Data Controller
Data controller is Portolano Cavallo Studio Legale, via Rasella 155, 00187 – Rome; telephone no.: +39 06 696661; e-mail address: info@portolano.it.
Definition of “Personal Data”
For the purposes of this Privacy Policy, for “personal data” – in compliance with Article 4 of the GDPR we shall mean “any information relating to an identified or identifiable natural person (‘data subject’); 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”.
This Privacy Policy only applies to the personal data collected through the website www.portolano.it(hereinafter, the “Website”) or with any other modality described herewith. This Privacy Policy does not apply to all data collected through other websites belonging to third parties, even if those websites can be accessed by means of a link on the Website. Please refer to the privacy policies of such third parties’ websites for information on the processing of personal data carried out by the them.
Categories of Data Processed
1) Data Provided Voluntarily by the Data Subjects
The Firm collects some personal data (name, surname, e-mail address, telephone number, postal address, etc.) that is voluntarily provided by the users of the Website by means of ad-hoc registration forms filled on the Website (e.g. subscription to our newsletter) or sent by e-mail or provided to the Firm or to its professionals or collaborators by the data subject himself/herself in some other way (for example: exchange of business cards, exchange of emails or other contact that shows through an active behavior an interest towards the activity of the Firm). Data that data subjects provide as part of applications for job positions in the Firm shall be subject to the privacy policy at this link.
2) Netsurfing Data
Computer systems and software procedures in charge of the correct functioning of the Website may collect, during their normal activity, some personal data, whose transmission is implicit in internet communication protocols. This type of information is not collected in order to be linked to identified subjects, but by its own nature, through processing and in combination with third party’s data, such information might be able to be used to identify users. Such category of data includes, among others: IP addresses relating to the computer used to access the Website, URI (Uniform Resource Identifier) addresses of the requested resources, time of the request, procedure used to forward the request to the server, the size of the answered file, the numeric code that points to the condition of the server’s answer (successful, error etc.) and any other parameter relating to the user’s operating system. This type of data is used only for the purpose of gathering statistic and anonymous information on the usage of the Website and to assure its correct functioning, and is immediately erased after the processing. The above mentioned data could be used to determine possible criminal liability arising from computer crimes in prejudice of the Website.
3) Use of Cookies
The Website makes use of cookies as explained in our Cookie Policy.
Purposes and Modalities of Data Processing
The Firm processes the abovementioned personal data only in relation to:
a) subscription to newsletter, invitation to events and seminars, or subscription to mailing lists concerning the sending of communications relating to the Firm (events organized, certifications and prices received, information concerning careers within the Firm);
b) requests for information on the Firm or contact requests;
The Firm protects your personal data adopting all security measures prescribed by the GDPR. The Firm shall process the personal data about you only for the time necessary for the achievement of the purposes above described. The processing may be carried out with or without the use of electronic means as well as with automated systems.
Legal Basis for the Processing
In relation to the cases described above in sub a):
– the data subject may request to subscribe to our newsletter specifically indicating the areas of his interest, through the specific section of the Website, thereby asking to receive scientific articles on judicial matters, jurisprudential changes and other legal matters relating to the practice areas of the Firm; or
– the data subject may receive information on our events and seminars on the basis of our legitimate interest to keep contacts with the data subject when the data subject already subscribed to one of our events or newsletters (also considering his reasonable expectations), save the right to object (“opt-out”); or
– the data subject may be entered into a mailing list as a result of contacts with the Firm or with a professional or collaborator of the Firm (for example, exchange of business cards or other contact that may constitute an active behavior demonstrating interest towards the Firm); in such a case it constitutes a legitimate interest of the Firm to keep in contact with him/her by sending communications concerning the Firm as well as events organized by the Firm and that the Firm thinks could be of interest to the data subject (duly considering the expectations of the data subject), save the right to object (“opt-out”).
Optional Personal Data Provision
Without prejudice to the provisions on netsurfing data, the data subjects have the ability to provide or not provide his/her personal data in the forms on the Website or through e-mail. Not providing the Firm with such data, however, may render it impossible for the Firm to send you the communications and information you asked for.
Communication and Disclosure of Personal Data – International Data Transfers
The personal data collected will be accessible to the employees and collaborators of the Firm duly appointed as data processors or to persons in charge of the processing. Some data may be communicated in anonymous and aggregated form to third parties for statistical purposes. In any case, such data shall not permit the identification of the data subjects. With the exception of cases allowed by the law, or provided in this Privacy Policy, personal data shall not be communicated or disseminated without data subjects’ consent.
Rights of the Data Subjects with Reference to Their Personal Data
The data subject has the right to obtain at any time confirmation as to whether or not there is personal data concerning him or her being processed, to access such personal data, to ask to receive the data in a structured, commonly used and machine-readable format in order to transmit the data to another controller, as well as to request at any time the erasure of such personal data, to obtain the restriction of processing or to object, in whole or in part, on legitimate grounds, to the processing of his or her personal data, in particular where it is processed for direct marketing purposes, and the data subject may exercise such right also by clicking in the section for such purpose below every communication. The exercise of such rights, however, may be subject to some limitations and exclusions pursuant to the GDPR and the applicable regulations.
Where the processing is based on the consent of the data subject, it shall be understood that the data subject has the right to withdraw his or her consent at any time. Such withdrawal shall not affect the lawfulness of processing based on consent given before withdrawal.
Right to lodge a complaint
Without prejudice to any other administrative or judicial remedy, every data subject, where it considers that the processing of personal data relating to him or her infringes the law, shall have the right to lodge a complaint with a supervisory authority.
Changes to this Privacy Policy
The Firm can amend this Privacy Policy in order to comply with developments in national and/or European law, as well as to keep up with technology innovations and other similar reasons.
Possible amended versions of this Privacy Policy will be published on the Website. Please read this Privacy Policy carefully and check periodically if there have been any amendments or revisions.
Exercise of Users’ Rights and Request of Information
To exercise your rights and for any questions or requests concerning the processing of your personal data by the Firm and this Privacy Policy, please contact us at the following e-mail address: info@portolano.it.
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