Privacy Policy

This document performs the function of the Privacy Policy of TRUST & WEALTH SRL (hereinafter also only: “Bespoke Trustees”) pursuant to Article 13 of the “European Data Protection Regulation” referred to in EU Regulation 2016/679 (hereinafter, “Regulation” or “GDPR” – General Data Protection Regulation).

Definition of “personal data”

For the purposes of this Privacy Policy, “personal data” – in accordance with article 4 of the Regulation – means “any information concerning an identified or identifiable natural person  («the data subject»); the natural person who can be identified, directly or indirectly, with particular reference to an identifier such as name, identification number, location data, an online identifier or one or more elements characteristic of their physical, physiological, genetic, psychic, economic, cultural or social identity” is considered identifiable”.

This Privacy Policy applies only to personal data collected through the

https://www.bespoketrustees.net (hereinafter, Site”).

This Privacy Policy does not apply to other websites owned by third parties, which can be accessed through any links on the Site.

Data voluntarily provided by the user

Bespoke Trustees collects some personal data (first name, last name, email address, telephone number, postal address, etc.) submitted to Bespoke Trustees by email.

Navigation Data

The  IT systems and software procedures responsible for the operation of the Site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.  This information is not collected to be associated with identified subjects, but by their very nature could, through processing and associations with data held by third parties, allow users to be identified. This data category includes the IP addresses of the computers used by users connecting to the Site, the uniform  resource identifier (URI) notation addresses of the requested resources, the time of the request, the method used to submit the request to the SERVER, the size of the file obtained in response, the numerical regulation indicating the status of the response given by the SERVER (successful, error, etc..) and other parameters related to the user’s operating system. This data is used for the purpose of obtaining anonymous statistical information on the use of the Site and to check its proper functioning, and is deleted immediately after processing. The data could be used for the assessment of liability in case of any computer crimes against the Site.

Use of cookies

The Site uses cookies in accordance with our Cookies Policy.

Purposes and methods of processing and legal basis of processing 

The above personal data will be processed exclusively in relation to the following:

1. the registration of the user for access to the content and information materials on the Site;
2. responses to requests for information or contact;
3. job or cooperation offers;
4. sending of newsletters, invitations to events, seminars, etc.;

Bespoke Trustees protects the personal data of users by adopting the security measures provided for by the Regulation.

Optional provision of personal data

Except as specified for navigation data, the user has the right to provide their personal data in the forms for registration to the Site or by email.  Failure to provide data has the following consequences:

• In case (a) of the preceding paragraph, failure to provide personal data may make it impossible for the user to access the contents and information materials on the Site;
• In case of (b) and (c) of the preceding paragraph, failure to provide personal data will make it impossible to send the requested information to the user and to consider any offers of employment or collaboration or their assigment;
• In case (d), failure to provide data will make it impossible to receive newsletters, invitations to events, seminars, etc from the Site.

Communication and dissemination of personal data

Users’ personal data will be accessible to employees and consultants of Bespoke Trustees formally designated as external or authorized data controllers. In particular, it should be specified that personal data will also be processed by B International Ltd, based at 38 Craven Street, London UK – WC2N 5NG for the management of the communication and marketing activities on behalf of Bespoke Trustees.

The management and storage of personal data will also take place on servers located within the European Union, owned by Bespoke Trustees or by third party companies appointed and duly appointed as data processors. However, Bespoke Trustees may, where necessary, move the location of the servers to Italy and/or the European Union and/or countries outside the EU In such case, Bespoke Trustees already ensures that the transfer of data outside the EU will take place in accordance with the applicable legal provisions, by concluding, if necessary, agreements that guarantee an adequate level of protection, and/or adopting the standard contractual clauses provided for by the European Commission. Some data may be communicated anonymously and aggregated to third parties for statistical purposes. In any case, this data does not allow the identification of users. Except in the cases permitted by law, or provided for in this Privacy Policy, personal data will not be disclosed or disclosed without the user’s consent.

Data retention period

Personal data will be processed by Bespoke Trustees until it is deleted from the Site by the user in cases (a) and (d). Personal data will be processed by Bespoke Trustees in the case of (e) until otherwise notified by the user. Personal data in cases (b) and (c) will be processed for a maximum period of one year, unless an employment or co-operation relationship is established or a professional assignment is given to Bespoke Trustees.

Source of the personal data being processed

Personal data are provided or collected directly by the user.

Rights of users with regards to their personal data

Rights granted to the user by GDPR include:

• Ask the professional for access to your personal data and any information relating to this; the rectification of inaccurate data or the integration of incomplete data; the deletion of personal data concerning you (at the occurrence of one of the conditions indicated in Article 17 (1) of the GDPR and in compliance with the exceptions provided for in paragraph 3 of the same article); the limitation of the processing of your personal data (to the use of one of the hypotheses indicated in Article 18(1) of the GDPR);
• request and obtain from the professional – in cases where the legal basis of the processing is the contract or consent, and the same is carried out by automated means – your personal data in a structured format that can be read by automatic device, also in order to communicate such data to another data controller (so-called right to portability of personal data);
• object at any time to the processing of your personal data to the use of specific situations that concern you;
• withdraw consent at any time, limited to cases where the processing is based on your consent for one or more specific purposes and concerns common personal data (e.g. date and place or birth or place of residence), or particular categories of data (e.g. data revealing your ethnic origin, political opinions, religious beliefs, state of health, or sex life). The processing based on consent and carried out before the withdrawal of the same, however, retains its lawfulness;
• lodge a complaint with the supervisory authority (Guarantor Authority for the Protection of Personal Data – www.garanteprivacy.it).

Exercise of rights and request for information

To exercise their rights and for any questions or requests relating to the processing of personal data by Bespoke Trustees, users may contact us at the following e-mail address: info@trustandwealth.net.

Data controller

TRUST & WEALTH SRL with registered office in 20121 Milan, Via Andegari 4.

Changes to the Privacy Policy

Bespoke Trustees may make changes to this Privacy Policy in order to transpose changes in national and/or community legislation, or to adapt to technological innovations or for other reasons. Any new versions of this Privacy Policy will be listed on the Site.

You are requested to review this Privacy Policy and to check it carefully periodically, in order to check for any updates or revisions that may be necessary.

Updated 8 July 2022