External Privacy Notice

Summary – This Notice

This Notice explains how we Process Personal Data. This Notice may be amended or updated from time to time, so please check it regularly for updates.

This Notice is issued by the association established under Italian law with the name “Pro Bono Italia” (“Pro Bono Italia”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact, including (but not limited to) visitors to our Site, Associated Law firms and Lawyers, Candidate Associated Law firms and Lawyers, Beneficiaries (together, “you”). Defined terms used in this Notice are explained in Section (R) below.

This Notice may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Notice carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Notice.

Collection of Personal Data

Summary – Collection of Personal Data

We collect or obtain Personal Data: when those data are provided to us (e.g., where you contact us); in the course of our relationship with you; when you make Personal Data public (e.g., if you make a public post about us on social media); when you visit our Site; or when you interact with any third party content or advertising on a Site. We may also receive Personal Data about you from third parties (e.g., third parties’ providers of contents or advertising).

Collection of Personal Data: We collect or obtain Personal Data about you from the following sources:

Data provided to us: We obtain Personal Data when those data are provided to us (e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your business card, or when you submit a job application).

Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g. organizing periodic meetings (which may be named Round Tables) in order to facilitate the discussion among Associated Law firms and Lawyers, Beneficiaries and other natural or legal persons interested in the development and diffusion of Pro Bono activities).

Data you make public: We collect or obtain Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).

Site data: We collect or obtain Personal Data when you visit our Site or use any features or resources available on or through a Site (e.g., the “Contact Form” available at the CONTACT US section of the Site).

Content and advertising information: If you interact with any third party content or advertising on a Site (including third party plugins and cookies) we receive Personal Data from the relevant third party provider of that content or advertising.

Creation of Personal Data

Summary – Creation of Personal Data

We create Personal Data about you (e.g., records of your interactions with us).

We also create Personal Data about you in certain circumstances, such as records of your interactions with us.

Categories of Personal Data we Process

Summary – Categories of Personal Data we Process

We Process: your personal details (e.g., your name); demographic data (e.g., your age); your contact details (e.g., your address); records of your consents;; payment details (e.g., your billing address); information about our Sites (e.g., the type of device you are using); details of your employer (where relevant); information about your interactions with our content or advertising; and any views or opinions you provide to us.

We Process the following categories of Personal Data about you:

Personal details: given name(s); preferred name; and photograph, gender; date of birth / age; nationality; salutation; title; and language preferences.

Contact details: correspondence address; telephone number; email address; messenger app details; online messaging details; and social media details.

Consent records: records of any consents you have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).

Professional/Employment records: dates and details of current and former positions held; details of current and former employers; details of the law firm and/or bar association to which Associated Law firms and Lawyers or Candidate Associated Law firms and Lawyers are members or wish to become member; job titles; job locations; subject matter experience.

Data relating to our Site: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; username; password; security login details; usage data; aggregate statistical information.

Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.

Sensitive Personal Data

Summary – Sensitive Personal Data

We do not seek to collect or otherwise Process Sensitive Personal Data. Where we need to Process Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.

We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);

Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud);

Establishment, exercise or defence of legal rights: We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal rights; or

Consent: We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Data (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, and you must ensure a valid legal basis applies to the Processing of those Sensitive Personal Data.

Purposes of Processing and legal bases for Processing

Summary – Purposes of Processing and legal bases for Processing

We Process Personal Data for the following purposes: carrying out Pro Bono Italia activities, including operating and managing our Site, communicating with you; managing our IT systems; conducting surveys; ensuring the security of our premises and systems; compliance with applicable law; improving our Site, and activities; and assessment of application by Candidate Lawyers to become members of the Pro Bono Italia.

The purposes for which we may Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:

Processing activity

Legal basis for Processing

Carrying out Pro Bono Italia activities (e.g., organizing periodic meetings (which may be named “Round Tables”) in order to facilitate the discussion among Associated Lawyers, Beneficiaries and other natural or legal persons interested in the development and diffusion of Pro Bono activities; maintaining relationships with Clearinghouses and NGOs): operating and managing our Sites, and our activities; providing content to you; displaying advertising and other information to you; communicating and interacting with you via our Sites, or our activities; and notifying you of changes to any of our Site, or our activities.

The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or

We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, or our services to you (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Communications and marketing: communicating with you via any means (including via email, telephone, text message, social media, post or in person) news items and other information in which you may be interested, subject always to obtaining your prior opt-in consent to the extent required under applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required.

We have a legitimate interest in carrying out the Processing for the purpose of contacting you, subject always to compliance with applicable law (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Management of IT systems: management and operation of our communications, IT and security systems; and audits (including security audits) and monitoring of such systems.

The Processing is necessary for compliance with a legal obligation; or

We have a legitimate interest in carrying out the Processing for the purpose of managing and maintaining our communications and IT systems (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

Surveys: engaging with you for the purposes of obtaining your views on our Site, or our activities.

We have a legitimate interest in carrying out the Processing for the purpose of conducting surveys, satisfaction reports and market research (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.

The Processing is necessary for compliance with a legal obligation; or

We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, breaches of our policies and applicable laws (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

Legal proceedings: establishing, exercising and defending legal rights.

The Processing is necessary for compliance with a legal obligation; or

We have a legitimate interest in carrying out the Processing for the purpose of establishing, exercising or defending our legal rights (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

Legal compliance: compliance with our legal and regulatory obligations under applicable law.

The Processing is necessary for compliance with a legal obligation.

Improving our Site, and activities: identifying issues with our Site, or our services; planning improvements to our Site, or our services; and creating new Site, or activities.

We have a legitimate interest in carrying out the Processing for the purpose of improving our Site, or our activities (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Reviewing and responding to request for admission to the Association membership received from Candidate Associated Law firms and Lawyers: analysis of suitability for the relevant admission; records of admission decisions; and acceptance details.

The Processing is necessary for compliance with a legal obligation; or

We have a legitimate interest in carrying out the Processing for the purpose of admission evaluation activities and assessment of related applications (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Disclosure of Personal Data to third parties

Summary – Disclosure of Personal Data to third parties

We may disclose Personal Data to: legal and regulatory authorities; our external advisors; our Processors; any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; and any third party providers of advertising, plugins or content used on our Site.

We may disclose Personal Data to other entities for legitimate business purposes and the operation of our Site as well as performance of our activities, in accordance with applicable law. In addition, we disclose your Personal Data to:

you and, where appropriate, your appointed representatives;

legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;

accountants, auditors, lawyers and other outside professional advisors to Pro Bono Italia, subject to binding contractual obligations of confidentiality;

third party Processors, located anywhere in the world, subject to the requirements noted below in this Section (G);

any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights;

any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;

any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and

any relevant third party provider, where our Site use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

International transfer of Personal Data

Summary – International transfer of Personal Data

We transfer Personal Data to recipients in other countries. We do not transfer Personal Data from the EEA to a recipient outside the EEA that is not in an Adequate Jurisdiction.

Because of the international nature of our business, we transfer Personal Data within the Pro Bono Italia group, and to third parties as noted in Section (G) above, in connection with the purposes set out in this Notice. For this reason, we transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

We do not transfer your Personal Data from the EEA to recipients located outside the EEA who are not in Adequate Jurisdictions.

Data security

Summary – Data security

We implement appropriate technical and organisational security measures to protect your Personal Data. Please ensure that any Personal Data that you send to us are sent securely.

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

Data accuracy

Summary – Data accuracy

We take every reasonable step to ensure that your Personal Data are kept accurate and up-to-date and are erased or rectified if we become aware of inaccuracies.

We take every reasonable step to ensure that:

your Personal Data that we Process are accurate and, where necessary, kept up to date; and

any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

Data minimisation

Summary – Data minimisation

We take every reasonable step to limit the volume of your Personal Data that we Process to what is necessary.

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Notice.

Data retention

Summary – Data retention

We take every reasonable step to ensure that your Personal Data are only retained for as long as they are needed in connection with a lawful purpose.

We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows:

we will retain Personal Data in a form that permits identification only for as long as:

we maintain an ongoing relationship with you (e.g., where you are a user of our services, or you are lawfully included in our mailing list and have not unsubscribed); or

your Personal Data are necessary in connection with the lawful purposes set out in this Notice, for which we have a valid legal basis (e.g., where we have a legitimate interest in processing those data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data),

plus:

the duration of:

any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data are relevant); and

an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim).

and:

in addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.

During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:

permanently delete or destroy the relevant Personal Data; or

anonymize the relevant Personal Data.

Your legal rights

Summary – Your legal rights

Subject to applicable law, you may have a number of rights, including: the right not to provide your Personal Data to us; the right of access to your Personal Data; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Data; the right to object to the Processing of your Personal Data; the right to have your Personal Data transferred to another Controller; the right to withdraw consent; and the right to lodge complaints with Data Protection Authorities. In some cases it will be necessary to provide evidence of your identity before we can give effect to these rights.

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:

the right not to provide your Personal Data to us (however, please note that we will be unable to provide you with the full benefit of our Site, or activities, if you do not provide us with your Personal Data – e.g., we might not be able to process your requests without the necessary details);

the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;

the right to request rectification of any inaccuracies in your Relevant Personal Data;

the right to request, on legitimate grounds:

erasure of your Relevant Personal Data; or

restriction of Processing of your Relevant Personal Data;

the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;

where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and

the right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority (in particular, the Data Protection Authority of the EU Member State in which you live, or in which you work, or in which the alleged infringement occurred, each if applicable).

Subject to applicable law, you may also have the following additional rights regarding the Processing of your Relevant Personal Data:

the right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf; and

the right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes.

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Notice, or about our Processing of your Personal Data, please use the contact details provided in Section (Q) below. Please note that:

in some cases it will be necessary to provide evidence of your identity before we can give effect to these rights; and

where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

Cookies and similar technologies

Summary – Cookies and similar technologies

We Process Personal Data by using Cookies and similar technologies. For more information, please see our Cookie Policy.

When you visit the Site we will typically place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We Process Personal Data through Cookies and similar technologies, in accordance with our Cookie Policy.

Terms of Use

Summary – Terms of Use

Our Terms of Use govern all use of our Site and our activities.

All use of our Site, and performance of our activities is subject to our Terms of Use. We recommend that you review our Terms of Use regularly, in order to review any changes we might make from time to time.

Direct marketing

Summary – Direct marketing

We Process Personal Data to contact you with information regarding our Site, or activities that may be of interest to you. You may unsubscribe for free at any time.

We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding our Site, or activities that may be of interest to you. We may send information to you regarding our Site, or activities, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us, subject always to obtaining your prior opt-in consent to the extent required under applicable law.

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any activities that you have requested.

Details of Controllers

Summary – Details of Controller

Pro Bono Italia acts as Controller for the purposes of this Privacy Notice.

Pro Bono Italia acts as Controller for the purposes of this Privacy Notice. Our Contact details are: Pro Bono Italia, Secretary General, Via G. Serbelloni, 4 – 20122 Milano.

Alternatively, you may contact us using our online Contact Us form.

Definitions

Adequate Jurisdiction” means a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Data.

Associated Law firms and Lawyers”: lawyers enrolled in the Italian Bar Association (Albo Nazionale Avvocati) and trainee lawyers enrolled in the register of trainees authorized to practice (Registro dei Praticanti Abilitati al Patrocinio), who have been admitted to the Association membership, either individually or as part of a law firm, and bar association that share the purpose and the activities of the Association.

Candidate Associated Law firms and Lawyers”: lawyers enrolled in the Italian Bar Association (Albo Nazionale Avvocati) and trainee lawyers enrolled in the register of trainees authorized to practice (Registro dei Praticanti Abilitati al Patrocinio), who have submitted a request for admission to the Association membership, either individually or as part of a law firm, and bar association that share the purpose and the activities of the Association.

Beneficiaries”: non-profit organizations pursuing social welfare purposes, as well as natural persons unable to afford legal assistance or obtain access to justice.

Clearinghouses”: non-profit organizations that collect and select requests for assistance from Beneficiaries and forward them to lawyers wishing to carry out Pro Bono activities.

Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Notice, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.

Controller means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.

Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.

EEA” means the European Economic Area.

Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

Process”, “Processing” or “Processed means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Processor means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).

Relevant Personal Data” means Personal Data in respect of which we are the Controller.

Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that are deemed to be sensitive under applicable law.

Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.

Site means any website operated, or maintained, by us or on our behalf.