Privacy Notice

iLS are committed to protecting and respecting your privacy. This privacy policy contains important information on who we are and how and why we collect, store, use and share your personal data that you provide to us either via our website or when you instruct us when you fill in an enquiry form, accept an invitation to a seminar, or sign up to a newsletter. This privacy policy also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

iLS collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

Using or accessing the iLS website indicates your acceptance of the privacy policy and the terms and conditions as they apply from time to time.

Our use of your personal data is subject to your instructions, Regulation (EU) 2016/679 (the “General Data Protection Regulation”, or GDPR).

This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.

Key terms

It would be helpful to start by explaining some key terms used in this document.

The terms we, us, our, collectively:

iLS (Milan) Società tra Avvocati S.r.l.
Enrolled with the companies’ register of Milan-Monza-Lodi under no. 11668690966 and registered with the Bar of Milan (Ordine degli Avvocati di Milano)
Registered Office: Via Turati 29, 20121, Milan

Data controller:

iLS (Milan) Società tra Avvocati S.r.l.

Registered Address:

Via Fatebenefratelli 15, 20121, Milan

Person responsible for data protection:

Mr Marco Pallucchini Wrede
Via Fatebenefratelli, 15
20121 Milan

Email: marco.pallucchini@ilsmilan.it
Telephone: +39 02 637 889 900

Personal data:

Any information relating to an identified or identifiable individual.

Personal data we collect about you

The personal data we will or may collect in the course of advising and/or acting for you is as follows:

Personal data we will collect:

Your name, date of birth, address and telephone number;
Information to enable us to check and verify your identity, (e.g. passport and/or driving licence details) and proof of address (e.g. utility bills and/or bank statements);
Electronic contact details, e.g. your email address and mobile phone number;
Information relating to the matter in which you are seeking our advice or representation;
Your financial details so far as relevant to your instructions, e.g. the source of your funds.

Personal data we may collect depending on why you have instructed us:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. National Insurance and tax details;
Contact Data includes billing address, delivery address, email address and telephone numbers;
Financial Data includes bank account and payment card details and/or building society details and your credit rating;
Transaction Data includes details about payments to and from you and other details of services you have purchased from us;
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website;
Profile Data includes your use of our services, your interests, preferences, feedback and survey responses;
Usage Data includes information about how you use our Website, services and products;
Marketing and Communications Data includes your preferences in receiving marketing from us, and your communication preferences;
Legal Matter Data includes information about you given to us in relation to your legal matter.

We may also collect, use and share:

Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

The personal data we request from you is to enable us to provide our service to you and to comply with our statutory obligations in respect of Anti-Money Laundering (AML), KYC and client due diligence. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.

How your personal data is collected

We collect most of this information from you through the form on our website or by corresponding by phone, email or otherwise when engaged to provide services. We use cookies on our Website.

This Privacy Notice should be read alongside our Cookies policy.

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact, Financial and Legal Matter Data by filling in forms or by corresponding with us by post, phone, email or otherwise.

This includes personal data you provide when:

We conduct open source searches on you in connection with our business development or business acceptance processes;
You or the organisation you work for are a counterparty of one or more of our clients;
You apply for a role or work experience opportunity with us;
You request or use our services or provide information to us;
You visit our Website;
You complete application forms on our Website;
You subscribe to our publications or attend a seminar;
You request marketing to be sent to you;
You enter a survey; or
You give us some feedback.

Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
  - analytics providers such as Google Analytics based outside the EU; and
  - online verification search providers based inside the EU;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside the EU;
- Identity and Contact Data from data brokers or aggregators based inside the EU;
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register, based inside the EU;
- Legal Matter Data from publicly available sources such as the Land Registry and the Intellectual Property Office, based inside the EU;
- Legal Matter Data from third parties involved in your legal matter.

However, we may also collect information:

From publicly accessible sources, e.g. Companies House or HM Land Registry;
Directly from a third party, e.g. credit reference agencies, client due diligence providers;
From a third party with your consent, e.g. your bank or building society, another financial institution or advisor;
Consultants and other professionals we may engage in relation to your matter;
Via our information technology systems, e.g. case management, document management and time recording systems;
Relevant websites and applications; automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason for doing so, e.g.:

To comply with our legal and regulatory/statutory obligations;
For the performance of our contract with you or to take steps at your request before entering into a contract;
For our legitimate interests or those of a third party;
Or you have given

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

What we use (process) your personal data for and our reasons for doing so

Our reasons to providing legal services to you:

For the performance of our contract with you or to take steps at your request before entering into a contract;
Conducting checks to identify our clients and verify their identity;
Screening for financial and other sanctions or embargoes;
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator;
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies;
To comply with our legal and regulatory obligations;
For our legitimate interests or those of a third party;
Ensuring business policies are adhered to, e.g. policies covering security and internet use;
Operational reasons, such as improving efficiency, training and quality control;
Ensuring the confidentiality of commercially sensitive information;
Statistical analysis to help us manage our practice, e.g. in relation to our financial performance, client base, work type or other efficiency measures;
For our legitimate interests or those of a third party;
Preventing unauthorised access and modifications to systems;
Updating and enhancing client records;
For the performance of our contract with you or to take steps at your request before entering into a contract, and/or to comply with our legal and regulatory obligations;
Ensuring safe working practices, staff administration and assessments;
The above does not apply to special category personal data, which we will only process with your explicit consent.

Promotional communications

We may use your personal data to send you updates (by email, text message, telephone or post) about legal developments that might be of interest to you and/or information about our services, including exclusive offers, promotions or new services or products.

We have a legitimate interest in processing your personal data for promotional purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal data with the utmost respect and never sell or share it with other organisations outside Italian Legal Services for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by contacting us by post, email or telephone by contacting our Office Manager.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who we share your personal data with

We routinely share personal data with:

Professional advisers who we instruct on your behalf or refer you to, e.g. experts as we deem fit to advance your case;
Other third parties where necessary to carry out your instructions, including, without limitation, HMRC, regulators and other authorities based in the United Kingdom or elsewhere who require reporting of processing activities in certain circumstances;
External auditors and the audit of our accounts;
Our bank;
Our case management

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Where your personal data is held

Information may be held at our office, third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs (see below: ‘Transferring your personal data out of the EEA’).

How long your personal data will be kept

We will keep your personal data after we have finished advising or acting for you. We will do so for one of these reasons:

To respond to any questions, complaints or claims made by you or on your behalf;
To show that we treated you fairly;
To keep records required by Law Society and SRA Regulations and other applicable laws and regulations, including, without limitation, in respect of us being Italian lawyers.

Retention Policy

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for legal, regulatory and tax purposes.

This policy sets out how long information will normally be held by us and when that information will be confidentially destroyed.

Responsibility

iLS is responsible for implementing and monitoring compliance with this policy.

Our process

Information (hard copy and electronic) will be retained for at least the period specified in our Data Retention Period.

All information must be reviewed before destruction to determine if there are special factors that mean destruction should be delayed, e.g.:

Potential litigation;
Complaints;
Ongoing cases.

We will endeavour to delete hard copy and electronically held documents and information at the end of the Data Retention Period.

The above does not apply to special category personal data, which we will only process with your explicit consent.

We will always treat your personal data with the utmost respect and never sell for marketing purposes.

Transferring your personal data out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA).

These non-EEA countries may not have the same data protection laws as the United Kingdom and EEA. We will, however, endeavour that the transfer complies with data protection law and all personal data will be secure.

If you would like further information, please contact us (see ‘How to contact us’ below).

Your rights

You have the following rights, which you can exercise free of charge:

Access

The right to be provided with a copy of your personal data (the right of access).

Rectification

The right to require us to correct any mistakes in your personal data.

To be forgotten

The right to require us to delete your personal data.

Restriction of processing

The right to require us to restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data.

Data portability

The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.

To object

The right to object:

At any time to your personal data being processed for direct marketing (including profiling);
In certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.

Not to be subject to automated individual decision-making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’; and:

Let us have enough information to identify you (e.g. your full name, address and client or matter reference number);
Let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
Let us know what right you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

We hope that we can resolve any query or concern you may raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.