Privacy Policy
Transparency is the foundation of trust. Find out exactly how Assemblea protects shareholder data and how we comply with EU Regulation 2016/679 (GDPR).
1. Who we are and our commitment
Assemblea ("We", "the Controller") is committed to protecting the confidentiality of your data. This policy explains how we collect, use and protect the personal information of users of our voting platform.
For the purposes of data protection legislation, we act both as a Controller (for the data of our direct clients) and as a Data Processor (for shareholder data uploaded by listed companies).
2. Categories of data we collect
To ensure the legal validity of votes, we process certain personal data necessary for the legal validity of votes:
- 01.Identification Data: first and last name, ID document series and number (where required under applicable legislation).
- 02.Financial Data: Number of shares held, voting rights.
- 03.Technical Data: IP address, audit logs, vote timestamp (for traceability).
3. Purpose of processing
We do not sell your data. We use it exclusively for:
- Conducting AGM/EGM meetings in accordance with Law 31/1990.
- Automatic generation of minutes and attendance lists.
- Validating participant identity through secure methods (2FA, e-Signature).
- Mandatory notifications regarding convening notices and voting results.
5. Your Rights
Under GDPR, you have the right to access, rectification, restriction, objection, erasure and portability.
Important regarding the "Right to be forgotten": Since shareholder voting data forms part of the company's statutory documents, complete erasure may be limited by legal archiving obligations (e.g. 10 years for financial and accounting documents).
