Privacy Policy

Privacy Notice

This Privacy Policy describes how TheItalianLawyer Ltd collects, uses and discloses information and all related choices you have regarding that information. This Privacy Policy has been updated so that it reflects recent changes in the European Data Protection Law.

 

1. Introduction

TheItalianLawyer Ltd (hereinafter as “TIL”, “we”, “us”, or “our” or “his” ) provides a marketing, social media and analytic platform through a Software as a Service (SaaS) model. At TIL the privacy and security of our customers, third parties and visitors are of paramount importance. This privacy policy explains how TIL processes information that can be used to directly or indirectly identify the data subject through the use of its website and platform.

For the purposes of this policy, TIL wants to introduce new GDPR key definitions:

 

Personal Data: any information relating to an identified or identifiable natural person (“data subject”); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

 

Processing: any operation or set of operations performed upon personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

 

Controller: the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data; where the purposes and means of processing are determined by EU or Member State laws, the controller (or the criteria for nominating the controller) may be designated by those laws.

 

Processor: a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller.

Any information stored on TIL’s platform is treated as confidential. All information is stored securely and

accessed by authorized personnel only. TIL implements and maintains appropriate technical, security and

organisational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.

 

2. Identification of the controller and data processor

Current European Data Protection Law distinguishes between the “controller” and the “processor” of the information. In general, the Client is the controller of the Customer Data. As a general rule, TIL is the Client’s Data processor which processes Customer personal data on behalf of the Client.

 

3. Information we collect and receive

TIL may collect and receive Customer Data in several ways:

 

– Customer data –

Customers and individuals to whom a Client grants access to a Website embedded with our Marketing Software routinely send Customer Data to TIL when using the Services.

 

– Customer who may decide to sign for Client services or newsletter or products provides TIL with an email

address, a phone number, a password, a domain and / or any other details of similar account. Furthermore, Clients who purchase TIL services will provide us billing information or address as credit card and banking information.

 

– As in this case, TIL servers collect information automatically when you access or use our website or services, and collect them in log file format. Information may include the Internet Protocol (IP) address, the address of the web page you visited before using the Website or Services, the type of browser and its configuration, the date and time they were used the Services, information about browser settings and plugins, as well as language preferences and cookie information.

 

– TIL collects information about the devices that access the Services, including the type of device, operating system used, device configuration, application IDs, unique device identifiers, and failure data. Whether or not all or part of this information is collected often depends on the type of device used and its configuration.

 

– TIL receive information that helps us estimate your location. We can use an IP address received through your browser or device to determine your approximate location. TIL may also collect information on the location of devices according to the consent process provided by your device.

 

– Cookies are small text files that we send to your computer or mobile device. They are unique to your account or your browser. TIL uses sessions cookies to improve the overall experience of the user by memorizing their login credentials or tracking the pages the duration of time the user spent on the website. TIL uses cookies and similar technologies on our Websites and Services that help us collect information. The Websites and Services may also include cookies and similar tracking technologies from third parties, which may collect other information about you through the Websites and Services, as well as through other websites and online services.

 

– TIL contracts with companies and people (“Third Party”) to provide services to our Customers and may need to share your information with them to provide information, products or services to you. In general, Third Party Services are software that integrates with our Services and they may share information with TIL. For example, if a cloud storage application has been activated to import files into a Landing Page, TIL may receive the user name and email address of the user.

 

– Third party may also receive several information from organizations, industries, website visitors, marketing

campaigns, affiliates and subsidiaries. TIL may combine data collected with the previous information and collect new information about relationship between IP addresses and postal codes or countries.

 

4. Sharing Personal Data

Personal data is not shared with or sold to other organizations for commercial purposes, except to provide products or services you have requested. However, under the following circumstances, it might be possible share your personal information:

 

• During a change in TIL activity. TIL may participate in a merger, acquisition, bankruptcy, dissolution,reorganization, financing, public offering of securities, acquisition of all or part of our company. Then, in measures that contemplate such activities (for example, due diligence), some or all of personal information may be shared or transferred, in accordance with standard confidentiality agreements.

 

• To comply with applicable legislation. If we receive a request for information, we may disclose Information if we believe it is reasonable to disclose this information in accordance with the requirements of applicable legislation, regulations and legal procedures.

 

• To enforce our rights, prevent fraud and for security. To protect and defend the rights, property or safety of TIL or third parties, including compliance with contracts or policies, or in relation to the investigation and prevention of fraud or security problems.

 

5. Our legal basis for processing personal data (European Territory Visitors only)

If you are a visitor from the European Territories (European Economic Area and Switzerland) our legal basis for collecting and using the personal data described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal data from you where the processing is in our legitimate business interests to, for example, administer our platforms and services and fulfil our contractual obligations as a service provider.

Personal data is used to improve the content of our Web pages and the quality and maintenance of our services in order to provide you with a tailored experience of our website and services.

Our legal basis for processing Personal Data in certain circumstances will also be based on your consent to do so or where we need the Personal Data to perform a contract with you or in order to enter into a contract with you. In some cases, we may also have a legal obligation to collect Personal Data from you.

 

TIL legitimate interest to process your personal data is balanced against your data protection rights and freedoms.

 

6. How TIL will use your information

The information that we collect are used for the following general purposes:

•  Products and services provision
•  Billing
•  Identification and authentication
•  Communication and marketing
•  Services improvement contact and research.
•  Profiling

 

TIL contracts with companies or entities or individuals (“Third Party”) to provide services to our Customers and may need to share your information with them to provide information, products or services to you.

 

TIL Customers use the Subscription Service to build webpages that their customers can visit to learn more about their business. TIL does not control the content of these webpages or the information that is gathered and managed by its Customers. That information belongs to them and is used, disclosed and protected by them according to their own privacy policies; which is independent from TIL’s Policy.

 

TIL collects information under the direction of its Customers and has no direct relationship with the individuals whose personal information it processes. TIL acts as a data processor. Then, communication in relation to data subjects’ rights should be redirected to the data controller.

 

7. Age limitations

TIL does not allow the use of our Services and Websites by any person under 16 years of age. If you are aware that anyone under the age of 16 has provided us with personal information, please contact us and we will take the necessary measures to eliminate this information.

 

8. Your rights (European Territory Visitors only)

If you have provide us with your personal information please be informed about the following rights you may exercise any time:

 

• Right of access – You have the right to obtain from the controller confirmation as to whether or not your personal data are being processed.

 

• Right of rectification – You have the right to obtain from the controller, without undue delay, the rectification of inaccurate personal data concerning you.

 

• Right to erasure – You have the right to obtain from the data controller the erasure of your personal data without undue delay.

 

• Right to restriction of processing – You have the right to obtain from the controller restriction of processing your personal information.

 

• Right to data portability – You have the right to receive your personal data you have provided in a structured, commonly used and machine-readable format.

 

• Right to object – You have the right to object at any time to the processing of your personal data.

 

Please be informed that the aforementioned rights are not absolute. In fact, the exercise of data subject rights must meet precise conditions included in the General Data Protection Regulation.

In order to exercise the previous rights, your request must be sent directly to the Data controller. Once the Data controller will receive your request, TIL will process it on behalf of the Data controller.

 

9. Security

TIL takes the security of your data very seriously. Slack strives to protect the Other information that you provide us against loss and misuse, as well as against unauthorized disclosure or access. These measures take into account the sensitivity of information we collect, process and store, as well as the state of current technology. TIL uses industry leading 256-bit SSL encryption to keep any information collected and/or transmitted to the Supported Platforms or Third-Party apps secure. Furthermore, personal information we collect are anonymised or at least pseudonymised.

 

10. Data Retention

TIL will keep the Client Data in accordance with the Client’s instructions, including any terms applicable in the Agreement with the customer and in the use of the functionality of the Services by the Client, as well as in accordance with the provisions of the applicable legislation.

 

We will retain your Personal Data for a period of time consistent with the original purpose of collection, including to pursue our legitimate business interests, comply with our legal obligations, resolve disputes and enforce applicable agreements.

 

The Data Controller has the duty of limiting the period for which the personal data is stored. Data controller will periodically review and evaluate that time period in order to respect your data privacy expectations.

 

11. Data Transferring

TIL complies with the EU – U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. TIL has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

 

To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

 

TIL will transfer personal data to any country outside the European Economic Area (EEA) one or the following conditions is met:

 

• When the third country ensures an adequate level of protection for the personal data (as determined by European Commission);

 

• In the absence of that adequate level of protection, the controller or processor whishing to transfer personal data must provide adequate safeguards towards enforceable data subject rights and effective legal remedies for data subjects are available;

 

• In the absence of that adequate level of protection and safeguards, a data transfer must meet one of the derogation for specific situations covered by the GDPR.

 

12. Changes in this Privacy Policy

TIL may modify this Privacy Policy at any time. Legislation, regulations and industry standards evolve, so these changes may be necessary; or maybe they could be due to changes in our activity. We will post the changes on this page and encourage you to review our Privacy Policy to stay informed. Should we implement changes that substantially alter your privacy rights, TIL will provide additional notice. If you do not agree with the changes in this Privacy Policy, you will be unable to properly use TIL services and platform.

 

13. Questions, Concerns or Complaints

Your privacy is important to us. If you have any questions, concerns, or complaints regarding this Privacy Notice or the way we collect and handle your information as a data Processor, please contact our Data Protection Officer (DPO) by email at gdpr@theitalianlawyer.com

 

TIL will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.