Privacy Policy


This Privacy Policy is made pursuant to art. 13 of Legislative Decree 196/03, Code for the Protection of Personal Data. By implementing the registration procedure, users voluntarily provide Aeffe Capital SA, Data Controller, with their personal data. The user’s personal data sent by users through the registration procedures for our services will be processed in compliance with the principles of personal data protection established by the Privacy Code (Legislative Decree 196/2003) and other applicable regulations. The provision of data is optional; however, failure to provide the data deemed mandatory (and marked with *) will prevent the proper registration to the site and the possibility of using the services provided by the portal and reserved for registered users.

Translated with (free version)


The Controller processes personal, identifying and non-sensitive data (in particular, name, surname, tax code, VAT number, email, telephone number – hereinafter “personal data” or also “data”) communicated when registering to the Controller’s website and/or when subscribing to the newsletter service offered by the Controller and/or when concluding contracts for the Controller’s services.


The personal data collected with this registration are processed in order to allow access to the services provided by the portal and reserved for registered users. In the event that the user has expressed consent at the time of activation of the service or expresses it subsequently and until the revocation of the same, personal data may be processed by Aeffe Capital SA to send advertising and commercial communications on its own products and services or those of third party companies, including by automated means, for the purpose of direct sales, as well as for sending market research and surveys.

In addition, in the event that the user consents, personal data may also be processed by Aeffe Capital SA to identify, including through electronic processing, specific behaviors and consumption habits in order to improve the services provided and address the commercial proposals of interest to the User and to offer third party advertisers the opportunity to optimize advertising campaigns. This is without prejudice to the possibility for Aeffe Capital SA to process the aforementioned data in aggregate form, in compliance with the measures prescribed by the Privacy Guarantor and by virtue of the specific exemption from consent provided by the same Authority, for analysis and electronic processing (e.g.: classification of the entire clientele into homogeneous categories by levels of services, consumption, spending, etc.) aimed at periodically monitoring the development and economic performance of the activities of Aeffe Capital SA, directing the related industrial and commercial processes, improving services, designing and implementing commercial communication campaigns.

Aeffe Capital SA will also use personal data for administrative and accounting purposes and for the performance of contractual obligations; for the same purposes, personal data will be made the subject of communication to investee or associated companies. The e-mail address will be usable, pursuant to Article 130, paragraph 4, of Legislative Decree 196/03, also for the purpose of direct sales of products or services similar to those already purchased by the user/customer.

Personal data are processed:

      1. Without express consent (art. 24 lett. a,b,c Privacy Code and art. 6 lett. b, e GDPR), for the following Service purposes:

        • Allow registration to the website;

        • Managing and maintaining the website

        • Allow subscription to the newsletter service provided by the Owner and any additional Services that may be required;

        • Fulfilling pre-contractual, contractual and tax obligations arising from existing relationships;

        • Fulfilling obligations under the law, a regulation, EU legislation or an order of the Authority;

        • Prevent or detect fraudulent activity or abuse harmful to the website;

        • Exercise Holder’s rights, e.g., the right of defense in court

          1. Only with specific and separate consent (Articles 23 and 130 Privacy Code and Article 7 GDPR), for the following Marketing purposes:

            • Send email newsletters, commercial communications and/or advertising material about products or services offered by the Owner



          Personal data sent through the registration procedures for our services are processed by Aeffe Capital SA with automated tools and for the time strictly necessary to achieve the purposes for which they were collected.

          Specific security measures are observed by the Data Controller to prevent data loss, illicit or incorrect use and unauthorized access.

          Personal data are recorded and stored on electronic databases owned by Aeffe Capital SA, based at 28, avenue Monterey L-2163 Luxembourg R.C.A. B233913. Data controller, as well as will be stored on servers in the territory of countries belonging to the European Union (EU) or outside the EU in compliance with the legislation on the protection of personal data.

          Personal data are processed by Aeffe Capital SA. The list of all Data Processors is a available upon request of users of the site.



          Users may at any time exercise their rights under Article 7 of Legislative Decree 196/2003, including the right to access their data and obtain their update or cancellation for violation of the law, to object to the processing of their data for the purpose of sending advertising material, direct sales and commercial communications, and to request an updated list of those responsible for processing, by written communication to be sent to: Aeffe Capital SA with registered office at 28, avenue Monterey L-2163 Luxembourg R.C.A. B233913

          Aeffe Capital SA

          28, avenue Monterey L-2163 Luxembourg R.C.A. B233913

          +352 691 669 020

          VAT LU31153434