Joint controllers

Cicu Law Firm & Partners is a shared mark and is not, as such, a legal person. The data collected through this website are processed under joint controllership, pursuant to Article 26 of Regulation (EU) 2016/679, by the lawyers who practise under the mark:

• Avv. Salvatore Cicu — Largo Augusto 7, 20122 Milan, Italy — VAT no. 01284890926 — scicu@clfp.it
• Avv. Davide Cicu — Largo Augusto 7, 20122 Milan, Italy — VAT no. 08302580967 — dcicu@clfp.it
• Avv. G. Claudio Cicu — Largo Augusto 7, 20122 Milan, Italy — VAT no. 03581330929 — ccicu@clfp.it

The joint controllers have determined, in a transparent manner and by means of an internal arrangement, their respective responsibilities for compliance with the obligations arising under the Regulation, with particular regard to the exercise of data subject rights and to the information to be provided under Articles 13 and 14. The essence of the arrangement is made available to any data subject who requests it, pursuant to Article 26(2) of the Regulation.

Data subjects may in any event exercise their rights in respect of and against each of the joint controllers, pursuant to Article 26(3) of the Regulation.

For any matter concerning the processing of personal data and for the exercise of data subject rights, you may write to info@clfp.it or call +39 02 8111 7993.

What data we collect

• Browsing data. The IT systems that operate this website acquire, in the ordinary course of their functioning, certain data whose transmission is inherent in the use of internet communication protocols: IP addresses, browser and device type, the time of the request, the pages requested and the outcome of the response.
• Data provided voluntarily. The data you communicate by writing to the addresses shown on this website or by completing the contact form: first name and surname, email address, telephone number where given, and the content of your message.

This website does not call for the provision of special categories of data. Please do not enter in the contact form information concerning health, legal proceedings or other special categories of data: where such data are required, they will be collected in the course of the professional relationship, with the safeguards proper to that context.

Why we process them

• Operation and security of the website, including the detection of anomalies and unlawful use.
• Responding to contact requests and assessing a possible professional engagement.
• Compliance with legal obligations, including those relating to anti-money laundering, taxation and professional conduct, where applicable.
• Establishment, exercise or defence of legal claims, including before the courts.

The data are not used for marketing purposes, nor for sending promotional communications.

On what legal basis

• Article 6(1)(b) GDPR — steps taken at the request of the data subject prior to entering into a contract, for the purpose of responding to contact requests.
• Article 6(1)(f) GDPR — the legitimate interest of the controller in the security of the website and in the defence of its own rights.
• Article 6(1)(c) GDPR — compliance with legal obligations.
• Article 9(2)(f) GDPR and Article 2-octies of the Italian Data Protection Code (Legislative Decree 196/2003, as amended) — where the professional relationship entails the processing of special categories of data or of data relating to criminal convictions and offences, for the establishment, exercise or defence of legal claims.

Processing carried out in the practice of the legal profession is in every case covered by professional secrecy, pursuant to Article 9(3) GDPR and to the rules of professional conduct.

Whether provision is mandatory

The provision of browsing data is necessary for the website to function. The provision of the data requested in the contact form is voluntary, but the fields marked as required are indispensable in order to reply: without them the request cannot be answered.

To whom they may be disclosed

The data are processed by the Firm's lawyers and staff, who are authorised to process them and bound by professional secrecy.

Processors. The data may be disclosed to parties acting as processors within the meaning of Article 28 of the Regulation, appointed by a specific instrument:

• the provider of hosting and email services;
• the providers of the platforms and applications used in performing the engagement, where they act on the lawyer's instructions;
• the accountant or tax adviser, limited to the activities carried out on the lawyer's behalf.

Recipients acting as independent controllers. The data may also be disclosed, within the limits of the performance of the engagement and of legal obligations, to parties that independently determine the purposes and means of the processing and therefore do not act as processors:

• judicial and administrative authorities, in the cases provided for by law, and the Italian Ministry of Justice as regards the electronic civil proceedings systems, including the lawyers' Consolle;
• agents for service, technical consultants, other counsel and opposing parties, to the extent necessary to carry out the mandate;
• banks and insurance companies;
• the accountant or tax adviser, where acting in compliance with its own professional and legal obligations.

The data are in no case disseminated, nor transferred to third parties for commercial purposes.

Transfers outside the European Union

The data are stored on servers located within the European Union. No transfers to third countries are envisaged; should any become necessary, they will take place solely on the basis of an adequacy decision of the European Commission or of appropriate safeguards within the meaning of Articles 46 et seq. of the Regulation, and notice of them will be given in this privacy notice.

For how long

Data subject rights

Within the limits and on the conditions laid down by Articles 15 to 22 of the Regulation, data subjects may exercise the right of access to their data, and the rights to rectification, erasure, restriction of processing and data portability, as well as the right to object to processing based on legitimate interests.

The exercise of these rights may be subject to the limits laid down by Article 2-undecies of the Italian Data Protection Code where responding would cause actual and concrete prejudice to the conduct of defensive investigations or to the exercise of a legal claim before the courts.

Requests should be sent to info@clfp.it. A reply is given without undue delay and in any event within one month of receipt.

Complaint to the supervisory authority

A data subject who considers that the processing of their data is unlawful has the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali), pursuant to Article 77 of the Regulation, in the manner indicated on that Authority's website, or to bring proceedings before the courts.

Security measures and automated decision-making

The website is served over HTTPS and the data are protected by technical and organisational measures appropriate to the risk, pursuant to Article 32 of the Regulation.

No automated decision-making, including profiling, within the meaning of Article 22 of the Regulation is carried out.

Changes to this notice

This privacy notice may be updated to reflect changes in the law or in the services offered through the website. The version in force is the one published on this page, together with its date.

What cookies are

Cookies are small text files that the websites you visit send to your device, where they are stored and from which they are sent back on your next visit. Alongside cookies there are other tracking technologies with a similar function, to which the same rules apply.

The matter is governed by Article 122 of the Italian Data Protection Code (Legislative Decree 196/2003, as amended) and by the Guidelines of the Italian Data Protection Authority of 10 June 2021.

Which cookies and technologies this website uses

This website installs no cookies. It stores a single item of information in your browser, using local storage (localStorage):

This item of information does not allow you to be identified, is not transmitted to any server — not even to the Firm's own — and is not combined with any other data. As it is a technology strictly necessary to provide a functionality you have requested, no consent is required under Article 122(1) of the Italian Data Protection Code: that is why no banner appears.

Sending the contact form may involve the use of technical session cookies, generated by the server for the sole purpose of ensuring the transmission of the communication and the security of the operation. They last only for the session, do not persist once the browser is closed and likewise fall among the technologies exempt from consent under Article 122(1) of the Italian Data Protection Code.

Profiling and third-party cookies

This website uses no profiling cookies, whether its own or third parties', and allows no third party to install tracking technologies through its pages.

There are no social media sharing buttons that install cookies, nor any content embedded from external platforms such as videos or maps.

The typefaces are embedded in the pages and served from the Firm's own domain: displaying them involves no request to any third-party server and therefore no disclosure of your IP address to anyone other than the joint controllers.

This website contains links to external pages — among them the journals hosting the contributions referred to in the Insights section and the lawyers' LinkedIn profiles. Those pages are governed by their own privacy notices, for which the joint controllers are not answerable: their cookies are installed only if you choose to follow the link.

Usage statistics

At present this website uses no statistics or audience measurement tools, whether its own or third parties'. The controllers hold, through this website, no data whatever on the behaviour of individual users.

Should such tools be introduced in future, the joint controllers will first update this notice. Your prior consent, collected by means of an appropriate banner, will be sought in every case in which the tool is not equivalent to a technical cookie according to the Italian Data Protection Authority's guidance, that is, whenever any one of the conditions those guidelines require is not met: minimisation of the IP address, no combination with other processing operations and no disclosure to third parties.

How to manage cookies from your browser

You may at any time review, restrict or delete the cookies and the information stored by your browser through its settings, ordinarily found under the heading relating to privacy or to website data. Detailed instructions are published by the manufacturers in their respective browser guides.

Removing the item of information described above means only that the choice between the light and dark display reverts to its default. Disabling technical cookies may, by contrast, impair the functioning of parts of this website.

Controllers and contact details

Any data collected by means of the technologies described above are processed under joint controllership, pursuant to Article 26 of Regulation (EU) 2016/679, by Avv. Salvatore Cicu, Avv. Davide Cicu and Avv. G. Claudio Cicu, who practise under the mark Cicu Law Firm & Partners — info@clfp.it.

For any further information on the processing of personal data, on the legal bases, on retention periods and on data subject rights, please see the privacy policy.

This notice may be updated to reflect changes in the law or in the functionalities offered through the website. The version in force is the one published on this page, together with its date.