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COOKIE POLICY

1. Data Controller

The Data Controller is:

ATLAS SOCIETA' DI GESTIONE DEL RISPARMIO S.P.A.
In abbreviated form: ATLAS SGR S.P.A.
VAT No.: 09935580960
Tax Code: 09935580960
EU VAT: IT09935580960
Registered Office: Corso Europa 16, 20122 Milano (MI), Italy
REA: MI-2122807
Certified Email (PEC): atlassgr-spa@legalmail.it

(hereinafter, the “Company” or the “Data Controller”).

2. What Are Cookies?

Cookies are small text files that websites send to a user’s device (computer, tablet, smartphone) where they are stored and later retransmitted to the same sites upon subsequent visits.

Cookies allow the Website to recognize a user’s device and facilitate navigation, improve functionality, and collect statistical information.

Cookies do not typically identify users directly, but they may allow identification when combined with other information.

3. Types of Cookies Used

The Website may use the following categories of cookies:

a) Technical Cookies (Strictly Necessary)

These cookies are essential for the proper functioning of the Website and do not require user consent.

They include:

  • Navigation cookies

  • Session cookies

  • Security cookies

  • Load balancing cookies

Legal basis: Article 6(1)(f) GDPR (legitimate interest in ensuring Website functionality).

b) Functional Cookies

These cookies allow the Website to remember choices made by the user (such as language preferences or region) and provide enhanced features.

These cookies require user consent where not strictly necessary.

Legal basis: Article 6(1)(a) GDPR (consent).

c) Analytical Cookies

These cookies collect aggregated information about how users interact with the Website (e.g., pages visited, time spent, traffic sources).

If analytical cookies are anonymized and configured to reduce identification risk, they may be treated as technical cookies under applicable Italian Data Protection Authority guidance. Otherwise, they require prior consent.

Examples may include:

  • Google Analytics (with IP anonymization enabled, where applicable)

  • Other web analytics tools

Legal basis: Article 6(1)(a) GDPR (consent), unless fully anonymized.

d) Profiling and Marketing Cookies

These cookies track browsing habits to deliver personalized advertising or measure marketing effectiveness.

These cookies are installed only with prior explicit consent.

Legal basis: Article 6(1)(a) GDPR (consent).

4. Third-Party Cookies

The Website may allow third parties to install cookies through embedded content or services (e.g., video players, analytics providers, social media plugins).

These third parties act as independent data controllers.

Users are encouraged to consult the privacy and cookie policies of such third parties.

5. Cookie Duration

Cookies may be:

  • Session cookies: deleted automatically when the browser is closed.

  • Persistent cookies: stored on the device until their expiration date or until manually deleted.

The duration of each cookie depends on its purpose and configuration.

6. Managing Cookie Preferences

Upon first access to the Website, users are presented with a cookie banner allowing them to:

  • Accept all cookies

  • Reject non-essential cookies

  • Customize their preferences

Users may withdraw or modify consent at any time through the dedicated “Cookie Settings” link available on the Website.

In addition, users can configure their browser settings to block or delete cookies. Disabling technical cookies may affect Website functionality.

7. Transfer of Data Outside the EU

Where third-party cookies involve data transfers outside the European Union, such transfers will take place in compliance with Articles 44–49 GDPR, including the adoption of Standard Contractual Clauses where required.

8. Data Subject Rights

Data subjects may exercise the rights provided by Articles 15–22 GDPR, including:

  • Right of access

  • Right to rectification

  • Right to erasure

  • Right to restriction

  • Right to object

  • Right to data portability

  • Right to withdraw consent

Requests may be sent to:
atlassgr-spa@legalmail.it

Data subjects also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali).

9. Changes to This Cookie Policy

The Company reserves the right to amend this Cookie Policy at any time. Updates will be published on the Website with the relevant revision date.

Revision Date: 21 Febraury 2026

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