Information notice on personal data processing under article 13 of the legislative decree no. 196 dated June 30, 2003
According to Article 13 Legislative Decree No. 196 dated June 30, 2003 (the Code), we hereby wish to provide you with some information concerning the processing of your personal data.
- Typology and purpose of data processing
At the time the information is collected and, subsequently, upon any other data processing exercise (as here in after defined) we may become aware of personal data refered to you, including any sensitive and judicial data as defined under Article 4, letters (b), (d) and (e) of the Code (the Data). The Data we may collect or that you may directly provide us with or through third parties, shall be exclusively treated in accordance with the terms described in this information notice and in conpliance with the applicable provisions of the Code.
The processing of the Data shall include the collection, recording, organisation, keeping, selection, retrieval, comparison, utilization, blocking, communication, deletion and destruction of the Data (the Processing). The Data shall not be disseminated.
The Data Processing will be carried out in order to:
(a) establish, manage and perform the professional activities entrusted with us, both in litigation or other legal activities (e.g. acquisition of any information functional to the acceptance of the engagement, conflict of interests checks, carry out any obligation arising from the engagement, etc);
(b) control the state of the relationship with the clients and monitoring credit and frauds risks relating to the activities requested;
(c) comply with obligations provided by law, regulations or community legislation and with the obligations set out by public authorities or supervisory bodies (e.g. obligations imposed by the anti-money laundering regulations);
(d) for administrative purposes; and
(e) to deliver brochures, newsletters, invitation to seminars and training events, in accordance with applicable ethical obligations.
- Modality of the Data Processing
The Processing shall be carried out in full compliance with the privacy, fairness, necessity, relevance, lawfulness and transparency principles as provided by the Code.
The Data shall be processed by electronic and non electronic means, in accordance with the security measures and requirements, both physical and logical, listed under articles 33-36 and Schedule B of the Code.
- Delivery of the Data and consequences in case of Processing Consent refusal
The delivery of the Data for the purposes under paragraph 1, letters (a), (b), (c) and (d) is compulsory and does not require the express consent with reference to your identification data as well as to sensitive and judicial data necessary for the performance of the judicial activities. On the contrary, with reference to any sensitive and/or judicial data to be used within other legal activities, we require your express consent in order to process this type of data. Your consent is necessary in order to establish, perform and/or continue our legal assistance to you and to comply with the contractual obligations resulting from the engagement. The failure to provide us with the Data requested may hinder the establishment, performance and/or continuation of our legal assistance to you. The delivery of the Data for the purposes under paragraph 1, letter (e) is optional and the consequent processing will be carried out only previous express consent of the person interested. The refusal to delivery the Data for the above mentioned purposes has no consequences.
- Disclosure and transfer of the Data
The Data delivered or obtained by us during our activity may be disclosured in Italy, in EU and Non-EU countries, to the following entities and/or categories of entities:
(a) to external counsels, to addressees, to subjects working in judicial field, to counterparties and their counsels, to arbitration boards and, in general, to any public or private entity to whom the communication is compulsory for the correct fulfillment of the duties pointed out under the above mentioned paragraph 1;
(b) to persons, companies and/or corporations, for the compliance of those duties in connection with the supply of specific processing services and/or of consultancy services requested by our firm or that may carry out activities connected with, instrumental to or in support of our activity or to activities that are necessary for the establishment and/or execution and/or conclusion of the contractual relationship established with you or to be established with you;
(c) to persons who have the right to have access to the Data pursuant to the provisions of law or community legislation; and
(d) to persons, companies and/or corporations that may become aware of the Data in their quality of “Data Processing Managers” (“Responsabili del Trattamento”) and/or persons appointed as “In charge Data Processing Managers” (“Incaricati del Trattamento”), according to the Code.
- Rights of the Data subject
As Data subject, you have all the rights stated in Article 7 of the Code. These rights may be asserted according to the modalities under Article 9 of the above mentioned Code. More specifically, we inform you that, if you apply to the Data Processing Manager, you are entitled to the following rights:
(a) to obtain confirmation as to whether or not personal Data concerning yourself exist, even if these Data have not been recorded yet, and to obtain communication of such Data in intelligible form;
(b) to be informed on (i) the source of the Data, (ii) the purposes and modality of Processing; (iii) the logic applied to the Processing, when carried out by electronic means; (iv) the identification data of the data controller and of the data processing manager; and (v) of the entities or categories of entities to which such Data may be communicated or that they may become aware of in their capacity as data processors;
(c) to obtain (i) updates, rectification and whenever necessary, integration of the Data; and (ii) the deletion, anonymization or blockage of the Data that may have been processed unlawfully, including those whose conservation is not necessary according to the purposes for which such Data have been collected or subsequently processed; (iii) certification that the operation as per point (i) and (ii) have been notified, as also related to their contents, to the entities to whom or to which the Data were communicated or disseminated, unless this fulfillment is proved to be impossible or to involve manifestly disproportionate effort compared to the right that is to be protected;
(d) to object, in whole or in part: (i) on legitimate grounds, to the Processing of the Data, even though they are relevant to the purpose of the collection; and (ii) to the Processing of the Data where it is carried out for the purposes of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.
- Data Controller and Data Processing Manager
The Data Controller is Pavesio e Associati – Studio Legale Associato with offices in Corso Vittorio Emanuele II, 68, 10121 Turin (Italy) (the Data Controller).
The Data Processing Manager of Pavesio e Associati is Carlo Peyron, partner of Pavesio e Associati – Studio Legale Associato, to whom you may write to exercise the rights under Article 7 of the Code.
If you require a complete list of the other members of the personal data processing team, you may address your request to the Data Processing Manager.
