I. Introduction

This privacy notice applies to any data processing undertaken by VGS Lawyers in connection with:

1. Client Services: Provisions of product or services by VGS Lawyers to actual or future clients;
2. Supplier Services: Provisions of products or services to VGS Lawyers from third parties and service providers;
3. Recruitment Activities: Provisions of personal data of a candidate for a position at VGS lawyers.

References in this notice to “you” or “your” are done to individuals whose personal information are processed by VGS lawyers in connection with client services, supplier services and recruitment activities.
References in this notice to “we”, “us”, or “our” are referred to VGS Lawyers.
References to our “clients” or “suppliers” include the employees or staff who is involved in processing personal data.

II. Importance of Personal data Protection

VGS Lawyer is aware of the importance of fair, transparent, and informed data processing activity. General Data Protection Regulation changed privacy reference points by including strict requirements and new principles with the sole intent of empowering data subject awareness toward data processing. Moreover, GDPR aims to favour the transparent, safe and free movement of personal data within European Union territory.

III. Data Controller and Data Processor

Data Controller is an individual or organisations that, alone or jointly, determines the purposes for which, and the manner in which any personal information is going to be processed.

Data Processor is an individual or organisations that, alone or jointly, process personal data on behalf of the data controller.

VGS lawyers, depending on the context of activities, might act as data controller or data processor.

IV. What personal data we collect about you

Personal data is any information related to an identified or identifiable natural person. Special categories of data includes are related to your ethnicity, religion, trade union membership, sexual orientation, political orientation.

In limited circumstances, VGS lawyers is likely to special category of data including health, genetic or biometric data as well as information about your criminal convictions. This might happen where VGS lawyers is required to collect certain information for certain legal or regulatory purposes or where you have provided us with such information as it necessary for undertaking a service we are providing to you.

We collect, store and transfer different kind of personal data:

• Identity Data: Including your names, marital status, date of birth, passport number, photographic identification, gender;
• Contact Data: Including your billing address, email address, telephone number;
• Financial Data: Including your bank account number;
• Profile data: Including your usernames or passwords, your interests or survey response;
• Marketing and Communications Data: including your communication preferences. We may track when you receive marketing communications from us.
• Usage of Data: Includes information about your use of VGS lawyer website or networking facilities; (Wi-Fi)
• Technical Data: Includes information such as your Internet protocol address (IP), login data, browser type, location, operating system.
• Special Category of Data:
  1. In relation to Immigration law matters, we may need to verify whether you are politically exposed person;
  2. In relation to Employment Law matters, we may need to know your trade union membership;

VGS lawyers does not aim to collect and process children personal information. However, we may process children personal data in relation to some private matters involving family law, tax law, and probate.
In the event you fail to provide personal information when requested, we may not be able to perform the contract we were seeking to enter into with you. In this last case, we may decline to provide you with our relevant services.
We require that any subject involved in processing your personal data is respecting duties of security and confidentiality provided by current laws and regulations.

V. How your personal data is collected

Direct Interactions: When you interact with us, you are providing us with your personal data. Such personal information includes Identity Data, Contact Data, Usage of Data or Technical Data. We may have access to the previous data when a) you fill in online forms in our websites, b) you reply to us by email or post, c) you visit our offices.

Websites, cookies and marketing: You also provide us with your personal information, which is Profile Data, Technical Data, Professional Information, and Marketing Communications when you use or visit our website.

Third parties sources: We may collect Identity Data, Contact Data, and Professional Information about you from third parties, when:

1. We provide our client services or other parties send us your personal data to enable to make operative the contract of service;
2. You provide your personal data to a third party with the intent of sharing it with us ( such as recruitment agencies or consultants);

Publicly available sources: We may collect Identity Data, Contact data, Professional Information or History from publicly available sources including:

1. Public registers of companies, law firms, accountants;
2. Public registers of sanctioned person and entities;
3. Other public sources accessible on the Internet which you use for professional reasons (Linked-In)

VI. Use of your personal data

VGS lawyer will use your personal data in the following circumstances:

1. Performing a contract: We may process your personal data with the purpose of performing a contract we were about to enter or have entered;
2. Legal or Regulatory Obligation: We may process your personal data in the event it is asked by legal or regulatory obligations;
3. Legitimate Interest: We may process your personal data where it is necessary for our interests (provided that your rights do not override such interest);
4. Consent and explicit consent: We may process your personal data when you authorised us in this sense by providing your consent or explicit consent.

VGS lawyer will use and process your personal data for the purposes for which it has been collected. However, we may need to process your personal data for a further reason that is compatible with the original purposes.
Should we need to process your personal data for unrelated purposes, we will notify you and we will explain the current legal basis that allows us to do so.

VII. Marketing communications and your right to opt-out

We will not use your personal information to send you marketing communications if you have request to not receiving them. Should you request to stop processing your personal information for marketing purposes we shall interrupt processing your personal data for those purposes.

VIII. Disclosure of your personal data

VGS lawyer may have to share your personal information with the following subjects and entities for the purposes we collected the personal data.

1. Your personal information will be shared within other VGS lawyer offices. As an International Law Firm, we may share your personal data between our offices to ensure adequate operation of our firm;
2. Any subject or entity to whom we are required to disclose your personal data by court decision or governmental authority;
3. Our professional advisers and consultant including, lawyers, bankers, auditors, accountants;
4. Any financial institution providing finance to us;
5. Service providers who provide information technology services to us;
6. Any external auditors who may carry out independent checks of your files for accreditation reasons.

We require that any subject, entity or organisation whom we share your personal data is obligated to respect the confidentiality and security of your personal data and to treat it in accordance with applicable laws and regulations.

IX. What type of cookies are used on our websites?

Cookie Name	Source	Purpose	Further Information
_ga	Google	Used to distinguish users.	Duration two years.
_gid	Google	Used to distinguish users.	Duration 24 hours.
WordPress	WordPress	Used to distinguish users.	Duration one year.

X. International Transfers

We may share your personal information through our offices in Italy and United Kingdom. This involves transferring of your data within the European Economic Area.
Whenever we may transfer your personal data out of the EEA, we must guarantee a similar degree of protection of your personal data by ensuring one of the following safeguards:

1. Data transferring to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
2. Data transferring to subjects or entities which contract of services has been approved by the European Commission;
3. Data transferring to providers or US subjects that are certified EU-US Privacy Shield.

XI. Data Security

VGS lawyer implements technical and organisational measures with the intent of provide security to data processing activities. The following security measures constitute how VGS lawyer respects and protect your personal data:

1. Encryption and Pseudonymisation of personal data;
2. Implementation of data security principles such as confidentiality, integrity, availability and resilience;
3. Adequate assessment to verify the effectiveness of our technical and organisational measures.

XII. Data Retention

The GDPR sets out several rights you, under certain conditions, are entitle to exercise. Each claim in relation to data subject rights shall be forwarded to info@vgslawyers.com.
Details of your rights

1. Right to be informed about how personal data is used;
2. Right to access to personal data;
3. Right to rectify eventual inaccurate personal data;
4. Right to have personal erased;
5. Right to restrict processing of personal data;
6. Right to data portability;
7. Right to object to processing of your personal data;
8. Right to not be subject to automated decision making, including profiling, where the decision produces a legal effect on you or rights.

VGS lawyers may need to request specific information from you to help us to confirm your identity. This is a basic security measure to ensure personal data is not disclosed to individuals are not entitle to receive it.
VGS lawyer will try to respond to your request within a calendar month.