This Privacy Policy is hereby made to inform you of the processing of personal data of the Client of 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”) and the Legislative Decree of August 10, 2018 no. 101, adapting the Personal Data Protection Code ex Legislative Decree of June 30, 2003 No. 196 to the national legislation of the provisions of the GDPR.

1. Personal data controller.

1.1 The data controller of personal data is Studio BSVA in the person of its legal representative, Avv. Francesco Senaldi, domiciled for the purpose in Varese, Via Marcobi n. 8/10 and at the following e-mail addresses: infomi@bsva.it and infova@bsva.it.

2. Purpose and legal basis of the processing of the Customer’s personal data.

2.1 Personal data are usually provided directly by the Client and in rare cases may be collected indirectly from third parties. If the Customer’s personal data are not obtained from the Customer in accordance with Article 14 letter g) of the GDPR, it undertakes to inform the Customer 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 It is understood that BSVA undertakes to collect and process Customer data in accordance with the principles established by the GDPR i.e. , of necessity, lawfulness, fairness, proportionality and transparency for the purposes and under the conditions of lawfulness.

2.3 More specifically, the processing of the Customer’s data is for the purpose of:

(i) to the professional assignment given to the BSVA Firm and the proper and complete performance thereof in both judicial and extrajudicial settings; and

(ii) to the fulfillment of the obligations incumbent on the professional and provided for by the applicable regulations including the fulfillment of obligations arising from the law, regulations or orders from the competent Authorities.

2.4 Data will be processed in hard copy and electronic format (including portable devices) and handled in the manner strictly necessary to carry out the above purposes.

3. Consequences of non-disclosure of personal data.

3.1 The provision of data for the above-mentioned purposes is necessary and any refusal to provide the data will make it impossible to fulfill the obligations arising from the law. Therefore, failure to provide the data referred to in letters i) and ii) of the above-mentioned paragraph 3.3 does not allow the completion of the contractual relationship itself.

4. Legal basis of processing.

4.1 Studio BSVA processes personal data lawfully whenever the processing is: (i) necessary for the performance of: (i) a mandate, (ii) a contract, and (iii) pre-contractual measures taken at the Client’s request; (ii) necessary to fulfill a legal obligation incumbent on the professional; and/or (iii) based on the Client’s express consent.

5. Recipients of processed personal data.

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 in paragraph 3.3 (i)-(ii);

(iv) to parties who process data in performance of specific legal obligations; and finally,

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

5.2 It is understood that, whenever the assignment given by the Client to BSVA also involves the processing of personal data of individuals other than the Client (therein included, its employees, suppliers, counterparties), the Client will have already informed them and obtained the relevant consents (if necessary) in favor of BSVA Studio, precisely for the purpose of enabling BSVA to execute the mandate assignment (as a presumption under Article 2729 of the Civil Code).

6. Dissemination of Personal Data and Profiling.

6.1 BSVA Customer’s personal data are not subject to dissemination or any fully automated decision-making process, including profiling.

7. Transfert of personal data to a third country.

8.1 Personal data are not transferred to countries outside the European Union.

8. Retention period.

8.1 Personal data collected and processed by BSVA for the above purposes will be retained for the duration of the mandate and thereafter for as long as the BSVA professional is subject to retention obligations for tax purposes or for other purposes required by law or regulation.

9. Customer Rights.

9.1 Under Articles 15-22 of the GDPR, Clients have the right to obtain from Studio BSVA, in the cases provided for, access to personal data concerning them (Article 15), rectification of inaccurate data (Article 16), supplementation of incomplete data or deletion of data (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 It is understood that, the Customer may also file a complaint with the Supervisory Authority at any time.

9.3 The interested party may exercise the above rights at any time or request information or clarification by writing an e-mail to privacy@bsva.it or by sending a letter to the following address BSVA Studio Legale Associato, Via Marcobi 8/10, Varese 21100 c/a Avvocato Francesco Senaldi