Privacy Notice

(A) This Notice

This Privacy Notice on the Processing of Personal Data (“Notice”) is provided by the association under Italian law called Pro Bono Italia ("Pro Bono Italia" and/or the "Association"), and is addressed to external parties from Pro Bono Italia with whom it interacts, including, without limitation, registered users of the Pro Bono Italia Platform, visitors to the Website, Associated Lawyers and Lawyer Candidates, Beneficiaries and their representatives, and representatives of Clearinghouses (collectively, the "Users").

Pro Bono Italia offers, not directly but through the activity of its members, pro bono legal assistance to non-governmental organizations that pursue objectives of social benefit and disadvantaged individuals or whose case is particularly worthy of support. In particular, the Pro Bono Italia Platform offers a technological solution that facilitates the intermediation of relationships between Lawyers and Clearinghouses in order to match requests for pro bono legal assistance with lawyers available to offer it, and allows for a faster and more efficient management of the Beneficiaries' requests for assistance.

Capitalized terms in the present Notice shall have the meanings attributed to them in Section (S).

For the purposes of this Notice, Pro Bono Italia is the Data Controller, with registered office in Milan (MI), Via Gabrio Serbelloni n. 4.

The contact details of the Data Controller are shown in Section (R) of the present Notice.

Please note that this Notice does not apply to Pro Bono Italia's Processing activity of the personal data of its Personnel, employees, consultants, or other personnel in connection with their duties within Pro Bono Italia.

This Notice is regularly reviewed and updated to reflect changes in Pro Bono Italia's practices regarding the Processing of Personal Data, or changes in applicable law. Users are encouraged to read this Notice carefully and periodically visit this page to review any changes that the Association may make to the Notice in accordance with its terms. Pro Bono Italia will notify Users of any significant changes to this Notice.

When Processing the User's Personal Data, Pro Bono Italia is committed to guaranteeing the compliance with the provisions of the national and European legislation on the protection of personal data and in particular of Article 32 of the GDPR, taking measures adequate to the risk that the Processing may pose on the rights and freedoms of individuals (where appropriate following an impact assessment of the Processing itself). These measures are revised whenever Pro Bono Italia deems it necessary or appropriate (for example, when new technological solutions are introduced).

(B) Collection of Personal Data

Collection of Personal Data: Pro Bono Italia collects or obtains Users’ Personal Data in the following ways:

• Personal Data provided by Users to Pro Bono: Pro Bono Italia may collect the User's Personal Data when the User provides them (for example, when the User registers on the Pro Bono Italia Platform or interacts with it, or when the User contacts Pro Bono Italia by e-mail or phone, or by any other means; or when the User provides a Pro Bono Italia representative with a business card or submits a job application to Pro Bono Italia).
• Personal Data collected in the ordinary course of business between Pro bono Italia and the User: Pro Bono Italia may collect the User's Personal Data in the ordinary course of its relationship with the User (for example, by organizing periodical meetings - which may be called "Round Tables" - in order to encourage discussion among Associated Lawyers, Beneficiaries and other natural or legal persons interested in the development and diffusion of Pro Bono's activity).
• Data expressly made public by the User: Pro Bono Italia may collect the User's Personal Data that the User expressly chooses to make public, including through social media (e.g., it may collect information from the User's profile(s) on social media, to the extent the User has chosen to publish a post on Pro Bono Italia).
• Data collected as a result of the User’s use of the Website or the Platform: Pro Bono Italia may collect the User's Personal Data when the User visits the Website or the Pro Bono Italia Platform; or uses one of the features or resources available on the Website (for example, the "Contact Form" available in the CONTACT);
• Data collected as a part of the interactions between the User and third parties: Pro Bono Italia may receive the User's Personal Data if the User interacts with the content or advertisements of third parties on the Website or on the Pro Bono Italia Platform (third party plug-ins and cookies).

(C) Creation of Personal Data

Pro Bono Italia may also create Personal Data in connection with the User in certain circumstances, such as in the event of recording the User's interactions with it.

(D) Categories of Personal Data

The categories of Users’ Personal Data that Pro Bono Italia can Process include:

• Personal data: surname; name; picture; gender; date of birth/age; nationality; marital status; and languages.
• Contact details: correspondence address; telephone number; e-mail address; contact details of electronic messaging applications; social media profile data.
• Consent: records of any consent that has been given by the User, together with the date and time, the manner in which the consent was given and any other information relating to the same (for example, the subject on which the consent was given).
• Employment: dates and details of current and former positions held; details of current and former employers; details of the law firm and/or bar association of Associated Lawyers or Lawyer Candidates who are or wish to become members; professional qualifications, titles, and job titles; work locations; work experience; areas of specialization of Associated Lawyers or Lawyer Candidates.
• Data obtained by consulting the Website or the Pro Bono Italia Platform: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connection to the Website or the Pro Bono Italia Platform; user name; password; access identifiers; usage data; aggregate statistical information.
• Reviews and opinions: any review or opinion that the User chooses to send to Pro Bono Italia or to publish through a post concerning Pro Bono Italia on social media.

(E) Sensitive Personal Data

Pro Bono Italia tries not to collect or otherwise Process the User's Sensitive Personal Data in the ordinary course of its relationship with the User. Where it is necessary to Process Sensitive Personal Data for any reason, Pro Bono Italia carries out its activities under one of the following legal bases:

• Accordance with the law: the Processing is required or permitted by the law (e.g., to meet the reporting requirements of Pro Bono Italy);
• Reporting and prevention of crimes: Processing is necessary for the reporting or prevention of crimes;
• Establishment, exercise or protection of legal claims: Processing is necessary for the establishment, exercise or protection of legal claims; or
• Consent: Pro Bono Italia has obtained, in accordance with current legislation, explicit consent prior to the Processing of the User's Sensitive Personal Data (as indicated above, this legal basis can only be used in the case of purely voluntary Processing - it cannot be used in any way in case of necessary or mandatory Processing).

If the User provides Sensitive Personal Data to Pro Bono Italia, the User is required to ensure that it is lawful for him to disclose such Sensitive Personal Data to Pro Bono Italia, as well as to ensure that a valid legal basis for the Processing of such Sensitive Personal Data applies.

(F) Purposes for which Pro Bono Italia may Process Users’ Personal Data

Pro Bono Italia Processes the Users Personal Data, in compliance with current legislation, for the following purposes:

Processing activity	Legal basis for Processing
Performance Pro Bono Italia activities (e.g., organizing periodic meetings, which may be called “Round Tables”, in order to encourage the discussion among Associated Lawyers, Beneficiaries and other natural or legal persons interested in the development and diffusion of Pro Bono activities; maintaining relationships with Clearinghouses and NGOs): managing and operating activities of the Website and the Pro Bono Italia Platform; providing content to the User; advertisements; communication and interaction with the User through the Website, or the Pro Bono Italia Platform.	The Processing is required on the basis of any contract stipulated with Pro Bono Italia or in order to enter into a contract with Pro Bono Italia; Pro Bono Italia has a legitimate interest in carrying out the Processing in order to manage the Website or the Pro Bono Italia Platform or to provide other services to the User (to the extent that such legitimate purpose does not conflict with the interests, fundamental rights or freedoms of the User); or Pro Bono Italia has obtained the User's prior consent to the Processing (this legal basis can be used only in case of purely voluntary Processing - it cannot be used in any way in case of necessary or mandatory Processing)
Management of the Pro Bono Italia Platform: management activities of the technological platform that allows: the organization, sharing, and filing of legal assistance requests transmitted by Clearinghouses on behalf of Beneficiaries; intermediating relationships between Lawyers and Clearinghouses in order to match pro bono requests for legal assistance with Lawyers available to offer it; collection and profiling of information on the specialization of Lawyers, Associated Lawyers and Lawyer Candidates; collection and archiving of anonymized legal work products provided spontaneously by the Associated Lawyers, in order to disseminate and make the pro bono legal assistance faster and more efficient, in which however the Associated Lawyer has removed any confidential details of the subject matter of the legal assistance provided; collection of aggregated data related to the legal assistance provided, Processed for statistical purposes, in order to ensure a more targeted and effective free legal assistance service.	Pro Bono Italia has a legitimate interest in carrying out the Processing for the purpose of managing the Pro Bono Italia Platform (insofar as such legitimate purpose does not conflict with the interests, fundamental rights or freedoms of the User); or Pro Bono Italia has obtained the User's prior consent to the Processing (this legal basis can be used only in the case of purely voluntary Processing - it cannot be used in any way in case of necessary or mandatory Processing).
Communications and Marketing: communicating with Users by any means (including, but not limited to, email, telephone, text message, social media postings, or in person) to provide Users with news or other information in which Users may be interested, subject to prior opt-in consent where required by applicable law; maintaining and updating contact information where appropriate; obtaining Users prior opt-in consent where required; and allowing and recording User opt-out or unsubscribe choice, where applicable.	Pro Bono Italia has a legitimate interest in carrying out the Processing for the purpose of communicating with the User, in compliance with the applicable law (insofar as such legitimate purpose does not conflict with the interests, fundamental rights or freedoms of the User); or Pro Bono Italia has obtained the User's prior consent to the Processing (this legal basis can be used only in the case of purely voluntary Processing - it cannot be used in any way in case of necessary or mandatory Processing).
IT system management: management and operation of communications, IT systems, security and audits (including, security audits) and monitoring of these systems.	Processing is required to be in compliance with applicable law; or Pro Bono Italia has a legitimate interest in carrying out the Processing for the purpose of managing and maintaining the communication, security and IT systems of the Association (to the extent that such legitimate interest overrides the interests, fundamental rights or freedoms of the User).
Surveys: interacting with the Users in order to obtain their opinion on the Website, on the Pro Bono Italia Platform, or on the activities carried out by Pro Bono Italia.	Pro Bono Italia has a legitimate interest in carrying out the Processing for the purpose of conducting surveys, satisfaction reports, and market researches (to the extent that such legitimate purpose does not conflict with the interests, fundamental rights or freedoms of the User); or Pro Bono Italia has obtained the User's prior consent to the Processing (this legal basis can be used only in the case of purely voluntary Processing - it cannot be used in any way in case of necessary or mandatory Processing).
Investigations: identifying, investigating and preventing policy violations and crimes in accordance with applicable law.	The Processing is necessary to comply with a legal obligation; or Pro Bono Italia has a legitimate interest in carrying out the Processing for the purpose of identifying and protecting the Company, the User and third parties from violations of the law (to the extent that such legitimate purpose does not conflict with the interests, fundamental rights or freedoms of the User)
Compliance with Applicable Law: Compliance with legal and regulatory obligations under applicable law.	The Processing is necessary to comply with a legal obligation.
Establishment, exercise, or protection of rights under the law: handling legal claims; establishing facts and claims, including gathering, reviewing, and submitting documents, facts, evidence, and witness statements; exercising and defending legal rights and claims, including proceedings before the appropriate judicial authorities.	The Processing is necessary to comply with a legal obligation. Pro Bono Italia has a legitimate interest in carrying out the Processing for the purpose of establishing, exercising or defending rights under the law (to the extent that such legitimate interest overrides the interests, fundamental rights or freedoms of the User). The Processing is required for the establishment, exercise, or protection of rights under the law.
Improvement of the Website and the Pro Bono Italia Platform: identifying problems related to the Website or Pro Bono Italia Platform; planning improvements to the Website, Pro Bono Platform services; and creation of a new Website or new activities.	Pro Bono Italia has a legitimate interest in carrying out the Processing in order to improve the Website, the Pro Bono Italia Platform or the activities carried out by Pro Bono Italia (to the extent that such legitimate purpose does not conflict with the interests, fundamental rights, or freedoms of the User).
Reviewing and responding to requests for admission of Lawyer Candidates to be members of the Association and to register on the Pro Bono Italia Platform: analysis of the suitability of the admission; collection of the Lawyer Candidate’s data and documents (i.e., ID card number and membership number with the respective bar association) records of admission decisions; and details regarding acceptance.	Pro Bono Italia has a legitimate interest in the Processing for the purpose of carrying out the candidacy evaluation activities (insofar as such legitimate purpose does not conflict with the interests, fundamental rights or freedoms of the User). Pro Bono Italia has obtained the User's prior consent to the Processing (this legal basis can be used only in case of purely voluntary Processing - it cannot be used in any way in case of required or mandatory Processing)

(G) Profiling

Associated Lawyers’ Personal Data may be subject to Profiling activities based on their respective areas of specialization, in order to facilitate the effective allocation of Beneficiaries' pro bono legal assistance requests.

Profiling	Purpose of Profiling activities	Consequences for the User
Creation of profiles of Associated Lawyers registered on the Pro Bono Italia Platform according to their area of specialization (e.g. civil law, criminal law, family law, commercial law).	Facilitate the efficient allocation of pro bono requests for legal assistance through the Pro Bono Italia Platform, based on the areas of specialization of Associated Lawyers.	This Profiling activity allows Clearinghouses to identify Associated Lawyers who are specialized in the areas of law relevant to the specific pro bono legal assistance request. Associated Lawyers may choose to be informed exclusively about the upload on the Pro Bono Italia Platform of pro bono assistance requests pertaining to their specified areas of specialization.

(H) Disclosure of Personal Data to Third Parties

Pro Bono Italia may disclose the User's Personal Data by providing them, for legitimate purposes related to its activity and in order to guarantee the functioning of the Website and of the Pro Bono Italia Platform, in compliance with the applicable law, to the following subjects:

• the User and, where appropriate, representatives designated by the User;
• auditors, lawyers and other consultants external to Pro Bono Italia who are subject to binding contractual confidentiality obligations;
• suppliers of IT and data processing services;
• third party Data Processors, located anywhere in the world, subject to the requirements set out in this Section (H) below;
• public authorities, if and to the extent that this is required by law or by an administrative measure, or for the exercise, verification and/or defense of a right in a court of law;
• judicial and regulatory authorities, upon request or in order to report any actual or suspected violation of the laws and regulations in force;
• any interested party, judicial and regulatory authorities, to the extent that it is needed for the establishment, exercise or protection of rights recognized by law;
• any interested party for the purposes of prevention, investigation, detection and prosecution of criminal offences or the execution of criminal sanctions, including the protection and prevention of threats to public safety;
• any relevant third party purchaser(s), in the event of a sale or transfer of all or part of the business or assets of Pro Bono Italia (including in the event of reorganization, dissolution or liquidation);
• suppliers of services related to marketing and advertising, such as social networks, advertising agencies or advertising partners; and
• any other relevant third party provider, where the Website or the Pro Bono Italia Platform use third party advertising, plug-ins and content. If the User chooses to interact with such advertising, plug-ins or content, the User's Personal Data may be shared with the relevant third-party provider. Pro Bono Italia recommends that the User review the third party's privacy policy before interacting with its advertisements, plug-ins or content.

In the event that Pro Bono Italia appoints a third party Processor to Process the User's Personal Data, the Processor will be subject to binding contractual obligations to (i) Process the Personal Data in accordance with prior instructions given in writing by Pro Bono Italia; and (ii) put in place measures respecting the protection of the confidentiality and security of the Personal Data.

(I) International Transfer of Personal Data

To the extent that it is necessary for the fulfillment of the purposes set forth in this Notice, Pro Bono Italia may transfer Users’ Personal Data to third parties located in countries outside the European Economic Area (EEA). If Pro Bono Italia transfers User Personal Data to countries outside the EEA, other than to Adequate Jurisdictions, it will do so with appropriate or suitable safeguards, based on Standard Contractual Clauses.

(J) Data Protection

Pro Bono Italia has implemented appropriate technical and organizational security measures to protect the User's Personal Data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unauthorized or unlawful forms of Processing, in accordance with applicable law.

Since the Internet is an open system, the transmission of information via the Internet is not completely secure. Although Pro Bono Italia implements all possible measures to protect the User's Personal Data, Pro Bono Italia cannot guarantee the security of the data transmitted to it over the Internet. The User assumes the risk and is responsible for ensuring that all Personal Data is sent securely.

(K) Data Accuracy

Pro Bono Italia shall take reasonable steps to ensure that:

• Users’ Personal Data is accurate and, where necessary, up-to-date; and
• In the event that any Personal Data Processed by Pro Bono Italia is inaccurate (in relation to the purposes for which it is Processed), it shall be deleted or rectified without delay.

From time to time, Pro Bono Italia may ask Users to confirm the accuracy of their Personal Data.

(L) Data Minimization

Pro Bono Italia takes appropriate measures to ensure that the Personal Data Processed is limited to that reasonably required in relation to the purposes set out in this Notice.

(M) Data Retention

Pro Bono Italia takes appropriate measures to ensure that Users’ Personal Data is only kept for as long as is necessary in relation to the purposes set out in this Notice. The criteria for determining the duration of the retention of Users’ Personal Data are as follows:

Pro Bono Italia retains Users’ Personal Data in a form that allows it to be identified only for as long as is necessary in connection with the purposes set forth in this Notice, unless applicable law permits or requires a longer retention period.

The criteria for determining the duration Users’ Personal Data is retained is as follows:

• Pro Bono Italia retains Personal Data for as long as:
  • Pro Bono Italia maintains a relationship with the User (e.g., the User uses Pro Bono Italia's services, or Pro Bono Italia legitimately includes the User in its mailing list, from which the User has not asked to be unsubscribed); or
  • The User's Personal Data is necessary in connection with the legitimate purposes set out in this Notice, which are based on a valid legal basis (e.g. Pro Bono Italia has a legitimate interest in Processing that data in order to perform its activity and fulfil its contractual obligations; or Pro Bono Italia has a legal obligation to retain the User's Personal Data).
• Plus
  (2) the duration of:
  • the applicable statute of limitations period (i.e., the period of time within which legal action may be brought against Pro Bono Italia with respect to Users’ Personal Data); and
  • an additional period of two (2) months from the end of the statute of limitations period (so that if a person brings an action at the end of the statute of limitations period, Pro Bono Italia has a reasonable period of time during which to identify any Personal Data that is relevant to the dispute).
• and
  (3) in addition, if legal action is brought against Pro Bono Italia, Pro Bono Italia will continue to Process Personal Data for this additional period where necessary in relation to the dispute.

During the periods set forth in paragraphs (2)(a) and (2)(b) above, Pro Bono Italia will limit the Processing of the User's Personal Data to the storage and safekeeping of such data, unless it is necessary to review such data in connection with any dispute or obligation under applicable law.

Once the periods referred to in paragraphs (1), (2) and (3) above are over, Pro Bono Italia may delete, permanently destroy or anonymize the Personal Data in question.

(N) User Rights

Under applicable law, the User has a number of rights relevant to the Processing of Personal Data, among which:

• the right to request access to or a copy of the Personal Data Processed or controlled by Pro Bono Italia;
• the right to request rectification of any inaccuracies in the User’s Personal Data;
• the right to request, for legitimate reasons:
  • the deletion of the User’s Personal Data Processed or controlled by Pro Bono Italia; or
  • the restriction of the Processing of the User’s Personal Data Processed or controlled by Pro Bono Italia;
• the right to object, on legitimate grounds, to the Processing of the User’s Personal Data;
• the right to have the User’s Personal Data transferred to another Data Controller, insofar as this is possible;
• where Personal Data is Processed on the basis of the User’s consent, the right to withdraw such consent; and
• the right to file complaints about the Processing of the User’s Personal Data with a Data Protection Authority.

To exercise one or more of these rights, or to make inquiries about these rights or any other provision of this Notice, or about the Processing of Personal Data, please use the contact details provided in Section (R) below. Please note that:

• in some cases Users will need to provide proof of identity before those rights can be exercised; and
• where the request requires the establishment of additional facts (e.g., whether the Processing is in violation of applicable law), Pro Bono Italia will review the request reasonably promptly before deciding what action to take.

(O) Cookies and similar technology

When the User visits the Pro Bono Italia Website or Platform, Pro Bono Italia generally places Cookies on the User's device or displays Cookies already present on the User's device, provided that Pro Bono Italia obtains the User's consent, where required, in accordance with applicable law. Pro Bono Italia uses Cookies to record information regarding the User's device, browser and, in some cases, browsing preferences and habits. Pro Bono Italia Processes the User's Personal Data through Cookies and similar technologies in accordance with the Cookie Policy.

(P) Terms of Use

The use of the Website and of the Pro Bono Italia Platform is regulated by the Terms of Use. Please read the Terms of Use carefully and periodically visit this page to review any changes that the Association may make to the Terms of Use. Pro Bono Italia will inform the Users of any significant changes to the Terms of Use.

(Q) Direct Marketing of Pro Bono Italia activities

Pro Bono Italia Processes Personal Data to contact the User via email, telephone, direct mail or other means of communication in order to provide him with information regarding the Website, the Pro Bono Italia Platform or activities that may be of interest to the User, subject to express consent, where required under applicable law.

The User can unsubscribe from the Pro Bono Italia mailing list at any time by simply clicking on the appropriate link included in each e-mail sent by Pro Bono Italia. After unsubscribing, Pro Bono Italia will not send further emails, but in some circumstances will continue to contact the User to the extent that is needed to carry out the activities requested by the User.

(R) Contact details of the Data Controller

Should you have any comments, concerns or questions regarding any of the information contained in this Notice or regarding any other matter relating to Pro Bono Italia's Processing of Personal Data, Pro Bono Italia may be contacted at the following address:

• Associazione Pro Bono Italia
• Secretary General
• Via G. Serbelloni, 4 – 20122 Milano.

Or via email at: privacy@probonoitalia.org

Alternatively, the User can contact Pro Bono Italia using the Contact Form found online on the Website.

(S) Definitions

• “Adequate Jurisdiction” means a jurisdiction that has been formally considered by the European Commission as capable of ensuring an adequate level of protection for Personal Data.
• “Associated Lawyers" means lawyers registered with the Italian Bar Association (Albo Nazionale Avvocati) and trainee lawyers registered with the Register of Trainees Qualified to Practice (Registro dei Praticanti Abilitati al Patrocinio) who have been admitted to the Association or whose registration with the Pro Bono Italia Platform has been approved, either individually or as part of a law firm or professional association, who share the aims pursued and the activities carried out by the Association and through the Pro Bono Italia Platform can express their willingness to provide assistance in relation to specific requests from Beneficiaries.
• “Beneficiaries" means non-profit organizations that pursue social assistance purposes, as well as individuals who cannot afford legal assistance or access to justice.
• “Clearinghouses" means the non-profit organizations that collect, integrate and select requests for pro bono legal assistance (coming not only from NGOs, but also from disadvantaged individuals) and assign them (also through the use of the Pro Bono Italia Platform) to the Lawyers who are willing to provide Pro Bono legal assistance in favor of the Beneficiaries.
• “Cookie" means a small file that is placed on the User's device when the User visits a website (including the Website). In this Notice, a reference to a "cookie" includes similar technologies such as web beacons and clear GIFs.
• “Data Controller” means the entity that decides how and why Personal Data is Processed. In many jurisdictions, the Data Controller has primary responsibility for compliance with privacy protection laws.
• “Data Processor” means any natural or legal person who Processes Personal Data on behalf of the Data Controller (other than employees of the Data Controller).
• “Data Protection Authority" means an independent public authority charged with overseeing compliance with privacy protection laws.
• “EEA” means the European Economic Area.
• “Lawyer Candidates" means Lawyers who, either individually or as part of a law firm or professional association, register on the Pro Bono Italia Platform in order to carry out pro bono legal assistance activities and whose application is pending final approval by Pro Bono Italia.
• “Personal Data” means information relating to any individual or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, identification number, location data, online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
• “Pro Bono Italia Platform” means the platform created and managed by Pro Bono Italia for the performance of the activity of collection, assignment and management of requests for legal assistance transmitted by individuals or organizations, through the Clearinghouses.
• “Processing”, “Process”, or “Processed” means anything that is done with any Personal Data, including by automated means, such as collecting, recording, organizing, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, dissemination or otherwise making available, aligning or combining, restricting, erasing or destroying.
• “Profiling” means any form of automated Processing of Personal Data consisting of the use of such Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning the personal preferences, interests, professional performance, economic situation, health, reliability, behavior, location or movements of said natural person.
• “Relevant Personal Data” means Personal Data with respect to which Pro Bono Italia is the Data Controller.
• “Sensitive Personal Data” means Personal Data relating to race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual orientation, actual or alleged crimes or penalties, national identification number or other information deemed sensitive under applicable law.
• “Standard Contractual Clauses" means a model transfer clause adopted by the European Commission or a Privacy Authority and approved by the European Commission.
• “User” means without limitation, registered users of the Pro Bono Italia Platform, visitors to the Website, Associated Lawyers and Lawyer Candidates, Beneficiaries and their representatives, and representatives of Clearinghouses
• “Website” means any website that is operated, or maintained, by Pro Bono Italia or on behalf of Pro Bono Italia.