Privacy Policy

DATA CONTROLLER

Following the website consultation, the data of natural persons identified or identifiable can be processed. The Data Controller BFF Bank S.p.A., based in Viale Lodovico Scarampo, 15, 20148 Milano.

DATA PROTECTION OFFICER

The Data Controller, according to the article 37 of the Regulation (UE) 2016/679 (GDPR), appointed a Data Protection Officer (DPO) reachable at the e-mail address DPO@bff.com.

TYPES OF DATA PROCESSED

Navigation data. IT systems and software procedures created for the website management acquire, during their usual activity, 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 computers and terminals used by users, addresses in URI / URL notation (Uniform Resource Identifier / Locator) of the requested resources, the time of the request, the method used in submitting the request to the server, the file size obtained in response, the numerical code indicating the status of the response given by the server (success, error, etc.) and other parameters related to the operating system and the IT environment of the User. This data is used for the sole purpose of obtaining anonymous statistical information on the use of the website and to check the correct functioning of the services offered.

Navigation data do not last for more than seven days (except for any need of crimes ascertainment by the judicial authorities).

Data communicated by the user. The optional, explicit, and voluntary transmission of personal data by the User in the data collection forms to the contacts on this site involves the subsequent acquisition of the data provided by the sender. These data will be processed by BFF Bank S.p.A., mainly with IT tools, in order to comply with the request of the User. Specific information will be uploaded on the BFF Bank S.p.A. website pages prepared for the provision of certain services.

Anonymous or aggregated data. Anonymization takes the form of processing with the aim of preventing the identification of the data subject. Anonymized data does not fall within the scope of data protection legislation. Aggregated data may be derived from personal data provided by the user but are not considered personal data since, as specified, they do not allow the identification of the data subject either directly or indirectly.

 

COOKIES

Cookies are small text files that are sent to the browser of the User by a web server and that are later stored on the hard disk of the User’s Computer. They are mainly used to allow the functioning of web sites and having them operate more efficiently, as well as of providing information to the owners of the same site.

The site uses technical session cookies, strictly limited to what is necessary for the safe and efficient navigation of the site.

These cookies are not permanently saved on the User’s computer and disappear when the browser is closed. Their use is strictly restricted to the transmission of session identification data (represented by random numbers originated by the server) necessary to allow the use of a specific service and the safe and efficient Website navigation. So-called session cookies used in this Website avoid having to resort to other IT technologies potentially prejudicial to the confidentiality of Users’ navigation and do not allow the acquisition of the User’s personal identification data.

Cookies will be stored for the purpose of adapting the Site to the individual needs of visitors, creating visit statistics and in order to maintain the User’s session; changes in cookie file settings can be made at any time.

BFF Bank S.p.A. reminds that the total or partial disabling of the so-called technical cookies can compromise the use of the functionalities of the site. In any case, the User can decide to accept or not the cookies by modifying the security settings of the browser.

Mozilla Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox

Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

Microsoft Edge: https://support.microsoft.com/en-us/windows/manage-cookies-in-microsoft-edge-view-allow-block-delete-and-use-168dab11-0753-043d-7c16-ede5947fc64d

Safari on Mac: https://support.apple.com/en-gb/guide/safari/sfri11471/mac

Safari on iPhone, iPad, or iPod touch: https://support.apple.com/en-gb/105082

This site uses both first-party and third-party cookies because Google Analytics services are applied, collecting information on how the website is used. The exert of Google Analytics services involve the collection of information through identifiers (if the users give their consent) to record which actions (‘events’) have been carried out on the website, as well as the subsequent anonymization of any personal data collected (including IP address, geographical region and type of device used).

For more information, please refer to Google’s privacy policy at the following address: https://policies.google.com/privacy?hl=en. For more information on the protection of personal data through the use of Google Analytics, please refer to the guide provided by Google at the following address: https://support.google.com/analytics/answer/6004245.

LINK TO OTHER WEBSITES

This Website contains links to access other websites. The presence of those links may entail the collection of data from and to sites managed by third parties. The Data Controller could not have control of the cookies or other tracking technologies on those websites, if managed by third parties. Therefore, this Cookie Policy does not apply, as the management of information collected by third parties is governed by the respective disclosures to which reference is made.

 

OPTIONAL PROVISION OF DATA

It is not mandatory to acquire the User’s consent to use only technical or analytical cookies assimilated to technical cookies. Deactivation and/or denial of their operation will result in the inability to properly navigate the website and/or the inability to access the services, pages, features or content available therein. For all other types of cookies (e.g. marketing and profiling) the Data Controller will require specific consent.

Except for what specified for navigation data, the User is free to provide their Personal data. The potential provision of personal data in data collection forms (e.g., to make a registration for events organized by the Data Controller, to receive newsletters, for contact purposes) or granting consent for further processing will be the subject to specific privacy information notices, which will be available in conjunction with the corresponding data collection forms. Please note, however, that Personal Data may be required to receive specific services, therefore, failure to provide them may result in the inability to procure whatever is proposed.

 

PROCESSING MODALITIES AND STORAGE PERIOD

Personal data are processed electronically for the time strictly necessary to achieve the goals for which they were collected. Specific security measures are observed to prevent loss of data, illicit or incorrect use and unauthorized access. Data collected for statistical analysis purposes are anonymized. Pursuant to Article 32 of Regulation (EU) 2016/679, BFF Bank S.p.A. has adopted all the necessary security measures to guarantee the protection of the Personal Data being processed, limiting the risks relating to the confidentiality, availability and integrity of the personal data collected and processed.

 

DATA SHARING, COMMUNICATION AND DIFFUSION

No data from the web service is disseminated. The processing operations connected to the web services of this site take place at the offices of the Data Controller and are carried out by staff expressly authorized by the latter pursuant to Article 29 GDPR, who work under the direct authority of the Controller (employees and contractors in various capacities) and are instructed accordingly. Data collected may be transferred or communicated to other entities qualified as data controllers under Articles 4.8 and 28 of the GDPR, including to subsidiaries of BFF Banking Group for activities strictly connected and instrumental to the operation of the service, such as the management of IT systems, or for processing operations effected by the other group companies for the same purposes. The Personal Data provided by the User requesting dispatch of informative material (brochures, informative material, etc..) is used only to perform the service or provision requested and are disclosed to third parties only if this is necessary for that purpose (companies that provide mailing services, labelling, shipping).

Besides those circumstances, data will not be communicated, nor granted to anyone, except if provided by contract or with the data subject’s consent. In this respect, Personal data may be transmitted to third parties, but only and exclusively provided that:

• There is the explicit consent to share the data with third parties;
• There is a need to share the information with third parties to provide the service requested;
• This is necessary to comply with requests of the judicial or public security authorities.

Personal data inherent in the website session are not transferred to parties residing in third countries or international organizations.

RIGHTS OF DATA SUBJECTS

Data subjects have the right to obtain by BFF Bank S.p.A., in the foreseen cases, the access to own personal data, the rectification or the erasure of them or the restriction or object of data processing (art. 15 and following of the Regulation). To exercise the aforementioned rights the Data Subject can contact the Data Controller by writing to BFF Bank S.p.A., Viale Lodovico Scarampo, 15, 20148 Milano. The Bank appointed a Data Protection Officer (DPO) reachable at the e-mail address DPO@bff.com.

 

RIGHT TO LODGE A COMPLAINT

The Data Subjects who consider that the processing of their personal data carried out through this website happens in violation of the provisions of the Regulation (EU) 2016/679 have the right to lodge a complaint to the Supervisory Authority as provided by art. 77 of the same Regulation, or to an effective judicial remedy (art. 79 of the Regulation (EU) 2016/679).

AMENDMENTS TO THESE PRIVACY POLICIES

BFF Bank S.p.A. periodically reviews the content of this document to comply with amendments legislative, organizational or due to technological evolution.