The Data Controller of the personal data collected on the Web Site is the Law Firm L2B, with registered offices in 36100 Vicenza (VI) – Italy, Contrà San Marco 25.
MANAGEMENT OF THE WEB SITE AND PLACE OF DATA PROCESSING
The Web Site is managed by L2B and is hosted on servers managed by an external company and located in the European Union (Amsterdam). The communications provided by the users of the Web Site are also transmitted to L2B’s server, in order to allow L2B to reply to such communications.
TYPE OF DATA PROCESSED
While operating, IT systems processes and software procedures that regulate the functionning of the Web Site, may collect some user’s information and personal data, whose collection is implicit in the usage of internet communication protocols.
The abovementioned information is not collected with the purpose of being associated and/or linked with other user’s data. Nevertheless, due to their nature, such information could lead to the identification of the users, where processed and/or associated with other data.
Such information shall include, without limitation, the IP addresses or domain names used by users to connect to the Web Site, the URI ((Uniform Resource Identifier) addresses of the resources requested, the time of this request, the procedures used to submit the request to server, the file size of the reply, the numeric code indicating the status of the server’s reply (successfully delivered, error and so on) and other parameters relating to the users’ operating system or IT environment.
Data provided by the user voluntarily
All data cointained in any electronic message, including the addresses of the senders, sent on a voluntary basis to the addresses posted on the specific section of the Web Site shall be acquired by L2B and shall be used in order to reply to said requests.
L2B shall use any information provided to it with transparency and only to pursue legitimate scopes.
In accordance with GDPR and the Privacy Law, the special categories of personal data (such as personal data revealing racial or ethnic origins, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural persons sex life or sexual orientation, etc.) voluntarily revealed by the user and/or provided with its prior consent shall be freely used by the recipient of such personal data.
Therefore, given that L2B intends to lawfully use the personal data provided by third parties, and considering that it might be difficult to get the user’s prior consent to the processing of their personal data, L2B invites users who wish to send their CV via the Web Site not to insert therein any of the abovementioned category of data, there being understood that the provision of the CV shall be construed as an implicit consent to the treatment of the personal data contained therein.
In any case, user’s consent to the possible transfer abroad of the CVs and of the data contained therein shall be requested and obtained during the candidate’s interview.
Synthetic exctracs of privacy policies and personal data treatment consent forms shall be made available, where necessary and upon request.
PURPOSES OF THE DATA PROCESSING
Navigation data are collected only to assess and verify the good functioning of the Web Site, and in order to collect some anonymous statistic information related to the usage of the Web Site by users. It remains understood that such information shall be deleted immediately after their processing.
Web contact’s and users’ navigation data shall be available for a maximum period of 7 (seven) days after the moment of their collection, except when such data must be used in order to ascertain potential liabilities for assumed violations, including IT violations, and offenses to the detriment of L2B or the Web Site.
Personal data provided by Web Site’s users who asked to be provided with informational material concerning L2B or L2B’s events and initiatives, or that have required to be contacted or have provided their own CV shall be managed by L2B in order to reply to and/or fulfill such requests and/or messages. Such data might be also transmitted to third parties where necessary and/or useful in order to fulfill such requests. Pursuant to GDPR and Privacy Law, these collection and processing activities are deemed to be lawful as their scope is to follow-up to the requests made by the same users.
L2B shall have the right to process and use the personal data acquired from the users in order to comply with the applicable laws and regulations, and also for pursuing its own and/or by third parties’ legitimate interest, for dealing with disputes, claims, and complaints of any sort or kind, as well as in order to protect the Web Site and its own informative and informatic systems.
The personal data provided by the users of the Web Site shall be processed by L2B’s authorized personnel, and/or third parties in their quality of “Data Processors” or “Data Controllers” in relation to the specific activities provided by such third parties. The different role of L2B’s personnel and partners in relation to the processing of personal data shall be connected to the specific activity performed by L2B from time to time.
The Web Site does not intentionally acquire personal information from users.
No cookies, neither the so-called persistent cookies nor any kind of user’s tracking system shall be used for transmitting personal data.
Nevertheless, the so-called session cookies (that are recorded on the user’s computer only temporarly and are deleted as soon as the browser is closed) are used, but their usage is strictly limited to the transmission of session identification data (random numbers generated by the server) that are necessary to allow the proper and efficient exploration of the Web Site.
Session cookies used in the Web Site prevent the collection of user’s personal data and, in any case, their use in the web Site is intended to avoid the usage of other IT techniques potentially prejudicial and much more invasive to the privacy of user’s navigation.
VOLUNTARY PROVISION OF DATA
Each user is free to disclose or not to disclose his/her personal data via e-mail and/or via the Web Site to L2B with the scope of providing his/her CV and/or for submitting an application as well as for requesting the provision of informational materials or for adhering to events and initiatives organized by L2B.
However, L2B reserves the right not to comply with the users’ request if users themselves fail or refuse to provide the necessary data.
PROCESSING METHODS AND DATA STORAGE CRITERIA
L2B shall manage and process the personal data provided by the users by means of automatic tools and by any suitable means (on paper and/or electronic means, etc.), and as long as it is necessary to pursue the purposes for which those data have been collected and or communicated. The personal data shall be stored, where necessary, for the time period prescribed under the applicable laws, and in case such data are used for informative purposes, they will be kept by L2B until the user unsubscribes to the related service.
Specific security measures have been implemented and adopted by L2B in order to prevent any loss of data, any prohibited or incorrect use of th esame and also unauthorized accesses to such data.
No data acquired through the Web Site shall be disseminated.
RIGHTS OF THE DATA SUBJECTS
Pursuant to articles 15-22 of the GDPR, personal data owners shall be entitled, at any time and where the conditions prescribed by law occur, to ask for and obtain the confirmation of their existence, to ascertain their contents and origin, to ask for their amendment, integration, updating, portability as well as the limitation of their processing.
The owner of the personal data shall have the right to request that such data are deleted, turned anonymous or blocked, as well as to object for legitimate reasons to their processing.
Said requests can be sent via e-mail to the address firstname.lastname@example.org.
The users of the Web Site that find that the processing of their data by L2B breaches the provisions of the GDPR may also send complaints to the Italian Data Protection Authority (www.garanteprivacy.it).
L2B Partners Studio Legale
Contrà San Marco n. 25
36100 – Vicenza (VI)
Tel: (+39) 0444 52 53 44
Fax: (+39) 0444 87 73 69