1. Data Controller
ZB Capital S.R.L., with registered office at Via Sant'Antonio di Padova 34, 00138, Rome, Italy (hereinafter "ZB Capital", "we", "us", or "our"), is the data controller of the personal data collected through this website and related communications, in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation, "GDPR") and applicable Italian data protection law (Legislative Decree 196/2003, as amended by Legislative Decree 101/2018).
For any privacy-related matter, you may contact us at: amministrazione@zbcapital.it
2. Data We Collect
We collect personal data only to the extent necessary to respond to your inquiry and, where applicable, to enter into a contractual relationship with you. The categories of data we process include:
- —Identification data: your full name, as provided via our contact form or direct correspondence.
- —Contact data: your email address and any telephone number voluntarily provided.
- —Investor profile data: the profile category you select (e.g., private investor, financial professional, institutional).
- —Message content: any information you voluntarily include in the message field of our inquiry form.
- —Technical data: standard server log data (IP address, browser type, page visited, timestamp) collected automatically for security and operational purposes.
We do not collect sensitive personal data (special categories under Article 9 GDPR), and we do not engage in automated decision-making or profiling for purposes that produce legal or similarly significant effects.
3. Purposes and Legal Basis of Processing
Responding to inquiries (Art. 6(1)(b) GDPR — pre-contractual measures)
When you submit an inquiry through our contact form, we process your data to respond to your request and, if applicable, to conduct preliminary discussions regarding a potential investment relationship.
Legal obligations (Art. 6(1)(c) GDPR)
We may process your data to comply with applicable legal, regulatory, and tax obligations, including those arising under Italian corporate and financial law.
Legitimate interests (Art. 6(1)(f) GDPR)
We process technical data for the security and proper functioning of our website and systems. We may also maintain records of communications for the purpose of protecting our legal interests.
Consent (Art. 6(1)(a) GDPR)
Where we send you informational or marketing communications, we will do so only on the basis of your explicit prior consent, which you may withdraw at any time.
4. Data Retention
We retain personal data only for as long as is necessary for the purposes described above, or as required by law. Specifically:
- —Inquiry data with no subsequent contractual relationship: retained for up to 12 months from last contact, then deleted.
- —Data relating to an established investment relationship: retained for the duration of the relationship and for a period of 10 years thereafter, in compliance with applicable Italian civil and tax law (art. 2220 c.c. and related provisions).
- —Technical log data: retained for a maximum of 90 days for security purposes.
5. Data Sharing and Transfers
We do not sell, trade, or rent your personal data to third parties. We may share your data with:
- —Professional advisors (lawyers, accountants, auditors) bound by confidentiality obligations, strictly to the extent required.
- —IT service providers who process data on our behalf as data processors under written agreements compliant with Art. 28 GDPR.
- —Competent public authorities, where disclosure is required by law or court order.
We do not transfer your personal data outside the European Economic Area unless adequate safeguards are in place in accordance with Chapter V of the GDPR.
6. Your Rights
Under the GDPR and applicable Italian law, you have the following rights with respect to your personal data:
- —Right of access (Art. 15): to obtain confirmation of whether your data is processed and to receive a copy.
- —Right to rectification (Art. 16): to correct inaccurate or incomplete data.
- —Right to erasure (Art. 17): to request deletion of your data under certain conditions.
- —Right to restriction of processing (Art. 18): to request that processing be limited in certain circumstances.
- —Right to data portability (Art. 20): to receive your data in a structured, commonly used format.
- —Right to object (Art. 21): to object to processing based on legitimate interests.
- —Right to lodge a complaint: with the Italian data protection authority, the Garante per la Protezione dei Dati Personali (www.garanteprivacy.it).
To exercise any of the above rights, please write to us at amministrazione@zbcapital.it. We will respond within 30 days of receipt of your request.
7. Cookies and Tracking Technologies
This website does not use third-party tracking cookies, advertising cookies, or analytics platforms that transmit personal data to external parties. We may use strictly necessary session-level technical cookies to ensure proper website functionality. No cookie consent banner is displayed because we do not deploy non-essential cookies.
8. Security
We implement appropriate technical and organisational measures to protect personal data against accidental loss, destruction, alteration, unauthorised disclosure, or access. All communications between your browser and our server are encrypted using TLS. Access to personal data within ZB Capital is restricted to those with a legitimate need to process it.
9. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or regulatory guidance. The date at the top of this page will always reflect the most recent revision. Continued use of this website after any update constitutes acceptance of the revised policy.