| The present document describes the general
Privacy Policy adopted by Tonucci & Partners’s Portal (hereinafter “Portal”)
for User’s personal Data Processing (data processing policies of
other web sites linked to the Portal are not covered by the present
document).
The document is of a generic nature and lays
down the correct criteria for data processing
to be performed on or through the Portal; users
may find detailed explanation of the implemented
criteria in the various Informative published
on the Portal sections to specify aims and
modalities for data processing in connection
with the available services and/or information.
Our Privacy Policy draws on the contents of
the Privacy Policy implemented by the Autorita`
Garante (Regulatory Authority) for personal
data protection of users accessing the Authority’s
official web site www.garanteprivacy.it.
Tonucci & Partners conforms its Portal Data
Protection policies with the provisions set
out in the Testo Unico (Unified Text) of regulations
on personal data protection (legislative decree
30 June 2003, n.196, Data Protection Code),
and with the cautions and procedures specified
by the Garante in the Data Protection memorandum
published on the Authority’s official web site.
Among these, the suggestions contained in the
Recommendation n.2/2001 adopted on the 17/05/2001
by European Data Protection Authorities, (reunited
according to the art. 29, Directive n. 95/46/EC),
aiming to identify the minimum requirements
for on-line personal data collection, and also
modalities, deadlines and type of information
the Data Controllers shall provide users with
when they access web pages, independently of
the purposes for connection.
Personal Data processing on Tonucci & Partners’s Portal will be performed fully complying
with the provisions of Ufficio del Garante
general opinion, 3 June 2004, Prot. N. 22457 – issued
together with the Consiglio Nazionale Forense
(National Forensic Council) – on personal Data
Protection in exercising forensic activities
(privacy and law firms).
Personal Data Controller (art.28 of the Data
Protection Code)
Users acknowledge that by accessing the Portal,
data relative to identified and identifiable
persons can be processed.
The Data Controller is Tonucci & Partners,
with seat in Rome, Via Principessa Clotilde
n. 7 CAP 00196, tel. +39 06362271 – fax +39
063235161 – e-mail: mail@tonucci.it.
Place of personal data processing.
Data processing in connection with Portal web
services will be performed at the aforementioned
Tonucci & Partners’s Office under the sole care
of Firm’s technical staff and, eventually,
persons in charge of maintenance operation.
Personal Data communication and the eventual
diffusion will be in compliance with Data Protection
Code provisions: upon user’s agreement or when
laid down by law, according to the discipline
in the articles 24 and 25 of the Code.
Categories and typologies of personal data
to be processed.
Navigation data
Electronic systems and software set to run
the Portal, collect some personal data implicit
with the use of internet communication protocols.
Although collected information is not associated
to identifiable users, by its own nature may
allow for user’s identification if processed
and associated with third parties data.
This category of data includes: IP addresses
or domain names of computers accessing the
Portal, the URI (Uniform Resource Identifier)
addresses of requested resources, the time
of the request, the method for submitting the
request to the server, the answer’s file size,
the numerical code showing the status of the
answer supplied by the server (ok, error, etc.)
and other parameters relative to operative
system and user’s computer environment.
Those data are used only for anonymous statistical
information on Portal’s use and to check for
Portal correct functioning and once processed
are immediately deleted. In case of crimes
against the Portal all collected data could
be used to investigate for responsibilities:
in all other cases, data on web contacts are
not stored permanently, unless users request
to so (i.e. access to their own summary pages
of requested services, information etc.).
Data supplied by users on a voluntary
basis
The optional, explicit and voluntary sending
of e-mails to the addresses specified on the
Portal, requires the acquisition of sender’s
address in order to give feedback on his requests,
and implies also the acquisition of other personal
data present in the message.
Specific and synthetic informative will be
progressively reported or displayed in the
Portal sections dedicated to on-line services.
Use of Cookies or user’s tracing/monitoring
systems.
With this regard, no User’s personal data
is acquired by the Portal.
The Tonucci’s Law Portal doesn’t use Cookies
for the transmission of personal information
or persistent cookies for permanent users tracing.
The use of the so called session cookies (which
are not permanently stored in user’s computers
and disappear when the browser is closed) is
strictly limited to the transmission of session
identification data (consisting of random numbers
generated by the server) necessary for a safe
and efficient navigation of the Portal.
Session cookies protect from user’s identification
while collecting personal data, and are used
instead of other electronic techniques potentially
harmful to the user’s navigation privacy.
Optional nature of data supplying
Nevertheless, Users are always free to provide
personal data when requesting for special services
(legal on-line consulting, request of information,
registration to the Newsletters service, etc.),
but if they refuse to provide certain data,
in some cases, it won’t be possible to process
their requests.
Data processing modalities
The personal data are processed with electronic
means for the time strictly necessary to fulfill
the purpose for their collection.
We implement specific safety measures to prevent
data loss, illegitimate or unfair use of data
and unauthorized access to the Portal databanks.
Concerned persons rights
The subjects whom personal data refer to, have
at any time the right to obtain a confirmation
on whether their data still exists or not and
have the right to know their content and origin,
to verify their accuracy or to ask for their
integration or update, or for their rectification
(art. 7 of legislative decree n. 196/2003).
According to the same article, users have
the right to ask for deletion, anonymization
or blocking of illegitimately processed data,
and also to oppose, on legitimate grounds,
to their processing.
All requests must be submitted to the Data
Controller, without formalities, by sending
a communication to the following e-mail address: mail@tonucci.it
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