GDPR PRIVACY & COOKIES POLICY
Information notice, pursuant to article 13 of Regulation (EU) 679/2016 (“GDPR”)
In relation to personal data Studio Ponchio (the “Firm” or the “Data Controller“) will come into possession with in the context of professional duties that you appointed us with, we inform you of the following:
1. Purposes of the data processing
The processing of your personal data has the following purposes:
a) Provide you with professional services, in particular the correct and complete performance of the professional duties received, both in judicial and extrajudicial;
b) Compliance with legal obligations, in particular the correct performance of the obligations under money laundering regulation for the purpose of the Legislative Decree No. 231/2007 as amended;
c) Legislative updating, in particular to send newsletter with respect to any possible regulatory updates which could be in your interest (e.g. anti – money laundering regulation, Legislative Decree No. 231/2001, Privacy, Corporate Law, etc.);
d) Participation to client satisfaction surveys, in particular your personal data, with your prior express consent, might be communicated to third parties (e.g. Top Legal, Legal Community, etc.) that may contact you for quality evaluation of the professional services offered you by the Firm.
e) Events planning, in particular your data, with your prior express consent, may be processed to participate to events organized by the Firm.
2. Data provision and possible refusal consequences
With respect to points a) and b) above, personal data provision is necessary for the performance of the professional duties, to carry out the activities and obligations described above. In case of refusal to provide the Firm with your personal data, the Firm will not be able to provide you with any professional services.
With respect to points c), d) and e), personal data provision is optional and your refusal shall not adversely affect the possibility to provide you with our professional services.
3. Data communication
In accordance with the purposes indicated above, personal data will be communicated to the following recipients:
a) data processors identified from time to time.
b) entities authorized by the Firm (e.g. associates) and to the ones who operate in the judiciary, to counterparties and their defenders, to arbitration committee and, in general, to all those public and private entities to whom the communication is necessary for the correct performance of the purposes indicated above;
c) companies and professionals that the Firm may use to make its services and to provide professional services or to protect its rights (e.g., accountants, tax consultants, auditing consultants, etc.);
d) banks, financial and insurance institutions;
e) technical management company of network and information systems;
f) public authorities, in case of audits, investigations and/or inspections;
g) companies and professionals for events organisation (e.g. event agencies).
4. Data transfer
Personal data may be transferred to Member States and to non-EU countries for the purposes referred to in point 1. In case of data transfer to non-EU countries, such countries shall ensure an adequate level of protection based on a specific decision of the European Commission or, otherwise, the addressee will be contractually obliged to provide data protection at an adequate level comparable to the protection provided by the GDPR.
5. Retaining personal data
Personal data shall not be kept for a period of time longer than is necessary to achieve the purposes for which they were collected and subsequently processed. Please note that also for the purposes of the money laundering regulation, the data shall be kept for ten years after the end of our mandates. Personal data shall be kept throughout the duration of the mandates given to us and also for a subsequent period:
i. within the terms of the statute of limitation provided by the current legislation;
ii. within the terms provided by the legislation which impose retaining personal data (e.g. tax declarations or money laundering documentation);
iii. within the necessary period in order to protect the Firm’s rights.
6. Data Controller
The Data Controller is Studio Ponchio Società Tra Professionisti Dottori Commercialisti CPA S.r.l. (tax code IT 01775330382).
7. Data Protection Officer
The Data Protection Officer can be contacted by email: firstname.lastname@example.org
8. Data Subjects’ Rights
At any time, in pursuance of articles 15 and 22 of the GDPR, you have the right to:
a) access to your personal data;
b) request the correction of your personal data;
c) withdraw your consent to the processing and the disclosure of your personal data, at any time;
d) request to delete your personal data, wherever possible;
e) receive your personal data in a structured, commonly used and machine-readable format and transfer your personal data to another data controller;
f) object to the processing of your personal data, wherever possible;
g) obtain any limitation to the processing of your personal data, wherever possible;
h) lodge a complaint with the data protection authority;
i) receive a communication in case of personal data violation;
j) request information about:
i. the processing purposes;
ii. personal data targets;
iii. the addresses or addresses targets to which personal data were or will be communicated, in particular if the relevant data are transferred to non-EU countries addresses or to international organisation and adequate guarantees existence;
iv. the period of retaining personal data;
v. all the available information on data origin where data have not been obtained from the data subject.
You could exercise such rights and/or obtain more information on personal data processing by writing a notice to email@example.com.
Any User browsing the Website may receive a minimum amount of information on the terminals used, regardless of whether they are computer desktops, notebooks or mobile devices, in small text files called “cookies” saved in the directories used by the User’s Web browser. There are different types of cookies, some are aimed at making the Website’s use more effective and at improving the User’s surfing experience, and others at enabling special features. More information may be found on http://it.wikipedia.org/wiki/Cookie.
Visitors may configure their own browser in such a way as to be informed of the receipt of the cookies or refuse them. The browser’s acceptance of the cookies may be disabled by changing the above-mentioned settings.
Types of cookies used
This type of cookies allows some sections of the Website to work correctly. This Internet Website only uses technical cookies, that is those used only for the purposes of the “transmission of a communication over an electronic communications network, or as strictly necessary in order for the provider of an information society service explicitly requested by the subscriber or User to provide the service” (cf. section 122, paragraph 1, of the Code).
They are not used for any further purpose and are normally directly installed by the data controller or by the Website manager.
They may be split into surfing or session cookies, which ensure the normal surfing and use of the Website (allowing, for instance, to make a purchase or to authenticate to have access to restricted areas);
- analytics cookies, assimilated to technical cookies if used directly by the Website manager to collect information, jointly, on the number of users and on how they visit the Website;
- feature cookies, which allow the User to surf based on a series of selected criteria (for instance, language, selected products for the purchase) in order to improve the service supplied to the User.
The Users’ prior consent is not requested to install such cookies, however, notwithstanding the obligation to make the disclosure under section 13 of the Code, which the Website manager may supply, should the latter use such devices only, as the Website manager may deem more expedient.
The acquisition and processing of data resulting from the use of technical cookies is compulsory for looking at the Website. Should the User object, it will not be possible to fully and correctly look at the Website. Save for technical cookies, the general rule for “Filing the information on the terminal of a contracting party or of a user, or the access to information already filed” still remains that of the User’s prior and informed consent (opt-in). This means that all cookies which may not be defined as “technical” and which therefore show greater criticalities from the point of view of the protection of the Users’ private sphere such as, for instance, those used for profiling and marketing purposes, may not be installed on the Users’ terminals if they have not been first properly informed and they have not given the relevant valid consent to said extent.
Third party Cookies
This type of cookies integrates features developed by third parties inside the Website’s pages, such as the icons and preferences given on the social networks in order to share the Website’s contents or for using third party software services (such as the software for generating maps and further software offering additional services). These cookies are sent from third party domain names offering their features amongst the Website’s pages.
For these types of cookies, the User may give the respective consent in one or more of the following ways:
- Through specific configurations of the browser used or of the relevant computer programmes used to surf the Website’s pages.
- By changing the settings for using the third party services.
The following cookies may appear on some of the Website’s pages:
By filling in the contact form with the respective Data, the User gives the respective consent to their use to answer to the requests for information, fee estimate, or of any other kind mentioned in the form’s heading.
Email, Name and Surname – Data not kept.
Google+(Google Inc.)+1 Button and social widgets
Google+(Google Inc.)+1 button and social widgets. The Google+ +1 button and social widget are interaction services with Google+ social network supplied by Google Inc.
Facebook I Like Button and social widgets
(Facebook, Inc.) The Facebook “I Like” and social widgets are interaction services with the Facebook social network, supplied by Facebook, Inc.
Twitter Tweet Button and social widgets
(Twitter, Inc.) The Twitter Tweet button and the social widgets are interaction services with the Twitter social network, supplied by Twitter, Inc.
(Pinterest, Inc.) The “pin it” button is an interaction service with the pinterest social network, supplied by Pinterest, Inc.
(Google Inc.) Google Analytics is a Web analysis service supplied by Google Inc. (“Google”).
Google could use the Personal Data to contextualise and customise the advertisements of its own advertising network (script set for anonymous tracking).
(Google Inc.) Yotube is a service for viewing video contents managed by Google Inc., which allows this Application to integrate such contents inside its own pages.
(Vimeo, LLC) Vimeo is a service for viewing video contents managed by Vimeo, LLC, which allows this Application to integrate such contents inside its own pages.
(Google Inc.) Google Fonts is a service for viewing fonts managed by Google Inc., which allows this Application to integrate such contents inside its own pages.
How to disable the cookies
Most Internet browsers are initially set to automatically accept cookies. Users may change these settings to block the cookies or to notice that some cookies are sent to the user’s device. In the event of different devices (for instance, computers, smart phones, tablets, etc.), users must ensure that each browser in each device is adjusted to show the respective preferences concerning cookies. Please note that, by disabling the cookies, all the features of the Websites are not ensured.
Click on the menu button and select Preferences.
Select the Privacy window.
Under the chronology Settings item: select use customised settings.
To enable the cookies, mark the Accept the cookies from the Websites item; to disable them, remove the mark from the item.
In case of any problems with the cookies, also ensure that the Accept third party cookies option is not set on Never. For further information, read the article Disable third party cookies. Choose how long the cookies may remain stored:
Keep them until: their expiry: the cookies will be removed when they reach the expiry date (date set by the Website sending the cookies).
Keep them until: Firefox is closed: the cookies stored on one’s computer will be removed when Firefox is closed.
Keep them until: ask me each time: display an alert each time a Website tries to set a cookie and ask the user if he/she wishes this cookie to be saved.
For further information: Firefox Cookies Settings.
If you do not wish the Websites to store the cookies on your PC, you may block the cookies. You may also customise the Websites for which you which to block the cookies.
To block the cookies:
Open the desktop, then touch or click on the Internet Explorer icon on the applications bar.
Touch or click on the Tools Button and then touch or click on Internet Options.
Touch or click on the Privacy tab and, under Settings, scrolling up to block all cookies and then click on OK.
For further information: Internet Explorer Cookies Settings.
Click on the Chrome menu of the browser’s tools bar.
Click on Show advanced settings.
In the “Privacy” section, click on the contents Settings button.
In the “Cookie” section, you may block the saving of cookies:
– Block all cookies. Select “Prevent Websites from setting data”. Please note that if you select this setting, you will prevent most of the Websites requesting the access from working. When a cookie is blocked, the blocked cookie icon is displayed on the location bar.
– Block third party cookies only. Select the “Block third party cookies and the data from the Websites” checkbox. Even if you have added a Website in the Exceptions list and you have chosen to allow the relevant cookies, the Website’s third party cookies will not be accepted if you select this checkbox.
For further information: Cookies Settings on chrome
Preferences > Advanced > Cookies These settings allow to configure the cookies management on Opera. The default setting foresees to accept all cookies. Accept the cookies only from the Website you are visiting. The third party cookies, which are sent from a domain name other than that you are visiting, are refused. Never accept the cookies. All cookies are refused. For further information: Opera cookies Settings
To set the cookies block by Safari on iOS 8, touch Settings > Safari > Block cookies and choose “Allow always”, “Allow only from the Websites I visit”, “Allow only from this Website”, or “Block always”. In iOS 7 or less recent versions, choose “Never”, “Of third parties and advertisers” or “Always”. For further information: Safari cookies Settings