PRIVACY | FOX & PATTON Advisor



web site: www.foxpatton.com



INFORMATION REGARDING THE COLLECTION OF PERSONAL DATA

We hereby inform users, pursuant to art. 13-14 of EU Reg. 2016/679, regarding the processing of personal data carried out through this website (hereinafter also referred to as "the Site") without extending to other websites that may be reached by the user via referral links inserted inside it.

The processing of personal data takes place in compliance with current legislation on the protection of personal data and is based on principles of correctness, lawfulness, transparency and data protection.

The Data Controller is:
• FOX & PATTON S.R.L., with headquarters in Via Pasquale Galluppi n. 5, 10134, TURIN (TO), ITALY. The telephone and email addresses are respectively 011 352535 and privacy@foxpatton.com.

The Personal Data Protection Officer (DPO) is:
• SPAZIOTTTANTOTTO S.R.L. with headquarters in Via Nino Bixio n. 8 VAT number 08283280017, Telephone and email numbers are respectively 0114337431, mail: dpo@spazio88.com, pec: spaziottantottosrl@pec.aruba.it.

The information is a general obligation that must be fulfilled before or at the latest when starting the direct collection of personal data. In the case of personal data not collected directly from the interested party, the information must be provided within a reasonable time, or at the time of communication (not registration) of the data (to third parties or to the interested party). Pursuant to the General Regulation for the Protection of Personal Data of natural persons (GDPR – Reg. (EU) 2016/679), the undersigned organization, Data Controller, informs of the following:

Sources and categories of personal data:
The personal data held by the undersigned organization are collected directly from the interested parties. This site does not collect data belonging to particular categories of data, by which we mean those suitable for revealing racial or ethnic origin, philosophical or other religious beliefs, political opinions, membership of trade unions, associations or organizations of a religious, philosophical, political or trade union, the state of health and sex life.

Telematic helpdesk service:
The Website allows visitors who request it to use the WILDIX KITE application to use a chat service with secretarial staff. The service requires authentication through the request for Name and Surname, and an email address, or by logging into a Facebook, LinkedIn, Twitter, or Google account. For this service, please refer to the privacy and cookie policy of https://www.wildix.com/wildix-privacy-cookie-policy/

Cookies:
Like others, this Website saves cookies on the browser used by the user concerned for the transmission of information of a personal nature and to enhance the experience. In fact, cookies are small text strings that the sites visited by the user send to his terminal (usually the browser), where they are memorized, sometimes even with characteristics of large temporal persistence, to then be re-transmitted to the same sites at the next visit. As explained below, it is possible to choose whether and which cookies to accept, bearing in mind that refusing their use may affect the ability to carry out some transactions on the site or the accuracy and adequacy of some customizable contents offered or the ability to recognize the user from one visit to the next. If you do not make any choice in this regard, the default settings will be applied and all cookies will be activated: however, at any time, you can communicate or change your decisions in this regard. The "Site" foxpatton.com uses Cookies to make our services simple and efficient for users who view the pages of the site. Users viewing the Site will see minimal amounts of information entered on their devices, whether they are computers or mobile devices, in small text files called "cookies" saved in the directories used by the User's web browser. There are various types of cookies, some to make the use of the site more effective, others to enable certain features.

Types of Technical Cookies:
This type of cookie allows certain sections of the site to function correctly. They are of two categories: persistent and session:
• persistent: once the browser is closed they are not destroyed but remain up to a preset expiration date
• session: they are destroyed every time the browser is closed

In particular, so-called session cookies are used, which are not stored permanently on the user's computer and disappear when the browser is closed and whose use is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to allow safe and efficient exploration of the site and which avoid the use of other IT techniques potentially prejudicial to the privacy of users' browsing and do not allow the acquisition of personal identification data of the user.

These cookies, always sent from our domain, are necessary to view the site correctly and in relation to the technical services offered. They will therefore always be used and sent, unless the user changes the settings in their browser (thus affecting the display of site pages). This site does not use analytical cookies, neither from first nor from third parties.

How to manage cookies:
When the user accesses the site, the banner is shown informing him of the use of technical cookies with a special closing tick.

Disabling cookies:
Almost all browsers offer the possibility of managing and not enabling cookies, in order to respect user preferences. In some browsers it is possible to set rules to manage cookies site by site, an option that offers more precise control over user privacy; another function available on some browsers is the incognito mode, so that all cookies created in this mode are deleted after closing.

Consult the following instructions for managing cookies in the relevant browsers:
Chrome
Firefox
Internet Explorer / Edge
Safari

Navigation data:
The computer systems and software procedures used to operate the website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the site, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user's IT environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning and are canceled immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the site.

Profiling data:
Profiling data regarding the data subject's consumption habits or choices are not directly acquired. However, it is possible that through links or by incorporating third-party elements, such information may be acquired by independent or distinct subjects. In this regard, see the section on third-party cookies.

Data provided voluntarily by the user:
The optional, explicit and voluntary sending of e-mails to the addresses indicated on the Site involves the subsequent acquisition of the sender's address, necessary to respond to requests, as well as any other personal data included in the e-mail. Even the explicit and voluntary sending of the forms that can be filled in on the site containing data of the interested party involves the treatment to follow up on the pre-contractual obligations or the execution of the services foreseen with the sending of the forms. This information in the forms may concern personal data, contact details, contact details, telephone numbers, accommodation facilities, e-mail addresses of the interested parties and of identified and identifiable third parties having cause with the site user.

Contact form:
By filling in the contact form with their data, the user consents to their use to respond to requests for information, quotes, or any other nature requested through the contact form. Any interest in collecting and/or recording particular or judicial data is excluded; therefore, please do not provide this information when filling out the contact form. In the event that the user voluntarily communicates his personal data belonging to particular categories (e.g. regarding the state of health), in this case the undersigned organization will proceed with the cancellation if it does not jeopardize the processing of the data.

Online Registration Form:
By filling in the contact form with their Data, the user consents to their use to respond to requests for information, quotes, or any other kind indicated by the header of the form. Personal data collected: Name, Surname, Gender, Place and date of birth, Tax code, Residential address, E-mail, Telephone and Mobile.

Purposes and legal bases of the processing:
Personal data is used:
a) to allow navigation on the site (ref. art.6 co.1 letter f) of the GDPR), as well as, for registered users, the use of the information and intelligence business platform, within the reserved areas.

Furthermore, all personal data may be processed:
b) for purposes related to obligations established by law, as well as by provisions issued by authorities legitimated by the law (ref. art. 6 co. 1 letter c) of the GDPR);
c) for the assessment, exercise or defense of a right in court and out of court (legitimate interest) of the undersigned organization (ref. art. 6 co. 1 letter f) of the GDPR);
d) for functional purposes, according to the legitimate interest of the Data Controller in particular; for navigation and usage logs to protect the site and the service from cyber-attacks, identify any malicious or fraudulent activity (ref. art. 6 co. 1 letter f) of the GDPR).

Consequences of refusing to provide data:
The provision of data collected from the interested party is optional but essential for the purpose of processing them for the purposes in letters a) and b). In the event that the interested parties do not communicate their indispensable data and do not allow the treatment, it will not be possible to proceed with the completion and implementation of the services offered and to follow up on the contractual obligations undertaken, with consequent prejudice to the correct fulfillment of regulatory obligations , such as e.g. accounting, fiscal and administrative ones, etc.

Apart from that specified for navigation data, the user is free to provide personal data for cookies and specific requests through forms, e.g. on products and/or services. Failure to provide such data may make it impossible to obtain what has been requested. For all non-essential data, including those belonging to particular categories, the provision is optional. In the absence of consent or incomplete or incorrect provision of certain data, including those belonging to particular categories, the required fulfilments could be so incomplete as to cause damage or in terms of penalties or loss of benefits, both due to the impossibility of guaranteeing the adequacy of the treatment itself to the obligations for which it is performed, and for the possible mismatch of the results of the treatment itself to the obligations imposed by the laws to which it is addressed, intending exempt the undersigned organization from any and all responsibility for any sanctions or afflictive measures.

Data processing methods:
The treatments connected to the web services of the site are treated with automated tools for the time strictly necessary to achieve the purposes for which they were collected; they take place at the server in Italy or the EU and are only handled by technical personnel in charge of processing, or by persons in charge of maintenance and administration operations. Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access and loss of confidentiality.

By data processing we mean their collection, registration, organization, conservation, processing, modification, cancellation and destruction or the combination of two or more of these operations. In relation to the aforementioned purposes, the processing of personal data takes place using manual, IT and telematic tools, with logic strictly related to the purposes themselves and, in any case, in order to guarantee the security and confidentiality of personal data will therefore be processed in compliance with the methods indicated in the art. 5 EU Reg. 2016/679, which provides, among other things, that the data are processed lawfully and correctly, collected and recorded for specific, explicit and legitimate, exact, and if necessary updated, pertinent, complete and not excessive with respect to the purposes of the processing, in compliance with fundamental rights and freedoms, as well as the dignity of the interested party with particular reference to confidentiality and personal identity, through protection and security measures. The undersigned organization has prepared and will further improve the access security and data retention system. An automated decision-making process (e.g. profiling) is not carried out.

Non-EU transfers:
The processing will take place mainly in Italy and the EU; the treatment that takes place in non-EU and non-EEA countries when, at the request of the interested party, the connections to the site come from these countries, is outside the responsibility of the Data Controller.

Storage period:
Personal data will be kept, in general, as long as the purposes of the processing persist according to the category of data processed. The Data Controller may be obliged to keep personal data for a longer period in compliance with a legal obligation or by order of an authority.

Recipient categories:
The data (only the indispensable ones) are communicated:
• to data processors and data processors, both internal to the organization of the writer and external, who perform specific tasks and operations (site administration, analysis of navigation and traffic data, management of e-mails and forms sent voluntarily by the 'user, etc.);
• in the cases and to the subjects foreseen by the law.

The data will not be disclosed unless otherwise provided by law or subject to anonymisation. Without prejudice to what is specified for cookies and third-party elements, without the prior general consent of the interested party to communications to third parties, it will be possible to start only services that do not provide for such communications. If necessary, specific and punctual consent will be requested and the subjects who will receive the data will use them as independent data controllers.

In some cases (not subject to the ordinary management of this site) the Authority may request news and information, for the purpose of controlling the processing of personal data. In these cases, the answer is mandatory under penalty of an administrative fine.

Rights of the interested party:
At any time you can: exercise your rights (access, rectification, cancellation, limitation, portability, opposition, absence of automated decision-making processes) when required in relation to the data controller, pursuant to articles from 15 to 22 of the GDPR, available at the following link (https://eur-lex.europa.eu/legal-content/IT/TXT/HTML/?uri=CELEX:32016R0679&from=IT#d1e2168-1-1); propose a complaint to the Guarantor (www.garanteprivacy.it); if the treatment is based on consent, revoke this consent given, taking into account that the revocation of the consent does not affect the lawfulness of the treatment based on the consent before the revocation. Requests should be addressed to the Data Controller by e-mail at the address: privacy@foxpatton.com

Information format:
This privacy statement can be consulted automatically via any Internet browser. In any case, please report the difficulties encountered in viewing this information in order to be able, if necessary, to provide for it with alternative means. This document will be subject to updates; It is the user's responsibility to consult the document and its updates.

March 28, 2023