Valid from March 2023

Who is the Data Controller?

The Data Controller is IRE AIFM Hub (Société à responsabilité limitée), with registered office 28, Boulevard d'Avranches, L-1160 Luxembourg. You can contact the Data controller by sending an email to aifm@ireaifm.com.

As Data Controller, IRE AIFM Hub (hereafter "IRE AIFM" or the "AIFM") ensures the highest level of confidentiality, protection and safety to the personal data referred to the data subjects it enters in contact with.

Preliminarily, the User surfing this website is invited to read all the sections of the present document, where a description of the cookies' operating method with respect to the processing of users' personal data is provided.

This is an information given pursuant to the EU Regulation 679/2016 (GDPR) and to the national regulation applicable to everybody who interacts with IRE AIFM web services that are available at the addresses belonging to the AIFM.

This information notice refers to the website https://ireaifm.com/

Further websites that You may access by clicking a weblink contained into this website are not under the Data Controller responsibility. We suggest that You consult the privacy notice published by the companies You get in contact with before exchanging your personal data.

What is a cookie?

A "cookie" is a small text file containing data, such as the name of a server or a unique ID, generated by a website and saved by the web browser that you use. Its purpose is to log the users' access to the website as well as other information about the navigation activities.

Cookies might be memorized in a permanent way and have a variable duration (so called persistent cookies), but they might also disappear when you close the browser or have a limited duration (so called session-cookies). Likewise, cookies might be installed both by the website you are visiting (so called first-party cookies) and by other websites (so called third parties' cookies) and they might be used for different purposes, such as online authentication, monitoring browsing sessions and retention of information on the activities carried out by users browsing the website.

Depending on the intended purposes it is possible to identify the following cookies' categories: technical, analytics and profiling cookies.

This website uses cookies that can be classified into the following categories: technical cookies (including session and preferences ones), analytics/statistical cookies and profiling/marketing cookies, both first and third parties' ones.

For each category of cookies, you can find below a description of the purposes pursued through their installation alongside with an analytical list of the cookies used on the Website.

Categories of cookies installed on the Website

Technical cookies

Technical cookies are needed in order to guarantee the proper functioning of the Website, both to offer the user a smooth browsing experience (e.g. to maintain access on reserved areas for the entire stay on the Website) and to correctly provide them the services required when browsing.

Thus, they are means used to guarantee, for instance, an efficient browsing, stability of the session, login's consistency and preselection of the selected browsing country. Moreover, they are needed to remember the user's choices related to the visualization of some of the elements of the page, like informative banners or the language (also called "elements of preference").

In order to use technical cookies and for the related processing activities the user's consent is not needed. The legal basis to process those data is the performance of services required directly by the data subject (article 6.1. b) of the GDPR).

Analytics/statistical cookies

This Website uses analytics. In particular, through analytics cookies – including third parties' ones – are gathered information on the ways users interact with the Website (number of visitors, visited pages, length of the stay, etc.) This information is used to improve the Website's features, allowing to record possible errors detected by the users and to ensure them a smoother and more immediate browsing experience. Since data is gathered in an aggregate form only – not allowing to identify the users in any way – these cookies are placed on an equal footing with technical ones.

Profiling cookies

Profiling cookies are used to gather information on the users' behavior when browsing the Website for advertising and marketing purposes, in order to detect and predict needs, preferences and habit of the users. In this category might be included also other kind of cookies, like the analytics when proper to provide information on users' online behavior. Thereby, in order to install this kind of cookies, user's consent is required.

Profiling cookies are used either by the AIFM or by third parties, including social networks, in order to send users more engaging and targeted advertising depending on the preferences showed during their browsing session, and to create profiles related to their interests.

Disabling profiling cookies (included those installed by social networks) will not interfere in any way on the possibility to access and to browse the Website.

Cookies used on the website

IRE AIFM Hub uses cookies. This website uses technical, analytical and profiling cookies – also third parties' ones – to improve the browsing experience and customize promotional activities in light of your interests. You can either accept their use by clicking on "Accept all cookies" or customize the management of the different kinds of cookies by selecting "Manage your preferences". If you want to limit the use of profiling cookies, thus maintaining technical and analytical cookies only, you can close the banner clicking "X": in this way, we will not be able to customize your browsing experience. For more information on the cookies used on the website (duration, function and their providers) and to change or withdraw your consent at any time, please see our Privacy-Cookie Policy

A "cookie" is a small text file containing data, such as the name of a server or a unique ID, generated by a website and saved by the web browser that You use. Its purpose is to log the users' access to the website as well as other information about the navigation activities. Cookies may be tracked by the system either for the duration of a session (namely, until the web browser is closed) or for a longer period.

How about accepting cookies?

As described in the dedicated banner published on the website, you can accept cookies by:

  • Clicking on the "Accept all cookies" button on the banner;
  • Clicking on the "Modify your preferences" button and, once you have made the choice related to each category of cookies, on the "Allow selection" button.

How can you disable cookies?

You can disable cookies at any time, either by using the area dedicated to cookies' preferences or through functionalities provided by the browser that you use. We specify that disabling cookies may imply a worse navigation, given that some website's functions may not be available. Most browsers are configured to accept, manage, and disable cookies through the setting tools. Some websites describing the steps to disable cookies into the principal browser are reported below:

Which types of personal data are processed?

IRE AIFM Hub processes the personal data gathered by the website navigation (in the ways and for the purposes described above) as well as information voluntarily provided by the user when he/she gets in contact with the Controller or it decides to use its services. If that is the case, a specific information notice is always provided to the User, and, whenever necessary, the User is invited to give his/her consent. Optional, explicit, and voluntary sending of personal data determines their processing for the purposes and to the extents provided for in the specific policies. To this end, we invite you to refer to the Privacy Policy available on the website.

Users' rights

In accordance with articles from 15 to 21 of the Regulation (EU) 679/2016, data subject may exercise specific data protection rights set out in the list above:

a) Right of access: right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and detailed information on the origin, the purposes, the categories of personal data concerned, the recipients and/or the transfer of data, and more;

b) Right to rectification: right to obtain from the controller without undue delay the rectification of inaccurate personal data, as well as the right to have incomplete personal data completed, including by means of providing a supplementary statement;

c) Right to erasure ("right to be forgotten"): right to obtain from the controller the erasure of personal data without undue delay when:

  1. the personal data are no longer necessary in relation to the purposes for which they were processed;
  2. consent on which the processing is based is withdrawn, and there is no other legal ground for the processing;
  3. the personal data have been unlawfully processed;
  4. the personal data have to be erased for compliance with a legal obligation;

    d) Right to object: right to object at any time to the processing of personal data having as a legal basis a legitimate interest of the Controller and/or to the processing for marketing purposes, including profiling. In the case of objection to the processing for marketing purposes, the personal data are not processed for those purposes anymore;

    e) Right to restriction of processing: right to obtain from the Controller restriction of processing where the accuracy of the personal data is contested (for a period enabling the controller to verify the accuracy of the personal data), the processing is unlawful and/or the data subject has objected to processing;

    f) Right to data portability: right to receive the personal data in a structured, commonly used and machine-readable format, and the right to have the data transmitted from one Controller to another, where technically feasible, only where the processing is based on consent or on an agreement and only for the data processed through electronic means;

    g) Right to lodge a complaint with a supervisory authority: without prejudice to any other administrative or jurisdictional claim, the data subject that considers the processing that concerns him/her is violating the Regulation has the right to lodge a complaint with the supervisory authority of the member state in which he resides or is established, as well as in the state where the assumed violation occurred;

    h) Right not to be subject to an entirely automated profiling: when the profiling is entirely automated, the right to obtain human intervention on the part of the Controller, to express his or her point of view and to contest the decision.

Moreover, the user has the right to revoke at any time the consent previously given to optional activities, notwithstanding the lawfulness of the processing activities carried out before the withdrawal.

Please note that any request to exercise data subjects' rights have to be addressed to the Data Controller, according to the following references:

  • By ordinary mail at the AIFM's office 28, Boulevard d'Avranches, L-1160 Luxembourg.
  • By e-mail at the following e-mail address: aifm@ireaifm.com

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