Privacy
The aim of this document is to describe in general the methods of management of the Dalla Vedova Law Firm's website (hereinafter referred to as "Website") with reference to the processing of personal data of users who browse it (the document does not apply to the processing carried out on other websites, pages, online services that may be reached by the user through hypertext links on this Website).
This document has been drafted in compliance with the principles and provisions regarding the Privacy Policy envisaged by Regulation (EU) no. 2016/679 concerning the protection of personal data ("GDPR").
Following consultation of this Website, data relating to identified or identifiable persons may be processed.
Data Controller
The Data Controller is the Dalla Vedova law firm, based in Rome, Via Vittorio Bachelet n. 12 - 00185, tel. +39 064440821 - fax +39 064462165 - e-mail: dvsl@dallavedova.com.
The processing operations related to the web services of this Website take place at the aforementioned premises of the Dalla Vedova law firm and are handled only by technical staff of the firm in charge of processing, as well as at the premises of the Data Processors referred to below.
Data processors
Specialized technicians in charge of maintenance and operational management of the web platform, as well as job consultants and accountants, whose names are available at the firm premises, may be recipients, pursuant to art. 28 of the GDPR, of the data collected following the consultation of this Website, as Data Processors appointed by the Data Controller.
Legal basis of the processing
The processing of personal data mentioned in this document by the Dalla Vedova law firm is based on the consent of the concerned users, in accordance with the provisions of Articles 6 and 7 of the GDPR, unless it is carried out to fulfill a legal obligation to which the Firm is subject in its capacity as Data Controller.
Any communication of personal data of users to third parties is based on the consent of the concerned users, unless the communication must be made to individuals required to process said data, or to judicial or administrative authorities, for the execution of specific legal obligations.
Categories and personal data being processed and purposes of the processing
Browsing data
The computer systems and software procedures used to make this Website operational, during their normal working, collect some personal data whose transmission is implicit in the use of Internet communication protocols.
Although such information is not collected to be associated with identified interested persons, the very nature of said information could allow users to be identified, through processing and association with data held by third parties.
This category of data includes IP addresses or domain names of the computers used by users connecting to the Website, the addresses detected by way of the Uniform Resource Identifier (URI) with respect to the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (success, error, etc.) and other parameters relating to the operating system and the user's computer environment.
Such data are used for the sole purpose of obtaining anonymous statistical information on the use of the Website and to check its correct functioning and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes to the detriment of the Website: apart from such an event, the data on web contacts spots are not stored permanently, unless any requests of the same users (e.g.: access to the pages of the Website that summarize the services used, the information requested, etc).
Data voluntary provided by the user
The optional, explicit and voluntary sending of e-mails to the addresses indicated on the Website entails the subsequent collection of the sender's address, necessary to respond to such requests, as well as any other personal data included in the message.
Specific summarized information will be progressively reported or displayed on the pages of the Website prepared for particular services upon request.
Use of cookies or other users’ permanent tracking/monitoring systems
No personal data of users is collected by the Website in such regard.
We do not use cookies to transmit information of a personal nature or for the purpose of profiling users, nor persistent cookies of any kind, neither systems for the permanent tracking of users.
The use of the so-called session cookies (which are not stored permanently on the user's computer and disappear when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to allow a safe and efficient browsing of the site.
The so-called session cookies used on the Website avoid the use of other technologies that could compromise the privacy of users' browsing, further to not allowing the acquisition of personal identification data.
Other cookies are used on this Website in an anonymized form for the access analysis service of Google Analytics.
Method of treatment
Personal data are processed for the time strictly necessary to achieve the purposes for which they were collected and which, however, does not exceed the deadlines set forth by the applicable legislation.
Pursuant to and for the purposes of Article 32 of the GDPR, suitable security measures are observed to prevent the risks of destruction or loss of data, of unauthorized access to said data, as well as of data processing not allowed or not compliant with the purposes of the data collection.
Data transfer abroad
Users' personal data may be communicated by the Data Controller to subjects located in the territory of the European Union and in countries outside the EU.
In relation to the transfer of your personal data in non-EU countries, this transfer can be made to:
a) third countries / international organizations for which there is an adequacy decision of the European Commission;
b) third countries / international organizations for which there are adequate guarantees pursuant to art. 46 of the GDPR and the interested parties have rights to action and effective remedies;
c) third countries / international organizations for which the transfer of personal data is permitted pursuant to art. 49 of the GDPR, provided that one of the following conditions exists: (i) the concerned party has explicitly consented to the proposed transfer, after being informed of the possible risks of such transfers for the person concerned, due to the lack of an adequacy decision and guarantees adequate, or (ii) the transfer is necessary for the execution of a contract concluded between the data subject and the Data Controller or the execution of pre-contractual measures taken upon request of the data subject, or (iii) the transfer is necessary for the conclusion or execution of a contract between the Data Controller and another natural or legal person in favor of the data subject, or (iv) the transfer is necessary for important reasons of public interest, or (v) the transfer is necessary to ascertain, exercise or defend a right in court, or (vi) the transfer is necessary to protect the vital interests of the person concerned or other persons, if the person concerned is physically or legally unable to give consent, or (vii) the transfer is made from a register which, under the laws of the European Union or the Member States, aims at providing information to the public and can be consulted from the general public as well as from anyone who is able to demonstrate a legitimate interest, only on condition that the requirements for consultation provided for by to the laws of the European Union or of the Member States are met; the foregoing without prejudice to the provisions of the further provisions of art. 49 of the GDPR.
A copy of any data transferred abroad, as well as a list of non-EU countries / international organizations to which the data are transferred, may be requested from the Data Controller, using the contact details indicated below.
Rights of the interested parties
The persons to whom the personal data refer are entitled at any time to obtain confirmation that personal data is being processed or not, and in such a case, to obtain access to personal data and information pursuant to art. 15 of the GDPR[1], to rectification (Article 16 of the GDPR[2]) or erasure of said data (Article 17 of the GDPR[3]), as well as to restriction of the processing of data (Article 18 of the GDPR[4]), or to object such processing (Article 21 of the GDPR[5]), as well as to lodge a complaint with a supervisory Authority in charge of the protection of personal data (Article 77 GDPR[6]).
Such requests must be sent to the Data Controller, without formalities, by means of an e-mail to the following address: dvsl@dallavedova.com
[1] Article 15 of the GDPR: “Right of access by the data subject - 1. The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are 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 organisations; (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; (g) where the personal data are not collected from the data subject, any available information as to their source; (h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) 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. 2. Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer. 3. The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form. 4. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others”.
[2][2] Article 16 of the GDPR: “Right to rectification - The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement”.
[3] Article 17 of the GDPR: “Right to erasure (‘right to be forgotten’) – 1. The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies: (a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; 4.5.2016 EN Official Journal of the European Union L 119/43 (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 have been unlawfully processed; (e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; (f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1). 2. Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data. 3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary: (a) for exercising the right of freedom of expression and information; (b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; (c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3); (d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or (e) for the establishment, exercise or defence of legal claims”.
[4] Article 18 of the GDPR: “Right to restriction of processing 1. The data subject shall have 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 defence of legal claims; (d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject. 2. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State. L 119/44 EN Official Journal of the European Union 4.5.2016 3. A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted”.
[5] Article 21 of the GDPR: “Right to object – 1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims. 2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing. 3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes. 4.5.2016 EN Official Journal of the European Union L 119/45 4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information. 5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications. 6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest”.
[6] Article 77 of the GDPR: “Right to lodge a complaint with a supervisory authority – 1. Without prejudice to any other administrative or judicial remedy, every data subject shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes this Regulation. 2. The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Article 78”.