Legal Documents

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•   This website contains proprietary information. The contents, and any opinions on information, advisory and products it contains, may not be modified, sold, or otherwise provided, in whole or in part, to any other person or entity without JCI Capital Ltd written permission. You may not reproduce (in whole or in part), transmit (by electronic means or otherwise), modify, link into, store, archive or in any other way use for any public or commercial purpose this site or any of the content without prior written permission of JCI Capital Ltd.

•   This website is intended for general information purposes. Any opinions on investment products contained herein are not intended to convey any guarantees as to the future investment performance of these products.

•   Under no circumstances should any material at this site be used or considered as an offer to sell or a solicitation of any offer to buy an interest in any security or investment managed by JCI Capital Ltd or its affiliates or any other product or service to any person in any jurisdiction, nor should it serve as the basis for any investment decision.

•   In addition to the information herein contained, one investor considering the products and services analysed should carry out his own due diligence, should carefully study the account forms, disclosure documents and/or risk disclosure statements which are provided directly by the asset management companies, banking or brokerage counterparties.

•   Past performance is no indication of future performance, and nothing on this Site should be interpreted to state or imply otherwise. The value of investments may fall as well as rise and investors may not get back the full amount invested.

•   This website may contain information that has been obtained from other sources. JCI Capital Ltd gives no representations or warranties as to the accuracy of such information, and accepts no responsibility or liability (including for indirect, consequential or incidental damages) for any error, omission or inaccuracy in such information.

•    In this website you may find addresses or hyperlinks leading out of this Website. The existence of any such links shall not constitute an endorsement, representation or warranty of such link. Users are advised that information on hyperlinked or referred-to websites is neither investigated nor analysed by JCI Capital Ltd. No warranty or representation, express or implied, is given as to the accuracy or completeness of such information.

•   JCI Capital Ltd reserves the right to change the terms, conditions, and notices under which this site is offered.

•   Opening this website shall not render the user a customer of JCI Capital Ltd nor shall JCI Capital Ltd owe such users any duties or responsibilities as a result thereof.

•   The Terms and Conditions of this website are without prejudice to any contractual terms you may enter into with us, which will take precedence over the Terms and Conditions of this website

•   Any use of this website shall be subject to UK law.

UK Stewardship Code Disclosure Statement

Under COBS 2.2 of the FCA Handbook, JCI Capital Limited (“the Firm”) is required to make a public disclosure in relation to the nature of our commitment to the above Code, which was published by the Financial Reporting Council (‘FRC’) in July 2010. The Code aims to enhance the quality of engagement between institutional investors and companies to help improve long -term returns to shareholders and the efficient exercise of governance responsibilities. It sets out good practice on engagement with investee companies and is to be applied by firms on a “comply or explain” basis. The FRC recognises that not all parts of the Code will be relevant to all institutional investors and that smaller institutions may judge some of the principles and guidance to be disproportionate. It is of course legitimate for some asset managers not to engage with companies, depending on their investment strategy, and  in such cases firms are required to explain why it is not appropriate to comply with a particular principle.

The seven principles of the Code are that institutional investors should:

  • Publicly disclose their policy on how they will discharge their stewardship responsibilities
  • Have and publicly disclose a robust policy on managing conflicts of interest in relation to stewardship
  • Monitor their investee companies
  • Establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value
  • Be willing to act collectively with other investors where appropriate
  • Have a clear policy on voting and disclosure of voting activity
  • Report periodically on their stewardship and voting activities

 

The application of these seven principles by a particular asset management company will depend upon the extent to which their business activities are subject to the Code. At the present time, although JCI Capital Limited endorses the principles of the Code, it does not comply with the detailed requirements of the Code for the following reasons:

  • We mainly invest in debt securities rather than equity instruments on behalf of our clients
  • We have no interaction with the management of companies in whom we invest on behalf of our clients
  • We determine our approach to stewardship on a case by case basis taking into account the actions that will lead to the most favourable outcome for the value of our investments

Should any of the above factors change, we will review our commitment to the Code at that time and make appropriate disclosure.

 

For further details on any of the above information, please contact: Stephen Ayme – Compliance Officer

JCI Capital Limited, September 2015

 

JCI Capital Limited Pillar 3 Disclosure and Policy as at 30 September 2015

Introduction

Regulatory Context

The Pillar 3 disclosure of JCI Capital Limited (“the Firm”) is set out below as required by the Capital Requirement Regulation Art. 431et seq.  This is a requirement which stems from Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on Prudential requirements for Credit Institutions and Investment Firms and amending Regulation (EU) No 648/2012 (“Capital Requirement Regulation”, “CRR”) which represented the European Union’s application of the Basel Capital Accord.  The regulatory aim of the disclosures is to improve market discipline.

Frequency

The Firm will be making Pillar 3 disclosures at least annually.  The disclosures will be as at the Accounting Reference Date (“ARD”).

Media and Location

The disclosure will be published on our website.

Verification 

The information contained in this document has not been audited by the Firm’s external auditors, as this is not a requirement, and does not constitute any form of financial statement and must not be relied upon in making any judgement on the Firm.

Materiality

The Firm regards information as material in disclosures if its omission or misstatement could change or influence the assessment or decision of a user relying on that information for the purpose of making economic decisions.  If the Firm deems a certain disclosure to be immaterial, it may be omitted from this Statement.

Confidentiality

The Firm regards information as proprietary if sharing that information with the public would undermine its competitive position.  Proprietary information may include information on products or systems which, if shared with competitors, would render the Firm’s investments therein less valuable.  Further, the Firm must regard information as confidential if there are obligations to customers or other counterparty relationships binding the Firm to confidentiality.  In the event that any such information is omitted, we shall disclose such and explain the grounds why it has not been disclosed.

Summary

The CRR, to which the Firm is subject to, has three pillars; Pillar 1 deals with minimum capital requirements; Pillar 2 deals with Internal Capital Adequacy Assessment Process (“ICAAP”) undertaken by a firm and the Supervisory Review and Evaluation Process through which the Firm and Regulator satisfy themselves on the adequacy of capital held by the Firm in relation to the risks it faces and; Pillar 3 which deals with public disclosure of risk management policies, capital resources and capital requirements.

The regulatory aim of the disclosure is to improve market discipline.

The Firm is an IFPRU broker, investment management firm and principal trader.  It acts as agent and principal. The Firm’s greatest risks have been identified as business and operational risk.  The Firm is required to disclose its risk management objectives and policies for each separate category of risk which include the strategies and processes to manage those risks; the structure and organisation of the relevant risk management function or other appropriate arrangement; the scope and nature of risk reporting and measurement systems; and the policies for hedging and mitigating risk, and the strategies and processes for monitoring the continuing effectiveness of hedges and mitigants.

The Company does not extend credit to third parties. The market risk system monitors suitability risk in relation to advisory and managed client mandates. All managed customers have their own settlement and custody arrangements and the Company only executes transactions on their behalf.

The Firm has assessed business and operational risks in its ICAAP and set out appropriate actions to manage them.

The Firm does not outsource any major business related operational function. Its IT infrastructure and IT support services are outsourced. In addition, the Firm relies on specialist external advisers for a number of matters, with a view to minimising operational risk. The Firm has an operational risk framework (described below) in place to mitigate operational risk.

Market Risk exposure has been assessed by the Firm Market risk arises principally through proprietary trading activity. The Firm has in place risk management procedures including a designated limit per trader which, when amalgamated, equals the total Firm limit. The Firm’s risk allocation and appetite is discussed at board meetings (or earlier as required). Periodic/daily reporting of all positions against the trading limits are communicated to the Chief Financial Officer.

The Firm’s Reporting Currency is GBP and all foreign currency assets are regularly converted into GBP on the basis of its needs

Background to the Firm

Background

The Firm is incorporated in the UK and is authorised and regulated by the FCA as an IFPRU Firm.  This is due to the firm being authorised to deal as principal, and place instruments on a non-firm commitment basis and on a commitment basis and gives the Firm the category of an IFPRU 730K firm.

The ICAAP covers the Firm only. The Firm is a Solo regulated entity.

Article 435

Disclosure: Risk Management Objectives and Policies
Risk Management Objective

The Firm has a risk management objective to develop systems and controls to mitigate risk to within its risk appetite.

Governance Framework

The Board of Directors is the Governing Body of the Firm and has the oversight responsibility.  It meets monthly and as at 30 September 2015 it was composed of:

  • Stephen Ayme
  • Francesco Masino
  • Chris Shepherd
  • Luca Vari

Further, on 6 November 2015, Flavio De Paulis was appointed to the Board of Directors.

The Board of Directors has oversight of risk management, as well as forming its own opinion on the effectiveness of the process. In addition, the Governing Body decides the Firm’s risk appetite or tolerance for risk and ensures that the Firm has implemented an effective, ongoing process to identify risks, to measure its potential impact and then to ensure that such risks are actively managed. Senior Management is accountable to the Board of Directors for designing, implementing and monitoring the process of risk management and implementing it into the day-to-day business activities of the Firm.

Risk Framework

The Firm has a risk management framework that includes a Risk Management Committee

Operational Risk

The Firm undertakes robust risk identification and scoring exercises across the Firm, this Risk Appetite Statement translates into the acceptance of risks rated L or below.  Any risk rated M or H is deemed to be unacceptable to the Company, deemed to be outside of the Firm’s Risk Appetite and must be addressed as a priority to ensure that it is able to receive a L rating.  Any risk rated M must be addressed as a priority to ensure that it is able to receive an L rating or have Pillar 2 capital allocated.

The bespoke IT system informs in real time market and credit risk exposure. Client services also constantly monitored so as to provide best service and best execution. Pre and post compliance functions are conducted in real time with further posted dated review and monitoring.

The Firm put in place a Model A clearing arrangement with and control and monitoring processes. This is complemented by the existing Model B arrangement in place which now provides additional and transaction bandwidth and system controls.

Market Risk

As a €730k full scope IFPRU investment firm, the Firm has a Trading Book in respect of its intra-day bond positions.  In addition there are Non-Trading Book Exposures, i.e. to Foreign Currency held on deposit and assets or liabilities held in Foreign Currency, such as Debtors, on the Firm’s Balance Sheet.   The Firm’s appetite for Market Risk is low (no overnight positions are held) and, for the purposes of Pillar 2, is assumed to be that calculated at Pillar 1.

Credit Risk

As a €730k full scope IFPRU investment firm, the Firm acts as principal, manages investments and neither holds client money nor assets nor lends money, and is, therefore, not exposed to Credit Risk in its traditional sense.  The Firm’s exposure to Credit Risk is the risk of failed trades, that commissions cannot be collected and the exposure to banks where revenue is deposited.  The Firm’s Credit Risk Appetite is low so the Firm only deals with regulated market makers and holds all cash with banks assigned high credit ratings.  Credit Risk, for the purpose of Pillar 2, is assumed to be that calculated at Pillar 1.

Disclosures concerning Board of Directors
  • Number of directorships (excluding those held in respect of FIRM) held by members of Board of Directors as at 30 September 2015

The number of outside directorships held by members of the Board of Directors is as follows:

  • Chris Shepherd – two
  • Luca Vari – one
  • Recruitment policy for selection of Board of Directors

The policy of the Company as at 30 September 2015 is to appoint relevant Heads of Departments and key personnel to the Board of Directors and to maintain an independent director. The object of the policy is to attract diverse skills, knowledge and experience to the Board of Directors. As at 30 September 2015,

  • Responsibility and Information Flow on risk to Board of Directors

As at 30 September 2015, The Board of Directors has oversight of the Firm’s risk management, with monthly reporting to the Board of Directors.

Article 437

Disclosure: Own Funds

The Firm is an IFRU Full Scope Firm. Tier 1 Capital comprises of share capital and audited reserves.

2015

£’000

Tier 1 Capital and Total Capital  

1,260

 

Article 438

Disclosure: Capital Requirements

The Firm has adopted the “Structured” approach to the calculation of its ICAAP Capital Resources Requirement as outlined in the Committee of European Banking Supervisors Paper, 25 January 2006.

The ICAAP assessment is reviewed by the Board of Directors and amended where necessary, on a yearly basis or when a material change to the business occurs. The Credit and Risk Committee reviews the ICAAP document to the Governing Body of the Firm which reviews and endorses the risk management objective each quarter or when a material change to the business occurs at the same time as reviewing and signing off the ICAAP document.

 

Article 112 exposure

8% of risk weighted exposure amount
2015

£

Central governments or central banks 0
Institutions 1,209
Corporates 94,071
Other items. 24,968
Total 120,248


Internal Ratings Based Approach
 

The Firm does not adopt the Internal Ratings Based Approach.

Article 439

Disclosure: Exposure to Counterparty Credit Risk

Counterparty credit risk is the risk that the counterparty to a transaction could default before the final settlement of the transaction’s cash flows.

For derivatives, counterparty credit risk arises primarily from unsettled security, commodity and foreign exchange transactions with a contractual settlement or delivery lag that is longer than the lesser of the market standard for the particular instrument or five business days (long settlement transactions).

The process for approving a counterparty’s risk exposure limit is guided by core credit policies, procedure and standards; experience and judgement of credit risk professional and the amount of credit risk. A Credit Risk committee has been established for the purpose of managing the counterparty credit risk exposure. Credit risk is monitored on a daily basis versus limits and any issues are escalated to risk and business management as appropriate.

The Firm does not engage in any credit derivative trading, hence no collateral or credit reserve are required. Furthermore, as the firm trades only intraday with no overnight exposures there is no wrong-way risk exposures.

All credit exposures are measured the mark-to-market method.

The Firm does not have any credit derivative hedge.

Article 440

Disclosure: Capital buffers

This disclosure is not in force as at 30 September 2015.

Article 441

Disclosure: Indicators of Global Systemic Importance

This disclosure is not applicable as we are not a Global Systemic Important Institution.

Article 442

Disclosure: Credit Risk Adjustments

Credit risk adjustments to exposure to trading counterparties are reviewed on a monthly basis by reference to the age of the exposure and the rating of the counterparty together with the company’s internal assessment of the counterparty (which is calculated by public domain information).

Any asset which is over 6 months past due is considered fully impaired unless there are mitigating circumstances.  However, no such balances existed at the balance sheet dated and the company considers that there is no assets where such a provision is needed for amounts past due for a shorter period or for any other probable loss except for small non-trading balances.

Counterparties are generally within the EU and US and large established institutions with significant market presence.

Article 443

Disclosure: Unencumbered Assets

All assets are unencumbered.

Article 444

Disclosure: Use of ECAIs
Article 112 exposure ECAIs and ECA Exposure value Exposure value after Credit Risk Mitigation
£’000 £’000
exposures to institutions; Fitch 5,447 5,447
exposures to corporates; Internal assessment

Suppliers – direct

489

103

489

103

 

Total

 

   

6,039

 

6,039

The Firm applies the standard association between ratings and credit quality steps as published by the EB.

For corporates with no assessment, an internal assessment if conducted with haircuts applied to reduce exposure.

Risk weighting is not lower than that for the standardized approach taking into account the country of incorporation.

Article 445

Disclosure: Exposure to Market Risk

The Firm has adopted the Trading Book and Non Trading Book (Articles 325-377) approach to its Pillar 1 capital calculation. Market risk exposure is calculated as follows.

Article 92(3) b requirements for trading book business

Item Own fund Requirement
Position risk nil
Large exposures which exceed limits in Arts 395-401 nil
Total nil

 

Article 92(3) c requirements

Item Own fund Requirement
Foreign Exchange Risk 38,246
Settlement Risk Nil
Commodities Risk Nil
Total 38,246

 

The Firm does not hold securitisation positions and therefore there is no Specific Interest Rate Risk to disclose.

Article 446

Disclosure: Operational Risk

The Firm uses the Basic Indicator Approach as set out in Articles 315-316 to calculate its Operational Risk Own Funds Requirement.

Item Own fund Requirement
Operational Risk £593,821

Article 447

Disclosure: Exposures in Equities not Included in the Trading Book

This disclosure is not required as the Firm does not have a Non-Trading Book Exposure to Equities.

Article 448

Disclosure: Exposure to Interest Rate Risk on Positions not Included in the Trading Book

Although the Firm has substantial cash balances on its Balance Sheet, there is currently no significant exposure to Interest Rate fluctuations.

Article 449

Disclosure: Exposure to Securitisation Positions

This disclosure is not required as the Firm does not Securitise its assets.

Article 450

Disclosure: Remuneration Policy

The Firm is a Remuneration Code Proportionality Level 3 Firm and has applied the rules appropriate to its Proportionality Level. The Governing Body is responsible for the Firm’s remuneration policy and generally meets on monthly basis. The Board of Directors includes one non-executive member and thus provides the required authority and independence for the determination of remuneration. All variable remuneration is adjusted in line with capital and liquidity requirements.

The Firm classifies senior managers and those staff whose professional activities have a material impact on the Firm’s activities as Remuneration Code Staff. The Firm has not paid a severance payment to a Remuneration Code Staff. The total number of Remuneration Code Staff is 4. The aggregate remuneration paid the Remuneration Code Staff during the previous 12 months was £715,488. No remuneration was awarded in the form of shares or share linked instruments or similar type of instruments to Remuneration Code Staff.

Total remuneration during the year financial year to 30 September 2015 was £715,459. No member of staff has been awarded a total remuneration of €1m or more.   All amounts relate to fixed remuneration.

Aggregate Quantitative Remuneration by Senior Management and other Remuneration Code Staff
  2015
  £’000
_____

 

Senior Management (SIF) 715
Other Remuneration Code Staff nil
_____

 

Total 715
_____

 

Article 451

Disclosure: Leverage

The leverage ratio at 31 December 2015 was 58%.

The ratio is calculated as Total Capital / Current assets (without off-balance sheet items).

The leverage ratio is calculated in accordance with the transitional provision exercised by the Regulator.

Management of company leverage is included a part of a departmental and company risk framework which is subject to review by the Board. The system is constantly being improved and enhanced as part of the company’s strategy to improve and enhance systems.

Limits are prescribed both in departmental and company basis, and on a gross and net intra-day basis.

The business does not trade on margin and as at the balance sheet date and 31 December 2015, did not have any off balance sheet items.

Web Disclaimer

The use of this website is subject to the following terms of use:

  • The material in the website is directed solely at Eligible Counterparties and Professional clients (as defined by the rules of the Financial Conduct Authority). The material is not directed at, may not be suitable for and should not be relied on by retail clients. By accessing the relevant pages you acknowledge that you are not a retail client.
  • Investments and foreign exchange can go up as well as down and involve the risk of loss. Past performance will not necessarily be repeated in the future.
  • The content of the pages of this website is for your general information and use only. It is subject to change without notice. The information contained in this website is believed to be reliable but no warranty or representation, expressed or implied, is given as to their accuracy or completeness
  • Your use of any information or materials on this website is entirely at your own risk, for which JCI Capital Limited shall not be liable. None of the services or investments referred to in this website is available to persons resident in any country where the provision of such services or investments would be contrary to local law or regulation. If you choose to use this website it is your sole responsibility to ensure you comply with any local laws and regulations and to seek legal advice if you are uncertain as to what these are.
  • Unless indicated otherwise, all information and images are the property of JCI Capital Limited.  By using the pages of this website, and/or by reading the material within it, you agree that you will use the information only for your internal business purposes and that you will not otherwise download copy, transmit or distribute in any way any of this material in whole or in part. All intellectual and other property information shall remain the property of JCI Capital Limited and no rights in it shall be transferred to you.
  • Unauthorised use of this website may give rise to a claim for damages and/or be a criminal offence. Any dispute arising from the use of this website is governed by English law.
  • From time to time this website may also include links to other websites, however these links are provided for your convenience to provide further information. JCI Capital Limited has no responsibility for the content of the linked website(s).
  • Trading futures, options or contracts for differences involves the risk of loss. You may lose more than the amount originally invested and, in respect of these products as well as other products traded on margin, you may have to pay more later. You should not invest in such products unless you are satisfied that they are suitable for you. It could be some time before you see a return on your investment. Changes in the rates of exchange between currencies may cause your investment/the income to go down or up. If you have any doubts as to the suitability of these investments you should seek financial advice.

JCI Capital Limited is authorised and regulated by the Financial Conduct Authority (FRN: 536817).

Registered Office: 78 Brook Street, London W1K 5EF. Registered in England & Wales (Company Number 7372983);     T: +44 (0)207 297 6700;   VAT No. GB 114182449

Extended Cookie Policy

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Activity strictly necessary for the functioning of the service

This Application uses Cookies to save the User’s session and to carry out other activities that are strictly necessary for the operation of the same, for example in relation to the distribution of traffic.

Activity regarding the saving of preferences, optimization, and statistics

This Application uses Cookies to save browsing preferences and to optimize the User’s browsing experience. Among these Cookies are, for example, those to set the language and the currency or for the management of first party statistics employed directly by the Owner of the site.

Other types of Cookies or third-party tools that might use them

Some of the services listed below collect statistics in aggregated form and may not require the consent of the User or may be managed directly by the Owner – depending on how they are described – without the help of third parties.

If any third party operated services are listed among the tools below, these may be used to track Users’ browsing habits – in addition to the information specified herein and without the Owner’s knowledge. Please refer to the privacy policy of the listed services for detailed information.

he services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics with anonymized IP (Google Inc.)

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Personal Data collected: Cookies and Usage data.

Place of processing: US – – Privacy Policy – Opt Out

Displaying content from external platforms

This type of services allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Google Maps widget (Google Inc.)

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Personal Data collected: Cookies and Usage data.

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This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

AddThis (Addthis Inc.)

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Personal Data collected: Cookies and Usage data.

Place of processing: US – Privacy Policy

Twitter Tweet button and social widgets (Twitter, Inc.)

The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.

Personal Data collected: Cookies and Usage data.

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Facebook Like button and social widgets (Facebook, Inc.)

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Personal Data collected: Cookies and Usage data.

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Google+ +1 button and social widgets (Google Inc.)

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Personal Data collected: Cookies and Usage data.

Place of processing: US – Privacy Policy

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The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.

Personal Data collected: Cookies and Usage data.

Place of processing: US – Privacy Policy

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In addition to what is specified in this document, the User can manage preferences for Cookies directly from within their own browser and prevent – for example – third parties from installing them. Through the browser preferences, it is also possible to delete Cookies installed in the past, including the Cookies that might possibly have saved the consent for the installation of Cookies by this website. It is important to note that by disabling all Cookies, the functioning of this site may be compromised. Users can find information about how to manage Cookies in their browser at the following addresses: Google ChromeMozilla FirefoxApple Safari and Microsoft Windows Explorer.

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Notwithstanding the above, the Owner informs that Users may take advantage of: Your Online Choices. This service allows Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of this resource in addition to the information provided in this document.

Data Controller and Owner

JCI Capital Limited 78 Brook Street W1K 5EF London – United Kingdom
[email protected]

Since the installation of third party Cookies and other tracking systems through the services used within this Application can not be technically controlled by the Owner, any specific references to Cookies and tracking systems installed by third parties are to be considered indicative. In order to obtain complete information, consult the privacy policy for the respective third party services listed in this document.

Given the objective complexity linked to the identification of technologies based on Cookies and their very close integration with the operation of the web, Users are encouraged to contact the Owner should they wish to receive any further information on the use of Cookies themselves and any possible use of them – for example, by a third party – carried out through this site.

Definitions and legal references

Personal Data (or Data)

Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

Usage Data

Information collected automatically from this Application (or third party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User

The individual using this Application, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refers.

Data Subject

The legal or natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller (or Owner)

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This Application

The hardware or software tool by which the Personal Data of the User is collected.

Cookies

Small piece of data stored in the User’s device.

Legal information

Notice to European Users: this privacy statement has been prepared in fulfillment of the obligations under Art. 10 of EC Directive n. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies. This privacy policy relates solely to this Application.