Privacy Policy

Last Update: August 2018

Introduction

Protecting the client’s privacy is an integral part of the services of Kodeks – Legal Languages. This policy is designed to explain which personal data concerning individuals we process, how we collect them, for which purposes and on which legal bases, and what your rights are as a data subject.

This policy is compliant with the applicable law and, in particular, the EU General Data Protection Regulation, or GDPR (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016).

(a) Which personal data do we collect?

We collect and process the following types of personal data:

• Contact and invoicing details: for instance, full name, title, home and/or business address, telephone number, fax, e-mail address, tax ID and/or VAT number;

• Payment data: for instance, date and amount of payments made in connection to our services, date and number of quote and/or invoice that we sent you.

• Data collected in the course of our business relationship: for instance, the data included in the documents you provided to us in connection to our services.

(b) How do we collect personal data?

We only collect and process personal data that the data subject provides to us (in order to perform the contract and the requested services and/or upon express consent given by the data subject for the purposes agreed from time to time) or that are available on public databases (for instance, professional registers, newspapers).

(c) Purposes of the data processing

The personal data under section (a) are processed for the following purposes:

• performing the services you requested. The legal basis of this processing is the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;

• managing the business. The personal data are processed in order to verify the status of your payments and to assess the business performance. The legal basis of this processing is the legitimate interest of the data controller in the proper management of the business;

• complying with a legal obligation to which we are subject, for instance, for tax purposes or replying to lawful requests by the public authorities. The legal basis of this processing is the necessity to comply with a legal obligation.

(d) Automated decision-making and profiling

No automated decision-making or profiling is carried out on your personal data.

(e) Retention period

We store your personal data until the processing is required for the purposes set out in this policy or for a longer period as required by the law. Upon expiry of the retention period, the personal data will be deleted or anonymized.

(f) How do we protect your personal data?

We implement technical and organizational measures that are appropriate to the risk profile of the personal data we process.

(g) With whom do we share your personal data?

We share your personal data with third parties only if and to the extent it is strictly necessary to achieve the purposes under section (c), for instance with:

• professional consultants, including accountants, legal counsels and auditors;

• courts, law enforcement agencies, or supervisory authorities, if permitted by the law or required to comply with a legal obligation.

In any case, the above-mentioned third parties are committed to ensuring standards of personal data protection that are not lower than those ensured by Kodeks – Legal Languages.

(h) International transfer of data

As a rule, we do not transfer your personal data to third countries outside the European Economic Area that do not provide the same level of data protection.

However, if the transfer becomes necessary for the purposes under section (c), the transfer should only take place in compliance with the applicable law and, in any case: 1) to third countries where the European Commission has decided that they ensure an adequate level of data protection; 2) if appropriate safeguards are provided; or 3) upon your consent to the data transfer.

(i) Data subjects’ rights

In connection with the personal data that we process about you, you may have the following rights:

• Right of access: you may have the right to know whether or not personal data concerning you are being processed and to access such personal data at any time.

• Right to rectify your personal data: if your personal data are inaccurate or incomplete, you may have the right to obtain their rectification.

• Right to erase your personal data: you may have the right to obtain the erasure of your personal data.

• Right to restriction of processing: you may have the right to obtain a restriction on the processing of your personal data.

• Right to data portability: you may have the right to receive the personal data concerning you, which you provided to us, in a structured, commonly used, machine-readable format, for the purpose of transferring the data to other data controllers.

• Right to object: you may have the right to object to the processing of your personal data, at any time, on grounds relating to your particular situation.

• Right to lodge a complaint with a supervisory authority: if you believe that your privacy rights have been violated, you may have the right to lodge a complaint with a supervisory authority in the European Union.

In order to exercise your rights, you may contact us pursuant to section (j).

The exercise of such rights shall not be manifestly unfounded or excessive.

(j) Contacts and policy updates

The data controller is Marco Battaglia, owner of Kodeks – Legal Languages di Battaglia Marco. If you have any question about this policy and your rights, you can contact us by post at:

125 via Rossini

25089 Villanuova sul Clisi (BS)

Italy

or by e-mail: marco.battaglia@kodekslegal.com

This policy may be updated from time to time, when it is necessary to reflect changes in the legal framework or in the business of Kodeks – Legal Languages di Battaglia Marco.