Privacy & Cookie Policy
In this Policy, we Athena S.r.l. S.t.a. (Tax and VAT number 11807950016) (hereinafter called as well “Controller” or “Company”), represented by our interim legal representative Mr Federico Ingenito (C.F. NGNFRC85A04G674C), with registered office in 10138-Turin, Via Susa, 31, define the methods used for the collection of the data of the visitors to our website https://www.athenalaw.it/ e https://www.athenalaw.eu/ (hereinafter the “Websites" in accordance with Art. 13 and 14 of the EU-Regulation no. 2016/679).
1. CONTROLLER, OBJECT AND PLACE OF PROCESSING
This Privacy Policy is released in accordance with the national and international laws on the protection of the Internet surfers visiting a website, regardless of the methods and tools used.
After collecting the user's consent, the Controller shall process Data strictly in compliance with the provisions of the GDPR and other national law, including any other provisions of the Supervisory Authority (i.e. The Data Protection Supervisor) if applicable.
The Data we collect may be transferred to a different country other than the one where the Data Subject resides, within the limits of the purpose for which the Users have given their consent.
For more information on the place of processing, the Data Subject may contact the Controller using the contact details under Section 10 and 12 of this Policy.
The Data Controller has committed to the protection and privacy of all visitors to its website https://www.athenalaw.it/ e https://www.athenalaw.eu/, and encourages all users to read the Privacy Policy carefully, as it is explained hereinafter.
2. METHODS AND PURPOSES FOR DATA PROCESSING AND USING
2.1. The Data may be communicated to employees and collaborators of the Data Controller trusted on the national The Data of the interested parties are collected in order to allow the Owner to provide his services in the field of legal, accounting, tax and tax consultancy, assistance and representation. In accordance with the provisions of Law 247/2012, as amended by Law 124/2017, the members of Athena Srl, regularly enrolled in the respective professional associations, exercise the profession in a corporate form.
The Data is collected, stored and, furthermore, disclosed outside the company context for the following express purposes: correct and complete execution of professional services (including assistance and representation in foreign jurisdictions or supranational bodies), tax compliance, execution of services or specific requests of the User / Customer (even outside the specificity of the judicial assistance).
The Data is collected and stored exclusively for the purposes indicated above, both through the Official Sites and through pages created on third-party platforms (Facebook, Twitter, LinkedIn, etc.)
The Data may be communicated to employees and collaborators of the Data Controller trusted on the national territory or outside of it.
Acceptance of this information legitimizes the data controller to communicate or disseminate the data collected to third parties identified above.
2.2. Possible new and different data processing terms shall be implemented by our Company only after sending a new Privacy Policy to the Data Subjects, and/or Users and obtaining their consent, wherever applicable.
2.3. The Controller has already implemented all the (IT and practical) safety measures needed to prevent the unauthorized access, modification, disclosure, or destruction of the Data, without prior consent of the Data Subjects.
We process your data within our organization for the stated purposes, and in accordance with the DPO, if available, or with the Data Processor.
You may obtain detailed information about the purposes for data processing and the collected Data by contacting the Controller using the contact details under Section 10 and 12 of this Policy.
The Privacy protocols and standards used by the Company for the protection of your personal data are based on the concepts described below.
2.3.1. RESPONSIBILITY AND LIABILITY FOR DATA PROCESSING AND USE
Due to the particular nature of the services performed by Athena Srl, the processing of data is managed over time by the entire staff of the company.
Only for certain particular cases, we may grant access to your data also to other parties with various tasks and responsibilities in terms of website management (i.e. Administration, marketing, and management staff, as well as hosting providers).
The Data Subject may request the Controller for an updated list of all Data Processors at any time.
2.3.2. TRASPARENCY WITH REGARD TO DATA PROCESSING AND USE
We collect and process data in accordance with the concepts stated in this Policy.
Before collecting and/or submitting their data, the Data Subjects may consult and read this Privacy Policy and freely decide whether they wish to agree with it.
A consent is required and may be tacitly given, even if the data are collected automatically (for example technical or profiling cookies).
The Data Subject may request the Controller at any time to supply more information on the statutory conditions of each processing, stating in particular if processing is based on a law provision, or an established contract, or if it is needed for the execution of an agreement, for marketing purposes or for other reasons.
2.3.3. COMPLIANT DATA COLLECTION
All data are collected and processed based on fair and lawful methods. Data are strictly saved for the explicit and licit reasons stated under Section 2 of this Policy, and never outside of the scope stated herein.
2.3.4. DATA VERIFICATION PRINCIPLE
All data are updated, arranged and saved so that all Data Subjects can access, whenever necessary, data that have been collected and saved, checking their quality, and possibly request any amendments, additions, cancellation if infringing any law, or alternatively exercise their rights under Section 9 of this Policy by the terms and methods stated under Section 10 of this Policy.
2.3.5. SAFETY PRINCIPLE AND ACTIVATED SAFETY MEASURES
2.3.5.1. The data collected and processed are protected against their illicit disclosure or alteration. This protection is undertaken by technical as well as informative (IT technology) tools and systems designed to minimize the risk of destruction, (accidental) loss, or access by unauthorized parties.
2.3.5.2. The above-mentioned safety measures are periodically tested and upgraded to the latest technical knowledge based on the nature of the data and the requirement of the processing methods.
2.3.5.3. Any third party, performing any ancillary activity of any type whatsoever, or supplying services on behalf of the Company and for which they are to carry out personal data processing, shall be considered as Data Processors and shall be obliged to comply with all relevant safety measures and privacy obligations.
2.3.5.4. The information we gather and acquire may be shared by us with the following third parties:
• Jurisdictional bodies;
• Public administrations;
• IT technicians
3. TYPE OF DATA AND PROCESSING METHODS
3.1. The data collected through the domain of the website web https://www.athenalaw.it/ and https://www.athenalaw.eu/, as well as through platforms owned by third parties (Facebook, Instagram, LinkedIn etc ..), they can fall: name, surname, telephone number, tax code, e-mail, IP connection number and any other information communicated directly by the Users, making use of the links on the web page, aimed at making contact with the company ("contact" or "write us" forms).
In general, the data can be:
a) Data provided voluntarily by Users: The Data collected and processed on the Sites are necessary for the provision of services. Consequently, in the event of non-conferment or lack of consent, the services that require their use cannot be provided.
Specific sections may be included in the sections of the Sites set up for the provision of Data.
In case of voluntary sending of e-mails to the addresses of the Holder, the same will acquire the mail references of the sender and any other information contained in the message. These data will be used to be contacted and in order to enable the execution of any requested services.
b) Navigation data: The automated procedures of the Sites acquire some Data, whose transmission is implicit in the use of internet communication protocols.
Although this information is not intended to be associated with identified Users, by their nature, if associated with other data held by third parties (eg internet service providers), they could allow the identification of those who surf the internet domain (eg IP addresses, names to domain of the PCs used by users connecting to the Sites, URL addresses of the requested resources, time of the request, numeric code relative to the status of the response given by the server).
These Data are used for statistical purposes, to check the traffic on the Sites and its correct functioning and to inform the persons registered in the newsletter of commercial (and non) business initiatives.
The Data Controller, or designated managers, keep track of the connections made for a limited period, in order to comply with any request from the judicial authority, entitled to request it in the phase of ascertaining responsibility in the case of computer crimes.
4. COOKIES
4.1. Our website uses cookies for its operation. Cookies are part of a code, actually a text file, installed within a browser to help the Controller change the contents according to the surfers, and supply the website service as described above.
Unless otherwise stated, our website uses cookies to make your online browsing an easier, more enjoyable experience, fulfilling your requests and ensuring a fluent navigation throughout the different pages of our site.
Some temporary markers may be installed on our website, and in this case your attention will be drawn to them and your consent will be requested.
For your knowledge, the main types of cookies used are:
a) technical and aggregate statistics cookies
The technical cookies have the function of allowing the carrying out of activities strictly related to the functioning of a web space. The technical cookies used by the Owner can be divided into the following sub-categories:
i. navigation cookies, which allow users to save browsing preferences and optimize the browsing experience;
i. analytics cookies, which acquire statistical information on how users navigate. This information is treated in aggregate and anonymous form;
i. functionality cookies - including those of third parties, which activate specific functionalities of the Sites and are necessary for the provision of services.
These cookies do not require the users' prior consent for their installation and use.
Other types of cookies or third-party tools that could make use of them
Some of the services lmay not require the consent of the Users and could be managed directly by the Owner, without the need for third parties. If among these tools there are present services managed by third parties, these could eventually perform activities of tracking users, even without the knowledge of the Owner.
Control of the installation of cookies
In addition to what is indicated in this statement, interested parties can manage every preference relating to cookies through their browser, preventing, for example, installation by third parties. By disabling all cookies, the operation of the sites may be compromised.
You can find information on how to manage cookies in your browser in the specific sections relating to Google Chrome's privacy policies, Mozilla Firefox, Apple Safari and Microsoft Windows Explorer.
The Owner informs that the User can use tools such as Your Online Choices (http://www.youronlinechoices.com/it/), through which it is possible to manage the tracking preferences of most of the advertising tools.
The owner strongly advises those browsing the sites listed above to use this resource in addition to the information provided in this statement.
For any other technical information relating to cookies, in addition to what is indicated in this statement, please consult the address:
http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/2142939.
5. DATA STORAGE METHODS
The Data, including navigation data, will be stored, in compliance with the GDPR, only for the time necessary to fulfil the purposes referred to in this information notice, ie 10 years, for the purpose of fulfilling legal obligations. The judicial and particular data will not be kept for a longer time than is essential to execute the provision of assistance, representation and judicial defence.
6. DATA ACCESS
6.1. The Data processed by the Controller may be accessed by the employees and partners of the latter who are assigned and/or responsible for in-house data processing and/or the corporate IT-systems. The access to the data is available strictly to these persons, if needed for the correct execution of their tasks, and limited to the only operations required.
6.2. The Controller provides for the protection of users' data and information against non-authorized access, illicit processing, accidental loss, destruction, and damage. Moreover, the Controller shall store these data and information for the period strictly needed for the intended application
7. DATA DISCLOSURE
7.1. The users' explicit consent to data disclosure is not required under Art. 6 letter b) and c) of the GDPR], if disclosure is requested by a Supervisory (like IVASS in Italy) or Judicial Authority, or any other competent Entity, or if needed to ensure the Controller's compliance with its legal obligations, or alternatively to enforce its defence in the framework of a judiciary proceeding. The afore-mentioned Authorities may access and keep the data as independent Data Controllers. In this case, the Data will not be disclosed, unless required by the service in point.
7.2. If needed for special services or products, personal Data may be disclosed to third parties, acting as independent Data Controllers, assigned to special operations that are strictly functional and linked to the service/product in point whose execution/delivery would be otherwise impossible.
7.3. Except for the above conditions 1-2-7, the Controller shall not disclose any personal, confidential data to any party outside of the EU or to other International organizations.
8. DATA TRANSFER
8.1. Personal data collected through domain names https://www.athenalaw.it/ and https://www.athenalaw.eu/ are stored on servers external to the company, owned by Microsoft, located in Ireland and the Netherlands. Any further information relating to the storage of personal data may be requested from the Data Controller, through the contacts referred to in point 12 of this Information.
8.2. In any case, it is understood that the owner, if necessary, will have the right to move the servers even outside the EU. In this case, the Data Controller ensures from now on that the transfer of data outside the EU will take place in compliance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses envisaged by the European Commission.
9. RIGHTS OF THE DATA SUBJECTS
9.1. The Data Subject has all rights under GDPR Art 15. More precisely, the Data Subject has the right:
i. To receive a confirmation of whether or not its personal details are kept, although not yet recorded, anywhere and this in an intelligible way;
ii. To be informed on:
a) The source of personal details;
b) The purposes and methods of processing;
c) The logics of a possible processing by means of any electronic system;
d) The identification details of the Controller, the Processors, and Representative designated in accordance with GDPR Art. 3, § 1;
e) The persons or group of persons entitled to access or share personal data and information in their office as designated representatives within the country of the User;
iii.
a) To receive an update, or request any change/ addition to the data if needed;
b) To request the cancellation, anonymity, or locking of data that are processed in discrepancy with the law, including those for which no storage is required for the purposes for which they were first collected, and then processed;
c) To receive a declaration that all operations under above letters a) and b) and their contents were extensively described to all those who received disclosure or shared the reference data, unless this would be reasonably impossible or entailed a disproportionate use of measures as compared to the rights for which protection is sought;
iv.
To fully or partly oppose and reject:
a) The processing of personal details for personal, fair reasons, and regardless of whether the data are or not relevant and useful to the purpose of collection; b) the processing of personal details for the purpose of sending advertisement or promotional material, unsolicited sale offers, market researches, or other marketing communications through automated call centres, unmanned email services, and/or other traditional marketing systems like telephone calls and/or regular mail services. The right of the Data Subject to oppose the processing of its data under above point b) (direct marketing) equally applies to automated and traditional marketing technologies, and without prejudice to the right of the Data Subject to oppose and reject just partly. Therefore, the Data Subject may decide to strictly allow and accept the sending of communications by a traditional system, or just by automated systems, both or none of the two.
Please note that the Data Subject is always entitled to oppose and reject the processing of its data for direct marketing purposes without having to give any fair reasons for it.
If applicable, the Data Subject is also entitled to the rights under GDPRO Art. 15-21 (right to have personal data rectified and a ‘right to be forgotten’ where the retention of such data infringes this Regulation or Union or Member State law to which the controller is subject, right of limiting data processing, right of data portability, and right to raise an opposition) as well as a right of claiming before the Supervisory Authority.
9.2. If allowed by the applicable laws, the user may request a copy of all data in our possession.
9.3. Before following up a specific request, we may ask you for some additional optional information, for example:
(i) Your identity;
(ii) More details needed to follow-up your requests.
9.4. The Controller commits to react to any question in due course and always within the terms established by the law. A Data Subject wishing to oppose/reject the processing of its data, shall contact us at the address stated under Section 11 and 13 of this Policy.
10. MODALITIES FOR THE EXERCISE OF THE RIGHTS OF THE DATA SUBJECT
All website visitors and the Data Subjects may exercise their rights under the EU Regulation 2016/679 at any time and free of charge by sending:
- A registered letter with bill of receipt to the current registered office in Turin, Via Susa 31,
- An Email to this address: info@athenalaw.it
11. CONTROLLER, AND OTHER PERSONS RESPONSIBLE ON ITS BEHALF
The data controller is the company Athena S.r.l. (P.I.-C.F. 11807950016), in the person of the legal representative pro tempore Mr. Federico Ingenito (C.F. NGNFRC85A04G674C), with registered office in Turin, Via Susa n. 31.
The updated list of data processors and data processors is kept at the company's registered office and can be accessed through a specific request formulated in the manner indicated above.
12. CONTACTS
The treatments carried out through the web domains https://www.athenalaw.it/ and https://www.athenalaw.eu/ take place at servers outside the company, owned by Microsoft, located in Ireland and the Netherlands. A copy of the data is stored on company-owned personal computers, periodically deleted upon backup.
For more information, you can always contact the owner.
Any comments, questions or requests regarding the use made by the Owner of the User's information must be sent to the e-mail address: info@athenalaw.it
13. FUTURE MODIFICATIONS TO THIS PRIVACY POLICY
As a result of the new laws and provisions enforced in the country, as well as the continuous review and upgrade of our services, this Privacy Policy may have to be adjusted or modified.
So, this Privacy Policy may change in time and we recommend all Data Subjects to check the Privacy section of our website from time to time.
To facilitate the identification of new Policy releases, the review date of the actual Policy is printed on the bottom line.
Please note: for modifications of the Privacy Policy relative to processing activities whose legal base is the consent of the Data Subject, the Controller shall take care of requesting a new consent, if needed.
14. REDIRECTING TOWARDS OTHER WEBSITES OF THIRDS
Our website contains some plug-ins that redirect the visitors to other websites and socials (YouTube, Vimeo, Facebook, Linkedin etc..). Plug-ins are software components that enable customization and facilitate surfing our pages.
However, we have no control on the access and management of other websites than the one where we promote our business.
For this reason, we will not be liable for the collection, processing, and disclosure of your data by other thirds linked to our web pages. We also prompt you to always read their Privacy Policy before accessing their space.
Review date: 6 August 2018