Privacy

PRIVACY POLICY
UPDATED TO EU REGULATION 2016/679

1) Introduction

Caiazzo Lex – Studio Legale takes user privacy very seriously and is committed to respecting it. This privacy policy (“Privacy Policy”) describes the personal data processing activities carried out by Caiazzo Lex – Studio Legale through the website www.caiazzolex.it (the “Site”) and the related commitments undertaken by the Firm in this regard.

Caiazzo Lex – Studio Legale may process the user’s personal data when visiting the Site and using the services and features available thereon. Specific information notices pursuant to Art. 13/15 of EU Reg. 2016/679 are normally published in the sections of the Site where users’ personal data is collected.

Where required by EU Reg. 2016/679, user consent will be requested prior to processing personal data. If the user provides personal data of third parties, they must ensure that the communication of such data to Caiazzo Lex – Studio Legale and the subsequent processing for the purposes specified in the applicable privacy policy comply with EU Reg. 2016/679 and applicable legislation.

2) Data Controller and Processor Identity Details

Data Controller:

Caiazzo Lex – Studio Legale

Via Vittorio Veneto, 54b

00187 – Rome, Italy

Tel. +39 06 99311259

info@caiazzolex.it

You may obtain information regarding data stored by us at any time and free of charge, and exercise your right to rectification, blocking, or erasure of data by contacting us via email or telephone using the contact details provided above.

3) Types of Data Processed

Visiting and consulting the Site generally does not involve the collection and processing of the user’s personal data, except for navigation data and cookies as specified below. In addition to so-called “navigation data” (see below), personal data voluntarily provided by the user when interacting with the Site’s features or requesting to use the services offered on the Site may be processed. In compliance with Privacy Regulations, Caiazzo Lex – Studio Legale may also collect user personal data from third parties in the course of its business activities.

4) Cookies and Navigation Data

The Site uses “cookies”. By using the Site, you consent to the use of cookies in accordance with this Privacy Policy. Cookies are small files stored on the hard drive of the user’s computer. There are two broad categories of cookies: technical cookies and profiling cookies.

• Technical cookies are necessary for the proper functioning of a website and to allow user navigation; without them, users may not be able to view pages correctly or use certain services.
• Profiling cookies are designed to create user profiles in order to send advertising messages in line with the preferences expressed by the user while browsing.

Cookies can also be classified as:

• “Session cookies”, which are deleted immediately when the browsing browser is closed;
• “Persistent cookies”, which remain stored within the browser for a set period of time. They are used, for example, to recognize the device connecting to a site, facilitating user authentication operations;
• “First-party cookies”, generated and managed directly by the operator of the website the user is browsing;
• “Third-party cookies”, generated and managed by entities other than the operator of the website the user is browsing.

5) Cookies Used on the Site

The Site uses the following types of cookies:

1. First-party session and persistent cookies, necessary to allow navigation on the Site, for internal security purposes, and for system administration;
2. Third-party session and persistent cookies, necessary to allow users to use multimedia elements present on the Site, such as images and videos;
3. Persistent third-party cookies used by the Site to send statistical information to the Google Analytics system, through which Caiazzo Lex – Studio Legale can perform statistical analyses of visits and access to the Site. The cookies used pursue exclusively statistical purposes and collect information in aggregated form.

Through a pair of cookies—one persistent and one session cookie (expiring when the browser is closed)—Google Analytics also saves a log with the start and end times of the visit to the Site. You can prevent Google from collecting data via cookies and subsequent data processing by downloading and installing the browser plug-in available at the following address: http://tools.google.com/dlpage/gaoptout?hl=it4. Persistent third-party cookies used by the Site to include buttons for certain social networks (Facebook, Twitter, and Google+) on its pages. By selecting one of these buttons, the user can publish the contents of the Site web page they are visiting on their personal social network page.

The Site may contain links to other sites (so-called third-party sites). Caiazzo Lex – Studio Legale does not access or exercise any control over cookies, web beacons, and other user tracking technologies that may be used by third-party sites accessible from the Site; Caiazzo Lex – Studio Legale exercises no control over content and materials published by or obtained through third-party sites, nor over their respective personal data processing methods, and expressly disclaims any related liability. Users are required to check the privacy policies of third-party sites accessed through the Site and to inform themselves regarding the conditions applicable to the processing of their personal data. This Privacy Policy applies only to the Site as defined above.

6) How to Disable Cookies in Browsers

It is suggested to read the guide for each respective browser regarding the cookie deactivation procedure.

7) Retention of Personal Data

Personal data is stored and processed through computer systems owned by Caiazzo Lex – Studio Legale and managed by Caiazzo Lex – Studio Legale or third-party technical service providers; for further details, please refer to the “Scope of Accessibility of Personal Data” section below. Data is processed exclusively by specifically authorized personnel, including personnel tasked with carrying out extraordinary maintenance operations.

8) Purposes and Methods of Data Processing

Caiazzo Lex – Studio Legale may process users’ common and sensitive personal data for the following purposes: use by users of services and features available on the Site, management of requests and reports from users, sending newsletters, managing job applications received through the Site, etc. Furthermore, with the user’s additional and specific optional consent, Caiazzo Lex – Studio Legale may process personal data for marketing purposes, i.e., to send promotional material and/or commercial communications relating to the Firm’s services to the indicated contact details, both through traditional methods and/or contact means (such as paper mail, operator-assisted phone calls, etc.) and automated means (such as internet communications, fax, e-mail, SMS, mobile device applications such as smartphones and tablets – apps -, social network accounts – e.g., via Facebook or Twitter -, automated phone calls, etc.).

Personal data is processed both in paper and electronic form and entered into the corporate information system in full compliance with EU Reg. 2016/679, including security and confidentiality profiles, and inspired by principles of fairness and lawfulness of processing. In accordance with EU Reg. 2016/679, data is kept and stored for the period of time necessary for processing.

9) Security and Quality of Personal Data

Caiazzo Lex – Studio Legale is committed to protecting the security of user personal data and complies with the security provisions set forth by applicable legislation to prevent data loss, unlawful or illicit use of data, and unauthorized access thereto, with particular reference to technical standards on minimum security measures. Furthermore, the information systems and software programs used by Caiazzo Lex – Studio Legale are configured to minimize the use of personal and identification data; such data is processed only to achieve the specific purposes pursued from time to time. Caiazzo Lex – Studio Legale uses multiple advanced security technologies and procedures designed to protect users’ personal data; for example, personal data is stored on secure servers located in protected and controlled access locations. Users can help Caiazzo Lex – Studio Legale update and maintain the accuracy of their personal data by communicating any changes regarding their address, qualifications, contact information, etc.

10) Scope of Communication and Access to Data

User personal data may be communicated to:

• All entities whose right of access to such data is recognized by regulatory provisions;
• Our collaborators and employees within the scope of their respective duties;
• All natural and/or legal persons, public and/or private, when communication is necessary or functional to the performance of our business and in the manners and for the purposes illustrated above.

11) Nature of Personal Data Provision

The provision of certain personal data by the user is mandatory to allow the Firm to manage communications, requests received from the user, or to contact the user back to follow up on their request. This type of data is marked with an asterisk [*]; provision is mandatory to allow the Firm to process the request, which otherwise cannot be fulfilled. Conversely, the collection of other data not marked with an asterisk is optional: failure to provide it will not entail any consequences for the user.

The provision of personal data by the user for marketing purposes, as specified in the “Purposes and Methods of Processing” section, is optional, and refusal to provide it will have no consequences. Consent given for marketing purposes extends to the sending of communications carried out through both automated and traditional contact methods, as exemplified above.

12) Rights of the Data Subject

12.1 Art. 15 (Right of Access), Art. 16 (Right to Rectification) of EU Reg. 2016/679

The data subject has the right to obtain from the data controller confirmation as to whether or not personal data concerning them is being processed, and, where that is the case, access to the personal data and the following information:

• a) the purposes of the processing;
• b) the categories of personal data concerned;
• c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
• d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
• e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
• f) the right to lodge a complaint with a supervisory authority;
• h) the existence of automated decision-making, including profiling, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

12.2 Right pursuant to Art. 17 of EU Reg. 2016/679 – Right to Erasure (“Right to be Forgotten”)

The data subject has the right to obtain from the data controller the erasure of personal data concerning them without undue delay, and the data controller has the obligation to erase personal data without undue delay where one of the following grounds applies:

• a) the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
• b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;
• c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
• d) the personal data has been unlawfully processed;
• e) the personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
• f) the personal data has been collected in relation to the offer of information society services referred to in Article 8(1) of EU Reg. 2016/679.

12.3 Right pursuant to Art. 18 – Right to Restriction of Processing

The data subject has the right to obtain from the controller restriction of processing where one of the following applies:

• a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
• b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
• c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise, or defense of legal claims;
• d) the data subject has objected to processing pursuant to Article 21(1) of EU Reg. 2016/679 pending the verification whether the legitimate grounds of the controller override those of the data subject.

12.4 Right pursuant to Art. 20 – Right to Data Portability

The data subject has the right to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data has been provided.

13) Withdrawal of Consent to Processing

The data subject has the right to withdraw consent to the processing of their personal data by sending a communication to the following address:

Caiazzo Lex – Studio Legale

Via Vittorio Veneto, 54b – 00187 – Rome, Italy

Tel. +39 06 99311259 – info@caiazzolex.it

accompanied by a photocopy of their identity document, containing the following text:

<<“Withdrawal of consent to the processing of all my personal data”>>.

Upon completion of this operation, your personal data will be removed from our archives as soon as possible.