1.      Introduction

This Privacy Notice is provided by LP Advisory S.r.l. (hereinafter “LP Advisory”, “our” or “we”) to visitors of our website (hereinafter "you" or "user") to explain who we are, how we collect, share, and use personal data of visitors of our website (hereinafter the “Site”), as well as how visitors can exercise their privacy rights

We welcome your visit to our website and your interest in LP Advisory's professional services. The protection and security of the personal data of our customers and users are very important to us. For this reason we are committed to ensuring that the Site and our business processes are designed to minimise the processing and collection of personal data and that the information collected is processed in accordance with the European Regulation (EU) 2016/679 ("GDPR"), Legislative Decree 196/2003, as supplemented and amended by Legislative Decree 101/2018 ("Privacy Code").

If you have any questions or concerns about our use of your personal data, or would like to exercise any of your rights — including, but not limited to, objecting to the processing of your personal data in the ways that we describe here — then please contact us using the details provided in this Privacy Notice.

2.      Who we are

LP Advisory S.r.l. is an electronic accounting data processing company, incorporated under the laws of Italy, with registered offices in Galleria del Corso 1, 20122 – Milan (Italy), tax code and VAT number 11444320961, e-mail address [info@tp-advisoryinternational.com], Tel. [+39 (0)2 82001001] and processes users' personal data as data controller.

3.      Information That We Collect 

We do not require registration to visit our websites. However, some services may require visitors to provide us with personal data, such as contact details and interests.

When you visit our Site, certain standardised information about your terminal or browser that you are using is stored by our web server.

This is necessary for the pursuit of a legitimate interest of ours, namely to monitor the technical functions of the Site, to increase the operational security of the server and, again, to provide our visitors with a rich and more intuitive user experience.

In such context we may need to collect the following information from you:

• IP address;
• date and time of access;
• browser you use, language settings, version of your operating system;
• volume of transferred data;
• access status;
• requested content

In order to answer your questions or to receive your CVs via the contact forms that are available in the “Contact” section of our Site, we may also process the following personal data:

• name and surname;
• date and place of birth;
• place of residence and e-mail address.

The lawful basis for this particular processing operation is the correct execution of your request.

4.      How We Use Your Personal Data

We use personal data in order to maintain functionalities on our websites such as:

• providing customer service to users;
• responding to user inquiries and fulfilling any user requests;
• sending administrative information to users, such as changes to our terms, conditions, and policies, as well as market information that we believe may be of interest to you.

We also use Personal Data to ensure that our business operations comply with any relevant legal obligations and match our legitimate interests.

Our business activities may include:

• data analysis;
• internal data audits;
• identifying usage trends for our websites;
• detecting, preventing, and investigating fraud in the use of our websites;[JT1] [JH Kim2] 
• cyber security monitoring;
• developing, enhancing, or modifying our products and services;
• validating users' ability to access or utilise our products and services
   

5.      Legal basis for processing personal information

Our legal basis for collecting and using the personal information as described above will depend on the personal information concerned and the specific context in which we collect it. However, we will generally collect personal information from you only where we have your consent to do so, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.

If we ask you to provide personal information to comply with a legal requirement or for contacting purposes, we will make this clear at the relevant time and advise you whether or not the provision of your personal information is mandatory (as well as of the possible consequences of not providing your personal information).

Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw such consent, independently of each other, at any time.

Withdrawal of your consent means that from that moment on your personal data can no longer be processed for such purposes. But it will also mean that we may potentially no longer be able to perform (or only perform to a limited extent) the services for which the personal data was originally provided.

6.      Data processors and authorized personnel

As data controller, we may also process your personal data with the support of other persons and entities that may be given access to your personal data in their capacity as data processors. These subjects are obliged to protect your personal data and may process such data only in accordance with our instructions and exclusively for purposes established by us.

In order to achieve the purposes described above, we may also use internal staff and other individuals expressly authorised to process your personal data. These persons may acquire knowledge of your information only with regard to the functions performed and on the basis of appropriate written instructions to be followed.

We may also communicate personal data to other persons or entities with whom they must be shared, by law or by contract, to allow the proper performance of the purposes described above (such as, for example, other companies or professional consultants).

Your personal data will never be disclosed to unauthorised third parties.

7.      Data security

We are continuously improving our administrative, technical and physical security measures in order to protect your personal data from unauthorised access, loss, destruction or modification. Our security measures also include firewall tools and data encryption and access controls in the information we share.

8.      Retention of personal data

We only retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained in this Privacy Notice.

If you are no longer interested in us using your personal data to make certain services available to you through our Site, you may request that they be deleted. Please note that we may continue to retain and use certain personal information about you when we have ongoing legitimate business need to process your personal information.

9.      Your Rights

You have the right to access any personal information that we process about you and you have the right to request information about:

• what personal data we hold about you;
• the purposes of the processing;
• the categories of personal data concerned 
• the recipients to whom the personal data has/will be disclosed;
• how long we intend to store your personal data for;
• If we did not collect the data directly from you, information about the source;
• the existence of automated decision processing tools, including profiling, and information on the methodology employed as well as the importance and consequences of such processing.

If, as an Italian resident, you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with:

Garante per la protezione dei dati personali (the "Garante"), Piazza Venezia 11 - 00187 Roma. Tell: +39 06.696771.

e-mail account: protocollo@gpdp.it. (Italy only).

If you would like to request to review, correct, update, suppress, restrict, or delete Personal Data that you have provided us through the Site, or if you would like to request to receive an electronic copy of your personal data for the purpose of transmitting it to another company (right to data portability), you may contact us as indicated in the "Who we are" section. We will respond to your request promptly, in compliance with applicable laws.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request. This is to ensure that your data is protected and kept secure. We will try our best to respond to your request as soon as reasonably practicable.

When asked to provide Personal Data, you may decline. However, choosing not to provide necessary information may limit our ability to supply you with requested services.

10.    Cookie Notice

This Site uses cookies.

Cookies make the use of websites more convenient and efficient. A ‘cookie’ is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. When you visit a site that uses cookies for the first time, a cookie is downloaded onto your computer/mobile device so that the next time you visit that site, your device will remember useful information such as visited pages or logging in options.

The following table contains a detailed list of the functional and/or technical cookies we use on our Site:

Type of cookie	Duration	Purpose
__cfduid	1 year 30 days	The cookie is used by cdn services like CloudFare to identify individual clients behind a shared IP address and apply security settings on a per-client basis. It does not correspond to any user ID in the web application and does not store any personally identifiable information.

 

11.    Updates

We may update this Privacy Notice from time to time in response to changing legal, technical, or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you with the significance of the changes we make.