Privacy Policy

Purpose of this statement

 

This privacy policy applies only to the web site cugiacuomo.it (Hereinafter the “Website”), which is owned by Avv. Fabrizio Cugia di Sant’Orsola, via Terenzio 7, 00193-Roma -  Contacts: t. +39 06 96038100; studio@cugiacuomo.it.

This Privacy Policy has the purpose to provide Users of the Website with the information required by article no. 13 of  Regulation (EU) 2016/679, titled General Data Protection Regulation (herein after the “GDPR”) and the Data Protection Act 2018. 

As a courtesy to Users, the Website may link to third party Web sites.This Privacy Policy does not apply to information that may be collected by Users accessing other website, which are beyond  ownership and control ofAvv. Cugia di Sant’Orsola., thatcannot guarantee that those third parties’ privacy practices comply with the standards outlined in this privacy policy

In accordance with the data protection regulatory framework, the data processing will comply with the principles of fairness, lawfulness and transparency, and protection of privacy and rights of the data subjects.


This Policy is effective as of May 25, 2018.The Data Controller can modify this privacy policy any time, publishing the updated versions of this Privacy Policy to this Website.

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Data Controller

Avv. Fabrizio Cugia di Sant’Orsola is the Data Controller of the personal data of Users, which access this Website.

The Data Controller manages the Website and collects and processes data of Users, which  access this Website and provide their personal data in the following sections:

 

-      Join our newsletter;

-      Contact us

 

The Data Controller may process personal data of Users by means of the Data Processor, Wolters Kluwer Italia S.r.l, which manages the WebSite and data officers which are specifically instructed and provide sufficient guarantees to implement appropriate technical and organisational measures in such a manner that processing will meet the requirements of this Regulation and ensure the protection of the rights of the data subject. The full list of data processors and data officers can be asked contacting the data controller.

If  Users have any questions about this Website or this Privacy Policy can contact the Data Controller by writing to: Avv. Fabrizio Cugia di Sant’Orsola, via Terenzio 7, 00193-Roma  Contacts: t. +39 06 96038100; studio@cugiacuomo.it

Data processing operations

Personal Data are processed at the Data Controller's operating offices in Italy and in any other places where the parties involved with the processing are located, in UE. 

The purposes and method of the processing

This website provide Users with information related to services offered by Avv. Fabrizio Cugia di Sant’Orsola.

The Data controller may process navigation data and data supplied voluntarily by Users, which provide their personal data in the following sections:

 

-      Join our newsletter;

-      Contact us

The User expressly authorizes the Data Controller to use the personal data received for the following purposes:

- send newsletters;

- reply to the messages received in the "Contact us" .

The personal data provided by the Users accessing the Sections indicated are used only to perform the service and / or manage and / or take charge of the request and are communicated to third parties only if this is necessary for this purpose, in compliance with the applicable legal and regulatory provisions. These data are not used for direct marketing and / or market research purposes.

Personal data are processed using automated electronic tools, with IT support (eg using electronic procedures and media) and / or manually (eg on paper) for the time strictly necessary to achieve the purposes for which the data are collected and in compliance with current regulations. The data are deleted when no longer necessary with respect to the intended treatment purpose.

 

Types of Data collected

Navigation Data

The computer systems and software procedures used to operate the Website acquire, during their normal operation, some personal data (so-called log files). The transmission of those data is an implicit part of use of the internet communication protocols. This information is not collected for association with identified data subjects, but by their very nature, they might permit the identification of users through processing and association with the data held by third parties. This class of data includes the IP addresses or domain names of the computers used by the persons that log onto the site, the URI (Uniform Resource Identifier) addresses of the requested resources, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the answer given by the server (successful, error, etc.), and other parameters regarding the operating system and the user's IT environment. These data are used only in order to obtain anonymous statistical information on use of the site and to monitor its proper functioning. They are deleted immediately after they are processed. The data might be used to ascertain liability in the case of hypothetical computer crime committed against the Site or third parties. Except for this possibility, the web contact data of the user are currently not stored on a permanent basis, unless requested by the user.

Regardless of the presence of any cookies, the following information may be recorded for any access to the website of the Data Controller by Register: type of browser (e.g. Internet Explorer, Netscape), operating system (e.g. Windows, Macintosh), the visitor's origin host and URL, and the data for the requested page. These data may be used in aggregate and anonymous form for statistical analysis of this website used by Register.it. These data are used only in order to obtain anonymous statistical information on use of the site and to monitor its proper functioning. They are deleted immediately after they are processed.

Data provided voluntarily by the User

Users can browse the Website without revealing their personal identity to the Data Controller. However, if the User chooses to provide his personal data, they will be collect and process in compliance with this privacy policy.

Personal data supplied voluntarily means:

- personal data (name, surname, date of birth), identification data (tax code), location data (address, etc.), contact details (telephone data, email).

The Data Controller does not process the special categories of personal data set out by article 9 of GDPR.

 

Cookies

This website does not allow sending third-party, and does not use cookies  profiling cookies and  technical and analytics cookies, such as:

  •       browsing or session cookies, which allow users to navigate and use a website;
  •       analytics cookies, which can be equated to technical cookies insofar as they are used directly by the website manager to collect aggregate information on the number of visitors and the pattern of visits to the website; 
  •       functional cookies, which allow users to navigate as a function of certain pre-determined criteria such as language or products to be purchased  so as to improve the quality of service.

In order to know the cookie policy please click here.

Optional or mandatory consent.

 

The provision of personal data is optional for all procedures connected with activation of the Services (registration, send messages in sections “join us” and “contact us”.) in the website, but if the user does not provide its personal data, the requested Services cannot be activated. The consent is also optional and not mandatory for the processing of personal data for sending advertising and informative material; for sending commercial information; for answering to messages and requests. 

 

 

 

Dissemination of your personal data

Personal data supplied voluntarily by the users in order to send resumes in the section “Join Us” and messages in the section “Contact us” or to require specific information referring to Services provided by the Data Controller will be processed exclusively to reply the messages and provide Services requested. They will not be provided to Third Parties, unless required by the User.

 

The Data Controller may communicate personal data of the users to public Authorities, if required.

 

The Data Controller is not responsible for the personal data of the user processed by social media, by accessing the Facebook page, Instagramm, Twitter, etc. from the Website.

 

If personal data is communicated to others on other Internet websites, the use and disclosure of the data communicated may be subject to other rules.

 

The Data Controller is never co-participant and does not control the privacy policies or rules of third parties. Hence, be informed, that in relation to other browsing the User is subject to the privacy rules of such third parties, if applicable. 

 

We invite the User to obtain information about this before communicating his personal data to others websites.

 

Principles relating to processing of personal data

 

Personal data will be processed in compliance with the principle of relevance and not excess with respect to the purposes pursued. Personal data will be kept for the time strictly necessary for the purposes pursued with the treatment of the same.

 

Personal data shall be: (a) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’); (b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shallnot be considered to be incompatible with the initial purposes (‘purpose limitation’); (c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’); (d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’); (e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; (‘storage limitation’); (f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).

 

 

Direct Marketing and Market Research

The Data Controller does not sell or transfer the personal data of the User collected during navigation on this Website to third parties for purposes of direct marketing and / or market research, without the explicit consent of the data subjects.

The Data Controller may associate the data of Users with the information that will be collected by other companies in order to improve and customize the services offered and the contents of the Website.

Data transfer

The personal data of the User of the Website processed by the Data are not transferred to third countries outside the European Economic Area ( EEA).

Rights of the data subject

Transparent information: Users may contact:

 Avv. Fabrizio Cugia di Sant’Orsola, via Terenzio 7, 00193-Roma  Contatti: t. +39 06 96038100; studio@cugiacuomo.it

 in order to have any information relating to processing to the data subject in a concise, transparent, intelligible and easily accessible form, using clear and plain language, in particular for any information addressed specifically to a child. The information shall be provided in writing, or by other means, including, where appropriate, by electronic means. When requested by the data subject, the information may be provided orally, provided that the identity of the data subject is proven by other means. 

The controller shall provide information on action taken on a request to the data subject without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. The controller shall inform the data subject of any such extension within one month of receipt of the request, together with the reasons for the delay. Where the data subject makes the request by electronic form means, the information shall be provided by electronic means where possible, unless otherwise requested by the data subject. If the controller does not take action on the request of the data subject, the controller shall inform the data subject without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

Right of access by the data subject:  Users shall havethe right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information: (a) the purposes of the processing; (b) the categories of personal data concerned; (c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations; (d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; (e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; (f) the right to lodge a complaint with a supervisory authority; (g) where the personal data are not collected from the data subject, any available information as to their source; (h) the existence of automated decision-making, including profiling, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject. The data subject shall have the right to be informed of the appropriate safeguards pursuant relating to the transfer. The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form. The right to obtain a copy shall not adversely affect the rights and freedoms of others

Right to rectification:The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. 

Right to erasure:The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay

Right to restriction of processingThe data subject shall have the right to obtain from the controller restriction of processing where one of the following applies: (a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data; (b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; (c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; (d) the data subject has objected to processing) pending the verification whether the legitimate grounds of the controller override those of the data subject.

Right to data portability:The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided

Spamming

 

The Data Controller does not tolerate spamming. In addition, the User is not authorized to include the address of another user  in any address list of the website (email or postal) without his/her express consent. The data Controller invites the user to report any cases of spamming or counterfeit email

 

Security measures

 

Personal data will be collected, processed, and kept in full compliance with the provisions regarding security measures. In any event, data will be stored strictly for the amount of time necessary to realize the aims illustrated hereinabove, which shall be for as long as the service relationship between the user and the data controller.

 

Right to Complaint

 

The User expressly acknowledges that the processing of data by the Data Controller is subject to the control of the Authority for the protection of personal data, which may be addressed any and every complaint about the collection, management and processing of data in the compliance with the data protection regulatory framework.

 

NO Profiling

 

The data of the Users of this Website are neither subjected to profiling nor processing through an automated decision-making process.

 

 

 

 

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