Arbo S.r.l., in the person of its directors and legal representatives, believes that the protection of personal data is a fundamental value and guarantees to lawfully process the personal data received through the Site, both manually and automatically, in accordance with the GDPR and national legislation on the protection of personal data, as well as the Code of Professional Ethics https://www.ordine-brevetti.it/it/codice-deontologico. Personal data will be kept confidential and will not be disclosed.
The Data Controller of the data collected or otherwise processed through or in connection with this Site, pursuant to and for the purposes of Article 4, no. 7) of the GDPR, is Arbo S.r.l. based in Genoa, Via Colombo 11/29 – 16121 Genoa, VAT number 02343030991, tel. +39 010.0897753, firstname.lastname@example.org.
The Studio has subscribed to a professional liability insurance policy; more information on this policy can be requested by sending an email to the address indicated above.
TYPE OF DATA PROCESSED AND SPECIFIC PROCESSING METHODS.
- Browsing data
The Site automatically acquires personal data whose transmission is inherent and implicit in the use of internet communication protocols. This information is not collected to be associated with identified interests, but by its very nature could, through processing and association with data held by third parties, make it possible to identify users. These data include IP addresses, domain names of computers used by users when connecting to the site, URI (Uniform Resource Identifier) addresses of the requested resources, the method used to submit the request to the server and the time of the same, the size of the file obtained in response, the numerical code relating to the status of the response given by the server (successful, error, etc.) and other indices related to the operating system and the computer environment of the user. These data are used solely for the purpose of obtaining anonymous statistics on Site use and to check its proper functioning; they are therefore kept only for the time necessary to carry out these activities and then deleted immediately after processing. Such data could allow the identification of users and be used and stored for the purpose of and for the time necessary to ascertain responsibility in the event of computer crimes against the Site.
No data deriving from the web service will be communicated or disseminated, except to fulfil the obligations established by Community laws, legislation or regulations.
- Data voluntarily provided by the user
The optional, explicit and voluntary sending of email to the addresses indicated on this Site or with the dedicated contact form (for example in order to request information) involves the acquisition and processing of the sender’s email address as well as any other personal data voluntarily communicated, for the purpose of examining and responding to the request and may, always for this purpose, be communicated to Studio professionals involved in this process. It is therefore recommended that users communicate only the personal data which is actually necessary and related to the request. The possible sending of particular categories of personal data (relating, in particular, to racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership in parties, trade unions, associations or organisations of a religious, philosophical, political or trade union nature, as well as personal data suitable for revealing state of health and sexual life) entails the immediate deletion of the data, unless the data subject has given his/her written consent to the processing of the same.
The legal basis for the processing of the data in question is the need to comply with your request and, where necessary, consent. The processing is limited to the time necessary for the purposes indicated above.
- Data relating to curricula voluntarily sent to the dedicated address
The personal data contained in the curricula sent to the addresses indicated on the Site will be processed by the partners of the Studio and/or collaborators responsible for such processing, for the sole purpose of evaluating possible collaborations or recruitment and will not be communicated to third parties. In the event of a negative evaluation, they will be deleted after two months from said evaluation and in any case will not be kept for more than one year. Any communication via curriculum or email accompanied by particular categories of personal data (relating, in particular, to racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership in parties, trade unions, associations or organisations of a religious, philosophical, political or trade union nature, as well as personal data suitable for revealing state of health and sexual life) entails the immediate deletion of the data, unless the data subject has given his/her written consent to the processing of the same.
PROCESSING PURPOSE AND RETENTION PERIOD
Personal data may be processed in hard copy or by computers.
Browsing data are processed for the purpose and for the time necessary to ensure the proper functioning of the Site and its efficient browsing, without identification purposes (please refer to the specific paragraph above, also with regard to the possibility of identification in case of computer crimes to the detriment of the Site).
Apart from browsing data, Arbo S.r.l. will process the personal data voluntarily and optionally provided by users by sending emails to the addresses indicated on the Site or through the contact form on the Site (such as, for example, identification and contact data and data relating to the subject of the user’s request) exclusively for the purpose and for the time of performance of the services, including informative, requested by users, or for the fulfilment of legal obligations (for example in the field of anti-money laundering) or for the pursuit of a legitimate interest (for example: management of complaints, disputes or litigation, debt recovery). These data will be kept for ten years or for as long as is necessary for the purpose for which they are processed, as well as for as long as may be required by law.
LEGAL BASIS OF THE PROCESSING
In relation to each of the purposes indicated in the previous section, the legal basis of the processing resides alternatively in the need to:
- fulfil requests of Site users and manage customers or potential customers;
- allow the proper functioning and efficient browsing of the Site;
- pursue the legitimate interests of the Data Controller (in particular: handling complaints, disputes or litigation, recover debts, prosecution of computer crimes)
- comply with legal or regulatory obligations.
PROVISION OF PERSONAL DATA – OPTIONAL AND NON-DISCLOSURE
Without prejudice to browsing data whose provision is mandatory as necessary for the proper functioning of the Site, the remaining personal data are provided by the user on an optional basis.
Failure to communicate such personal data may, however, make it impossible for Arbo S.r.l. to comply with user requests. Users are advised to disclose only the personal data strictly necessary and related to the service requested. Failure to give consent to the processing where necessary (for example for particular data) makes it impossible for Arbo S.r.l. to respond to requests.
PROCESSING RECIPIENTS AND SECURITY MEASURES
The data processing operations connected to the Site will be carried out by responsible persons and data processors, including any persons named responsible for occasional maintenance operations, chosen and designated by Arbo S.r.l. in order to carry out specific processing operations and bound by compliance with the provisions of this policy, as well as by current legislation on the protection of personal data and by a specific confidentiality obligation. To request the complete list of those responsible and the processors, please write to the following email address: email@example.com.
Personal data will be disclosed to third parties only if necessary for the specific purpose underlying the processing or with the express consent of the data subject, and the third parties will operate as data processors or data controllers.
Arbo S.r.l. has adopted specific security measures to prevent the risk of loss or unlawful or incorrect use of personal data, including unauthorised access thereto.
PROCESSING LOCATION AND TRANSFER TO NON-EU COUNTRIES OR INTERNATIONAL ORGANISATIONS
The Site is hosted on machines located in: Pescara, Abruzzo.
The personal data is also transferred to countries outside the European Union or international organisations.
AUTOMATED DECISION MAKING AND PROFILING
The personal data collected through the Site are not subject to automated decision-making processes or profiling.
The cookies installed on the Site are stored in the memory of the user’s computer in order to facilitate subsequent access to the Site and improve its consultation. So-called session cookies remain stored in the user’s computer only until the browser is closed and transmit only the session identification data (consisting of random numbers generated by the server) necessary to allow the safe and efficient browsing of the Site. The receipt of cookies used by the Site may be interrupted by users by changing the settings of their browser at any time, but this may prevent the use of some or all of the features of this Site.
The receipt of cookies can be managed or interrupted through the following links:
Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
After doing so, however, some Site features may not work properly.
PROCESSING FOR THE PURPOSE OF COMPLETING THE PROFESSIONAL MANDATE.
Arbo S.r.l. may also process the personal data of its customers and potential customers and/or natural persons who are their employees (hereinafter, cumulatively, the “Customers”), also acquired through this Site or through the contact form or email addresses indicated on the Site, for the purpose of carrying out the professional assignment received from customers, or pre-contractual measures requested by (potential) customers.
The processing of Customers’ personal data takes place with manual or computer tools, in any case adopting appropriate measures to guarantee security and confidentiality and in full compliance with the national and Community legislation on privacy.
The purpose of processing Customer or potential customer data is to: (i) establish, manage, execute or terminate the professional relationship, (ii) fulfil the obligations deriving from national or Community legislation, for example tax or administrative, or from a decision legitimated by an authority, (iii) send informative material (for example newsletters) and/or invitations to events and/or send and/or disclose information (by publication or advertising) regarding the identification of the Customer and the assignment carried out in his/her favour, with the specification that the processing indicated in point (iii) is carried out following the express consent of the data subject when necessary by law. If consent is necessary for the purposes of processing, the Customer has the right to withdraw it at any time.
The legal basis for the processing of Customers’ personal data is, as appropriate, the fulfilment of the professional contract or a pre-contractual measure, consent, fulfilment of a legal or regulatory obligation or a binding order of the authority, the legitimate interest consisting in the recovery of fees and expenses for the activity carried out and/or in the defence against any liability actions and/or in any case in the defence of their rights, within the limits provided by law and in particular by the GDPR.
As necessary for the purposes indicated above and in compliance with the principle of minimising access, Customers’ personal data may be processed by Arbo S.r.l.’s partners or collaborators, in their capacity as authorised processors, as well as communicated to categories of external and internal parties (including, by way of example and not limited to: professionals or natural or legal persons who provide consulting services or who collaborate with Arbo S.r.l.), who, depending on the case, will process the data as autonomous controllers, responsible parties or data processors.
To receive the complete list of such third parties, please send a specific request to the following email address firstname.lastname@example.org.
Data subjects may exercise all the rights indicated in the following section entitled “Data Subject Rights”, as indicated below.
DATA SUBJECT RIGHTS (ARTICLES 15-22 GDPR)
The data subject has the right to obtain confirmation from the data controller as to whether or not their personal data is being processed and, if so, access to their personal data and the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients, as well as any transfer to third countries or international organisations;
- the envisaged retention period of the personal data or the criteria used to determine such a period;
- the data subject’s right to ask the controller to rectify or delete personal data or to restrict the processing of personal data concerning him or her or to object to their processing;
- the right to lodge a complaint with the Data Protection Authority (https://www.garanteprivacy.it/);
- where the data are not collected from the data subject, the available information on their origin;
- the existence of an automated decision-making process, including profiling referred to in Article 22, paragraphs 1 and 4 of the GDPR and, at least in such cases, significant information on the logic used and the importance and expected consequences of such processing for the data subject;
- the existence of adequate safeguards if the personal data is transferred to a third country or an international organisation;
- the right to obtain copies and the portability of the personal data.
To exercise the rights described above, the user can contact Arbo S.r.l. by writing to the following email address email@example.com.