The purpose of this Privacy Policy is to inform our Clients about the processing of personal information carried out by our law firm, BSVA Studio Legale Associato (“BSVA”), pursuant to Articles 13 and 14 of the EU Regulation 2016/679 of the European Parliament and of the Council of Europe of April 27, 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data (the “GDPR”).

1. Data controller.
The data controller is BSVA in person of its legal representative, Avvocato Francesco Senaldi, domiciled in Varese at Via Marcobi n. 8/10. The Milan and Varese offices can be reached by e-mail at: infomi@bsva.it and infova@bsva.it.

2. Purpose and legal basis.
2.1 Personal data are usually provided directly by the Client and in rare cases may be collected indirectly from third parties. If the Client’s personal data are not obtained from the Client in accordance with Article 14 letter g) of the GDPR, BSVA undertakes to inform the Client that the personal data are not subject to dissemination and fully automated decision-making processes, including profiling as referred to in Article 22, paragraphs 1 and 4 of the GDPR.

2.2 BSVA undertakes to collect and process Client’s data in accordance with the principles of necessity, lawfulness, fairness, proportionality, transparency for specific lawful purposes as set forth by the GDPR.

2.3 Specifically, the processing of the Client’s data is necessary:

(i) to perform a professional engagement that may include judicial or extrajudicial proceedings; and

(ii) to fulfill relevant obligations under applicable laws and regulations or orders of the competent Authorities.

2.4 Data will be processed in hard copy and electronic format (including portable devices) and managed in accordance with the above purposes.

3. Consequences of non-disclosure.
Failure to provide the information mentioned at paragraph 2.3 will not allow the execution of the contractual relationship between the Client and BSVA provided that BSVA will be unable to fulfill the obligations arising from the law.

4. Legal basis.
BSVA processes personal data for the performance of: (i) a mandate, (iii) pre-contractual measures, (iii) a contract; or (iv) to fulfill a legal obligation incumbent on the professional, and/or (v) based on the Client’s express consent.

5. Recipients.
5.1 Personal data provided by the Client may be disclosed:

(i) to consultants and accountants and other professionals who provide services functional to the purposes for which the data are collected and processed;

(ii) to judicial and/or administrative and/or tax authorities for the fulfillment of legal obligations;

(iii) to banking and insurance institutions that provide functional services for the purposes stated above at paragraph 2.3 (i)-(ii);

(iv) to parties who process data in accordance with legal obligations; and

(v) to Service Providers (including providers for the BSVA Web Site “www.bsva.it”; please refer to the Cookie Policy).

5.2 If the Client engagement involves the processing of personal data of individuals other than the Client (such as, its employees, suppliers, counterparties), the Client will inform them in advance and obtain the relevant consents (if necessary) in favor of BSVA, for the purpose of enabling BSVA to perform its professional engagement (article 2729 of the Italian Civil Code).

6. Dissemination and Profiling.
BSVA Client’s personal data are not subject to dissemination or any fully automated decision-making process, including profiling.

7. Transfer of personal data to a third country.
Personal data are not transferred to countries outside the European Union.

8. Retention period.
Personal data collected and processed by BSVA for the above purposes, will be retained for the duration of the engagement and, thereafter, for as long as necessary to comply with the retention obligations for tax purposes or for other purposes required by laws or regulations.

9. Client Rights.
9.1 Under Articles 15-22 of the GDPR, Clients have the right to obtain: access to their personal data (Article 15), the rectification of inaccurate data (Article 16), the integration of incomplete data or deletion (Article 17), restriction of processing (Article 18), notification in the event of rectification or erasure of personal data or restriction of processing (Article 19), data portability (Article 20), the right to object (Article 21), non-submission to decision-making based solely on automated processing including profiling (Article 22).

9.2 Clients may also file a complaint with the Supervisory Authority at any time.

9.3 The data subject may exercise the above rights at any time or request information and/or clarifications by writing an e-mail to infomi@bsva.it or by sending a letter to the following address: BSVA Studio Legale Associato, Via Marcobi 8/10, Varese 21100, attention of Avvocato Francesco Senaldi.