Privacy

PRIVACY POLICY PURSUANT TO ARTICLE 13 OF REGULATION (EU) 2016/679 – USERS OF THE WEBSITE

Definitions

  • Cookies: are text files (letters and/or numbers) that contain small amount of information which are stored by the browser in the User’s computer or mobile device when the User visits a website. At the Users’ subsequent visits the browser re-transmits cookies to the website that originated them. Cookies can be stored only for the amount of time needed to use a specific website (i.e. session cookies) or for a longer period of time independently from the session (i.e. persistent cookies).
  • Job Applications: the spontaneous job applications sent by the Users to FPB by way of an e-mail to info@fpblegal.com.
  • Personal Data: any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Privacy Policy: this document, consisting of the policy regarding the processing of Personal Data and the policy relating to Cookies.
  • Regulation: Regulation EU No. 2016/679 of April 27 2016.
  • Website: this website.
  • Processing: any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
  • Users: users of the Website.

Data Controller

The Data Controller referred to in this Privacy Policy is Studio legale Ferrari Pedeferri Boni & Soci – Studio Legale Associato, with its registered office in Milan (MI), Via Fatebenefratelli, 22, Italian Fiscal Code and VAT No 0878850966 (“FPB“).

Any request of the Users concerning the Processing of personal data performed by FPB regarding their Personal Data (including the exercise of the rights referred to in paragraph 7 below), will be addressed to FPB by mail service at the registered office, or by email to the following address privacy@fpblegal.com

Purposes and legal basis of Processing

  1. enabling navigation on the Website, primarily through the use of Cookies: consent.

The collection of Personal Data for the purpose referred to in letter a) is regulated in the Cookies Policy, available at the following paragraphs 8 and 9, of which FPB recommends reading.

  1. Management of Job Applications in favour of Users: consent.

The collection of Personal Data for the purpose referred to in letter b) is necessary in order to manage and answer to spontaneous Job Applications sent to FPB by the Users through the Website, and the refusal of the consent will prevent the User from sending his/her job application through the Website. This Processing operations are based on the free, specific, informed and unequivocal consent of the User, expressed through a declaration or positive action (eg flag) on ​​the Website. The withdrawal of consent can be exercised at any time, following the instructions in paragraph 7 letter a) of this Privacy Policy.

  1. Performing statistical analysis, in an aggregate form, in order to improve the use of the Website by Users, where possible, through the use of anonymous Personal Data (Personal Data that does not identify or make Users identifiable): legitimate interest.

The collection of Personal Data for the purpose referred to in letter c) is based on the legitimate interest of FPB represented by the benefit that the FPB can obtain from the setting up of a Website able to improve browsing and Users’ experience, which we believe to prevail Users’ right to privacy. Opposition to this Processing can be exercised at any time by following the indications in paragraph 7 letter f) of this Privacy Policy.

  1. management of the contact requests sent by the Users to FPB: legitimate interest.

The collection of Personal Data for the purpose referred to in letter d) is based on the legitimate interest of FPB represented by the benefit that FPB can obtain from managing the contact and/or assistance requests sent by the Users, which we believe to prevail Users’ right to privacy. Opposition to this Processing can be exercised at any time by following the indications in paragraph 7 letter f) of this Privacy Policy.

Personal Data collection procedures

  1. Personal Data automatically collected by the Website: these are the Personal Data collected by the Website through, but not limited to, Cookies (available at following paragraphs 8 and 9, of which FPB recommends reading);
  2. Personal Data entered on the Website or expressly communicated by the Users by email to FPB’s address available on the Website: these are the Personal Data provided, by way of example, in order to submit spontaneous Job Applications and to send contact requests to info@fpblegal.com.

Potential categories of recipients of Personal Data

Personal Data are processed by FPB and/or third parties, selected for reliability and competence, and to which such Personal Data may be disclosed as necessary or appropriate, provided that they are located within the European Union. In particular, FPB informs Users that Personal Data may be processed by, and/or communicated to:

  1. employees and/or collaborators of FPB;
  2. third parties suppliers of services necessary to guarantee the functioning of the Website (by way of example, a company that deals with hosting services);
  3. third parties having professional relationships with FPB, necessary for the management of the Job Applications.

Retention period of Personal Data (or criteria for its determination)

Personal Data are kept by FPB for the period of time strictly necessary to achieve the purposes for which they were collected, as indicated in paragraph 3 above. In particular, except for the exercise of the right of withdrawal of the consent referred to in the following paragraph 7 letter a) or the right of opposition referred to in paragraph 7 letter f), FPB retains Personal Data for the following duration terms:

  1. Cookies: for the purpose referred to in paragraph 3 letter a), Users are strongly advised to read the Cookies Policy, available at the following paragraphs 8 and 9;
  2. Personal Data for managing the Job Applications: for the purpose referred to in paragraph 3 letter b), for a period of 6 months from the receipt of the Job Application spontaneously sent by the User through the Website, in order to manage and answer to the Job Application sent by the User. By way of derogation from this deadline, in case of a grievance or a complaint being sent to FPB’s email address, the User’s Personal Data will be kept for the period referred to in letter d) below;
  3. Personal Data spontaneously sent to FPB’s contact e-mail address: for the purpose referred to in paragraph 3 letter d), for a period of 6 months from the receipt of the contact and/or assistance request sent by the User, in order to assess if the User requires further assistance on this regard. By way of derogation from this deadline, in case of a grievance or a complaint being sent to FPB’s email address, the User’s Personal Data will be kept for the period referred to in letter d) below;
  4. in any case, FPB is authorized to keep, in whole or in part, Personal Data for a maximum period of 10 years from their collection, limited to the information necessary to comply with legal obligations and enable FPB itself to investigate, exercise and defend, where applicable, its own right in court.

Once these terms have expired, FPB will automatically delete the Personal Data collected, or transform them into an irreversible anonymous form.

Users’ Rights

Pursuant to and for the purposes of the Regulation, for the period referred to in paragraph 6 of this Privacy Policy, each User has the right to:

  1. with reference to the Processing referred to in paragraph 3 letter b), withdraw the consent at any time, without prejudice to the lawfulness of the Processing based on consent before its withdrawal, by sending an email to FPB (see Article 7 of the Regulation);
  2. ask FPB for access to Personal Data and information regarding the related Processing and any copy in electronic format, unless otherwise specified by the User (see Article 15 of the Regulation);
  3. request the correction and/or integration of Personal Data, without undue delay (see Article 16 of the Regulation);
  4. for specific reasons (for example, unlawful processing, withdrawal of consent, non-existence of the purpose of the Processing), request cancellation of Personal Data, without unjustified delay (see Article 17 of the Regulation);
  5. with reference to specific cases (for example, inaccuracy of Personal Data, unlawful Processing, exercise of a right in court), request the limitation of Processing (Article 18 of the Regulation);
  6. to receive Personal Data in a readable format, in order to consent their transfer to a different data controller or, where technically feasible, to request the transmission of Personal Data by FPB directly to such different data controller (so-called portability of Personal Data – see Article 20 of the Regulation);
  7. with reference to the Processing referred to in paragraph 3, letters c) and d), to object at any time to the Processing of Personal Data by sending an email to FPB (see Article 21 of the Regulation);
  8. to receive Personal Data in a readable format, in order to consent their transfer to a different data controller or, where technically feasible, to request the transmission of Personal Data by FPB directly to such different data controller (so-called portability of Personal Data – see Article 20 of the Regulation);
  9. be informed by FPB without undue delay of any violations or unauthorized access by third parties to their systems containing Personal Data (so-called data breach – see Article 34 of the Regulation);
  10. propose a complaint to the supervisory authority of the EU country in which the User resides, works or in which they believe the violation of their rights has occurred (see Article 77 of the Regulation).

For further information on the terms and conditions for the exercise of the rights granted to the User, the latter may consult the text of the EU Regulation published at the following link: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016R0679&from=EN , or contact FPB in the forms provided for in paragraph 2 of this Privacy Policy.

COOKIES POLICY

Type of Cookies

  1. Technical Cookies:

 

  1. Purposes: these cookies are essential to make the Website working properly, allowing the User to navigate through and use its essential features. These cookiesdo not collect information on Users that could be used for marketing  Technical cookies are useful for, inter alia: (i) recording the data provided by the User during a browsing session; (ii) remembering the settings chosen and the login details of the User while browsing the Site; (iii) displaying contents in the language chosen for each access, recognizing from which country the User is connected (and remembering this setting in future accesses). Acceptance of these cookies is a necessary condition for the proper use of the Website, and their denial may prevent or severely impair the ability to browse the Website.
  2. Collected data: information related to the browsing.
  3. Term: session cookie.

  1. Cookies functional for browsing:

 

  1. Purposes: these cookies allow a significantly more comfortable use of the Website while browsing. These cookies remember the login details of the User, avoiding the data entry for each new session of browsing. These Cookiesare not essential for browsing the Website, but they make easier and faster its use.
  2. Collected data: information related to the navigation and concerning the User’s preferences showed while browsing the Website.
  3. Term: session and permanent cookies.

  1. Google Analytics cookies

  1. Purposes: these cookies are provided by Google Inc. to monitor, in an anonymous and aggregated manner, statistical analysis of the surfing of the Users on the Website, in order to adapt and improve the Website on the basis of such analysis outcomes, in compliance with the interests shown by the same Users.
  2. Collected data: information related to the device and the browsing session of the User on the Website, which never allow FPB to autonomously identify the Personal Data of the Users, such as: (i) the domain name from which the User accesses the Internet; (ii) the address of the website from which the User is connected to the Website, if available; (iii) the date and time of connection to the Website, how long the session lasted and which pages were visited; (iv) portion of the Internet protocol address (IP) of the User; (v) the User’s device operating system and the browser used by the User; (vi) the aggregated demographic details of Users who access the Site.
  3. Term: session cookie.

For further information about Google Analytics cookies, the User may access to the following web page: https://tools.google.com/dlpage/gaoptout.

Consent and denial to the Cookies

The User may give his/her consent to the use of the Cookies described in previous section 8, through the instruction indicated in the banner shown on the Website.

The consent given to the Cookies may be amended any time by the User pursuant to the instructions provided by this Privacy Policy, which is accessible through the link shown within the banner and in each page of the Website (footer). To this end, the User may also contact FPB any time, in order to obtain information regarding the specific procedures through which this User may express his/her consent or exercises selective denial or remove Cookies.

However, FPB informs that in case technical Cookies described in previous section 8.1 are disabled, the proper ability to browse the Website may be prevented or severely impaired. Therefore, in order to better use FPB’s services available through the Website, the User is strongly recommended to not disable the technical Cookies.

Save for the above, with reference to all the Cookies on the Website, the User may amend their settings, pursuant to the procedures to this end provided through the setting panel of the browser used, such as, for example:

Moreover, with specific reference to profiling and advertising Cookies, save for the faculty to use the instruments provided by the browser to enable or disable the single cookies, FPB informs the User that the website www.youronlinechoices.com lists the main providers whose services allow websites’ editors to collect and use information referred to the correct use of behavioural advertising. The User may disable or enable all the companies or, alternatively, set his/her preferences for each single company. To this end, the User may access to the instrument available at the web page www.youronlinechoices.com/it/le-tue-scelte in order to monitor every preference on the behavioural advertising given while browsing the Internet.