This notice describes the processing of personal data of guests and users of Di Pietro Studio Legale’s internet website (www.dpsl.it: the “Website”), as well as of those who decide to attend events, activities, and initiatives promoted through the Website (together, the “Users”).
DPSL may modify this privacy policy to adapt it to future extensions or future changes of the Website or services offered. In the case of significant changes, DPSL will publish a communication on the Website and/or send an email notification to report the changes and collect a possible request to exercise the rights recognized by the legislation on personal data protection.
1. Data controller
The data controller is Avv. Antonio Giuseppe Di Pietro, with legal office in via Bigli 28, Milano, Italy (“DPSL”).
2. Personal data categories
2.1. Personal data provided by the Users
The personal data gathered through the Website are the data communicated by the Users through the filling of the forms on the Website or by sending a request to DPSL at the addresses indicated on the Website.
The data collected include identification and contact data of the Users (name and surname, email address, telephone number), personal data inserted in the communications and requests sent to DPSL, as well as other data necessary to answer and to carry out specific Users’ requests.
We recommend Users to communicate only data that are updated, pertinent, and not exceeding the specific purposes of the processing. If Users find themselves in the necessity to communicate data of third parties, we remind Users to fulfill legal requirements relating to personal data protection and, particularly, to promptly inform third parties of the communication of their data to DPSL, and of the characteristics of the processing by DPSL.
Any unnecessary data will be immediately deleted or anonymized.
2.2. Navigation data
For every access to the Website, the systems automatically record and analyze the access data (IP address of the provider, information on the used browser, visited pages, date, time, and duration of each visit). Data are automatically collected through the Website and do not require any action by the User.
The data collected are exclusively anonymous and aggregated and they do not allow any possible identification of the Users: they allow only to detect and resolve possible technical problems.
3. Purposes of the processing
Personal data of the Users (“Data”) might be processed for the following purposes.
3.1. Newsletter or sectorial mailing list registration
The Data collected through the filling of the registration form to the newsletter service – or in order to receive any possible specific sectorial communication relating to sectorial mailing list services, which you have been invited or have required to be registered to – (name, surname, company, e-mail address) will be processed to send communications for information and academic purposes on the activity of DPSL, including possible invitations to events and/or conferences organized and/or sponsored by DPSL also in collaboration with third parties, or in which the lawyers of DPSL are involved as speakers.
The provision of Data is necessary to register to and benefit from the newsletter or sectorial mailing list services: therefore, in case of refusal or if the User does not communicate the requested data, the receiving of DPSL’s newsletter or sectorial communication will not be possible.
The User may revoke his/her registration to the newsletter or sectorial mailing list at any moment, following the procedure specified in the endnotes of each newsletter/sectorial communication or by sending a specific communication to DPSL at the addresses indicated in paragraph 7.
The processing is necessary for the performance of a contract to which the User is party and/or in order to take steps at the request of the User prior to entering into a contract, as well as DPSL’s legitimate interest in providing constant updates on relevant news in the area of interest of its clients or potential clients. Such legitimate interest does not prejudice the rights and freedoms of the data subjects, since the processing concerns data not belonging to special categories of personal data and is limited to sending communications and updates relating to the sector in which the data subject carries out its professional activity, or of its interest.
3.2. Event registration, follow-up, and simultaneous newsletter registration
The Data collected (name, surname, company, e-mail address) through the filling of the registration form to the events promoted on the Website or on online platforms of the data controller will be processed for: (i) the participation of the User to the requested event and the receiving of follow-up information related to them; and (ii) with the Users’ consent provided through the box at the bottom of the registration form on the different communication channels or online platforms, for sending DPSL’s newsletter.
3.2.1. Participation to the events and follow-up
The events can be organized and/or sponsored by DPSL, also in partnership with third parties, or will involve DPSL’s professionals as speakers.
In this context, the Data can be communicated to other public and private parties, involved in management and organizational activities, and/or to suppliers of necessary and accessory services (i.e. speakers, hostesses, communication companies in charge of sending service communications on the events). These parties will process the data, as appropriate, as independent data controllers or as data processors in virtue of a specific assignment conferred by DPSL. The provision of Data is necessary to complete the registration to the event: therefore, in case of refusal or if the User does not communicate the requested data, the attendance to the event will not be possible.
The processing is necessary for the performance of a contract to which the User is party and/or in order to take steps at the request of the User prior to entering into a contract, for compliance with relating legal obligations to which DPSL is subject, and, with respect to the sending of follow-up relating to the subjects covered during the event, the processing of the User’s Data finds its legal ground on the legitimate interest of DPSL in promoting its expertise and activities in those subjects. This legitimate interest of DPSL is deemed to be reasonable and in accordance with the User’s interest in being informed and up to date on the news and DPSL activities in the field of the subjects covered during the event.
In case of registration of the User to events and/or activities organized and/or sponsored (also) by third parties other than DPSL and upon the User’s consent (that can be expressed when sending the registration request to each event), the Data could be communicated also to such third parties, who will act as independent data controllers, according to their personal data protection policies that such third parties will send to Users in the respect of the deadlines set by the law. Such consent is merely discretional, and any refusal will not affect the registration of the User to the event. Such consent can be revoked at any time, by sending a specific communication to DPSL at the addresses indicated in paragraph 7, without prejudice to the lawfulness of the processing based on the consent given before the revocation.
3.2.2 Sending of DPSL’s newsletter
If the User gives its consent through the box at the bottom of the registration form, present on the Website or in the different online platforms, the Data collected on the occasion of the participation to the events promoted through the Website or the platforms will also be processed for sending DPSL’s newsletters via email.
Such consent is merely discretional, and any refusal will not affect the registration of the User to the event. Such consent can be revoked at any time, by sending a specific communication to DPSL at the addresses indicated in paragraph 7, without prejudice to the lawfulness of the processing based on the consent given before the revocation.
The above-described data processing is not necessary to participate in events promoted on the Website, and any opposition and/or revoke of the consent to the reception of such communications will not have any consequence for the User.
3.3. Management of unsolicited job applications
The Data collected through the filling of the recruiting form on the Website will be processed only for evaluating candidates’ profiles and for scheduling an interview (if needed).
The communication of Data marked with an asterisk (*) is necessary in order to reply to candidates’ applications: consequently, in case of failure in providing such Data, DPSL will not be able to evaluate the professional profile and the establishment of any possible collaboration.
The provision of Data included in the cover letter is merely discretional and any failure in their communication will not affect the candidate’s application.
The processing is necessary for the performance of a contract to which the User is party and/or in order to take steps at the request of the User prior to entering into a contract, and for compliance with relating legal obligations to which DPSL is subject.
3.4 Reply to Users’ requests
The Data will also be processed to reply to requests that Users may send to addresses available on the Website. For this purpose, Users need to communicate their contact details as, in their absence, it will not be possible for DPSL to reply.
The processing is necessary for the performance of a contract to which the User is party and/or in order to take steps at the request of the User prior to entering into a contract, and for compliance with relating legal obligations to which DPSL is subject.
4. Means of the processing
The Data will be processed through electronic and manual means by DPSL’s staff and associates, and/or by companies duly appointed as data processors and provided by DPSL with detailed operative instructions, especially concerning the adoption of minimum safety technical and organizational measures.
The whole list of data processors is stored at the Data Controller’s premises and shall be consulted upon request, to be forwarded to the addresses indicated in paragraph 7.
5. Data recipients
The Data shall be communicated and transferred to the categories of entities as described in the purposes and in the modalities of the processing.
If necessary to achieve the purposes of the processing, the Data can be transferred abroad also:
- in case of events that take place outside Italy;
- in case of a request regarding foreign jurisdictions.
The transfer of Data outside of the European Union will take place – if towards countries that do not benefit from an adequacy decision by the European Commission and, therefore, do not provide an appropriate level of personal data protection – only (I) upon the adoption of appropriate guarantees such as, for instance, the subscription of clauses approved by the European Commission, or (II) under a derogation from the ban of transfer outside the European Union, such as, for example, upon the collection of informed and explicit consents of Users, or to the extent that is necessary to execute a contract between the User and DPSL, or between DPSL and a third party for the benefit of the User.
6. Retention period
The Data collected and processed by DPSL, for the purposes described in paragraph 3, may be retained in such a way that allows the identification of the Users for a period of time necessary to achieve the purposes of the processing and, in particular:
- for the processing described in paragraphs 3.1. and 3.2.2., i.e. to receive DPSL’s newsletter, for a period of 36 (thirty-six) months from registration, extendable for further 36 months where the Users do not revoke its consent, through the link at the bottom of: (i) each e-mail sent; (ii) the e-mail that reminds the possibility to revoke the consent – sent one month before the deadline –, and (iii) the e-mail sent in case of a modification of this privacy policy;
- for the processing described in paragraph 3.2.1., i.e. for the participation to the events promoted on the Website, for the entire duration of the event and for the following 6 months;
- for the processing described in paragraph 3.3., i.e. for the evaluation of unsolicited job applications, for a period of 12 (twelve) months from the receipt of the application;
- for the processing described in paragraph 3.4, i.e. to answer to any Users’ request, for a period of 12 (twelve) months from the last contact.
The Data will be stored for a longer period if necessary to fulfill legal obligations, or for the protection of DPSL’s rights, until the expiry of the related prescription period.
7. Rights of the users and contact details
The Users may, at any time and within the limits in which the rights are applicable,: (I) obtain confirmation of the existence or non-existence of his/her personal data; (II) request the access to his/her personal data; (III) request the correction or cancellation of such data, or the limitation on their processing; (IV) oppose the processing, or revoke his/her consent to the processing, without prejudice to the lawfulness of the processing based on the consent given before the revocation; (V) receive in a structured, customary and machine-readable format his/her personal data provided to DPSL, as well as request that such data are transferred to another data controller (right of personal data portability); (VI) lodge a complaint to the personal data protection authority or to the competent judicial authority.
The request to exercise such rights shall be sent to one of the following addresses:
- Via email, to the address segreteria@dpsl.it;
- Via registered mail to Di Pietro Studio Legale, via Bigli 28, Milano, Italy.
Any request relating to data recipients or any clarification request regarding this information shall also be addressed to the same contact details.
8. Links to other websites
This privacy information regarding the processing of personal data concerns only Data collected through the Website and with reference to purposes identified in paragraph 3., and it is not and shall not be deemed applicable to other websites consulted and/or that can be consulted through links and/or widgets (e.g. social networks): these further websites will process the Data as independent data controllers and according to their respective privacy information, whose consultation by the users is expressly recommended.
