Data Controller and Data Processor
The Data Controller is the Firm, in the person of Atty. Salvatore Aprigliano, with registered office in Via Fabio Filzi 41, 20124 Milano.
The Data Processor is the Firm, in the person of Atty. Salvatore Aprigliano, with registered office in Via Fabio Filzi 41, 20124 Milano.
Data Controller’s Email: firstname.lastname@example.org
- User: any individual and/or corporation requesting the Firm’s assistance, and wishing to use one of the services offered by the Firm.
- Website: https://www.apriglianos.com/
- Service: the system created and designed by the Firm, aimed at calculating the costs connected with a User’s citizenship application, and provide them with a quote.
- Form: the contact form the User fills in with their personal data in order to ask for information/quotes, or to forward any other type of requests, thus consenting to the processing of their data.
- Personal Data: any information shared by the User through the Form, including their first name, surname, email, postal address, city, and telephone number.
By filling in the Form with their Personal Data, the User must consent to its processing in order to receive an answer.
Types of Data Collected
Data Provided by the User
If you personally forward an email to any of the email addresses specified on the Website, we will use your email address to answer your message. We may also use any other data you may have shared with us for the same purpose.
The Firm also collects your Personal Data when you register for the Service and when you use it to request a quote, always with your consent. We use this information to create a file for you, in order to keep track of your quotation history.
When a field is marked with an asterisk, it means that you must provide your Personal Data in order to forward your requests, and to access the Service’s features, as stated upon registration.
All your Personal Data will be stored with your consent, and used to provide you with the services, save your quote drafts, and/or access your personal area on the portal.
The Personal Data you provide to us may be used, with your consent, to send you promotional information on our or third parties’ services and/or products through automated (email apps, text messaging apps or devices, fax machines, MMS apps or devices, social networks, Whatsapp, online instant messaging apps, or automatic answering apps or devices) and/or non-automated (standard mail, telephone) tools. You always have the right to withdraw your consent, and ask us to stop sending you such communications at any time. In case of consent withdrawal, the Firm will not be liable if your use of the Service is blocked.
Principles Applicable to Personal Data Processing
GDPR provides for the protection of individuals during the processing of their personal data, and that such processing must be carried out in accordance with the principles of correctness, lawfulness, transparency and protection of confidentiality and fundamental rights.
Purpose and Legal Basis of Personal Data Processing, and Optional Nature of the Provision
All Personal Data collected by the Data Controller through the use of the Website are processed, with the User’s consent, for the purposes described below:
- Allowing the User to request a quote for the service they need, and to get in touch with the Firm.
For the purposes referred to in letter A, the Data Controller applies, as legal basis of the processing, the need to process personal data in order to perform a contract, in particular to fully process the request, and thus creating a complete quote, pursuant to Art. 6(b) of GDPR.
Providing any data for the purposes referred to in letter A is optional, but refusing to provide them will prevent the Data Controller from obtaining a quote, and thus ensuring the Firm provides the requested services.
In particular, for the purposes referred to in letter A, the User must have provided their consent in order to ensure the generation of a correct and complete quote.
Personal Data Processing/Storing Methods and Places
The Data Controller must ensure that personal data is processed in full compliance with GDPR, both in paper and/or electronic format, also with the aid of automated procedures. As it follows, data processing may also occur through any automated tools that can store, manage, and transmit them.
Personal Data subjected to collection and processing shall be safeguarded and monitored, through physical and logical means, in such a way as to minimize the risk of unauthorized access, distribution, loss, or destruction, pursuant to Art. 25 and Art. 32 of GDPR.
Processing is authorized for as long as the data is necessary to fulfill the purposes for which it was collected.
Pursuant to Art. 7, P. 3 of GDPR, you have the right to easily and quickly withdraw your consent at any time, stopping the processing of your data, and requesting their deletion, by delivering a notice to the Data Controller.
Following your request, all your Personal Data will be deleted, subject to any information that we may need to keep storing in order to abide with our legal obligations. Furthermore, if you ever get a warning, and/or are suspended or sanctioned for fraudulent or suspicious behavior, or if you ask for your data to be deleted after requesting a quote, the Data Controller reserves the right to keep your Personal Data for a period of 2 (two) years from receipt of your request, in order to prevent any frauds or repeated frauds.
Conversely, if you do not ask the Data Controller to delete your information, your Personal Data shall be kept in storage for a maximum of 10 (ten) years, starting from the date of your last access to the Website and/or app.
Personal Data Recipients
All Personal Data collected may be processed by subjects or categories of subjects acting as Data Processors pursuant to Art. 28 of GDPR, or who are authorized to process data pursuant to Art. 29 of GDPR.
In all other cases, Personal Data shall never be shared with anyone, except when it may be necessary to share them with any individuals, bodies, and/or Authorities in accordance to the applicable law.
Transferring Personal Data to Another Country or International Organization
Any Personal Data collected through the Website and/or the app may be transferred outside of the country exclusively to perform the services requested through the Website and/or the app, and in compliance with all relevant provisions of GDPR.
Some of your Personal Data may be shared with recipients located outside the European Economic Area. The Data Controller guarantees that such recipients will process any Personal Data in compliance with GDPR.
Collecting Navigation Data
During your browsing of the Website, the IT systems and technical procedures and software may automatically collect some personal data as part of their operations and working internet protocols, which your are required to provide in order to access and use the platform.
Each time you access the Website, and each time you retrieve or request content, such access data is stored in our systems, in the form of spreadsheets or text data files.
For example, this category of data includes the IP addresses or domain names of computers used by users connecting to the Website, the URIs (Uniform Resource Identifiers) of the resources required, the date and time of the request, the method used to submit the request to the server, the amount of data transmitted, the numerical code indicating the status of the data response from the server, and other parameters relating to the users’ operating system and computer environment.
The Data Controller may use this data for the sole purpose of obtaining anonymous statistical information about the Website, in order to identify your preferred pages, provide content better suited for you, and monitor that everything is working as it should. It may also be used, with your explicit consent, to deliver communications and reminders (for example, requests for contact by email).
Following the request of an Authority, we may have to provide such data in order to help defining liabilities in the event of cyber-crimes damaging the Website or its users.