4cLegal

Information on the processing of personal data pursuant to art. 13 of EU Regulation 2016/679 ("Information Notice" or "Privacy Policy")

Dear User,

4c S.r.l., with registered office in Via Fontana 18, 20122 Milan, Tax Code and VAT No. 08797090969, as Data Controller (hereinafter "4cLegal" or "4c" or "Controller") considers privacy and protection of personal data one of the main objectives of its activity. This document has been drafted pursuant to art. 13 of the EU Regulation 2016/679 (hereinafter: "Regulation" or "GDPR") in order to allow you to know our policy on the processing of personal data; we therefore invite you, before communicating any personal data to the Controller, to carefully read this Privacy Policy because it contains important information on the protection of your personal data. This Privacy Policy is provided for the site www.4clegal.com (hereinafter only "Site") and is an integral part of the services offered through the same. The processing of your personal data will be based on principles of correctness, lawfulness, transparency, limitation of purpose and storage, minimization and accuracy, integrity and confidentiality, as well as the principle of accountability referred to in art. 5 of the Regulation. Your personal data will therefore be processed in accordance with the legislative provisions of the Regulation and the confidentiality obligations provided therein. We specify that the processing of personal data means any operation or set of operations, carried out with or without the aid of automated processes and applied to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, diffusion or any other form of making available, comparison or interconnection, limitation, cancellation or destruction.

INDEX

1. 1. Owner of the Database
   2. Personal data subject to processing
      1. Navigation data
      2. Personal data voluntarily provided by the user of the Site
      3. Personal Data collected through the 4cLegal Talks section of the Site
      4. Personal Data collected in the Professional Panel section of the Site and third-party data
      5. Personal Data collected in connection with the issuance of Sustainability Accreditation
      6. Personal Data collected for participation in the Talent Academy
      7. Cookies
   3. Purpose of the processing, legal basis and mandatory or optional nature of the conferment
   4. Recipients of Personal Data
   5. Transfer of Personal Data
   6. Storage of Personal Data
   7. Rights of Data Subjects
   8. Changes
   9. Contact

1. Owner of the Database

The data controller is 4c S.r.l., registered office in in Via Fontana 18, 20122, Milan, tax code and VAT number 08797090969.

2. Personal data subject to processing

Following the navigation of the Site, we inform you that 4c will process personal data that may consist of an identifier such as a name, an identification number, an online identifier or one or more characteristic elements of your physical, physiological, economic, cultural or social identity capable of making the subject identified or identifiable (hereinafter only "Personal Data"). The Personal Data processed are as follows:

a. Navigation data

The computer systems and software procedures used to operate the Site acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified interested parties, but by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of computers used by users who connect to the Site, URI (Uniform Resource Identifier) of requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the response from the server (successful, error, etc..) and other parameters regarding the operating system and computer environment. This data is used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning, to allow - given the architecture of the systems used - the proper provision of services, for security reasons and to ascertain responsibility in case of hypothetical computer crimes against the Site or third parties; and are usually deleted after seven days.

b. Personal data voluntarily provided by the user of the Site

The Site offers users the opportunity to voluntarily provide personal data through, for example, registration forms for events organized by 4c, contact forms, to request services and/or by sending optional, explicit and voluntary e-mail messages to the addresses indicated on the Site.

c. Personal Data collected through the 4cLegal Talks section of the Site

By registering to the private area of the section called 4cLegal Talks (https://www.4clegal.com/user/login) you will be asked for some Personal Data such as your name, surname, e-mail and telephone number, the company you belong to, the job position you hold. Through this section of the Site, in addition to accessing its contents, you can make comments on articles and news published; these comments will be accessible only to members of that section. We therefore invite you not to enter Personal Data and other information that is not relevant or necessary for the use of this service.

Furthermore, by filling out the specific "Contact Author" section at the bottom of each content published in the Talks section, 4c may collect your Personal Data in order to communicate them to the author of the publication and thus put you in contact with him. From the moment of communication, your Personal Data will thus also be processed by the author of the editorial contribution as autonomous data controller.

d. Personal Data collected through the so-called. Professional Panel section of the Site and third-party data

If you decide to register in the section of the Site called “Professional Panel” (https://panel.4clegal.com/en/login) you will be asked to provide certain Personal Data, including: details of professional experience, skills acquired, contact details and more generally all work and study experience carried out. In addition, you will be asked to provide a copy of your professional risk insurance policy, an identity document and Chamber of Commerce registration, a copy of your Professional Panel membership card and your CV. The Personal Data will be processed by 4c for the purpose of verifying their truthfulness in order to allow you to be accredited to the Professional Panel and, subsequently, to the platforms activated by 4c customers where permitted, and according to the conditions and terms provided for from time to time (so-called Panel) and thus to use the services offered and requested by you.

In order to obtain validation of the declared skills and professional experience (the so-called "track records"), you will be asked to fill in dedicated forms in which to enter the details of such skills/assignments/experience. In order to obtain validation of your track record, 4c may contact your client or the person indicated in the validation request, using the contact details you have provided to us, so that we can ask for confirmation of the truthfulness of the information you have provided to 4c and to verify what you have declared. The third party's data and information will then be processed by 4c for this specific purpose.

Once the track record has been confirmed by the contact you have provided to us and verified by 4c, the track record will be considered valid for the purposes of enrolment in the Professional Panel and also for the purposes of accreditation to the 4c Client Panels.

We specify that when you provide Personal Data of third parties to 4c (for example, for the purpose of issuing one or more track records, by means of the information contained in the CVs) you act as the autonomous data controller, assuming all the legal obligations and responsibilities. In this sense, you grant 4c the widest possible indemnity with respect to any dispute, claim, request for compensation for damage caused by processing, etc., which may be received by 4c from third parties whose data have been processed through the use of the functions of the Site in violation of the rules on the protection of personal data applicable. In any case, should you provide or otherwise process data of third parties in the use of the Site, you warrant as of now - assuming all related responsibilities - that this particular hypothesis of processing is based on a suitable legal basis under Article 6 of the Regulation which legitimates the processing of the information in question.

With specific reference to the compilation of track records, we invite you not to provide Personal Data relating to criminal convictions and offences (for the definition see art. 10 of the Regulation) or other information relating to your state of health, political opinions or religious beliefs (referred to in art. 9 of the Regulation) with respect to your person and also with respect to third parties (such as customers or third parties indicated as subjects to be contacted for the validation of a track record), specifying that if you decide to give such data to 4c, the latter will not be able to process them in any way and will therefore provide for their deletion.

We would also like to inform you that if you decide to register with the Panels dedicated to 4c's client companies, the company from which you have requested accreditation will process your Personal Data as an autonomous data controller; we therefore invite you to consult the information on the processing of personal data of 4c clients from whom you have requested accreditation, in order to find out how your Personal Data will be processed and how to exercise the rights recognized by the Regulation with regard to 4c clients. Finally, once you have been accredited to the Professional Panel, 4c may also invite you to be accredited to specific Panels of its clients if deemed to be in line with your expertise (see the purpose of "Referral to Clients" in section 3 of the Privacy Policy); in such cases, you will be free to be accredited as well as to decline the invitation received.

e. Personal data collected for the issue of Sustainability Accreditation (so-called "ESG")

In the context of the services of issuing Sustainability Accreditation - which allow 4c's client company to verify that the professionals it employs comply with the ESG parameters - 4c will invite the professional firms indicated by its client to access a dedicated section of the panel.4clegal.com platform so that they can select the ESG items they believe they meet, describing the policies actually applied and, if necessary, attaching documentation to prove the statements made. They may also provide us with third-party information and personal data, such as contact details of employees or clients, so that we can contact them to validate the claims made in order to issue one or more Sustainability Statements (for example, to confirm the existence of a plastic-free or work-life balance policy, or of complaints flows, etc.).

Once a firm has been accredited to the platform, its personal data will be processed in accordance with section 2.d of this Privacy Policy.

The personal data of the above-mentioned third parties will therefore be processed by 4c for the purpose of verifying the truthfulness of the declarations made in the context of the above-mentioned project, and therefore for the issue of the Sustainability Accreditation for the benefit of the professional firm that requested it.

As part of the above processing activities, we would like to clarify that in providing personal data to third parties subject to 4c, you act as an independent data controller, assuming all the obligations and responsibilities of law. In this sense, it confers on this point the widest possible indemnity with respect to any dispute, claim, request for compensation for damages from treatment, etc.. that may be received by 4c from third parties whose data have been processed as part of the project above in violation of the rules on the protection of personal data applicable.

We also invite you not to provide Personal Data relating to criminal convictions and offences (as per art. 10 of the Regulations) or other information relating to your state of health, political opinions or religious beliefs (as per art. 9 of the Regulation) with respect to your person and also with respect to third parties (customers, collaborators and other stakeholders indicated as subjects to be contacted for the issuance of one or more Sustainability Accreditation), specifying that, should you decide to confer such data to 4c, the latter will not be able to process them in any way and will therefore provide for their deletion (for example, for the purposes of validating the parenting policy you must not provide us with the contact details of those who have actually taken maternity leave; or for example, to validate a parenting policy, you must not provide contact details of employees with disabilities who work in the Practice).

f. Personal data collected for participation in the Talent Academy

If you decide to participate in the Talent Academy promoted by 4c, you will be asked to provide some of your Personal Data as well as a video presentation of your application, in accordance with the procedures set out in the call for applications and in the dedicated pages of the Website.

On this occasion, we invite you not to provide Personal Data or other information relating to your health status, political opinions or religious beliefs (as per art. 9 of the Regulations) with respect to your person and also with respect to third parties, specifying that, should you decide to provide such data to 4c, the latter will not be able to process them in any way and will therefore provide for their deletion.

In the context of the processing activities mentioned above, we specify that in the conferment of personal data of third parties to 4c you act as autonomous owner of the treatment, assuming all the obligations and responsibilities of law. In this sense, it confers on the point the widest indemnity with respect to any dispute, claim, request for compensation for damages from treatment, etc. that may be received by 4c from third parties whose data have been processed as part of the project above in violation of the rules on the protection of personal data applicable.

g. Cookies

For information on the use of cookies through the Site, we invite you to consult our Cookies Policy. Cookies Policy.

3. Purposes of the processing, legal basis and mandatory or optional nature of the conferment

Your Personal Data may be processed by 4c, with your consent where necessary, for the following purposes

a. To enable the provision of the requested services (including, for example, to allow you to register for an event, respond to your requests for information, register on the Site, the Professional Panel or the Talks section, to apply for the Academy, to allow you to contact the author of an article published on the Site, provide you with support services, etc.; hereinafter also only "Provision of Services").

As mentioned above, we specify that if you request registration with the so-called Professional Panel (see section 2.d. of this Privacy Policy) or to the section of the Site known as the Market Place, 4c may analyse your skills and professionalism, including those included in your track record or CV, in order to:

- signal your profile to 4c's client companies that use our services, so that you may be contacted by these subjects in order to be accredited to the Panel of the same, as well as to be invited by them to participate in a specific competitive procedure (so-called "beauty contest") and thus obtain the possibility to make an economic offer to receive a professional assignment,

- be recommended by the Panel so that it can evaluate them and, if necessary, gain independent accreditation, without prejudice to the possibility of refusing such invitations/signals as well as the possibility of autonomously seeking out panels to which to apply for accreditation independently of the notification from 4c. For such processing (hereinafter also referred to as "Referral to Clients"), 4c may process and analyze the Personal Data provided in order to better understand your professional experience and qualifications; this assessment is necessary and functional so that the Referral to Clients may be relevant and you may have a real possibility of obtaining one or more professional assignments appropriate to the skills and experience you have described to us.

The provision of your Personal Data as described above is entirely optional, but failure to do so will make it impossible for us to provide you with the services described above.

The legal basis for the above processing is art. 6(1)(b) of the Regulation, i.e. the performance of a contractual obligation or pre-contractual measures taken at your request as they are processing aimed at providing 4c services; In the context of the Talent Academy your Personal Data collected through the Site will be processed to evaluate your request to participate/candidate.

In this context, 4c reserves the right to use the presentation videos submitted by you for the purpose of promoting the Talent and therefore publishing them in whole or in part on the Site and on the communication channels at its disposal, including 4c's social pages ("Video Publication"). For this specific purpose of Publication of the videos, you will be asked to give your consent; if you do not give your consent, you will not be prevented from sending your application; this consent is free and revocable by writing to the "Contact" section of this Policy;

b. Facilitate the provision of the Services to 4c's clients, for example by collaborating with 4c for the purpose of issuing track records and Sustainability Accreditation confirming or not the statements made by the same (see sections 2.d and 2.e of this Privacy Policy), hereinafter also only "Validations". In such cases, in fact, 4c reserves the right to contact the interested parties (clients, professional firm collaborators) at the contact details provided by 4c clients (registered professionals, professional firms, companies) for the purposes of issuing a track record or a Sustainability Accreditation. This processing is based on 4c's legitimate interest (art. 6.1.f of the Regulations) in offering a service to validate the skills possessed by its clients' suppliers. 4c has carried out a balancing of interests for such processing, which has been found not to be detrimental to the rights and freedoms of the data subjects. If you wish to object to such processing, you may do so by ignoring the email received; in this way, 4c will also cease any further processing of your personal data. If, on the other hand, he or she decides to reply to the email received, 4c will retain his or her personal data, including his or her validation as long as the professional remains registered with the Professional Panel.sti.

c.Carry out marketing activities, such as carrying out surveys and market research also through online surveys, sending you information and promotional material regarding 4c's activities, products and services, including 4c's newsletter ("Marketing"). These communications may be made via e-mail, SMS, social channels 4c, through paper mail and / or the use of telephone with operator; it should be noted that the owner collects a single consent for the purposes of Marketing Pursuant to the General Provision of the Guarantor for the Protection of Personal Data "Guidelines on promotional activities and combating spam", of July 4, 2013, and by virtue of art. 6(1)(a) of the Regulation.

If, in any case, you wish to object to the processing of your Personal Data for Marketing purposes carried out by the means indicated herein, you may do so at any time by contacting the Data Controller at the addresses indicated in the "Contacts" section of this Policy or by using the unsubscribe mechanism found in the footer of the commercial emails, without affecting the lawfulness of the processing based on the consent given before the revocation. We remind you that you may also object to the use of some of the contact means used (selective opt-out).

The provision of your Personal Data for these purposes is therefore entirely optional and does not affect the provision of services, it being understood that you will not receive marketing communications;

d. analyze your Personal Data, especially Personal Data inferred from your activities, Personal Data collected by Browser to improve our services (e.g. our websites, our events, promotional communications) and show you only content that may be of interest and to be able to send you customized information and promotional material about the services and products offered by 4c ("Personalize our services"). This purpose of Personalizing our services may also be pursued through the use of cookies for targeted advertising (see Cookies Policy) and the analysis of your interaction with 4c's social channels (such as Instagram, Facebook, LinkedIn, Twitter, etc. "Social Pages") - in this case, the processing of your Personal Data is carried out by 4c as co-processor with the provider of the social network used (in accordance with the EDPB (the European Data Protection Board) Guidelines n.8 /2020 on the use of social networks); therefore, the privacy policies of these providers also apply, which we invite you to consult.

This processing is based on your consent in accordance with art. 6(1)(a) of the Regulation that you can express or revoke through the banner on your first visit to the Site with regard to Personal Data collected by browser and device, the data collection forms in which we ask you to express your preferences regarding the Personal Data you provide and Personal Data inferred from your activities.

The provision of your Personal Data for this purpose is therefore entirely optional and does not affect the provision of Services.

If you do not wish to receive personalised services or useful content, you may revoke your consent at any time by contacting the Data Controller at the contact details given in the "Contacts" section below; to revoke your consent to the use of third party cookies and for targeted advertising, please refer to the Cookies Policy of the Site;

e. To send you offers on products or services similar to those you have purchased and requested from 4c by email even in the absence of your specific consent ("Soft Opt-in"), unless you expressly refuse to receive such communications, which you may express at any time by writing to privacy@4clegal.com or by expressly denying your consent for Marketing purposes.

This treatment is legitimate under Article 130, paragraph 4, of the Privacy Code, provided that these are communications about products or services similar to those that have been the subject of your purchase and request and that you, adequately informed, you have not objected or will not object in the future to such communications. This means that you may object to the processing of your Personal Data for such purposes both when requesting products and services available on the Site (expressly denying consent to processing for Marketing purposes), and during subsequent commercial communications from the Data Controller, by writing to privacy@4clegal.com or through the unsubscribe mechanism present in the footer of the e-mails received;

f. To send you satisfaction surveys in case of your participation in an event 4c. These questionnaires are exclusively aimed at knowing your satisfaction with the event in which you took part, your opinion of the teachers and speakers and more generally to allow you to share with 4c suggestions and opinions on events and seminars (so-called "Customer Satisfaction Survey").

The legal basis for this processing is 4c's legitimate interest under Article 6(1)(f) of the Regulation. You are free to participate in such Customer Satisfaction Surveys as well as to object to the processing of your Personal Data for such purpose by contacting 4c at the contact details provided in the "Contact Us" section of this Policy;

g. To follow up your request for assistance which may be formulated by means of chat, e-mail, or telephone by calling the toll-free number of 4c and more generally through the contact details published on the Site ("Customer Care").

The provision of your Personal Data for this purpose is optional, but failure to do so will make it impossible for us to provide you with the requested assistance services.

The legal basis for this processing is art. 6(1)(b) of the Regulation, i.e. the performance of a contractual obligation or of pre-contractual measures taken at your request;

h. To comply with legal obligations (e.g.: in tax matters) to which 4c is subject ("Compliance with legal obligations"). The provision of your Personal Data may be mandatory (e.g.: because it is necessary for billing purposes).

The legal basis for this processing is Article 6(1)(c) of the Regulation;

i. If you register for a 4c event, you provide your Personal Data to the event organizer so that the latter can send you information and promotional material for autonomous direct marketing purposes ("Communication to third parties").

The release of your Personal Data for this purpose is absolutely optional as is the release of your consent. Such processing, in fact, will be carried out only if you give your specific consent, which may be requested when you register for the event, pursuant to art. 6(1)(a) of the Regulations. You may revoke your consent at any time by contacting the Data Controller at the addresses indicated in the "Contacts" section of this Policy;

j. Analyze your Personal Data, the skills you have entered in the Panel of 4c's client companies, and the offers you have submitted for participation in the beauty contest in order to optimize the services that 4c offers to its clients and to make Panels for its clients ("Service Optimization"). The legal basis for such processing is 4c's legitimate interest (Art. 6(1)(f) of the Regulation) in improving its services and making Panels effectively for its customers. You can always object to such processing by writing to privacy@4clegal.com.

k. Prevent fraud and abuse in the use of the Site and allow 4c to defend its rights and legitimate interests ("Abuse/Fraud").

This processing is carried out on the basis of a legitimate interest of the Data Controller pursuant to art. 6(1)(f) of the Regulations to prevent and detect fraudulent or potentially unlawful activities and allow 4c to defend itself in court;

l. Statistical purposes, without it being possible to trace your identity ("Statistics"). This activity does not involve the processing of Personal Data as 4c is not able to trace your identity.

4. Personal Data Recipients

4c shares your Personal Data with the following categories of entities ("Recipients"):

• Persons authorized by 4c: these are the employees and collaborators of 4c who have signed a confidentiality agreement and specific rules for the processing of your Personal Data;
• 4c's Data Processors: external subjects to whom 4c entrusts certain processing operations. For example, this category includes system security providers, consultants, accountants, hosting providers, providers of technological platforms for sending e-mails, and the call center platform;
• CNF or COA: if you have requested to receive training credits for your participation in an event, 4c will provide your name to the Consiglio Nazionale Forense (National Forensic Council) or to the Council of the territorial Bar Association of competence in order to satisfy its request;
• The Police or other competent authorities: this happens, for example, when 4c has to comply with a judicial order, a legal obligation or when it is necessary for the Holder's defence in court;
• Lecturer of an event, subject to their consent, for the purpose of "Communication to third parties" described in section 3.i. of this Policy. The lecturer is indicated from time to time during registration for the event;
• Companies which are clients of 4c and which have an active Panel or have an active profile on the so-called marketplace, so that the profile of the professional enrolled in the Professional Panel can be assessed by the company for the conferral of professional appointments. In this case, you will know the name of the 4c client to whom you have been referred, since 4c will contact you to invite you to apply to the Panel of that client. For more information on this treatment, see sections 2.d. and 3.a. of this Privacy Policy;
• Authors of the so-called 4cLegal Talks section of the Site: if you have requested to contact the author of the article, 4c will contact him/her on your behalf and provide your Personal Data in order to follow up and acknowledge your request for contact;
• Clients/referrals to attest to the professional skills/experience declared by the interested party registered on the Professional Panel for the purposes of track record validation (see section 2.d. of the Privacy Policy);Clients/collaborators or other stakeholders for the issue of a Sustainability Accreditation (see section 2.e. of the Privacy Policy).

Please note that this Privacy Policy does not apply to the processing activities carried out by third-party websites that can be reached through links on the Site, for which you are invited to consult the privacy policies published there, nor to the activities carried out by 4c clients if you have registered with a Panel or joined a competitive procedure and by the authors you have asked to contact through the Talks section of the Site.

5. Transfer of Personal Data

4c may transfer some of your Personal Data to recipients that may be located outside the European Economic Area. 4c ensures that the processing of your Personal Data by these recipients is done in compliance with the Regulation. Indeed, transfers may be based on an adequacy decision, the Standard Contractual Clauses approved by the European Commission or another appropriate legal basis. Further information is available from the Data Controller by writing to the addresses indicated in the "Contacts" section of this policy.

6. Storage of Personal Data

The Personal Data processed for the purpose of providing the Services, including the Signaling to Customers, will be kept strictly for the time necessary to achieve those purposes. In any case, since the processing of Personal Data is carried out for the provision of services, 4c will keep the Personal Data until the time allowed by Italian law to protect its interests (Art. 2946 c.c. and ss.). Personal Data processed for Marketing and Personalize our services purposes will be kept, as a general rule, until your consent is revoked.

For further information on cookies, please refer to the Cookie Policy of the Site.

The Personal Data processed for Validation purposes will be kept until the professional is removed from the Professional Panel.

Personal Data processed for Soft Opt-in purposes will be processed until you object to such processing by contacting the Data Controller or by using the unsubscribe link found in the footer of the Soft Opt-in and Marketing email.

Personal Data collected through Customer Satisfaction Surveys will be stored for 1 year and then deleted or anonymized by the Data Controller.

Personal Data processed for Customer Care purposes will be kept for the time necessary to handle your request and for the following 5 years.

Personal Data processed for the purposes of Compliance with legal obligations will be kept until the time required by the specific obligation or applicable law.

Your Personal Data processed for the purpose of Communication to third-parties will be kept, as a general rule, until your consent is revoked.

Your Personal Data processed for the purpose of Abuse/Fraud will be retained for as long as necessary for such purpose and therefore until such time as 4c is required to retain it to protect itself in court and to report such data to the competent authorities upon the occurrence of an Abuse/Fraud.

Further information regarding the period of retention of Personal Data and the criteria used to determine this period may be requested by writing to the Data Controller at the addresses indicated in the "Contact" section of this policy.

7. Rights of the Interested Parties

Data subjects have the right to ask 4c, at any time, to access their Personal Data, to obtain their correction or cancellation, and to object to the processing. They also have the right to request the limitation of the processing of their Personal Data, and to receive the Personal Data they have provided to 4c in a structured, commonly used and machine-readable format.

To manage your preferences with respect to Marketing and Soft Opt-in processing, you may also use the unsubscribe link in the footer of our commercial emails.

To manage your consent with respect to cookies, please see our Cookies Policy.

To revoke your consent (for Marketing and Personalize our services purposes) you can write an email to: privacy@4clegal.com

If you wish to object to the processing of your Personal Data for the sending of Customer Satisfaction Surveys and for other processing purposes based on the legitimate interest of 4c, pursuant to art. 6(1)(f) of the Regulation, you can write to: privacy@4clegal.com

Finally, we remind you that the interested party has the right to lodge a complaint, pursuant to art. 77 of the Regulation, before the Supervisory Authority, which in Italy is the Guarantor for the Protection of Personal Data, if he/she considers that the processing of his/her Personal Data is contrary to the law in force.

8. Changes

The possible entry into force of new sector regulations, as well as the constant review and updating of services, may result in the need or usefulness to change the procedures and terms described in this Policy. It is therefore possible that this document may be modified over time. We therefore invite you to periodically consult this page. We will post any changes to this Policy on this page and, if the changes are material to your rights and freedoms, we will notify you by additional means and contact you directly using your Personal Data held by 4c.

9. Contact

To exercise the above rights or for any other request regarding the processing of your Personal Data, you may contact the Data Controller at any time:

• 4c S.r.l., Via Fontana 18, 20122 Milano
• e-mail: privacy@4clegal.com