Cookie & Privacy Policy

Pursuant to the current legislation on the protection of personal data (“Privacy Policy“), including EU Reg. 2016/679 (“GDPR“) and the provisions of the Italian Data Protection Authority (the “Data Protection Authority“) no. 229/2014 on the identification of simplified procedures for the provision of information and acquisition of consent for the use of cookies, SILVER FIR CAPITAL SGR S.p.A., in its capacity as a data controller (the “Data Controller“), provides you with the following information regarding the cookies installed on the domain (the “Website“).


  1. What are cookies?

Cookies are small text strings that the sites you visit send to your terminal equipment (usually your browser), where they are stored and then sent back to the same sites the next time you visit.

Some cookies are installed by the site operator and are known as “first-party” cookies. While visiting a website, a user may also receive cookies on their terminal that are sent from different websites or servers (“third parties”), which contain certain elements (such as, for example, images, maps, sounds, specific links to pages on other domains) found on the website that the user is visiting.

Depending on the type and purpose of the cookies, different requirements and purposes under data protection legislation apply. The types of cookies used by the Website are set out below.


  1. Technical cookies

Technical cookies enable the transmission of a communication over an electronic communications network, or to the extent strictly necessary for the provider of an information society service explicitly requested by the subscriber or user to provide such a service.

For this type of cookie, it is not necessary to obtain the user’s consent, but the following information on the type and purpose of cookies used by the Website is sufficient:


  • A. Session or navigation technical cookies

They ensure normal navigation and use of the Website (e.g., they save your session, save your browsing preferences, remember certain selection criteria such as language, etc.).

These first-party cookies remain on the site for the duration of a session, that is, until you close the browser used for web browsing.


  • B. Functionality technical cookies

They allow the user to browse according to a set of selected criteria (for example, language) in order to improve the service provided to them. These first-party cookies remain on the site for the duration of a session, that is, until you close the browser used for web browsing.


  • A. Analytical technical cookies

The Website uses third-party analytics cookies, which are considered similar to technical cookies in that they are used directly by the Website operator to collect information, in aggregate form, on the number of users and how they visit the Website.

These cookies remain on the site for the duration of a session, that is, until you close the browser used for web browsing.


  1. Profiling cookies

The Website does not use profiling cookies, which are necessary to create user profiles in order to send advertising messages in line with the preferences expressed by the user within the pages of the Website.


  1. Managing cookie preferences

When you first access any page of the Website, you will see a banner containing a short information notice. By continuing to browse, by accessing another area of the Website or by selecting an element of the Website (e.g., an image or a link), you consent to the use of cookies.

Cookies are generated by opening and closing the browser (when you log in to a session) and are deactivated by clearing the browser cache.

You can also object to registering cookies on your hard drive by configuring your browser to disable cookies. For more information, see the specific help page of the web browser you are using.


  1. Communication and dissemination of data

The data collected using cookies may be processed by the system administrator. This data may be communicated to IT consultancy companies appointed as data processors.

The data collected using cookies will not be transferred to third parties or otherwise disseminated.

Data collected using Google Analytics cookies may be transferred by this third party outside the European Union, in particular to the United States of America, in compliance with the Privacy Policy. In any case, for more information, please visit Google’s cookie policy.


  1. User rights

As the party concerned by the processing of personal data, you have the right – at any time – to obtain confirmation of the existence or non-existence of such data and to know its content and origin, to verify its accuracy or to request that it be supplemented or updated, or corrected (Art. 15 and 16 of the GDPR).

In addition, you have the right to request deletion, restriction of processing, and portability of data, as well as the right to lodge a complaint with the supervisory authority and to object in any case, on legitimate grounds, to the processing of your personal data (Art. 17 et seq. of the GDPR). You can exercise these rights vis-à-vis the Data Controller or the Data Processor, using the following addresses: email:


  1. Data Controller and Data Processor

The Data Controller of personal data processing is SILVER FIR CAPITAL S.G.R. S.p.A., with a registered and operative office in Piazza San Babila n. 5, 20122, Milan (MI), email:, T: +39 02 7640 9833.

The Data Controller has decided not to appoint a DPO pursuant to Art. 37 of the GDPR.