Informative Notice on Privacy
D.Lgs. 30 June 2003 n. 196

With reference to the processing of personal data:

1. Nature of the Data in Possession of the Firm

In the documents and electronic archives of ASTOLFO DI AMATO & ASSOCIATI-AVVOCATI (“the Firm”), there is information about our clients such as: addresses, telephone numbers, e-mails, fiscal codes, VAT numbers, fiscal standing, information about civil and criminal controversies which are pending and/or concluded, judicial registers, details about corporate activities and other information necessary for the fulfillment of professional assignments.

2. Nature and Purpose of the Firm’s Processing of Personal Data

The data processing is an operation or a set of operations developed within the Firm’s professional activity and involves information gathering and the registration, modification, selection, extraction, comparison, exploitation, interconnection, communication, conservation, cancellation and destruction of the personal data.  The operation may involve the use of electronic or computer-based means.

The Firm treats the personal data of clients and possibly third parties, exclusively for purposes closely connected and instrumental to the execution of the professional assignment and to the fulfillment of the professional and accounting obligations established by law.

The following activities are included: research; elaboration of opinions and legal advice in order to safeguard the rights and interests of the client; drafting of judicial acts; participation at hearings; other activities connected and instrumental to safeguarding the client’s rights; bookkeeping and the fulfillment of the accounting and fiscal obligations of the Firm.

The conferment of the personal data for such aims is partly compulsory, according to civil and fiscal laws, and partly optional through necessity, due to the parties’ professional relationship and the Firm’s professional activities.  The partial or total refusal of the client or data subject to confer the requested personal data will make it consequently, impossible or extremely difficult for the Firm to execute the professional assignment.

3. Treatment Conditions of the Personal Data and Safety Measures Adopted by the Firm

The Firm treats the data in a proper manner and in accordance with Article 33 of the Code.

The data is treated, for the above-mentioned purposes, through insertion in the Firm’s paper archives and through the use of computers and other electronic means (e.g., email) for the drafting of acts, opinions and other documents.  In every case, the treatment is strictly for professional purposes and all necessary measures are adopted in order to guarantee the security and the confidential nature of the data.  With regards to this:

· In accordance with Article 30 of the Code, the Firm has designated its members (e.g., partners, collaborators and secretarial staff) to treat the personal data collected by the Firm;

· the access to such data is limited exclusively to the above-mentioned members of the Firm, who carry out the operations only for purposes connected to the professional activity and in accordance with the law and with the instructions given by the Firm;

· the above-mentioned members of the Firm are strictly forbidden from communicating the personal data to unauthorized persons, without the previous authorization of the data subject;

· in order to prevent unauthorized persons from accessing the personal data, the Firm has adopted the following security measures: a password is required to access all computers; the paper archives and files of the Firm are constantly supervised to insure they are inaccessible to unauthorized persons during work hours and locked outside of office hours; and drafts and photocopies of documents are properly destroyed.

Should the data processing be terminated, for whatever reason, the data will be destroyed or conserved exclusively for personal purposes and, in every case, without being intended for systematic communication or dissemination as required by Article 16 of the Code.

4. Categories of Subjects to whom the Data can be Communicated

The Firm may divulge the treated personal data to public and private subjects, only if necessary for asserting or defending a right in a legal proceeding or executing the professional assignment.

5. Rights of the Data Subject in Accordance with Article 7 of the Code

Article 7 of the Code provides the following rights:

1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exists, regardless whether the data has already been recorded, and communication of such data in an intelligible form.

2. A data subject shall have the right to be informed of:

a) the source of the personal data;

b) the purposes and methods of the processing;

c) the logic applied to the processing, if the latter is carried out with the help of electronic means;

d)  the identification data concerning data controller, data processors and the representative designated [for the treatment of data];

e)  the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know the data in their capacity as designated  representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing.

3. A data subject shall have the right to obtain:

a) updating, rectification or, where interested therein, integration of the data;

b) erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected  or subsequently processed;

c)  certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.

4. A data subject shall have the right to object, in whole or in part:

a)  on legitimate grounds, to the processing of personal data concerning him, even though they are relevant to the purpose of the collection;

b)  to the processing of personal data concerning him, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.

The data subject may delegate the exercise of the rights established in Article 7 of the Code.

Rights may be exercised in the following manner:

-  By email to:  diamatoeassociati@diamato.eu;

-  By certified letter, with return receipt requested, to the following address:

Studio Legale
Astolfo Di Amato & Associati-Avvocati
Via Nizza n. 59
00198 ROMA

By fax to: 06.84242253

6.  Misc.

The party in charge of the treatment of personal data is the Firm Astolfo Di Amato & Associati-Avvocati.

Upon written request, the Firm will provide the name of the Data Processor.

The Data Controller

Astolfo Di Amato & Associati-Avvocati