4cLegal

a. to enable you to navigate the Site and to provide the services you request from time to time from the Data Controller such as, for example, contact and/or information requests and more generally requests for assistance, to register for events, to download documentation on the Site, as well as to tutor you on our products and to enable your participation in the Talent "Academy" if you have spontaneously submitted your application through our Site or on 4c's other channels ("Provision of Services"). Processing for this purpose is based on fulfilling your request. It is not mandatory to provide Data to 4c for this purpose, but failing to do so will make it impossible to fulfill your request. With specific reference to the "Academy" Talent, we would like to clarify that, we may search for potential candidates on the Register of Practitioners website or contact you on Linkedin and/or 4c's Social Pages in order to propose you to participate in the Talent. In such cases we will send you an email and if you are not interested of course you can ignore it as well as object to such processing and we will not contact you again even for subsequent editions. Such processing is based on 4c's legitimate interest and your interest in participating in an initiative that might allow you to find employment in your legal field. In addition, also in the context of the Talent "Academy", after you submit your application and subject to your specific consent that you can express through the form that will be sent to you by email after your application (and that you can revoke at any time), we may publish your video presentation on the Site and on our communication channels, including the Social Pages of 4c to promote the Talent "Academy". b. to carry out marketing activities, such as processing surveys and market research including through online polls, sending you informational and promotional material and the newsletter of 4c or third parties pertaining to the legal ecosystem that have a partnership with 4c or are customers of 4c, by contacting you via e-mail, text message, 4c's Social Pages, paper mail and/or telephone with operator ("Marketing"). This processing is based on your consent, which you can revoke at any time by contacting us or clicking the unsubscribe button in the footer of our commercial emails, without affecting the lawfulness of the processing based on the consent given before revocation. You can also object to the use of only some of the contact means used (selective opt-out). c. to analyze your Data in order to show you content that may be of interest to you and to send you personalized informational and promotional material ("Personalize our Services"), including by using Cookies for targeted advertising and analyzing your interaction with 4c's Social Pages. In the latter case, the processing of your Data is carried out by 4c as a co-owner of the processing with the provider of the social network used (in accordance with EDPB (the European Data Protection Board) Guideline No. 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, which you can revoke at any time by contacting us or in the manner indicated in the Site's Cookie Policy. d. to send you offers on products or services similar to those purchased and requested from 4c by e-mail, 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 contacting us, through the unsubscribe mechanism present in the footer of the e-mails you receive, or by expressly denying your consent for Marketing purposes. This processing is legitimate under Article 130, paragraph 4, of the Privacy Code. e. to contact you on Linkedin by means of a cognitive and interlocutory private message, where you are a follower of 4c's page or where you are a follower of 4c's employees, and only in case of your expression of interest will subsequent communications ("Contact") follow Such processing is based on the legitimate interest of 4c and more generally third parties to join the 4c network and is justified by the expression of interest you have shown in following the 4c page or in general the 4c team members. Of course, you can always object to such processing by writing to us via email (privacy@4clegal.com) or even directly in the dedicated chat of 4c's Social Pages. f. to disclose your Data to the Event Lecturer or Partner so that they may send you informational and promotional materials for independent direct marketing purposes ("Third Party Communication") if you register for a 4c event and give your specific consent to do so, which you may revoke at any time by writing to 4c or directly to the Partner or Lecturer. The identity of the Partner or lecturer will be indicated to you at each event Please also note that the list of participants in an event carried out in partnership with third parties may be provided to the Partner for the management of the event itself by virtue of the execution of the existing contract between 4c and the individual Partner. In this case, your Personal Data will only be disclosed for this purpose and cannot be processed by the Partner for autonomous marketing purposes unless you have given the above consent. g. to fulfill legal obligations and orders to which we are subject, which form the legal basis for processing your Data ("Fulfilling legal obligations"). h. to prevent fraud and abuse in the use of the Site and enable us to defend our rights and legitimate interests ("Abuse/Fraud"). This processing is done on the basis of the Owner's legitimate interest in preventing and detecting fraudulent or potentially unlawful activities and enabling us to defend ourselves in court. i. for statistical purposes, without being able to be traced back to your identity ("Statistics"). Please note that such processing is not performed on Data and therefore can be freely carried out by the Data Controller. Such processing is based on the legitimate interest of 4c.

• Persons authorized by us to perform any of the Data-related activities described in this document, such as our employees and contractors who have assumed a duty of confidentiality and abide by specific rules for the processing of your Data;
• Our Processors: external parties to whom we delegate certain processing activities. For example, security system providers, consultants, accountants, hosting providers, etc. We have agreements in place with each of our Processors to ensure that your Data is processed with adequate safeguards and only in accordance with our instructions;
• System Administrators: our employees or those of Data Processors to whom we have delegated the management of our computer systems and who are therefore able to access, modify, suspend or restrict the processing of your Data. These individuals have been selected, properly trained, and their activities are tracked by systems that they cannot modify, as required by the regulations of our competent supervisory authority;
• CNF or COA: when you request recognition of educational credits as a result of attending a 4c event, we will provide your name to the National Bar Council or the relevant territorial Bar Council in order to fulfill your request;
• Police authority or any other authority whose provisions are binding on us: this is when we must comply with a judicial order or the law or defend ourselves in a legal proceeding;
• Event lecturers/event partners: are indicated from time to time during event registration and your Data is disclosed to them for the purposes of "Communication to third parties" (see sect. 3.f) only in case of your consent or to enable you to attend the event;
• Authors of the cd. Talks section of the Site or Influencers that can be contacted through the cd. Influencer Hub section of the Site: when you request to be put in touch with one of these individuals, we will follow up on your request by contacting them on your behalf and providing them with your Data.

• Provision of Services (see sect. 3.a): they will be kept for the time strictly necessary to achieve those same purposes. Since these are processing operations carried out for the provision of services, the Data Controller may further retain your Data for as long as permitted by Italian law to protect its interests (Art. 2946 et seq. of the Civil Code);
• Marketing (see sect. 3.b) and Personalizing our services (see sect. 3.c): will be retained, as a general rule, until your consent is revoked;
• Soft Opt-in (see sect. 3.d): they will be processed until you object to such processing;
• Contacts (see sect. 3.e): they will be processed until you object;
• Comunicazione to third parties (cf. sect. 3.f): will be retained, as a general rule, until your consent is revoked, unless the communication is made in order to comply with a request of yours (e.g., for the recognition of educational credits) and in that case the retention criteria established for the Delivery of Services previously indicated will be followed;
• Fulfilling legal obligation (see sect. 3.g): will be retained as long as required by the specific obligation or rule of law or regulation applicable;
• Abuse/Fraud (cf. sect. 3.h): they will be retained for as long as necessary to achieve those same purposes and thus until such time as 4c is required to retain them in order to protect itself in court and communicate them to the competent authorities upon the occurrence of an Abuse/Fraud.

More information regarding the Data retention period and the criteria used to determine this period may be requested by writing to the Data Controller at privacy@4clegal.com. Once the relevant retention period has expired, your Data will be deleted in accordance with our retention policy, unless 4c needs to further retain your Data to defend itself or its clients in court. You can request more information about our retention policy and criteria by writing to us here: privacy@4clegal.com.

• Access your Data (right of access): we will provide you with your Data, such as your name, age, IP Address, Unique Identifiers, email and expressed preferences, along with the Privacy Policy you received when you provided it;
• Exercise your right to portability of your Data (right to Data portability): we will provide you with an interoperable file containing Data about you;
• Correct your Data (right to rectification): for example, you can ask us to change your e-mail address or phone number if they are incorrect;
• Restrict the processing of your Data (right to restrict processing): for example, when you believe that the processing of your Data is unlawful or that processing based on our legitimate interest is inappropriate; and;
• Delete your Data (right to erasure): for example, when you do not want your Data to be stored;
• Object to processing activities (right to object): you have the right to object to the processing of your Data by explaining to us the reasons for your objection. In this case, 4c reserves the right to evaluate your request, which may not be accepted if there are compelling legitimate grounds for processing that override your rights, interests and freedoms. You also have the right to object at any time and without justification to the conduct of profiling and marketing activities, including by registering with the Register of Objections pursuant to Presidential Decree No. 26 of January 27, 2022.
• Withdraw your consents (right to withdraw consent). Please note that pursuant to Presidential Decree No. 26 of January 27, 2022, you may object to or revoke your consent to marketing activities by registering with the Register of Oppositions. If you have given your consent to marketing activities in the context of contractual relationships with us or the same have ceased no more than thirty days ago and therefore the Register of Oppositions does not apply, if you are no longer interested in receiving such communications you may revoke your consent at any time by writing to the address listed below

You may exercise the above rights or express any concerns or complaints about our use of your Data directly at: privacy@4clegal.com.

At any time, you can also:

• Contact our Data Protection Officer ("DPO"), here: dpo@4clegal.com;
• Contact the representatives of the EU national data protection authorities, a list of all Authorities by country can be found here: https://edpb.europa.eu/about-edpb/board/members_en.

Altre Tecnologie di Tracciamento: pixel tag (tracciatori utilizzati con i Cookie e incorporati nelle immagini delle pagine web per tracciare determinate attività) o identificatori univoci incorporati nei link alle comunicazioni commerciali che ci inviano informazioni quando vengono cliccati.

Other Tracking Technologies: pixel tags (trackers used with Cookies and embedded in web page images to track certain activities) or unique identifiers embedded in links to commercial communications that send us information when clicked.

Company or Legal Department: this refers to 4c customers who have concluded a contract with us for the use of the services provided on the Panel Platform by signing the contract on behalf of their company or public law body. Our services are often used in particular by the legal departments of companies, so we will also use this term within this Privacy Policy.

Browser: refers to the programmes used to access the Internet (e.g. Safari, Chrome, Firefox, etc.).

Cookie: is a small text sent to your Browser from our site (hosting the Panel Platform) by our Partners. It allows the site to store information such as the fact that you have visited the site, your language and other information. Cookies are used for various purposes, such as to record your preferences regarding the use of Cookies (Technical Cookies), to analyse and improve our services and to create new services and features or to personalise our services, including content that may be useful to you. The information transmitted by Cookies is subject to combination and/or cross-referencing with one of the Other Tracking Technologies, where applicable.

Personal Data: any information relating to an identified or identifiable natural person, directly or indirectly, as well as any information related or reasonably linkable to a particular individual or household. For example, an email address (if it relates to one or more aspects of an individual), IP Addresses and Unique Identifiers are considered Personal Data. Hereinafter, for convenience, the Personal Data referred to in this Privacy Policy will be referred to simply as "Data".

Device: refers to the electronic device (e.g. iPhone) through which you visit the Panel Platform.

Unique Identifiers: information that can uniquely identify the user through the Browser, the Device. In the Browser, the IP Address and Cookies are considered Unique Identifiers. On the Device, advertising identifiers provided by manufacturers, such as Apple's IDFA and Android's AAIG, that we use to analyse and improve our services and to create new services and features are considered Unique Identifiers. Please note that for these purposes and in line with the views of European regulators, we do not use other unique identifiers such as MAC addresses and IMEIs as they are not resettable by the user.

IP address: is a unique number used by the Browser, the Device to connect to the Internet. The Internet service provider provides this number to identify the provider and/or the approximate area where the user is located. Without this Data, you cannot connect to the Internet and use our services or content that may be useful to you.

Social Pages of 4c: indicates the social network pages used by 4c, and in particular those indicated at the following addresses: Instagram, Facebook, LinkedIn, Twitter.

Partner: this definition includes selected Partners with whom we may share your Data. Partners may belong to the following sectors: legal professionals; professors and other professionals who collaborate as speakers at 4c events and whose identity will be disclosed at individual events; companies, institutions and other entities that participate in the organisation of a 4c event and whose identity will be disclosed at individual events; information and communication services; professional and consulting activities; business support services; other third parties whose identity will be disclosed on a case-by-case basis.

Data Processor: refers to an entity appointed by us to process your Personal Data solely on behalf of 4c S.r.l. and in accordance with your written instructions.

Site: includes this Site (www.4clegal.com) where this Privacy Policy is located.

Data Controller or Controller: refers to the legal person, public authority, service or other entity that, individually or jointly, determines the purposes and means for the processing of your Personal Data. This definition typically refers to 4c S.r.l.. In other cases, it is preceded by the word "autonomous" (e.g., "autonomous data controller" or "autonomous data controller") to indicate that your Personal Data is processed by an entity other than 4c S.r.l.