Privacy Policy

Privacy policy for external contact persons

Privacy Policy

Introduction

Athena Investments (“Athena“) processes personal data about you as a contact person employed at a vendor, collaboration partner, client, or a stakeholder that Athena has entered into a contract with. Further, Athena processes personal data about you in connection with preparation of insider lists as required by the market abuse regulation.

Filing of complaint

If you wish to file a complaint regarding Athena’s processing of your personal data, you can contact the relevant contact person by email at privacy@athenainvestments.com or by telephone at +39 06 48793200.

You can also choose to file a complaint with the relevant local data protection authority.

In Denmark:

Danish Data Protection Agency (in Danish Datatilsynet)
Borgergade 28, 5
1300, København K
Telephone number: +45 33 19 32 00
Email address: dt@datatilsynet.dk
Website: www.datatilsynet.dk

In Italy:

Italian Data protection Supervisor (Garante per la protezione dei dati personali)
Piazza di Monte Citorio n. 121
00186 ROME
Telephone number: (+39) 06.696771
Email address: garante@gpdp.it
Website:https://www.garanteprivacy.it/web/guest

Personal data processed by Athena

Athena processes the ordinary personal data you have provided to Athena, i.e. your name, email, telephone number, address, your position in the company you are employed at, etc. In addition to the listed ordinary personal data, Athena processes your date of birth and national identification number in connection with preparation of insider lists as required by the market abuse regulation.

Athena does not process special categories of personal data (sensitive personal data) about you.

Purpose and legal basis for processing

The processing of your personal data is necessary for the purposes of the legitimate interests pursued by Athena which are regarded not to be overridden by your interests or fundamental rights. Such interests are, for instance, fulfilment of contractual obligations with the company that you are employed at, invoicing for the services your company provides to Athena or vice versa, contacting you if Athena has any questions to the specific services as well as maintaining and enhancing customer relationships.

If you are a stakeholder or you appear in our insider lists, Athena processes your personal data because it is necessary for compliance with a legal obligation to which Athena is subject.

Recipients of your personal data

Athena may disclose personal data about you to certain third-party recipients, such as intra-group companies or service providers. Such parties will only process personal data about you on behalf of Athena and in accordance with the instructions given by Athena. Thus, these third-party recipients are not permitted to process your personal data for their own purposes.

Transfer of your personal data to a third country (outside of EU/EEA)

In certain cases, your personal data may be transferred to outside of EU/EEA. Athena ensures that such transfer will be carried out in accordance with the applicable data protection laws. This entails that any party outside of EU/EEA that will receive your personal data will ensure an adequate level of protection, for example, by adhering to the EU-US Privacy Shield or entering into the EU standard contractual clauses with Athena. If you have any inquiries in relation hereto, you are welcome to contact Athena by sending an email to privacy@athenainvestments.com.

Storage of your personal data

Athena will store your personal data that is necessary for bookkeeping purposes for 5 years from the year which the invoice is related in accordance with the special rules on retention of bookkeeping material in the Danish Bookkeeping Act. Hereafter, such personal data will be deleted.

Athena will further store your personal data for as long as Athena is in contact about the business relationship, unless you instruct Athena to delete your personal data, which Athena will accommodate subject to retaining data necessary for business purposes, e.g. accounting, and legal requirements. If there is an actual or potential legal dispute with the company you are employed at, your personal data will be retained as long as necessary for these purposes.

Your rights as a data subject

As a data subject you have the right to access the personal data Athena processes about you. Furthermore, depending on the circumstances you also have the right to rectification of your personal data, erasure, restriction of the processing of your personal data, data portability and the right to object against the processing of your personal data.

If you wish to exercise any of the above-mentioned rights, you are welcome to contact Athena by sending an e-mail to privacy@athenainvestments.com.

Changes to this Privacy Policy

This Privacy Policy (“Privacy Policy“) will be updated on a regular basis and when necessary due to changes in applicable law. The Privacy Policy will always include information on the effective date of the most recent version. To the extent, the changes of the Privacy Policy are regarded as material and significant, you will be expressly informed hereof, for example, on Athena’s website.

Effective date of the recent update of this Privacy Policy

14/06/2018