Bank of America Merrill Lynch International Limited , Milan Branch (the “Company”) pursuant to section 13 of Italian Legislative Decree 196/2003 - Personal Data Protection Code (further on, the "Code"), acting as data controller (the “Data Controller”), will process personal data provided in the context of your contractual/professional relationship with the Company, otherwise collected in the course of the same relationship with the Company, according to section 4, par. 1, lett. a) of the Code.
Personal data (“Personal Data”) means any information relating to a natural person who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, the possession of the data controller under the contractual/professional relationship in force.
The processing of Personal Data referable to you will be carried out both with paper and electronic means, for the following purposes:
(i) purposes connected and necessary to the management and execution of the contractual relationship with the Company; and to notice your requests;
(ii) with the provision of your consent, also provided orally, for purposes connected to marketing and/or networking activities, such as sending invitations to participate in events specifically organized for that purposes. In addition, surveys and market researches, commercial and promotional communications concerning products and/or services provided by the Company can be involved. The purposes above will be carried out with automated and non-automated means (e.g. email, sms, ordinary mail, etc.). Your consent may be revoked at any time, for example, communications sent via email will give you the opportunity to refuse further sending. The consent is free and voluntary, and the refusal to provide it will only prevent you from receiving communications, promotions and offers, of course not affecting the contractual/professional relationship in force;
(iii) purposes related to the fulfillment of obligations required by law, regulations, national and EU provisions, rules imposed by public authorities.
The Company may communicate Personal Data referring to you for the purposes set out above, to the following entities: (i) natural persons, companies, associations or professional firms providing services or advice to the Company resident within the EU or in third countries; (ii) other companies of the group which the Company belongs to; (iii) subjects and entities allowed to access the data by legal provisions, regulations or public authorities' orders.
The subjects and entities mentioned above will act as autonomous data controllers or, in limited cases, they will be appointed by the Company as data processors. Upon request, the Data Controller can provide access to the list of subjects to which Personal Data may be communicated.
Furthermore, the Company informs you that Personal Data provided may be entirely or partially communicated to other companies belonging to the group to which the Company is part of, with legal offices within the EU or in third countries, according to the purpose limitation principle. In the field of the international transfer of Personal Data, in case of necessity to transfer your Personal Data to countries not providing an adequate level of data protection standards, the Company undertakes to implement the necessary and suitable security measures able to properly protect Personal Data.
The non-submission of Personal Data requested by law or necessary to perform and manage the contractual relationship may impede the execution of the relationship or to provide you with the adequate reply to your requests.
Lastly, you can exercise data subject’s rights as per section 7 of the Code and filing a request to the Data Controller in order to obtain confirmation about the existence of Personal Data referable to you, information about purposes, methods and subjects involved in the processing, the update, erasure, anonymization or, on legitimate grounds, the blocking of the data that has been processed unlawfully.
Data Controller is Bank of America Merrill Lynch International Limited, Milan Branch – Via Manzoni 5 – Milano