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.
Arnone & Sicomo 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 the 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 Arnone & Sicomo – International Law Firm, with seat in Palermo, Via Samartino, 45 – CAP 90141, Tel. +39 091 612 4005 – e-mail:email@example.com
Place of personal data processing
Data processing in connection with Portal web services will be performed at the aforementioned Calogero Boccadutri’s Office. 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.
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: firstname.lastname@example.org