Pursuant to Article 13 of Italian Legislative Decree No. 196/2003 and Articles 13-14 of Regulation (EU) 2016/679, Trevisan & Cuonzo Avvocati (hereinafter referred to as “the Firm” or “Trevisan & Cuonzo”) wishes to inform you that we will come into possession of your personal data related to all services provided in connection with the facilities at the Brera.Hub location in Via dell’Annunicata 21, Milan, Italy.
1. Data Controller
For the purposes of the GDPR Data Protection Legislation currently the appointed Data Controller is:
Trevisan & Cuonzo Avvocati
Fiscal Code/VAT number 10912290151
Main Office: 20121 – Milan, Palazzo Beccaria, Via Brera, 6, Italy
T: +39 02 8646 3313; F: +39 02 86463892
2. Definition of ‘Personal Data’
Personal Data also include:
a) contact details, such as name, surname, job title and / or company role, company address, residence – where necessary -, telephone number, mobile number, fax number and e-mail address;
b) payment details, such as data required for processing payments and fraud prevention, including credit / debit card numbers and other related billing information;
c) commercial information, ie data related to economic-financial aspects, credit worthiness, industrial and production aspects, where necessary for the realization / development of a project or contractual relationship;
d) special categories of Personal Data may be collected (for example, regarding your membership of a professional association or trade union, health, etc.), in connection with your registration/participation of an event or seminar organised at the Brera.Hub facilities in particular, on these occasions, Trevisan & Cuonzo may ask you to provide information about your health for the purpose of identifying and taking into consideration any disabilities or special dietary requirements you may have. Any use of this information is based on your consent however if you do not provide this information to us we will not be able to take all the necessary precautions;
e) other Personal Data that could be acquired during future meetings/events hosted at the Brera.Hub and / or your offices for you and your team of collaborators.
Your Personal Data may be collected on various occasions, such as when you:
• request information and/or quotes relating to the spaces and services provided at the Brera.Hub location, such as: equipped offices, meeting room and event spaces and the related services connected with the organization of all events at Brera.Hub;
• navigate on/interact with the Brera.Hub website;
• attend a seminar, conference, showroom, exhibition, meeting or any other event organized at Brera.Hub;
• provide a service agreement proposal.
As a general practice, Trevisan & Cuonzo collects and processes the Personal Data voluntarily provided by you by e-mail or paper and/or by hand, etc., and you will thereby be giving your consent to the processing.
On certain occasions (see for example letter c above), your Personal Data may be collected by public sources and/or third parties.
In these cases, your Personal Data may, for example, be acquired through public sources and sources publicly and generally accessible to anyone, including: company registers, company statements and member lists, company records and/or acts, records and events related to bankruptcy or other insolvency proceedings, legal acts detrimental to creditors and mortgage surveys (such as, for example, registration or cancellation of mortgages, transcription and cancellation of foreclosures, injunctions or judicial acts, and related annotations) kept in registers managed by the Inland revenue; as well as information collected and held by external suppliers and/or collaborators named as Personal Data Controllers.
3. Purpose of Personal Data Processing
Please be aware that Trevisan & Cuonzo may use your Personal Data for the following Purposes only (“Purposes”):
a) carry out preliminary requisites for the stipulation of the contract, implementation of pre-contractual measures, fulfilment of contract obligations;
b) managing and handling the business relationship between you and Brera.Hub, including payment processing, billing and all other necessary support services;
c) complying with the legal obligations that are binding for Trevisan & Cuonzo, which include, for example, records-keeping obligations, anti-money laundering obligations (in particular those set forth by Legislative Decree No. 231/2007 and subsequent amendments) and obligations for the prevention of the use of the financial system for the purpose of money laundering and terrorist financing (such data collection is, therefore, mandatory pursuant to Article 21 of Legislative Decree No. 231/2007 “Customer’s obligations” and subsequent amendments), as well as obligations related to compliance with antitrust regulations;
d) managing and ensuring your security when accessing the Brera.Hub facility, information and communication systems, online platforms, websites and other systems, including for the purpose of preventing and detecting security threats, fraud or other criminal or harmful activities;
e) for insurance purposes;
f) Identifying persons authorised to act on your behalf;
g) complying with obligations imposed by judicial authorities and/or for protecting Trevisan & Cuonzo’s rights;
h) for any purpose related and/or ancillary to any of the above, or for any other purpose for which you provided your Personal Data.
Where you have provided specific consent, your Personal Data may also be processed for the following additional purposes (“Additional Purposes”):
i) marketing purposes, by sending communications related to Brera.Hub events, activities, services and projects (hereinafter “Other Purposes”).
You are entitled to withdraw any consent given for the Additional Purposes at any time by sending a request to the following email address: firstname.lastname@example.org.
4. Legal basis for processing and consequences of the refusal to have Personal Data processed
With particular reference to the data processing for the purposes listed in Article 3 above, please note that the processing of your Personal Data is carried out:
• because processing is necessary for the performance of your instructions, to satisfy your requests, for the execution of an agreement entered into with you; and/or for the implementation of pre-contractual measures;
• to comply with legal obligations;
• because processing is necessary for a legitimate interest of the Firm or of any third parties that receive your Personal Data, unless your fundamental interests, rights and freedoms prevail over such interests.
Furthermore, the use of your Personal Data may only be justified for certain additional Purposes when you have provided further express consent.
In principle, should you choose not to provide Trevisan & Cuonzo with your Personal Data and/or withhold consent, there will be no detrimental consequences. However, in certain circumstances, if you do not provide Personal Data and/or give consent to the processing of such Personal Data, Trevisan & Cuonzo may be unable to operate and perform the legal services on your behalf, since, for example, this Personal Data is necessary to process your instructions or orders. In such case, the Firm will contact you immediately to inform you of this.
If you do not give your express consent for Additional Purposes, you will not receive any communication from the Firm for these Additional Purposes, nor will your Personal Data be used for these Additional Purposes. In any event failure to give consent here will not prevent the Firm from providing the services contractually agreed.
5. Types of Personal Data processing
Processing is carried out through the following operations or set of operations: collection, recording, organisation, storage, consultation, treatment, alteration, selection, retrieval, comparison, use, interconnection, blocking, disclosure, cancellation and destruction of Personal Data.
Personal Data may be processed by either means, paper and/or electronic files (including mobile devices) and processed in ways strictly necessary to meet the aforementioned purposes.
The processing is carried out by the owner, the office manager of the Firm and/or other authorized persons that will be identified from time to time.
6. Processing, Communication and Disclosure of Personal Data
Your Personal Data will be processed by the Data Controller and other authorized persons in compliance with the principles of lawfulness, correctness, transparency, purpose limitation and retention, data minimization, accuracy, integrity and confidentiality.
For the proper implementation of the relationship and/or for administrative, billing and other commercial purposes, your Personal Data may be disclosed – where necessary and on a confidential basis – to external collaborators and service providers.
In particular, where necessary, we may communicate your Personal Data to:
• persons, companies or professional firms that provide assistance and advice to the Owner on matters relating to management, accounting, administrative, legal, fiscal, financial and credit recovery connected to services and/or activities provided by the Firm with reference to Brera.Hub; and/or
• people, companies or professional firms that provide assistance, collaboration and professional advice necessary and/or to support the provision of services and/or activities provided by the Studio with reference to Brera.Hub.
On a confidential basis, we may disclose your Personal Data to:
• Third parties in order to improve and promote our services, as well as for system maintenance;
• Companies providing services in the field of anti-money laundering, credit recovery and for other crime prevention purposes;
• Service providers, including those external to the Firm, on both a national and international level.
Trevisan & Cuonzo shall disclose your Personal Data in one or more of the following circumstances only: (i) upon your authorization; (ii) when required by law or applicable regulation, or ordered by a judicial/administrative authority; or (iii) to investigate the existence of any actual or suspected fraudulent or criminal activity.
For more information, please contact Trevisan & Cuonzo at the following email address: email@example.com.
7. Transfer of Personal Data abroad
The firm is active internationally, partnering with foreign commercial contacts in connection with Brera.Hub services. Therefore, your Personal Data may be transferred abroad if required for the performance of the Purposes and/or Additional Purposes.
In particular, your Personal Data may be transferred to non-EU countries in respect of which the European Commission has decided, in accordance with Article 45 of Regulation (EU) 2016/679, that the laws in force therein ensure an adequate level of protection of Personal Data.
In the absence of such a decision by the European Commission, your Personal Data may be transferred to non-EU countries only after Trevisan & Cuonzo has implemented adequate safeguards on data protection, in accordance with Article 46 of Regulation (EU) 2016/679, for example by adopting standard contractual clauses established by the European Commission (available at the following link: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en).
The Firm ensures and will always ensure an adequate level of protection of your Personal Data. In this regard, we will always ask our suppliers, agents, consultants, etc. to provide equal safeguards for the protection of your Personal Data.
8. Personal Data Storage
The Firm shall retain the Client’s Personal Data in accordance with the applicable law and for as long as is strictly necessary for the performance of the service agreement. Upon termination of the agreement, the Firm shall retain such Personal Data for as long as is strictly necessary for the purposes of compliance with the applicable civil and accounting laws.
9. Security and Transfer of Personal Data
The processing, storage and treatment of your Personal Data are ensured through appropriate technical and organizational measures to keep your Personal Data confidential and secure in accordance with our internal procedures. Personal Data may be stored on our Personal Data management systems, on those of our suppliers or on paper files.
10. Your Rights
You may at any time exercise the rights you are entitled to under the applicable law. Such rights include:
• Receive confirmation that Trevisan & Cuonzo is processing your Personal Data and request to access them;
• Updating, changing and/or amending your Personal Data where inaccurate e/o incomplete;
• Request the cancellation, anonymization, blocking of your Personal Data processed in breach of the law;
• Under certain circumstances, request the restriction of processing;
• Object to the processing of data related to you for legitimate reasons;
• Receive Personal Data you provided in a structured, commonly used, machine-readable and interoperable format, and request that such Personal Data be transmitted to another data controller without hindrance;
• Withdraw the consent for the processing of your Personal Data given for specific purposes;
• Refer the matter to the Data Protection Authority.
In order to exercise one or more of the rights listed above, you may send a specific request to the Firm:
• by post to: Trevisan & Cuonzo, 20121 – Milan, Palazzo Beccaria, Via Brera, 6, Italy; or
• by email at: firstname.lastname@example.org.