Privacy Policy

PRIVACY POLICY ON THE PROCESSING OF PERSONAL DATA

www.saccuccipartners.com (Updated January 15, 2021)

This policy is provided pursuant to Articles 13, paragraph 1, and 14, paragraph 1, of the European General Data Protection Regulation (GDPR) no. 679/2016 and Article 13 of Legislative Decree no. 196/2003 of the Personal Data Protection Code, to those who interact exclusively with this website.

This policy is not provided for third-party websites that may be consulted through links present on this site.

This document contains all the necessary information to inform the data subject about the rules for processing and managing data collected through the site.

DATA CONTROLLER

The Data Controller is the associated law firm Saccucci & Partners – International Law Firm, Via Lisbona 9 – 00198 Rome, email studio@saccuccipartners.com

LEGAL BASIS FOR PROCESSING

The legal basis for processing the data subject’s personal data is consent.

By declaring to have read the information on the processing of their personal data, the data subject gives their consent to the processing.

The legal basis for some processed data may also be a contractual obligation or a legal obligation incumbent on the data controller.

PROCESSED DATA

While Browse the website, different types of data may be collected, some of which will be acquired automatically, while others only with the data subject’s consent. Specifically, the data collected through the website are as follows:

Technical Data

• IP (internet protocol) address
• Date and time of visit
• Browser used
• Number of clicks made
• Physical address of the device from which the connection is made (so-called MAC Address)
• Addresses in notation of requested resources
• Cookies

The acquisition of technical data is implicit in the operation of the website itself and never leads to the identification of the data subject.

Cookies

Cookies are small files that the website, or a third-party site, sends to the data subject’s terminal where they are stored and then retransmitted to the same sites when necessary.

The website does not use profiling cookies, but only technical cookies.

Technical cookies are anonymous cookies whose acquisition is necessary to allow the data subject to navigate the site and use all its features. Their presence also helps to make Browse and web use faster, for example by facilitating certain procedures when making online purchases, when authenticating in restricted access areas, or when a website automatically recognizes the preferred language. Specifically, the technical cookies used are:

• Functionality or Preference Cookies: These allow the storage of pre-selected functionality choices by the data subject, such as language or geographic area.
• Navigation Cookies: These ensure normal navigation and use of the website (allowing, for example, to make a purchase or authenticate to access restricted areas).

Technical cookies will be automatically deleted by the browser according to the methods provided by the browser itself.

Personal Data

• Name and Surname
• Email address
• Phone number
• Tax code or VAT number
• Place of residence or domicile

Personal data is recorded through the website only if consciously and voluntarily entered by the data subject before the provision of the service through the contact form on the “contacts” page, or another electronic tool.

SOCIAL NETWORKS

The website is equipped with plugins for the social networks Google, Facebook, LinkedIn, and YouTube. Any cookies may be activated if provided by the social network and only when the data subject voluntarily decides to use such plugins or if they have logged into the social network before Browse the site and the session is still active.

For the processing of data collected by social networks, please refer to their respective privacy policies:

• Google Plus: https://policies.google.com/privacy
• Facebook: https://www.facebook.com/policy.php
• LinkedIn: https://www.linkedin.com/legal/privacy-policy
• YouTube: https://www.youtube.com/static?template=privacy_guidelines

PURPOSES OF PROCESSING

The collected data will be used for the following purposes:

• To allow the data subject to request information;
• To allow the data subject to receive written or verbal information;
• To re-contact the data subject who has requested information;
• To perform anonymous statistical analysis;
• To defend the rights of the data controller.

NATURE OF PROVISION

The provision of personal data is optional. Failure to provide the requested personal data will prevent the data subject from using the services provided through the website, excluding navigation.

PERIOD OF RETENTION OF PERSONAL DATA

The data subject’s personal data will be retained for the time necessary to provide the requested service and/or to fulfill the contract entered into with the data subject and/or to comply with legal obligations.

PLACE OF PROCESSING

The data subject’s personal data is processed at the data controller’s headquarters, but it may also be transferred for data security purposes to different subjects, appointed as data processors, located in Italy or in any case within the European Union. The data subject can contact the data controller to obtain all information regarding such transfer and the responsible parties.

PROCESSING METHODS

Data processing occurs both through paper support and with the aid of electronic tools. The data provided and other data communicated to us and referring to third parties will be:

• Processed lawfully and fairly;
• Collected and recorded for specific, explicit, and legitimate purposes, and used in other processing operations compatible with those purposes;
• Accurate or, in any case, corresponding to the information provided to us;
• Relevant, complete, and not excessive in relation to the purposes for which they are collected or subsequently processed;
• Stored in a form that allows the identification of the data subject for a period not exceeding that necessary for the purposes for which they were collected or subsequently processed.

SECURITY MEASURES

Specific and adequate technical and organizational security measures are adopted pursuant to Article 32 of the European Regulation to minimize the risk of destruction, loss of data, illicit or incorrect use, unauthorized access, or processing not permitted or not compliant with the purposes for which they were acquired.

COMMUNICATION AND DISSEMINATION OF PERSONAL DATA

The data provided by the data subject will be communicated exclusively to qualified third parties and only where necessary for the performance of the requested services or for legal obligations, with a guarantee of protecting the data subject’s rights and in compliance with the European Regulation and the Privacy Code, duly appointed as data processors or data handlers, or to subjects to whom the communication of data is due by virtue of legal or regulatory provisions. In particular, your data may be communicated to:

• Subjects, entities, or authorities to whom the communication of your personal data is mandatory by virtue of legal or regulatory provisions;
• Individuals, companies, or professional firms that provide assistance and consultancy to the Data Controller in accounting, administrative, tax, and fiscal matters.

The complete list of data processors is available by sending a request to the Data Controller at the email address: studio@saccuccipartners.com.

Your personal data will not be subject to dissemination.

DATA TRANSFER ABROAD

The data subject’s personal data will not be transferred abroad, nor does the data controller intend to transfer it.

However, the data subject’s use of social plugins and the Google Analytics service itself will involve the sharing of some collected data with Google, Facebook, LinkedIn, and YouTube. For the transfer of such data, the data subject’s consent will not be necessary by virtue of what is established by the Italian and European authorities (Decision no. 1250/2016 – Privacy Shield).

DATA SUBJECT’S RIGHTS

The data subjects to whom the personal data refer have the right at any time to:

• Withdraw their consent to the processing of their personal data;
• Obtain confirmation of the existence or otherwise of the same data and to know its content and origin, verify its accuracy or request its integration or updating, rectification, or erasure;
• Obtain confirmation of the existence or otherwise of personal data concerning them, and their communication in an intelligible form.

The data subject has the right to obtain indications regarding:

• The origin of the personal data;
• The purposes and methods of processing;
• The logic applied in case of processing carried out with the aid of electronic instruments;
• The identification details of the data controller, data processors, and the designated representative;
• The subjects or categories of subjects to whom the personal data may be communicated or who may become aware of them as designated representative in the territory of the State, data processors, or persons in charge of processing.

The data subject also has the right to obtain:

• The updating, rectification or, when interested, the integration of the data;
• The erasure, transformation into anonymous form, or blocking of data processed in violation of the law, including those whose retention is not necessary in relation to the purposes for which the data were collected or subsequently processed;
• The certification that the operations referred to in numbers 1 and 2 have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in cases where this fulfillment proves impossible or involves a manifestly disproportionate use of means compared to the protected right;
• In cases of processing based on consent, the receipt of the provided data, in a structured, commonly used and machine-readable format.

The data subject has the right to object, in whole or in part:

• For legitimate reasons, to the processing of personal data concerning them, even if pertinent to the purpose of collection;
• To the processing of personal data concerning them for the purpose of sending advertising material or direct sales or for carrying out market research or commercial communication.

Requests should be addressed to the Data Controller via email at studio@saccuccipartners.com or, by mail, to Saccucci & Partners, via Lisbona 9, 00198 Roma.

The data subject always has the right to lodge a complaint with the Italian Data Protection Authority (http://www.garanteprivacy.it/home/diritti/come-agire-per-tutelare-i-nostri-dati-personali).

HOW TO CONTROL AND MANAGE COOKIE INSTALLATION

You can set your cookie preferences directly in your browser. For instance, you can prevent third parties from installing cookies. By setting your browser preferences, you can also delete previously installed cookies, including the cookie which includes your consent, if any, to cookie installation by this website. Please note that, by disabling all cookies, the operation of this website might be compromised. Further information on how to manage cookies in the most common browsers, is available at the following links: Google Chrome, Mozilla Firefox, Apple Safari, Microsoft Windows Explorer.

You can also visit the web site https://www.aboutcookies.org/, in English, to learn how to manage/delete cookies, based on your type of browser.