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Privacy Privacy

Tarquinio Giribaldi s.r.l. (hereinafter also referred to as “Tarquinio Giribaldi”, “TG”, “we”, “us” or“our”) is a leading global professional services firm providing a broad range of fiscal, customs, maritime and port services for the maritime and transportation industry, building and property sector, customs, accounting and fiscal divisions.Tarquinio Giribaldi is committed to protecting your privacy. This commitment reflects the value we place on earning and keeping the trust of our customers, suppliers, employers, business partners and others who share their personal information with us.


What does this privacy statement do?

This Privacy Statement (“Statement”) explains Tarquinio Giribaldi’s information processing practices. It applies to any personal information you provide to Tarquinio Giribaldi and any personalinformation we collect from other sources. This Statement is a statement of our practices and ofyour rights regarding your personal information. This is not a contractual document, and it does not create any rights or obligations on either party, beyond those which already exist under dataprotection laws.This Statement does not apply to your use of a third party site linked to on this website.


Who is responsible for your information?

Throughout this Statement, “Tarquinio Giribaldi” refers to Tarquinio Giribaldi s.r.l., including its parent, affiliated and subsidiary companies (also referred to as “we”, “us”, or “our”). The Tarquinio Giribaldi entity responsible for your personal information (and the controller for the purposes of data protection laws) will be the member of Tarquinio Giribaldi that originally collects information from or about you. This may also be explained in separate privacy notices made available when your personal information are first collected by that Tarquinio Giribaldi entity, for example where you orthe business you work for engages us to provide a service.Some of the services which Tarquinio Giribaldi provides to its clients are provided as a processor, which means that the Client remains primarily responsible for your information. In these circumstances, we may re-direct a query about our use of your information to our client.


Quick read:

Tarquinio Giribaldi collects personal information from or about its clients to provide a broadrange of services and professional advice and in the industries and branches of the market where Tarquinio Giribaldi operates, including the contractual, pre-contractual, commercial, logistics,technical and consulting activities. Tarquinio Giribaldi also collects some personal informationdirectly, for example over its websites and applications. Tarquinio Giribaldi uses personal information to deliver services to clients. For its own purposes,it also uses personal information to analyze and improve how it delivers those services, to contact representatives of its clients or prospective clients and to market to them. If Tarquinio Giribaldi uses your personal information, you will have certain important rights which you can exercise. The rights you will be able to exercise will depend on how and why Tarquinio Giribaldi uses your information.If you have any questions, would like further information about our privacy and information handling practices, would like to discuss opt-outs or withdrawing consent, or would like tomake a complaint about a breach of the Act or this Statement, please contact the Privacy Officer: Alternatively, you have the right to contact your local Data Protection Authority. If you have any questions relating to this Statement, please contact us at Tarquinio Giribaldi s.r.l., Via Scarincio n. 48 – 18100 Imperia (IM), Italy, VAT n. IT 00093360089. Email


When and how we collect your information?

Tarquinio Giribaldi collects personal information in the following ways: • When we perform services for our clients.
• When we perform consulting or give professional advices.
• When you request a service from us.
• When you register with or use any of our websites or applications.
• When you attend a Tarquinio Giribaldi site or event.
• When you apply for a position at Tarquinio Giribaldi.
• If you contact us with a complaint or query.
• When you engage with us over social media.


What information do we collect?

Information you provide to us For purposes of this Statement, “website” includes our mobile applications. When you request services, we ask that you provide accurate and necessary information that enables us to respond to your request. When a visitor provides personal information to us, we use it for the purposes for which it was provided to us as stated at the point of collection or as obvious from the context of collection, for example providing a quote for services to perform, applying for aposition at Tarquinio Giribaldi or creating a profile on a website or application.


1. Information we collect from clients or third parties

By way of example and without any limitation you can voluntarily provide your personal information to us through the fulfillments of digital and papers forms to request for and avail of certain kind of specific services or by voluntarily sending an email to the email addresses listed onto our websitesor mobile applications.The kind of information collected through the forms are necessary to allow you to request andaccess the services available on our websites and we will not use it for any other purposes. Some ofthe information requested by the forms are mandatory (required fields) as necessary for TarquinioGiribaldi to complete the service required by you. You are always able to recognize the mandatory information required as the relevant field is marked with a [*] (or any other highly-distinctiveidentification symbol).When we provide the services listed above for our clients, we may collect personal informationsuch as but with no limitation to your name, contact details, email address, telephone number,date of birth, job, position, gender, marital status, bank and financial details, credit card details, identification document number and validity, driver’s license number and validity, VAT number,fiscal code, nationality and spoken languages. We may also collect (in each case as strictly relevantto the services we provide) sensitive information about you, such as criminal convictions or healthinformation in relation to life, health and professional liability. Most of the personal information we receive relates to your specific need to obtain a special service from us. More information about the personal information collected for each of our services, together with the purpose and legal basis for collecting the information, will be provided to you in separate privacy notices which are relevant to the services which affect you. Tarquinio Giribaldi could request you to provide your preferences of contact about the possible sending of newsletter, as per required by you.We will not collect any sensitive information through our website unless this is required. Sensitive information includes a number of types of data relating to: race or ethnic origin; political opinions;religious or other similar beliefs; trade union membership; physical or mental health; sexual life or criminal record. We suggest that you do not provide sensitive information of this nature unless we specifically request this information. If you provide us with sensitive personal information, you understand and give your explicit consentthat we may collect, use and disclose this information to appropriate third parties for the purposesdescribed in this Statement. If you provide personal information about other individuals such as employees or dependents, you must obtain their consent prior to your disclosure to us.


2. Information we collect from clients or third parties

We may ask you for some or all of the following types of information when you register for events,request products or services, manage accounts, access various content and features or directly visitour websites. This includes, but is not limited to:• Contact information, such as name, e-mail address, postal address, phone number and mobilenumber;• User name, password, password reminder questions and password answers;• Communication preferences, such as which newsletters you would like to receive;• Search queries;• Contact information about others when you refer a friend to a particular site or service (note: thisinformation is used solely to facilitate requested communications); and• Information posted in community discussions and other interactive online features.In some instances, we automatically collect certain types of information when you visit our websitesand through e-mails that we may exchange. Automated technologies may include the use of webserver logs to collect IP addresses, “cookies” and web beacons. Further information about our use ofcookies can be found in our Cookie Notice.


3. Social media

You can engage with us through social media websites or through features such as plug-ins orapplications on Tarquinio Giribaldi or Mansueto Group websites that integrate with social mediasites. You may also choose to link your account with us to third party social media sites. Whenyou link your account or engage with us on or through third party social media sites, plug-ins, orapplications, you may allow us to have ongoing access to certain information from your social mediaaccount (e.g., name, e-mail address, photo, gender, birthday, the posts or the ‘likes’ you make).If you post information when you interact with our websites through social media sites, plug-ins orother applications, depending on your privacy settings, this information may become public on theInternet. You can control what information you share through privacy settings available on somesocial media sites. For more information about how you can customize your privacy settings andhow third party social media sites handle your personally identifiable information, please refer totheir privacy help guides, privacy notices and terms of use.


4. Mobile devices

If you access our websites on your mobile telephone or mobile device, we may also collect yourunique device identifier and mobile device IP address, as well as information about your device’soperating system, mobile carrier and your location information. We may also ask you to consentto providing your mobile phone number (for example, so that we can send you push notifications).


How do we use your personal information?

The following is a summary of the purposes for which we use personal information. Moreinformation about the personal information collected for each of our services, together with thepurpose and legal basis for collecting the information, will be provided to you in separate privacy notices which are relevant to the services which affect you.


1. Perfoming services for our client

We process personal information which our clients provide to us or about them in order to provideservices and professional advice and in the industries and branches of the market where weoperate, including the contractual, pre-contractual, commercial, logistics, technical and consultingactivities. Tarquinio Giribaldi also collects some personal information directly, for example over itswebsites and applications. This may impact you, for example, where you are the employee of ourclient. The precise purposes for which your personal information is processed will be determined bythe scope and specification of our client engagement, and by applicable laws, regulatory guidanceand professional standards. It is the obligation of our client to ensure that you understand thatyour personal information will be disclosed to Tarquinio Giribaldi (or to service providers such asTarquinio Giribaldi).For the hereinbefore provided purposes only, your personal information could be shared with:• collaborators and employee of the companies under the Mansueto Group;• suppliers of goods and services available on our websites;• other companies of the Mansueto Group; and• partner network of Tarquinio Giribaldi and the Mansueto Group.Tarquinio Giribaldi also collects some personal information directly, for example over its websitesand applications.


2. Administering our client engagement

We process personal information about our clients and the individual representatives of ourcorporate clients in order to:• carry out “Know Your Client” checks and screening prior to starting a new engagement;• carry out client communication, service, billing and administration;• deal with client complaints;• administer claims.


3.Contacting and marketing our client and prospective clients

We process personal information about our clients and the individual representatives of ourcorporate clients in order to:• contact our clients in relation to current, future and proposed engagements;• send our clients newsletters, know-how, promotional material and other marketingcommunications;• invite our clients to events (and arrange and administer those events).


4. Conducting data analytits

Tarquinio Giribaldi is an innovative business, which relies on developing sophisticated productsand services by drawing on our experience from prior engagements. Tarquinio Giribaldi is notconcerned with an analysis of identifiable individuals, and we take steps to ensure that your rightsand the legitimacy of Tarquinio Giribaldi’s activities are ensured through the use of aggregated orotherwise de-identified data.


5. Legal basis

All processing (i.e. use) of your personal information is justified by a “lawful basis” for processing. Inthe majority of cases, processing will be justified on the basis that:• the processing is necessary for the performance of a contract to which you are a party, or totake steps (at your request) to enter into a contract, according to art. 6 co. 1 letter b) General DataProtection Regulation UE 2016/679, hereinafter also referred to as just “GDPR”.• the processing is in our legitimate commercial interests, subject to your interests and fundamentalrights (e.g. where we use personal information provided to us by our clients to deliver our productsand services, and that processing is not necessary in relation to a contract to which you are a party);or• the processing is necessary for us to comply with a relevant legal obligation (e.g. where we arerequired to collect certain information about our clients for tax or accounting purposes, or wherewe are required to make disclosures to courts or regulators) according to art. 6 co. 1 letter c) GDPR.In limited circumstances, we will use your consent as the basis for processing your personalinformation, for example, where we are required to obtain your prior consent in order to send youmarketing communications.Before collecting and/or using any special categories of data, or criminal record data, we will establish a lawful exemption which will allow us to use that information. This exemption will typically be:• your explicit consent;• the establishment, exercise or defense by us or third parties of legal claims; or• a context specific exemption provided for under local laws of EU Member States and othercountries implementing the GDPR, such as in relation to the processing of special category data forinsurance purposes, or for determining benefits under an occupational pension scheme.


Do we collect information from children? 

Our websites are not directed to children and we do not knowingly collect personal informationfrom children on our websites. Children are prohibited from using our websites. In the light ofthis and despite we do not provide any products or services directly to children, we could processchildren’s personal information only insofar as strictly necessary to provide the required goods andservices and solely if consciously agreed by the children’s parents and shared by them.


How long do we retain your personal information?

How long we retain your personal information depends on the purpose for which it was obtainedand its nature. We will keep your personal information for the period necessary to fulfill the purposesdescribed in this Statement unless a longer retention period is permitted by law, in accordance withthe Tarquinio Giribaldi policy of Record Retention.In specific circumstances we may store your personal information for longer periods of time so thatwe have an accurate record of your dealings with us in the event of any complaints or challenges,or if we reasonably believe there is a prospect of litigation relating to your personal information ordealings.


Do we disclose your personal information?

We may share your personal information with other Tarquinio Giribaldi and Mansueto entities,companies, brands, divisions, subsidiaries, partners, collaborators and employee of these entitiesunder or connected to the Mansueto Group, including suppliers of goods and services, to serve you,including for the activities listed above.We do not rent, sell or otherwise disclose personal information about our online visitors with unaffiliated third parties for their own marketing use. We do not share your personal informationwith third parties except in the following circumstances discussed below.

Business Partners

We disclose personal information to business partners who provide certain specialized services tous, or who co-operate with us on projects. These business partners operate as separate controllers,and are responsible for their own compliance with data protection laws. You should refer to theirprivacy notices for more information about their practices.Examples include:• Maritime and Port services – maritime and transport agencies, shipping companies, customsagencies, ports and port offices, tourist and travel agencies, shore services agencies, fiscalrepresentatives and tax agents, real estate agencies and agents;• Fuel and Energy Products trading – refineries, fuel and energy products producers, producersand suppliers of lube oils and greases, bunker companies, bunker traders and brokers, providers ofbunker services, carriers and forwarders, ports and port offices, maritime agencies, service agencies.• Catering Services, Entertainments and Setting Up – catering companies ashore and on-board,banqueting and foodservice agencies, marine and naval agencies, wedding planners, flowercompanies and florists, location setting-up trades, entertainers, musicians and singers, transportcompanies, forwarders and carriers.


Authorised Services Providers

We may disclose your information to service providers we have retained (as processors) to performservices on our behalf (either in relation to services performed for our clients, or information whichTarquinio Giribaldi uses for its own purposes, such as marketing). These service providers arecontractually restricted from using or disclosing the information except as necessary to performservices on our behalf or to comply with legal requirements. These activities could include any of theprocessing activities that we carry out as described in the above section, ‘How we use your personalinformation.’Examples include:• IT service providers who manage our IT and back office systems and telecommunicationsnetworks;• marketing automation providers;• contact center providers.These third parties appropriately safeguard your data, and their activities are limited to the purposesfor which your data was provided.


Legal requirements and Business Transfers

We may disclose personal information (i) if we are required to do so by law, legal process, statute,rule, regulation, or professional standard, or to respond to a subpoena, search warrant, or other legalrequest. (ii) in response to law enforcement authority or other government official requests, (iii)when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss,(iv) in connection with an investigation of suspected or actual illegal activity or (v) in the event thatTarquinio Giribaldi is subject to a merger or acquisition to the new owner of the business. Disclosuremay also be required for company audits or to investigate a complaint or security threat.


Do we transfer your personal information across geographies?

We are an organization which operates globally and may transfer certain personal information across geographical borders to Tarquinio Giribaldi and Mansueto Group entities, authorized service providers or business partners in other countries working on our behalf in accordance with applicable law. Our affiliates and third parties may be based locally or they may be overseas someof which have not been determined by the European Commission to have an adequate level of dataprotection.When we do, we use a variety of legal mechanisms to help ensure your rights and protections travelwith your data:• we ensure transfers within Tarquinio Giribaldi are covered by agreements based on the EUCommission’s standard contractual clauses, which contractually oblige each member to ensure thatpersonal information receives an adequate and consistent level of protection wherever it resideswithin Tarquinio Giribaldi;• where we transfer your personal information outside Tarquinio Giribaldi or to third parties whohelp provide our products and services, we obtain contractual commitments from them to protectyour personal information. Some of these assurances are well recognized certification schemes likethe EU – US Privacy Shield for the protection of personal information transferred from within the EUto the United States, or the standard contractual clauses; or• where we receive requests for information from law enforcement or regulators, we carefullyvalidate these requests before any personal information are disclosed.Examples of countries we transfer personal information to include, but are not limited to, the UnitedStates of America, the United Kingdom, France, Spain, Germany, The Netherlands, Greece, Croatia,Singapore, Maldives, Seychelles.If you would like further information about whether your information will be disclosed to overseasrecipients, please contact us as noted below. You also have a right to contact us for more informationabout the safeguards we have put in place (including a copy of relevant contractual commitments,which may be redacted for reasons of commercial confidentiality) to ensure the adequate protectionof your personal information when this is transferred as mentioned above.


Do we have security measures in place to protect your personal information?

The security of your personal information is important to us and Tarquinio Giribaldi has implementedreasonable physical, technical and administrative security standards to protect personalinformation from loss, misuse, alteration or destruction. We protect your personal informationagainst unauthorized access, use or disclosure, using security technologies and procedures, such asencryption and limited access. Only authorized individuals access your personal information, andthey receive training about the importance of protecting personal information.Our service providers and agents are contractually bound to maintain the confidentiality of personalinformation and may not use the information for any unauthorized purpose.


What chances do you have about your personal information?

We offer certain choices about how we communicate with our customers and what personalinformation we obtain about them and share with others. When you provide us with personaldetails, if we intend to use those details for marketing purposes, we will provide you with the optionof whether you wish to receive promotional e-mail, SMS messages, telephone calls and postalmail from us. At any time, you may opt out from receiving interest-based advertising from us bycontacting us as per listed under the “Contact” paragraph below.You may also choose not to receive marketing communications from us by clicking on theunsubscribe link or other instructions in our marketing e-mails, visiting the “Account” section onour website, or contacting us as noted below in the “Contact” paragraph.


How can you update your communication preferences?

We take reasonable steps to provide you with communication about your information. You can update your communication preferences in the following ways.


If you have created a profile or account on one of our websites, you can update your contact information after you log into your account.


If you request electronic communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in the communication.

Mobile Devices

If you previously chose to receive push notifications on your mobile device from us but no longerwish to receive them, you can manage your preferences either through your device or the applicationsettings. If you no longer wish to have any information collected by the mobile application, you may uninstall the application by using the uninstall process available on your mobile device.


Contact us by e-mail or postal address as noted below. Please include your current contactinformation, the information you are interested in accessing and your requested changes.If we do not provide you with access, we will provide you with the reason for refusal and inform you of any exceptions relied upon.


Other rights regarding your data

According to GDPR, subject to certain exemptions, and in some cases dependent upon the processingactivity we are undertaking, you have certain rights in relation to your personal information.We may ask you for additional information to confirm your identity and for security purposes,before disclosing the personal information requested to you. We reserve the right to charge a feewhere permitted by law, for instance if your request is manifestly unfounded or excessive.You can exercise your rights by contacting us. Subject to legal and other permissible considerations,we will make every reasonable effort to honor your request promptly or inform you if we requirefurther information in order to fulfill your request.We may not always be able to fully address your request, for example if it would impact the duty ofconfidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

Right to Access (art. 15 GDPR)

You have right to access personal information which Tarquinio Giribaldi holds about you. If youhave created a profile, you can access that information by visiting your account. Alternatively youcan access to your personal “ftp” account created by us on purpose.

Right to Rectification (art.16 GDPR)

You have a right to request us to correct your personal information where it is inaccurate or out ofdate.

Right to be Forgotten (Right to Erasure) (art. 17 GDPR)

You have the right under certain circumstances to have your personal information erased. Yourinformation can only be erased if your data is no longer necessary for the purpose for which it wascollected, and we have no other legal ground for processing the data.

Right to Restrict Processing (art. 18 GDPR)

You have the right to restrict the processing of your personal information, but only where:• its accuracy is contested, to allow us to verify its accuracy; or• the processing is unlawful, but you do not want it erased; or• it is no longer needed for the purposes for which it was collected, but you still need it to establish,exercise or defend legal claims; or• you have exercised the right to object, and verification of overriding grounds is pending.

Right to Data Portability (art. 20 GDPR)

You have the right to data portability, which requires us to provide personal information to you oranother controller in a commonly used, machine readable format, but only where the processingof that information is based on (i) consent; or (ii) the performance of a contract to which you area party.

Right to Object to Processing (art. 21 GDPR)

You have the right to object the processing of your personal information at any time, but only wherethat processing is has our legitimate interests as its legal basis. If you raise an objection, we havean opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.


Contact us

If you have any questions, would like further information about our privacy and informationhandling practices, would like to discuss opt-outs or withdrawing consent, or would like to make acomplaint about a breach of the Act or this Statement, please email us to orthe following postal address: Tarquinio Giribaldi s.r.l., Via Scarincio n. 48 – 18100 Imperia (IM), Italy.Alternatively, you have the right to contact your local Data Protection Authority.


Changes to this statement

We may update this Statement, from time to time, according the current laws and regulations inforce. When we do, we will post the current version on our websites, and we will revise the versiondate located at the bottom of this page.We encourage you to periodically review this Statement so that you will be aware of our privacypractices.



In case of disparity between the Italian and the English version of the Statement, the Italian version shall prevail, inasmuch as the English version is a mere transltion.



This Statement was last updated on May 25th, 2018.


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