to the proposed transfer after having been informed of the possible risks of such transfers.

8. Period of retention of personal data
In the case of the purchase of services against payment, the data shall be retained for a maximum period of time equal to the period of limitation of the rights enforceable by UCapital24, as applicable from time to time, as a rule 10 years from the termination of the contract.
The data entered in the contact form, (name, surname, e-mail, telephone), filled in by the Users in order to obtain information on the services offered by the Controller with which, however, a contractual relationship is not established, will be stored for a maximum period of 12 months.

9. Cookies
Cookies are small text files that visited sites send to the User's terminal, where they are stored and then transmitted back to the same sites on the next visit. Cookies allow sites to function correctly and efficiently to improve the user experience by allowing the relevant site to store the information in the memory of your computer or other device.
Cookies can be classified in different ways, i.e. according to the site that generates them, according to their duration and according to their purpose of use.
Classification of cookies according to the site that generates them:
First Party Cookies: these are generated by the site you are visiting and only that site can read this data.
Third Party Cookies: these are generated by other sites, outside of the one the user is visiting. When you visit a page on a site, you may encounter content posted by external sites such as Facebook, Twitter, You Tube, Vimeo or others, and these sites may generate cookies. Our site has no control over them. Users are advised to check such sites and their Privacy Policy.

Classification of cookies according to their duration:
Temporary (or session) cookies: these do not have an expiry date, and are deleted as soon as the browsing session ends or the browser is closed.
Persistent cookies: they have an expiry date and remain on the computer even when the browsing session ends or after closing the browser. They can be read by the site that created them on subsequent visits to the same site.

Classification of cookies according to their purpose of use:
Technical cookies
Profiling cookies
Analysis cookies
In detail, combining the classifications we have:
First-party Technical Cookies: This type of cookie allows certain sections of the Site to function properly. They are of two categories, temporary (or session) and persistent (see above). These cookies are necessary to display the site correctly and in relation to the technical services offered, they will therefore always be used and sent, unless the visitor changes the browser settings (with the possibility, however, of not making the most of or rendering some of the services offered by the site unusable). Technical cookies are those used, for example, to authenticate oneself, to use multimedia contents such as flash player or to allow the choice of navigation language. In general, it is not necessary to obtain the User's prior and informed consent. The legal basis for their use is the legitimate interest of the Controller in the smooth operation of the website/app. In addition, analytical cookies are also assimilated to technical cookies through which the Owner only learns information of a statistical nature, collected in aggregate form, relating to the number of visitors and how they use the website / App. If the information is not collected in aggregate and instead includes identification data (for example, the IP address used by the user's device which has not been anonymised), the cookies used to collect this additional data will be qualified as "profiling cookies", active only with the user's consent.
Technical cookies to integrate third-party functions: This type of cookie integrates functionalities developed by third parties within the pages of the site such as icons and preferences expressed in social networks for the purpose of sharing site content or for the use of third-party software services (such as software to generate maps and other software offering additional services). These cookies are sent from third party domains and partner sites that offer their functionality between the pages of the site.
Analysis cookies from third party services: These cookies are used to collect information on the use of the site by users: pages visited, time spent on the site, traffic origins, geographical origin, age, gender and interests for the purpose of marketing campaigns. These cookies are sent from third party domains outside the site and according to the regulations in force they can be assimilated to technical cookies "if instruments are adopted to reduce the power of identification and the third party does not cross-reference the information collected with others that it already has" or they can be assimilated to profiling cookies otherwise.
Profiling cookies: these are those cookies necessary to create user profiles in order to send advertising messages in line with the preferences expressed by the user within the pages of the site. This type of cookie does not currently operate within the Ucapital Intelligence Site / App.
social widgets and plugins: some widgets and plugins provided by social networks may use their own cookies to facilitate interaction with the relevant site;

The cookies installed on the Site are listed below in detail. For each of them you will find a link to the relevant information on the processing of personal data and how to deactivate the cookies used. Technical cookies do not require prior consent for their installation. With regard to non-technical cookies, the user's prior consent will be required at first access. Without such consent, cookies cannot be installed on the user's device, who can manage his preferences at any time.
Any consent given to the use of cookies is valid for 6 months, after which the cookie banner will be shown again to renew your preferences.
List of technical cookies that do not require consent
The following cookies will be installed on users' devices without prior request for consent.
List of cookies that require prior consent from the user
Consent is required for the following cookies, without which they will not be installed on users' devices. 

 

How to disable cookies via browser configuration:

In general, cookies can be disabled by the User by checking and/or modifying the settings of his/her browser according to the instructions made available by the respective providers at the links indicated below:

• Internet Explorer
• Mozilla Firefox
• Google Chrome
• Apple Safari
• Opera

More information on cookies can be found at http://www.youronlinechoices.com/it.

10. Rights of the Interested Parties.
Interested parties may exercise their rights under Articles 7(3) and 15 et seq. of the GDPR by sending an e-mail to privacy@ucapital24.com, or, alternatively, a communication by registered letter with acknowledgement of receipt to the registered office of UCapital24 at Via dei Piatti 11, 20123, Milan (MI).

The Interested Party may, in particular:
obtain confirmation as to whether or not personal data concerning him/her are being processed and the purposes of such processing;
access their personal data and information on the processing, and request a copy of such personal data;
obtain the rectification of inaccurate personal data and the integration of incomplete personal data;
obtain, if one of the conditions set out in Article 17 of the GDPR applies, the deletion of personal data concerning him/her;
obtain, in the cases provided for in Article 18 of the GDPR, the restriction of processing;
if the conditions set out in Article 20 of the GDPR are met, receive the personal data concerning him/her in a structured, commonly used and machine-readable format and request their transmission to another data controller, if technically feasible.


Right to object to processing for the pursuit of the legitimate interest of the Controller.
Each Data Subject has the right to object at any time to the processing of his/her personal data carried out in pursuit of a legitimate interest of the Controller. In the event of an objection, personal data shall no longer be processed, unless there are legitimate grounds for processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

Right to withdraw consent.
Where consent is required for the processing of personal data, each Data Subject may also revoke any consent already given at any time, without prejudice to the lawfulness of the processing based on the consent given before revocation. Consent may be revoked by sending an e-mail to privacy@ucapital24.com.

Right to lodge a complaint with the Garante.
Each data subject may lodge a complaint with the Garante per la Protezione dei Dati Personali if he or she considers that his or her rights under the GDPR have been violated, according to the procedures indicated on the Garante's website accessible at: www.garanteprivacy.it.

12. Amendments to this policy
This privacy policy may be subject to updates or changes (including as a result of new legislation or regulations), so Users are encouraged to check this document regularly. Substantial changes will in any case be highlighted via the Site or notified by e-mail.

Date of last revision: 08/08/2022