×
Graziadei Studio Legale - Privacy Policy on the Processing of Personal Data
pursuant to Regulation (EU) 2016/679 (General Data Protection Regulation or “GDPR”)
1. General information and Data Controller
1.1 This policy on the processing of personal data (“Privacy Policy”) is meant to provide you with information regarding the collection, processing, use, confidentiality and type of personal data that you provide to Graziadei Studio Legale (“Graziadei”) or that are automatically collected during your interaction with the website www.graziadeistudiolegale.it (“Website”).
1.2 Pursuant to the GDPR the Data Controller is Graziadei Studio Legale, with registered office at Via Antonio Gramsci 54, 00197 Rome, Italy, VAT number 07340781009 and e-mail address studio@graziadeistudiolegale.it.
2. Data collected and processed by Graziadei and categories of data specifically not processed
2.1 Personal Data
Graziadei collects and processes your Personal Data exclusively when: (a) you send your Curriculum Vitae to the e-mail account indicated on the Website; (b) you sign up for “Brand New - Newsletter” via the dedicated section of the Website; or (c) you send e-mails to the e-mail account indicated on the Website.
2.1.1 Recruitment
Using the instructions included in the Recruitment section of the Website, you may apply for open positions at Graziadei or submit your voluntary candidacy for a future job with the firm.
When you send your CV to one or more of the e-mail accounts indicated in the Recruitment section of the Website, Graziadei collects and processes your Personal Data (e.g. name, surname, e-mail address, date of birth, academic qualifications and work experience as well as all other Personal Data you provide, except for data indicated in §2.4 of this Privacy Policy) for the sole purpose of assessing your candidacy.
2.1.2 Brand New - Newsletter
By filling in the form in the “Brand New - Newsletter” section of the Website you sign up to Graziadei’s periodic newsletter. As a result, Graziadei will send information to your e-mail address. With reference to any such subscription, Graziadei collects and processes solely the following Personal Data: name, surname and e-mail address.
2.1.3 Unsolicited sending of e-mails
When you send unsolicited communications, requests, messages or any other information to one of the e-mail accounts indicated on the Website, Graziadei collects and processes the following Personal Data: your e-mail address and any other Personal Data you provide with your communication, except for the data indicated in §2.4 of this Privacy Policy.
2.2 Usage Data
When you browse the Website, Graziadei may collect and process technical information about your browsing history on the Website and your device, such as your IP address, proxy, operating system, browser and its add-ons, and URL of the website site from which you have arrived and that of the website to which you depart (“Usage Data”). The Website uses cookies exclusively for reasons strictly necessary for the functioning of the Website and to optimise your browsing experience such as storing your preferences or browsing session (technical cookies and aggregate statistics). The Website’s cookies do not collect Personal Data. You can disable them anytime through your browser settings (e.g. Apple Safari, Google Chrome or Mozilla Firefox). Disabling cookies does not compromise browsing activities on the Website but the overall experience may vary: for instance, the Website may not be able to track your last access, language or country.
2.3 Google Analytics and Google Tag Manager
The Website uses Google Analytics and Google Tag Manager, web analysis and statistics services provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA, 94043, USA). Google Analytics collects information and data about the use of the Website in order to trace and examine access to the Website, evaluate the Website, prepare reports regarding the Website and provide sharing services in conjunction with other Google services. Google Tag Manager collects statistics about the use of the Website.
2.4 Categories of data specifically not collected or processed: social network and other online platforms interaction, sensitive data and irrelevant data
All interactions between the Website and social network sites or other online platforms, via widgets or other tools present on the Website, are subject to the privacy settings you use on those social network or other online platforms. In these cases Graziadei does not collect and process your data.
Moreover, Graziadei expressly excludes collecting and processing your sensitive data. Therefore, any communication containing sensitive data or in any event data not relevant to communications of a professional nature that you may send for any purpose to Graziadei’s e-mail account will be immediately deleted.
3. Purposes and legal basis of data processing
3.1 Recruitment
Personal Data will be collected and processed in order to allow Graziadei to assess your application. The legal basis for this processing is your consent (article 6(1)(a) GDPR), expressed by applying for the position.
3.2 Brand New - Newsletter
When you sign up for “Brand New - Newsletter” your Personal Data will be collected and processed in order to allow Graziadei to provide you with periodic updates on the Website’s contents by sending e-mails to the e-mail address indicated at the time of signing up. The legal basis for this processing is your consent (article 6(1)(a) GDPR), expressed by signing up for “Brand New - Newsletter” through the form on the Website.
3.3 Receiving e-mail messages
Personal Data will be collected and processed in order to allow Graziadei to answer any requests that you send to one of the e-mail accounts indicated on the Website. The legal basis for this processing is your consent (article 6(1)(a) GDPR), expressed by requesting Graziadei’s professional services.
3.4 Preventing fraud and illegal activities and ensuring the protection of rights
Personal Data and Usage Data will be collected and processed in order to allow Graziadei to prevent fraud or other online illegal activities as well as to protect its own rights and those of its users. The legal basis for this processing is pursuit of a legitimate interest (article 6(1)(f) GDPR), so your express consent is not required.
3.5 Cookies, Google Analytics and Google Tag Manager
Graziadei uses optional cookies, Google Analytics and Google Tag Manager in compliance with the provisions of the GDPR in order to improve and optimise the services offered on the Website as well as to evaluate the statistics of the Website. The legal basis for this processing is pursuit of a legitimate interest (article 6(1)(f) GDPR), consisting of checking the proper functioning of and statistical performance of the Website. As such your express consent is not required for that processing.
3.6 Other purposes
Personal Data and Usage Data will be collected and processed in order to allow Graziadei to comply with the legal obligations imposed on it by Italian and EU law, regulations, rules and any other provisions adopted by public authorities in general and supervisory and regulatory authorities in particular. The legal basis for this processing is compliance with a legal obligation (article 6(1)(f) GDPR).
Moreover, Graziadei may collect and process Personal Data and Usage Data in order to protect your vital interests or those of another natural person (article 6(1)(d) GDPR) and in order to perform a task carried out in the public interest or in the exercise of official authority vested in the controller (article 6(1)(e) GDPR).
Neither of these forms of processing require your express consent.
4. Data processing
4.1 In processing Personal Data and Usage Data, Graziadei adopts all the security measures required to prevent access, disclosure, alteration, destruction and other unauthorised operations on data.
4.2 The data processing is carried out through computerised, electronic and paper tools, with operational methods and a logic strictly connected to the purposes set forth in this Privacy Policy.
4.3 Apart from what is necessary to use Google Analytics and Tag Manager services (§3.5), Graziadei will not transfer Personal Data and Usage Data to third countries or international organisations and will not allow third parties to access those data, with the exception of those specifically appointed as data processors (e.g. hosting provider, employees), which are required as such to respect the provisions of the GDPR.
5. Place of processing
Data are only processed at the premises of the Data Controller or, if Graziadei appoints a data processor other than the Data Controller under § 4.3, at the premises of the Data Processor. You may ask Graziadei for more information at any time.
6. Period of data storage
6.1 The Personal Data and Usage Data will be stored solely for the length of time necessary to achieve the purposes for which data are collected and processed, unless the applicable law requires longer periods of storage. Thereafter, data will be deleted.
6.2 If you exercise your right to object to the processing of Personal Data or Usage Data, withdraw your consent for any such processing based on your consent or request the interruption of the processing or the erasure of data, the retention of data shall cease before the time specified in § 6.1, without prejudice to what is mandated by applicable law.
7. Your rights
7.1 Right to withdraw consent: pursuant to article 7 GDPR, where processing is based on your consent, you may withdraw your consent at any time without affecting the lawfulness of processing based on consent before the withdrawal.
7.2 Right of access: pursuant to article 15 GDPR you have the right to obtain from Graziadei confirmation as to whether or not your Personal Data are being processed, and if so to obtain access to those data. You also have the right to obtain from Graziadei a copy of your processed data.
7.3 Right to rectification: pursuant to article 16 GDPR you have the right to obtain from Graziadei the rectification of your inaccurate Personal Data.
7.4 Right to be forgotten: pursuant to article 17 GDPR you have the right to obtain from Graziadei the erasure of your Personal Data.
7.5 Right to restriction of processing: pursuant to article 18 GDPR you have the right to obtain from Graziadei the restriction of processing of your Personal Data.
7.6 Right to data portability: pursuant to article 20 GDPR you have the right to obtain Personal Data provided to Graziadei in a structured, commonly used and machine-readable format and to transmit those data to another Controller.
7.7 Right to object: pursuant to article 21 GDPR you have the right to object at any time to processing of your Personal Data.
7.8 Right to complain: you have the right to lodge a complaint with the Supervisory Authority.
7.9 Communication of data breach: except for the situations set out in article 34(3) GDPR, in the event of a data breach concerning your Personal Data that may involve a high risk to your rights, you have the right to obtain from Graziadei a communication of the Personal Data breach.
8. Data Processor
8.1 Graziadei Studio Legale is appointed the Data Processor.
8.2 Graziadei reserves the right to appoint, if necessary, other Data Processors. You may request Graziadei to furnish an updated list of the Data Processors at any time.
