We take your security and data protection with the utmost reliability and professionalism. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Please note this website is not intended for children and we do not knowingly collect data relating to children.
1. IMPORTANT INFORMATION
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice sets out how we use and processes your personal data through your use of this website, including any data you may provide through this website when you contact us to request our services (by way of a contact form or an email or a phone call), and regardless of whether you become our client or not.
To summarise, this policy:
- Sets out the types of personal data that we collect about you
- Explains how and why we collect and use your personal data
- Spells out how long we keep your personal data for
- Explains how to lodge a complaint and at which authority
- Lays down when, why and with whom we will share your personal data;
- Sets out the legal basis we have for using your personal data;
- Explains the effect of refusing to provide the personal data requested;
- Indicates the different rights and choices you have when it comes to your personal data; and
- Explains how we may contact you and how you can contact us.
Davide Palazzo is the controller and responsible for your personal data (collectively referred to as ”Italian lawyers in London”, “we”, “us” or “our” in this privacy notice).That means Davide is the responsible for determining the purposes and means of the processing of your personal data.
Email address: email@example.com
YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal information we hold about you is accurate. Please keep us informed if your personal information changes during your working relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer the following categories of personal information:
• Identity Data
Full name and personal information (Including ID, National Insurance Number, Codice Fiscale, job title, date of birth, passport number).
• Contact Information
Billing address, delivery address, home, email address and telephone numbers.
• Technical Data
Including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Financial Details
Including bank account details, bank statements to evidence funding, tax status information for fraud prevention purposes and payment data, such as data necessary for processing payments and fraud prevention, including credit/debit card, numbers, security code numbers and other related billing information collected from publicly available resources and credit agencies.
• Usage Data
This includes information about how you use our website, and services.
• Other Data
This include any kind of documentation, in Italian or in English, relevant to the instructions we may receive from you / your matter.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
If you fail to provide the Company with personal information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
• Direct from you. You may give us your data by post, phone, email or otherwise. This includes personal data you provide when you:
• submit an enquiry regarding our services;
• enter into a client-attorney relationship with us; or
• give us some feedback.
• During the course of dealing with you for or on behalf of our clients.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
• From Electronic data source such as Company house, and from public source where you have made available your information online.
• Third parties involved in a legal proceeding., and those to whom you have given your consent to share your information with us (including bank, consultants, financial advisors).
• Technical Data from the following parties:
(a) analytics providers [such as Google based outside the EU];
(b) advertising networks; and
(c) search information providers.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• If it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• To reply to your enquiries or provide you with any information/services you may request to us from time to time.
• Where you have given explicit consent to do so.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by sending us an email at firstname.lastname@example.org
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
To perform our contract with you
- To assess whether we can act on your behalf and assist you with your matter, to determine the terms of engagement, to take steps to enter into a contract, to manage and administer the contract, to provide you with our services and to ensure that our records are kept update
- Updating and maintaining client records
- To contact you in the course of providing you with our services, and to deal with your enquiries and requests from time to time
- In order to provide you with any information or services that you request from us
- If we are working on your matter with other professionals, we will share data and disclose relevant data and information regarding your Matter where necessary. If you do not wish for us to do so, please notify your us in writing.
To comply with our legal obligations
- Collecting and providing information required by or relating to audits, enquiries or investigations by regulatory bodies.
- To comply with our legal and professional responsibilities and related disclosures, for activities relating to the prevention, detection and investigation of crime and comply with audits of regulatory bodies (such as conducting checks to identify and verify clients and their identity), and to comply with court orders and exercises and/or defend our legal rights
When it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests
- To comply with courts orders and exercise and and/or defend our legal rights
- For insurance purposes
- To enable access to all parts of our website, to notify you of any changes or developments to our website and to use, analyse information to administer, support, improve and develop our website (including troubleshooting, testing, system maintenance and support)
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
Personal data is not subject to disclose. All your personal data are strictly kept private and confidential at all times, unless we are expressly authorised by you to disclosure such data to third parties, or in the event we must comply with your instructions or with any relevant laws and regulations, applicable from time to time, under which we provide our services as lawyers.
6. INTERNATIONAL TRANSFERS
In order to deliver services to you it is sometimes necessary for us to transfer your Personal Data outside the European Economic Area (EEA), for example:
- if you or we have service providers located outside the EEA;
- if you are based outside the EEA;
- where there is an international dimension to the matter on which we are advising you.
As such, it may be necessary to transfer the personal information we collect to countries outside of the EEA which do not provide the same level of data protection as the country in which you reside and are not recognised by the European Commission as providing an adequate level of data protection. We only transfer personal information to these countries when it is necessary for the services we provide you, or it is necessary for the establishment, exercise or defence of legal claims or subject to safeguards that assure the protection of your personal information, such as European Commission approved standard contractual clauses.
In certain circumstances we may need to ask your consent unless there is an overriding legal need to transfer the Personal Data.
7. DATA SECURITY
All your personal data is saved on electronic data storage equipment and files kept in safe private locations where they will be secure and not available to any third parties. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements and where required, for the establishment, exercise or defence of legal claims. However we reserve the right to keep your personal data for a longer time where reasonably required by the specific purposes of my processing mentioned above.
Following this period of time, your physical and electronic files shall be securely and safely destroyed.
9. YOUR LEGAL RIGHTS
By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country.
To summarise, you have the right to:
Request access to your personal data.
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Ask for a correction of the personal data that we hold about you.
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request to delete or remove your personal data.
This is made where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data.
This is where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data.
This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Withdraw consent at any time where we are relying on consent to process your personal data.
However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Request the transfer of your personal data to you or to a third party.
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
If you wish to exercise any of the rights set out above, please Contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee to cover our administrative costs of providing the information for:
• baseless or excessive/repeated requests, or
• further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We’ll respond as soon as we can.Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll notify you and keep you updated.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You have the right by law to make a complaint at any time to the Information Commissioner’s Office, the UK’s supervisory authority for data protection issues (https://ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner’s Office so please contact us in the first instance.
Information Commissioner’s Office
Wycliffe House, Water Lane
Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113