1. DATA CONTROLLER.
BERTACCO RECLA & PARTNERS. Address: Via San Damiano n. 9, 20122 Milan, tel. 02.45386060, e-mail firstname.lastname@example.org.
2. CONTACT DETAILS OF THE DATA PROTECTION OFFICER.
There is currently no Data Protection Officer.
3. PURPOSE AND LEGAL BASIS OF THE PROCESSING ACTIVITIES.
In case of browsing on the Site, the following types of personal Data (hereinafter also the “Data”) will be processed, for the following purposes:
These Data, necessary for the use of web services, are also processed for the purpose of:
a) obtaining statistical information about the usage of web services (most visited pages, number of visitors by time or day, geographical areas of origin, etc.);
b) checking the correct functioning of the services offered.
The navigation data are processed for the legitimate interest of the Firm to guarantee the security of the Site, checking its correct functioning and obtaining statistics in relation to its use (Article 6, paragraph 1, letter F) of the GDPR).
Data provided voluntarily:
a) in the e-mails / faxes spontaneously sent to our addresses: the optional, explicit and voluntary submission of personal Data to the e-mail addresses or fax numbers published on the Site entails the subsequent acquisition of such Data, necessary to respond to requests sent in relation to our legal services (Article 6, paragraph 1, letter b) of the GDPR). The User is free to provide such Data. However, failure to provide them may prevent obtaining the information or service requested;
b) in the contact forms on the Site: filling out the “Contacts” form on the Site and submitting your personal Data entails the subsequent acquisition of such Data, necessary to respond to requests sent in relation to our services (Article 6, co. 1, let.b) of the GDPR). The User is free to provide such Data. However, failure to provide them may prevent obtaining the information or service requested;
c) on the occasion of calls made to the telephone number of our Firm: when you contact our telephone number, we may process personal Data, spontaneously communicated to us during the telephone conversation or reasonably requested by us, to respond to your requests and provide what is necessary (Article 6, paragraph 1, letter b) of the GDPR). You are free to provide such Data. However, failure to provide them may make prevent obtaining is the information or service requested.
The Data provided on the Site when registering for the newsletter will also be processed for inclusion in the archive of Users / visitors who wish to receive our newsletter, to offer and manage the services requested, for administrative operations, as well as to fulfil specific obligations or to follow specific tasks required by law. The legal basis of the Data processing described above consists in the fulfilment of the contractual, pre-contractual or commercial relationship established of which the User is a party and in legal obligations.
With the free and optional consent of the User (Article 130 of Legislative Decree 196/2003; Article 6, paragraph 1, let. A) GDPR), which can be expressed by selecting the appropriate consent box, the Data provided may be used for providing information material as well as for statistical extrapolations, in any case until possible opposition.
4. COMMUNICATION OF PERSONAL DATA.
The subjects who can come into possession of the Data are the Firm’s lawyers and employees who deal with the management and maintenance of the Site and assist clients and potential clients. In the event that the User has provided consent to the processing Data for the purpose of receiving information material, the Firm’s corporate communication department can become aware of such Data. Furthermore, the External Data Processors (e.g. the Firm’s IT service providers) may become aware of personal Data. The Firm may release such Data upon request to the Judicial Authority as required by law. In no case will the Data be disclosed to third parties for marketing purposes.
5. TRANSFERRING PERSONAL DATA TO A THIRD COUNTRY OR TO AN INTERNATIONAL ORGANISATION OUTSIDE THE EUROPEAN UNION.
The transfer of Data outside the EU or to international organizations is not envisaged.
The Data Controller reserves the right to transfer your Data to countries outside the European Union if the transfer is covered by adequate decisions issued by the European Commission or by appropriate safeguards provided by the current legislation.
6. DATA RETENTION TIME.
The navigation data is not retained for more than seven days (except for any need to ascertain crimes by the judicial authorities). The other data will be stored in a form that allows the identification of the data subjects for the time necessary to fulfil the aforementioned purposes, compatibly with other legal obligations. Our firm has adopted a procedure for Data retention: also for reasons inherent to the ordinary prescription times, the minimum retention is currently envisaged in 10 years.
7. RIGHTS OF THE DATA SUBJECT.
At any time, you may exercise the following rights:
a) right of access, rectification, erasure, restriction: the Data Subject can obtain access to the Data at any time, rectification of the Data if incorrect, erasure of overabundant Data except for those required by law and restriction to process the Data.;
b) right to data portability: the Data Subject has the right to receive in a structured, commonly used and machine-readable format, the Data provided to a data controller and has the right to transmit such Data to another data controller without hindrance by the data controller to whom he provided them exclusively in the cases provided for by art. 20 of the GDPR;
c) right to revoke consent at any time: the interested party can revoke the consent at any time, assuming the consequences (including no longer receiving information material from the Firm), without prejudice to the obligation for the Data Controller to continue to hold the Data when this is necessary to fulfil a legal obligation or for the execution of a task of public interest or connected to the exercise of public authority vested in the Data Controller.
d) the right to file a complaint with a privacy supervisory authority.
e) for the purpose of sending informative material in case of consent, the Data Subject may nevertheless:i. request the Data Controller, at any time and free of charge, to receive communications exclusively through traditional contact methods such as paper mail or calls via operator; ii. object, at any time and free of charge, to the processing of the Data for the aforementioned purposes. In this case, the Data Subject’s right to object to the processing of the Data through automated contact methods (eg. E-mail, MMS or SMS messages, social networks, etc.), extends to traditional contact methods; iii. object, at any time and free of charge, to the processing of their personal data for the aforementioned purposes only in part, i.e. by expressing a choice on how to contact, without any consequence except the impossibility of receiving information material from the Firm.
The rights mentioned above can be exercised by post or by e-mail to the addresses indicated in paragraph 1 above.
8. COMPULSORY OR OPTIONAL NATURE OF THE PROVISION.
The provision of data is mandatory given the nature of the relationship that is established between the Data Subject and the Data Controller for the services requested, also related to the sending of the newsletter.
9. CONSEQUENCES OF A POSSIBLE REFUSAL TO RESPOND.
If customers / Users refuse to provide the mandatory data requested in relation to the requested services also related to the sending of the newsletter, the Data Controller will not be able to provide its service. On the other hand, no consequence is foreseen for the failure to provide any data of an optional nature.
BERTACCO RECLA & PARTNERS