Privacy Policy

In the course of doing business with Mediolanum International Funds Limited (Fund Manager) and Mediolanum International Life dac (Insurance undertaking) “hereinafter Mediolanum”, you may share non-public personal and financial information with us. Mediolanum respects your right to privacy. We understand that you have entrusted us with this private information and we recognise the importance of protecting unnecessary or unauthorised access to it.

This Privacy Policy should be read together with our Cookies Policy.

I.   Type of personal data collected

For the purposes of GDPR Mediolanum is a data controller who appoints third party providers (data processors) to process customer data. This policy also covers any processing of data relating to visitors to the Mediolanum websites.

We may amend or update this Privacy Policy from time to time. If we make material changes to this Policy which will have an impact on you (for example, if we intend to process your personal data for any purpose(s) that were not communicated to you when we first collected your data), we will notify you of these changes before the new activities begin. This notice also tells you about your rights under data protection law in relation to our processing of your data and how the law protects you.

There is a separate Cookies Policy which explains how Mediolanum makes use of cookies and other similar tracking technologies.

II.  The Purposes for Which We Use Your Data

Mediolanum will only ever use your information for a limited number of purposes, including to provide our products and services to you in line with any contract between us.

To comply with our legal and regulatory obligations, including establishing your identity, residence and tax status in order to comply with laws and regulations in the areas of taxation, financial crime, anti- money laundering and counter-terrorist financing, or to comply with court orders, enactments or rules of law or the instructions of regulatory bodies.

To operate our business in line with our legitimate interests, including risk and compliance monitoring, identifying improvements which can be made to our products and services, maintaining and improving our security systems.

To protect your vital interests or those of another natural person. Where you have given your consent, including for cookies from our website.

To process your subscriptions / Information requests / Complaints and to provide the additional services that we make available on our website.

III.   Information that we collect

We may collect personal information about you when you communicate or transact business with us based on Mediolanum’s separate business models as a Fund Manager and Insurance undertaking. This includes data collected by our third-party service providers including distributors, depositaries, custodians, administrators). The data shared with third party providers may be in writing, electronically or by telephone.

Whilst using the site, we may ask you for certain information, such as your name, company, email address. We may also collect certain information from the device you use to access the Mediolanum International Funds Platform, such as your IP address, what browser you use and what type of device you are using. This information is collected by our trusted partners as necessary to resolve requests for information / support / enquiries & complaints.

IV.   Exercising Your Data Protection Rights

You have a number of rights in respect of how Mediolanum uses your data and these are as follows:

Access – You have the right to be informed of how we collect, share and use your personal information and to request a copy of the data we hold about you.

Rectification – You have the right to have inaccurate information corrected and incomplete information updated.

Erasure – Under certain circumstances you have the right to have your data or a portion of it deleted. Restriction – Under certain circumstances you have the right to have the use of your data restricted. Objection – Under certain circumstances you have the right to object to the processing of your data. Portability – Under certain circumstances you have the right to obtain a transferable copy of certain data to which can be transferred to another provider.

Withdrawal of Consent – You have the right to withdraw consent to the use of your data at any time where this is the legal basis for its use. The withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Please note that if you withdraw your consent, we may not be able to continue to provide the related service to you.

V.   International Transfers of Data

Mediolanum may transfer your data to countries outside of the European Union in order to provide our products or services to you but will only do so where we have arrangements in place to ensure that an equivalent level of protection is in place to protect your privacy rights.

VI.  Retention of Data

Mediolanum is committed to keeping your information for no longer than is necessary.

VII.   Non provision of personal data

Where the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, and such data is not provided by you to us, we may not be able to provide or continue to provide the products or services you have requested.

You are not obliged to provide us with any of your personal data. However, if you want to use certain aspects of the web site you will need to provide us with the information that is requested on the relevant page. If you don't provide us with this information, we won't be able to process your request.

VIII.   Security

Your Personal Data will be held on secure servers. The nature of the Internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the Internet. No data transmission over the Internet can be guaranteed to be 100% secure. However, we will take all reasonable steps (including appropriate technical and organisational measures) to protect your Personal Data and we treat all the data held with the utmost care and security.

IX.   Sharing Your Data

We will keep your personal data confidential but may disclose it to third parties where necessary for the purpose of providing the products or services that you have requested, including associated group companies.

We may also share your data with regulatory and other governmental bodies where required by or under any enactment or rule of law or court order, including, but not limited to, the Revenue Commissioners, An Garda Siochana, the Companies Registration Office and the national Financial Intelligence Units in any other country in which Mediolanum is active. If we are required to make such a disclosure, we may not be able to tell you that a disclosure has been made and we may have to stop providing our services to you for a period of time and may not be able to tell you why.

X Who do we share your personal data with?

Support Services - We also use a number of service providers to assist us in providing our services, some of whom will have access to your data (e.g., we use various software service providers like Adobe who host our data in the cloud as part of their services). Where we engage a third party to process your data on our behalf we ensure that your privacy rights are respected and that they process your personal data in accordance with applicable data protection law.

Third Party Privacy Policies

Some of our partners ask us to make you aware of their privacy policies. These policies are available by following the links below:

• Google Privacy Policy – Privacy & Terms – Google
• Adobe Privacy Center

Questions and Complaints

If you have any queries or complaints in connection with our processing of your personal data or this Privacy Policy, you can get in touch with us at the following contact details:

Email: dataprotection@mediolanum.ie

Address: Mediolanum International Funds Limited, The Exchange, Georges Dock, IFSC, Dublin 1, Ireland

Phone: +353 1 231 0800

You also have the right to lodge a complaint with the Irish Data Protection Commission (“DPC”), our lead data protection supervisory authority in Europe, or your local data protection supervisory authority, if you are unhappy with our processing of your personal data. Details of how to lodge a complaint with the DPC can be found on the DPC’s website at https://www.dataprotection.ie, or you can call the DPC directly on +353 1 01 7650100

Privacy Information Notices

Italy - https://www.bancamediolanum.it/privacy

Spain - https://www.bancomediolanum.es/es-ES/informacion-legal/politica-proteccion-de-datos.html