PRIVACY POLICY

1. GENERAL

1.1. Rossanamoruso BV (hereinafter: “Rossanamoruso”) fully respects the privacy of its (prospective) clients and the users of its website (hereinafter collectively referred to as the “Users”).

1.2. Rossanamoruso processes the personal data transmitted to it in accordance with the legislation in force, and, in particular, Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data, applicable from 25 May 2018 (hereinafter the “GDPR”).

1.3. Access to the website http://rossanamoruso.com (hereinafter, the “Website”) implies the User’s full acceptance of this Privacy Policy (hereinafter the “Policy”).

1.4. The User acknowledges having read the information below and authorizes Rossanamoruso to process, in accordance with the provisions of this Policy, the personal data that he or she communicates as part of the legal services offered by Rossanamoruso (hereinafter, the “Services”).

1.5. The Policy is valid for and applicable to the entire Website and for the registrations on this Website, such as the newsletter and contact form. Rossanamoruso cannot be held responsible nor liable for any data processed on other websites the Users may be directed to on the Website.

2. DATA COLLECTED

2.1. By requesting our Services, the User allows, Rossanamoruso to record and store, for the purposes mentioned in point 3 here below, the following information:

identifying data, such as the first name and surname, e-mail address and telephone number;
the banking information necessary for the Services, such as bank account numbers, IBAN and BIC/SWIFT;
invoicing information;
communications between the User and Rossanamoruso;
Any other personal data required to provide the Services you requested.

2.2. When the User accesses the Website, the servers consulted automatically record certain data, such as:

the type of domain with which the User connects to the Internet;
the IP address assigned to the User (when connected);
the date and time of access to the Website and other data related to traffic;
location data or other data relating to the communication;
the pages visited;
the type of browser used;
the platform and/or operating system used;
·the search engine as well as the keywords used to find the Website.

2.3. No personal data identifying the User is collected through the servers consulted. This information is kept for statistical purposes only and to improve the Website.

2.4. We may also collect some of your data through other companies, including from the following sources:

other companies that have requested our services relating to a case that involves you (for example as a third party, opposing party, etc.);
bailiffs, other lawyers or notary publics.

3. PURPOSES OF PROCESSING THE DATA

3.1. We process your data for various purposes. For each purpose, only the data relevant to the purpose in question are processed. Rossanamoruso collects, stores and uses its Users’ data for the following purposes, in particular:

to establish, carry out and conduct the contractual relationship with the User;
to analyse, adapt and improve the content of the Website;
to provide the Services;
to allow the User to receive e-mails and newletters;
to facilitate the availability and use of the Website;
to respond to requests for information;
for any other purpose to which the User has expressly consented.

3.2. The legal basis of the processing of your personal data is:

(i) the User’s consent; or

(ii) the execution of any request from the User or the necessity for the performance of an agreement with the User; or

(iii) a legal obligation imposed on Rossanamoruso;

(iv) Rossanamoruso’s legitimate interest, provided that it is in accordance with the User’s interests, freedoms and fundamental rights.

If the legal basis of our processing is the User’s consent, the User has the right to withdraw it at any time without prejudice to the lawfulness of the processing performed prior to withdrawal.

4. RIGHTS OF THE DATA SUBJECT

According to the regulations on the processing of personal data, the User has the following rights:

Right to be informed about the purposes of the processing and the identity of the data controller.
Right of access: the User may at any time have access to the data that Rossanamoruso has on him/her or check if it is included in the database of Rossanamoruso.
Right to rectification: we take all reasonable steps to ensure that the data we kept is up to date. We encourage Users from time to time to consult us to check that their data is still up to date. If data is inaccurate or incomplete, Users have the right to ask us to correct it.
Right to object: the User may, at any time, object to the use of his/her data by Rossanamoruso.
Right to cancellation: the User may, at any time request the deletion of his/her personal data, except those which Rossanamoruso has a legal obligation to keep on record.
Right of limitation of processing: the User may, in particular, obtain a limitation of processing when he/her has objected to the processing, when he/her disputes the accuracy of the data, or when he/her considers that the processing is illegal.
Right of portability: The User has the right to receive the personal data that he/her has communicated to Rossanamoruso and may also ask said company to send this data to another DPO.

5. PERIOD OF STORAGE

Rossanamoruso will keep the personal data of its Users for the duration necessary to achieve the objectives pursued within the context of their contractual relationship.

6. COMPLAINT WITH THE SUPERVISORY AUTHORITY

The User is informed that he/her has the right to file a complaint with the Data Protection Authority if he/her believes their rights have been infringed.

7. SECURITY

7.1. In addition, Rossanamoruso has taken the appropriate organizational and technical measures to ensure a level of security adapted to the risk and that, to the extent possible, the servers hosting the personal data processed prevent:

unauthorized access to or modification of this data;
improper use or disclosure of such data;
unlawful destruction or accidental loss of such data.

7.2. In addition, associates, partners, interns or employees of Rossanamoruso who have access to this data are subject to a strict confidentiality obligation. Rossanamoruso may in no way be held liable in the event that this data is stolen by a third party.

8. COMMUNICATION TO THIRD PARTIES

8.1. Rossanamoruso treats personal data as confidential information. It will not communicate them to third parties in no circumstances other than those specified in the Policy, such as to achieve the objectives or under the conditions in which the law requires it to do so.

8.2. Rossanamoruso may communicate its Users’ personal information to third parties to the extent that such information is necessary for the performance of the Services or an agreement with its Users.

8.3. The communication of this information to the aforementioned persons shall, in all circumstances, be limited to what is strictly necessary or required by the applicable regulations.

9. DIRECT MARKETING

9.1. The personal data will not be used for direct marketing purposes for articles or services that would not be identical or similar to those for which the User has already called upon Rossanamoruso, unless the User has previously explicitly consented to such use by ticking the boxes provided for this purpose (“opt-in”).

9.2. In the context of direct marketing, this means that Users can unsubscribe at any time from newsletters and other commercial communications from Rossanamoruso. Such Users will be put in “opt- out”. Users can unsubscribe by sending an email to the following address: info@rossanamoruso.com or by clicking on the unsubscribe link at the bottom of each email.

9.3. When the User has given his consent to the use of this information for direct marketing purposes, the latter retains the right to object to such use at any time, upon request and free of charge. The User may simply communicate his request by writing to the following address: info@rossanamoruso.com