Privacy and Cookie Policy

HSBC Global Asset Management (France) (hereinafter also “AMFR”) is committed to protecting clients' privacy and maintaining the confidentiality and security of client information.

This page describes management of the website www.etf.hsbc.com/etf/it (the “Site”) as regards processing the personal data of users accessing the Site.

This information is provided, also pursuant to the art. 13 of Legislative Decree no. 196/2003 (the “Privacy Code”), to users visiting the Site.

The information applies to the Site only and does not concern any other websites which may be visited by an user via external links.

AMFR does not disclose client information to anyone, except as permitted by law and as deemed necessary by AMFR to provide our services through the Site. This may include sharing information with affiliated and non-affiliated companies that perform support services. In addition, AMFR may provide information to governmental or other entities to comply with applicable laws and regulations.

DATA CONTROLLER

Visiting this Site may result into the processing of data concerning identified or identifiable persons.

The data controller is HSBC Global Asset Management (France), with registered office in Coeur Défense, 110 esplanade du Général de Gaulle, La Défense 4, 92400 Courbevoie, France and postal code at 75419, Paris, Cedex 08, France.

CATEGORIES OF PROCESSED DATA

Navigation data

The information systems and software procedures relied upon to operate this Site acquire personal data as part of their standard functioning; the transmission of such data is an inherent feature of Internet communication protocols.

Such information is not collected in order to relate it to identified data subjects, however it might allow user identification per se after being processed and matched with data held by third parties. This data category includes IP addresses and/or the domain names of the computers used by any user connecting with this Site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.), and other parameters related to the user's operating system and computer environment.

These data are only used to extract anonymous statistical information on Site use as well as to check its functioning. The data might be used to establish liability in case computer crimes are committed against the Site.

Data provided voluntarily by users

Sending e-mail messages to the addresses mentioned on the websites, which is done on the basis of a freely chosen, explicit, and voluntary option, entails acquisition of the sender's address, which is necessary in order to reply to any request, as well as of such additional personal data as is contained in the message(s).

Cookies

No personal data concerning users is acquired by the website in this regard. However, cookies may be used in order to make websites work efficiently and help provide a better user experience.

Cookies are small text files, which often include a unique identifier that is sent by a web server to the user device (computer, smartphone, tablet or any other internet enabled de-vice used to visit a website), usually to the user’s browser, in which they are stored to be then retransmitted to the website on the user’s subsequent visits to those websites

The Italian applicable law (Privacy Code and rules enacted by the Italian Data Protection Authority (Garante per la protezione dei dati personali)) identifies two types of cookies:

Technical Cookies

Technical cookies are those used exclusively with a view to carrying out the transmission of a communication on an electronic communications network, or insofar as this is strictly necessary to the provider of an information service that has been explicitly requested by the contracting party or user to provide the said service." (art.122(1) of the Privacy Code).

They are not used for further purposes and are usually installed directly by the data controller or the website manager. They can be grouped into browsing or session cookies, allowing users to navigate and use a website (e.g. to purchase items online or authenticate them-selves to access certain sections); analytics cookies, which can be equated to technical cookies insofar as they are used directly by the website manager to collect aggregate information on the number of visitors and the pattern of visits to the website; functional cookies, which allow users to navigate as a function of certain pre-determined criteria such as language or products to be purchased so as to improve the quality of service.

Users' prior consent is not necessary to install these cookies, whilst information under art. 13 of the Privacy Code has to be provided in the manner considered to be most appropriate by the website manager – if only such cookies are relied upon

Profiling Cookies

Profiling cookies are aimed at creating user profiles. They are used to send ads messages in line with the preferences shown by the user during navigation. In the light of the highly invasive nature of these cookies vis-à-vis users' private sphere, Italian and European legislation requires users to be informed appropriately on their use so as to give their valid consent.

These cookies are referred to in article 122(1) of the Privacy Code where it is provided that "Storing information, or accessing information that is already stored, in the terminal equipment of a contracting party or user shall only be permitted on condition that the contracting party or user has given his consent after being informed in accordance with the simplified arrangements mentioned in section 13(3)."

Cookies used in the Site

The Site uses only technical cookies to make it work efficiently and help provide a bet-ter user experience. The Site does not use profiling cookie.

The Site uses functional cookies, which allow users to navigate in function of certain pre-determined criteria (such as language and the client type selected by the user) so as to improve the quality of service.

The user can delete or disable cookies at any time through the cookie control area of the browser if desired. The Cookie options are generally found within the Options menu then Privacy section of the user particular browser. Each browser is slightly different and constantly updating.

For more information on cookie visit the website of the Italian Privacy Authority (Garante della Privacy) http://www.garanteprivacy.it/cookie

PROCESSING ARRANGEMENTS

Personal data is processed with automated means for no longer than is necessary to achieve the purposes for which it has been collected. Specific security measures are implemented to prevent the data from being lost, used unlawfully and/or inappropriately, and accessed without authorisation.

DATA SUBJECTS’ RIGHTS

Data subjects are entitled at any time to obtain confirmation of the existence of personal data concerning them and be informed of their contents and origin, verify their accuracy, or else request that such data be supplemented, updated or rectified (art. 7 of the Privacy Code).

The above article also provides for the right to request erasure, anonymisation or blocking of any data that is processed in breach of the law as well as to object in all cases, on legitimate grounds, to processing of the data. All requests should be sent to HSBC Global Asset Management (France) at the address mentioned in the “Data Controller” section above.

This Privacy and cookie Policy can be amended at any time without prior notice.