Cookie Policy

Cookie Policy

provided pursuant to Article 13 Regulation (EU) 2016/679 (“GDPR”)

With this document (“Cookie Policy“), the Data Owner, as defined below, wishes to inform you about the methods and purposes of the processing of your personal data resulting from the use of cookies and other tracking tools on the website www.simonwealthlex. it (hereinafter, the “Site“), in compliance with the provision issued by the Garante della Privacy on 8 May 2014 “Identification of the simplified procedures for the provision of information and acquisition of consent for the use of cookies” and subsequent clarifications and updates (most recently provision no. 231 of 10 June 2021 “Guidelines for cookies and other tracking tools”), art. 122 of Legislative Decree no. 196 of 30 June 2003 (the “Codice della Privacy“) and art. 13 of the GDPR.

  1. DATA CONTROLLER AND DATA PROTECTION OFFICER

The Data Owner is Simon WealthLex Società tra Avvocati a responsabilità limitata, with registered office in via Caradosso n. 16, 20123 Milan in the person of its legal representative pro tempore (hereinafter “SWLex” or the “Data Controller“).
In order to exercise your rights, listed in paragraph 7 below, as well as for any other request relating to the same and/or to this Information Notice, you may contact the Data Owner at the following addresses:

  • telephone: +39 02 89093918

    Before proceeding, it is necessary to read the information

    Read the information on the processing of personal data by clicking here.
  • email: sta@swlex.it 

    Before proceeding, it is necessary to read the information

    Read the information on the processing of personal data by clicking here.
  • The Data Owner has appointed a Data Protection Officer (“DPO”) pursuant to Art. 37 of the GDPR, whom you may contact to exercise your rights as well as to receive any other information relating to the same and/or to this Policy, by writing to sta@swlex.it 

    Before proceeding, it is necessary to read the information

    Read the information on the processing of personal data by clicking here.
  1. WHAT COOKIES ARE AND WHAT THEY ARE USED FOR

Cookies are small text strings, normally made up of letters and/or numbers, that websites visited by the User send and place on his/her terminal (usually through the browser) where they are stored and archived in order to be then re-transmitted to the same websites that generated them on the occasion of the User’s next visit, thus keeping memory of his/her previous interaction with the Site.
The information encoded by cookies includes personal data (e.g. IP address, User name, e-mail address, etc.) or non-personal data such as language settings or information on the type of device used by the User to browse the Site.
Cookies therefore perform various functions and allow the Site to be navigated efficiently, remembering the User’s preferences and improving the User’s browsing experience. For example, cookies are used to store computer authentications, the User’s preferred language or other information or preferences regarding specific configurations, monitor sessions, make it easier and more efficient to use online content, show the User advertisements that may be of interest to him/her, etc.

  1. GENERAL CATEGORIES OF COOKIES

Depending on the criterion considered, cookies can be classified into various categories.
For example, depending on the entity that installs cookies on the User’s terminal, a distinction can be made between: (a) “first-party cookies”, which are installed directly by the operator of the website visited by the User and are only visible to him/her; and (b) “third-party cookies” installed by the operator of another website, which installs cookies through the former.
On the basis of the duration of processing, a distinction can be made between: (a) “session cookies”, which are stored temporarily during the browsing session and are automatically deleted from the User’s terminal once the browser is closed; and (b) “persistent cookies”, which instead remain on the User’s terminal until a pre-determined expiry date or until they are deleted.

The classification that best meets the ratio of the legislation on the protection of personal data is the one that distinguishes cookies into two macro-categories:

  • “technical cookies“, i.e. those cookies that are strictly necessary for the proper functioning of the website or its operation based on the navigation choices made by the User. This category includes the so-called “navigation cookies”, which guarantee the normal navigation and use of the website (allowing, for example, the regular display of pages or their scrolling, etc.) as well as the so-called “functionality cookies”, which allow the User to navigate the website according to the criteria selected by the same (e.g. language, products selected for a purchase) in order to improve the service requested. The technical storage of and access to the information contained in technical cookies does not require the User’s consent;
  • “profiling cookies“, which analyse and record the User’s recurring actions or behavioural patterns when using the Website’s functionalities in order to (i) create a profile of the User, (ii) classify the User within different profiles grouping homogeneous groups of users, (iii) in order to send the User targeted advertising messages in line with the User’s preferences when surfing the Web. Technical storage of and access to the information contained in technical cookies is conditional on the User’s consent.

To the two macrocategories mentioned above, one can add that of the so-called “analytical cookies”, used to process statistical analyses, such as analyses aimed at (i) assessing the effectiveness of the services rendered through the Site, (ii) designing the Site, or (iii) measuring its “traffic”, i.e. the number of visitors, possibly classified according to the characteristics of interest (e.g. geographical area, time slot etc.).

The processing of data collected by means of analytical cookies does not require the User’s consent where such data is used only to produce aggregate statistics in relation to a single site or mobile application and, for data collected by “third party” analytical cookies, only if (a) the structure of the “third party” analytical cookie is such that it reasonably prevents the identification of the User and if (b) the “third party” refrains from taking actions on the data (e.g. combination, enrichment etc.) aimed at identifying the User. If these specific conditions are met, analytical cookies (both first- and third-party) are assimilated to technical cookies.

  1. TYPES OF COOKIES USED BY THIS SITE, PURPOSE, LEGAL BASIS

Without prejudice to the general categories described above, the Data Owner has deemed it appropriate to adopt here a different classification of the cookies present on the Site, distinguished according to the legal basis that justifies the processing of personal data collected through cookies, in accordance with the provisions of the GDPR and Article 122 of the Codice della Privacy.

In particular, the Data Owner has divided the cookies on the Site into the following types:

  1. “Necessary cookies“

These are the cookies that ensure the ordinary usability of the Site, allowing, for the Owner, to pursue the correct technical-informatic functioning of the Site and, for the User, to correctly view the web pages of the Site, including the maintenance of the choices made by the User during navigation. Both technical cookies and functionality cookies present on the Site fall into the category of “Necessary Cookies”: technical cookies will always be active, while the User may at any time object to the use of functionality cookies by deactivating them through the simple functionalities set up by the Data Owner in the “Privacy Preference Center”, in this case renouncing the use of the services provided by the Site through such cookies. The Owner’s storage of and access to the information contained in the necessary Cookies does not require the User’s consent as it is based on the Owner’s legitimate interest ex art 6, lett. f) of the GDPR to be identified in the Owner’s need to ensure the proper functioning of the Site.

  1. List of cookies

A cookie is a small piece of data (text file) that a website, when visited by a user, asks the browser to store on the device in order to remember his/her information, such as preferred language or login details. These cookies are set by us and referred to as first party cookies. We also use third party cookies – that is, cookies from a domain other than the website you are visiting – for our advertising and marketing efforts. In particular, we use cookies and other tracking technologies for the following purposes:

Strictly necessary and anonymised analytical cookies

These cookies are necessary for the operation of the site and cannot be disabled in our systems. They are usually only set in response to actions you take that constitute a request for services, such as setting privacy preferences, logging in or filling out forms. You can set your browser to block or have it warn you about these cookies, but as a result some parts of the site will not work. These cookies do not store any personal information.

This Site uses first-party technical cookies, the installation of which does not require the user’s consent.

  1. “Performance cookies”

These are cookies that allow the Data Owner to pursue statistical purposes, such as the processing of statistics in aggregate and anonymous form on the use of the Site by users, in order to understand, for example, which are the most or least popular pages of the Site, the recurring browsing patterns of the user community and to improve the performance of the Site itself. Analytical cookies that can be assimilated to technical cookies fall into the category of “Performance cookies”. The Owner’s storage of and access to the information contained in them does not require the User’s consent as they are based on a legitimate interest of the Owner, pursuant to Article 6, letter f) of the GDPR, to be identified in the Owner’s interest in acquiring information useful for improving the Site’s performance. However, since these cookies are not strictly necessary for the operation of the Site, the User may object to their use at any time by deactivating them through the simple functions set up by the Data Owner in the “Privacy Preference Centre”. Deactivating performance cookies does not in any way affect the use and operation of the Site, but only prevents the Data Owner from using navigation data for generating usage statistics of the Site.

The following third- party analytical cookie is used on the Site:

On the other hand, there are no profiling cookies on the Site, i.e. cookies for targeted advertising.

  1. HOW TO MANAGE YOUR COOKIE PREFERENCES: THE PRIVACY PREFERENCE CENTRE

When accessing the Site for the first time, the User will see an immediate pop-up banner containing the short information notice on cookies, the link to this extended cookie policy and a series of functions for managing his/her preferences regarding the cookies to be installed on his/her device.

In particular, through the functions contained in the banner the User will be able to: (i) accept all cookies present on the Site, including those for targeted advertising, by giving his/her consent; (ii) refuse the installation of all cookies present on the Site other than those strictly necessary for the proper functioning of the latter (i.e. Necessary cookies”); (iii) access, through a special link, the Privacy Preference Centre, where you can obtain more information on the specific cookies present on the Site, grouped by homogeneous categories, and, where applicable, give or revoke consent or oppose processing with reference to the categories of cookies to be enabled or disabled on your device; (iv) close the cookie banner by clicking on the special icon and continue browsing the Site by maintaining the default settings.
The Data Owner specifies that the “default” cookie setting implies the installation only of the necessary Cookies as well as those that are equivalent to them, where present.
At any time, the User may change the choices on cookies made when first accessing the Site, by accessing the Privacy Preference Centre, through the link contained at the bottom of the home page of the Site, and operating the relevant functions.
Users may also manage their cookie preferences through the settings of the browser used, which allow them to delete/remove all or some cookies or block the sending of cookies or limit them to certain sites.
Below are instructions and links to guides on how to manage cookies for the main desktop browsers:

Managing Ad Preferences: https://tools.google.com/dlpage/gaoptout/

 

For browsers other than those listed above, you should consult the relevant guide to find out how to manage cookies. For example, if you use a mobile device, you should refer to the relevant instruction manual to find out how to manage cookies.

  1. TRANSFER OF PERSONAL DATA OUTSIDE THE EU

The User’s personal data collected using cookies (e.g. third party cookies) may be transferred to countries outside the EU: such transfer is in any case legitimate as it is guaranteed by the existence of adequacy decisions issued by the European Commission and/or by the prior signature of Standard Contractual Clauses adopted on the basis of the European Commission’s templates pursuant to Article 46, 2, letter c) and d) of the GDPR.
The User may request a copy of the guarantees adopted by writing to the Owner at the addresses indicated in paragraph 1 of this Cookie Policy.

  1. RECIPIENTS OF PERSONAL DATA

The User’s personal data may be disclosed to the employees, assimilated personnel and collaborators of the Data Owner assigned to the pursuit of the purposes indicated above, who will operate in their capacity as persons authorised to process personal data and will have received adequate operating instructions.

Furthermore, in order to pursue the purposes set out in paragraph 4 above, the User’s personal data may be processed by third parties belonging, by way of example, to the following categories:

  • providers of technical assistance services for the management and maintenance of the Site;
  • providers of statistical processing services on the use of the Site;
  • companies that provide management and maintenance services for the Owner’s information systems;
  • companies owning social media sites;
  • authorities and supervisory and control bodies and, in general, public or private entities with public functions entitled to request the data in accordance with the provisions of current national and European legislation;
  • companies, associations or professional firms providing assistance and consulting services.

The subjects belonging to the above categories operate, in some cases, as data controllers specifically appointed by the Data Owner in compliance with Article 28 GDPR, and in other cases completely independently as separate data owners, it being understood that, in the latter case, the communication of your personal data to such independent data owners would take place solely for the purposes of pursuing the purposes set out in paragraph 4 above.
The complete and updated list of the subjects to whom your personal data may be communicated can be requested by contacting the Owner at the address indicated in par. 1 of this Cookie Policy.
Data collected using cookies will not be disclosed.

  1. RIGHTS OF THE DATA SUBJECT

In relation to the processing operations described in this Policy, as a data subject, you may, under the conditions set out in the GDPR, exercise the rights set out in Articles 15 – 21 of the GDPR, in particular:

  • right of access: right to obtain confirmation as to whether or not personal data relating to you are being processed and, if so, to obtain access to your personal data – including a copy thereof – and communication of, inter alia, the information referred to in Article 15 of the GDPR;
  • right to rectification: the right to obtain, without undue delay, the rectification of inaccurate personal data concerning him/her and/or the supplementation of incomplete personal data pursuant to Article 16 of the GDPR;
  • right to erasure (right to be forgotten): the right to obtain, without undue delay, the erasure of personal data concerning him/her, in the cases indicated in Article 17 of the GDPR; the right to erasure does not apply to the extent that the processing is necessary for the performance of a legal obligation or the performance of a task carried out in the public interest or for the establishment, exercise or defence of legal claims;
  • right to restriction of processing: right to obtain the restriction of processing, in the cases indicated in Article 18 of the GDPR;
  • right to data portability: the right to receive, in a structured, commonly used and machine-readable format, the personal data concerning you provided to the Data Owner and the right to transmit them to another data owner without hindrance, where the processing is based on consent and is carried out by automated means, as set out in Article 20 of the GDPR. In addition, the right to have your personal data transmitted directly by the Owner to another owner if this is technically feasible;
  • right to object: right to object to the processing of personal data concerning you, unless there are legitimate grounds for the Owner to continue the processing, pursuant to Article 21 of the GDPR;
  • right to withdraw consent at any time without affecting the lawfulness of the processing based on the consent given before the revocation;
  • right to lodge a complaint with the Garante per la protezione dei dati personali, Piazza Venezia n. 11, 00187, Rome (RM).

The above rights may be exercised towards the Data Owner by contacting the references indicated in paragraph 1 above. The Data Owner shall take charge of your request and provide you, without undue delay and, in any case, no later than one month from receipt thereof, with information on the action taken regarding your request.
The exercise of your rights as a data subject is free of charge pursuant to Article 12 of the GDPR. However, in the case of requests that are manifestly unfounded or excessive, including due to their repetitiveness, the Data Owner may charge you a reasonable expense contribution, in light of the administrative costs incurred in handling your request, or deny satisfaction of your request.
Finally, we inform you that the Owner may request further information necessary to confirm the identity of the data subject.

The Data Owner