POLICY ON THE PROCESSING OF PERSONAL DATA

This policy describes the processing of personal data of visitors and users of LCA Studio Legale's "Your Way to Italy by LCA" website (www.yourwaytoitaly.it: the "Site") (collectively, "Users").

The data controller may amend this policy to accommodate future expansions or changes to the Site or the services offered. In the event of substantial changes, the data controller will post a notice on the Site and/or send an e-mail notification to point out the changes and collect a possible request to exercise the rights recognized by the data protection legislation.

1. DATA CONTROLLER

The data controller is LCA Studio Legale, with legal address in Via Della Moscova 18, 20121, Milan, fiscal code and VAT number 04385250966 ("LCA").

2. DATA COLLECTED

   2.1 Data communicated by Users

The personal data collected by the Site are the data communicated by Users through the completion of the forms on the Site, or as a result of sending a request to "Your Way to Italy by LCA” at the contact details indicated on the Site.

The data collected include identification and contact data of Users (e.g. first and last name, e-mail address, telephone number), personal data included in communications and requests transmitted to "Your Way to Italy by LCA”, as well as additional data necessary to respond to and execute specific requests of Users.

We recommend that Users communicate only data that are up-to-date, relevant and not exceeding the specific purposes of the processing. In the event that Users find themselves in the need to communicate data of third parties, we remind Users to fulfill their legal obligations regarding the protection of personal data and, in particular, to appropriately and promptly inform third parties of the communication of their data to, and the characteristics of the processing by, LCA.

Any unnecessary data will be immediately deleted or anonymized.

   2.2 Browsing data

Each time the Site is accessed, the systems automatically record and analyze access data (e.g. provider IP address, information about the browser used, pages visited, date, time and duration of each visit). The information is collected automatically by the Site and does not require any action on the part of the User.

The data collected is only anonymous and aggregated data, and therefore cannot lead to the identification of Users: it simply allows the detection and resolution of any technical problems.

  3. PURPOSES OF PROCESSING

Users' personal data ("Data") may be processed for the following purposes.

3.1 Responding to requests from Users

The Data will also be processed in order to respond to requests that Users may transmit to the contact details available on the Site: for this purpose, it is necessary for Users to communicate their contact details as, without them, it will not be possible for "Your Way to Italy by LCA” to respond to them.

The legal basis of this processing is the need to execute pre-contractual and contractual measures taken at the request of the User, and to fulfill the related legal obligations.

3.2 Newsletter’s subscription

The Data collected at the time of filling in the registration form for the newsletter service - (first and last name, company, e-mail address) will be processed for the purpose of sending informative and informative communications on the activities of "Your Way to Italy by LCA”, including possible invitations to events and/or conventions organized and/or otherwise sponsored by LCA also in collaboration with third parties.

The provision of Data is necessary to finalize the subscription to, and take advantage of, the newsletter service: therefore, in case of refusal or failure to provide the requested Data, it will not be possible to receive the newsletters of "Your Way to Italy by LCA”.

The User may unsubscribe from the newsletter service at any time, by following the procedure indicated at the bottom of each newsletter or by sending a specific communication to "Your Way to Italy by LCA” at the contact details indicated in point 7 below.

The legal basis for this processing is the need to execute pre-contractual and contractual measures taken at the request of the User, as well as LCA's legitimate interest in providing constant updates regarding relevant news in the field of interest of its clients or potential clients. Legitimate interest that does not imply a prejudice to the rights and freedoms of the interested parties since the processing concerns data not belonging to special categories of personal data and is limited to sending communications and updates of interest to the interested party.

If, when filling in the forms on the Site, the User has given his/her consent via the box at the bottom, the Data collected will also be processed for sending, via e-mail, the newsletter "Your Way to Italy by LCA”.

Consent is purely optional: failure to give consent will not prevent the User's participation in the event; any consent given may be revoked at any time by writing to the contact details indicated in point 7 below, without affecting the lawfulness of the processing carried out on the basis of the consent before revocation.

The processing of data as described above is not necessary for sending requests through the forms on the Site, and any withdrawal of consent and/or opposition to receiving such communications will have no consequences for the User.

 4. METHODS OF PROCESSING

The Data will be processed by manual and computerized means by staff and collaborators of LCA and/or companies expressly appointed as data processors, and to whom LCA has given detailed operating instructions with particular reference to the adoption of adequate technical and organizational security measures.

The complete list of Data processors is kept at the owner's office and is available upon request, which may be forwarded to the contact details indicated in Section 7 below.

  5. DATA RECIPIENTS

The Data will be communicated and transferred to the categories of subjects indicated when describing the purposes and methods of processing.

To the extent necessary to achieve the purposes of the processing (and by virtue of the same legal bases), Data may also be transferred abroad:

·        in case of events taking place outside Italy;

·        in case of a request concerning foreign jurisdictions.

The transfer of Data outside the European Union will take place, if to countries that do not benefit from an adequacy decision of the European Commission and, therefore, that do not offer an adequate level of protection to personal data, only (i) after the adoption of appropriate safeguards such as, by way of example, the signing of the standard clauses approved by the European Commission or (ii) upon the occurrence of an exception to the prohibition of transfers outside the European Union and, therefore, again by way of example, upon the collection of the explicit and informed consent of the User, or to the extent that it is necessary to execute a contract concluded between the User and LCA, or between LCA and a third party for the benefit of the User, or upon the execution of pre-contractual measures taken at the request of the User.

  6. DATA RETENTION

The personal data collected and processed by LCA, for the purposes identified in point 3 above, may be kept in a form that allows the identification of the User for the period necessary to achieve the purposes of the processing and, in particular:

·        to respond to requests from Users, for the period of 12 (twelve) months from the last contact made;

·        to receive "Your Way to Italy by LCA”’s newsletter, for the period of 36 (thirty-six) months from the date of subscription, extendable by subsequent periods of 36 months where the User does not revoke consent to the sending of the newsletter, by clicking on the appropriate link at the bottom of: (i) each e-mail sent; (ii) the e-mail reminding the User of the possibility of unsubscribing from the newsletter - sent one month in advance of the expiration date; and (iii) the e-mail sent in the event of an update to this privacy policy.

The Data may be retained for longer periods where necessary to fulfill legal obligations, or for the protection of LCA's rights, until the expiration of the relevant limitation period.

  7. USERS’S RIGHTS AND CONTACTS

The User may, at any time and to the extent that the rights are applicable: (I) obtain confirmation of the existence or non-existence of personal data concerning him/her; (II) request access to his/her personal data; (III) request the rectification, erasure or restriction of the processing of his/her personal data; (IV) object to the processing, or revoke his/her consent to the processing, without prejudice to the lawfulness of the processing on the basis of the consent given before revocation; (V) receive, in a structured, commonly used and machine-readable format, the personal data concerning him or her provided to LCA, as well as request that such data be transmitted to another data controller (right to personal data portability); (VI) lodge a complaint with the Data Protection Authority, or appeal to the competent judicial authority.

Requests to exercise the above rights should be sent to one of the following addresses:

·        via e-mail, to immigration@lcalex.it;

·        by registered mail with return receipt, to LCA Studio Legale in 20121 Milan (MI), Via Della Moscova 18.

Requests relating to the recipients of the Data, as well as requests for clarification of this policy, may also be addressed to the same addresses.

  8. LINKS TO OTHER WEBSITES

This information on the processing of personal data is provided exclusively in relation to the Data collected through the Site and with reference to the purposes identified in point 3., and not also for any other websites consulted and/or consultable through links and/or widgets (e.g. social networks): these additional websites will process the Data as autonomous controllers and in accordance with their respective information notices, the consultation of which by users is expressly recommended.