ADVANCED ELECTRONIC SIGNATURE SERVICE
Premises
The firm of Dr. Genise Francesco Maria, accountant, located at Via Plinio 1, 20129 Milan (hereinafter also referred to as
"Studio Genise" or "Studio"), as part of its own document dematerialization project, has introduced a
a computer process that uniquely assigns a remote advanced electronic signature (FEA) (hereinafter also
"Service") to a natural person, useful for signing electronic documents. The electronic documents to be signed using the
Services are those necessary or useful for the execution of the services that the Company provides, based on an agreement, to the user.
of the FEA or prepared in the course of the same, guaranteeing the same legal validity and evidentiary efficacy of the
traditional paper documents. After signing, the electronic document will assume the characteristics of a digital document.
of integrity and immutability. Electronic documents signed with FEA will fulfill the form requirement referred to in art.
1350 no. 13 of the Civil Code and shall have the same legal and evidentiary effect recognized by our legal system to
private writings (Article 2702 of the Civil Code).
Membership in the Service is completely free and optional. In the following text, the term "Signatory" refers to the individual who requests...
to the Firm the provision of the Service.
DESCRIPTION AND TERMS OF USE OF THE SERVICE
FEA solutions must comply with the technical rules set out in the DPCM of 22/02/2013, which in Article 56 stipulate:
"1. Advanced electronic signature solutions guarantee:
a) the identification of the signatory of the document;
b) the unique connection of the signature to the signatory;
c) the signatory's exclusive control over the signature generation system, including any biometric data.
used for the generation of the signature itself;
d) the possibility of verifying that the signed electronic document has not been modified after the signature was affixed.
signature;
e) the possibility for the signatory to obtain evidence of what has been signed;
f) the identification of the entity referred to in Article 55, paragraph 2, letter a);
g) the absence of any element in the subject of the subscription that is intended to modify the acts, facts or data contained therein.
represented;
h) the unique connection of the signature to the signed document.”
a) Identification of the signatory
of the document;
The Service activation process is initiated by the company following:
A. of the Company's receipt of the (i) activation request of the
FEA - which must also contain an active mobile phone number and active email address b) The unique connection of
signature to the signatory
c) The exclusive control of
signer of the system of
signature generation;
of the Signatory - with acceptance, by the Signatory, of the present terms and conditions
"General Terms and Conditions of Use of the Service" which is concluded with an electronic signature.
simple through consents affixed electronically on a telematic form
(e.g. check box);
B. of the identification of the Signatory by the Firm, through the
Reception:
• of an image of the valid identity document of the
Signatory (scan or photograph).
• an active mobile phone number,
• an active email address.
The term "identity document" refers exclusively to one of the following documents:
of the Signatory:
• Identity Card
• Driver's License
• Passport
The firm performs identification before starting the activation procedure.
of the Signatory by verifying a valid identity document
and other procedures defined by the Firm or via web recognition.
The unique connection between signature and Signer occurs according to one or both of the following:
available modes:
• by accessing the signing feature via the received link
to the email address of the Signatory provided to the Firm during the
acknowledgment and acceptance of FEA conditions
• by providing the mobile phone number to which they will be sent
the OTPs for signing. Without the OTP being applied.
Unfortunately, it is not possible to sign the proposed documents.
The Service is structured to give the Signatory exclusive control of the system.
of signature generation, as the solution allows the Signer himself to:
• to have complete control over what is shown to him at the time of
signature; in particular, the Signatory can view the parts of the document and
View the points where the FEA should be applied.
• to have exclusive control over the process, with the guarantee of
unique connection of the same to the signed electronic document.
Upon signing the documentation, the code is successfully verified.
The OTP entered by the Signer constitutes the electronic signature of the
electronic document; in this way, the FEA is associated in a secure and non-
modifiable in the electronic document. d) The possibility of verifying that the
computer document
the undersigned has not suffered
changes after signing
of the signature;
e) The possibility for the signatory to
obtain evidence of how much
underwritten
f) Identifying the subject
provider of FEA solutions
g) The absence of any
element in the subject of
signing an agreement to modify it
the acts, facts, or data contained therein
represented
h) The unique connection of
signature on the signed document
Without entering the OTP code sent via SMS to the mobile phone number.
If communicated by the Signer, or with an incorrect OTP, it is not possible.
apply the electronic signature to the documents proposed for signing.
Sending the OTP to the mobile phone indicated at the time of signing strengthens the connection.
one-to-one correspondence between signature and Signer.
The documents to be signed are produced in a format that prevents
the inclusion within them of programs or instructions potentially capable of
to modify the acts, facts or data represented in the documents themselves.
The integrity of the document is guaranteed by the affixing of a certificate.
non-qualified digital "one-shot" signature of the Signer, within the pdf via
the creation of a signature compliant with the standard called PAdES.
Furthermore, the inclusion of the time reference and the watermark is planned.
thunderstorm.
The FEA technologies used involve the digital fingerprints (hashes) of the
digital document to be signed. The correspondence between a fingerprint
recalculated and the one "sealed" within the signatures, allows you to verify that the
the signed document has not been modified after the signature was affixed.
Before signing the documents, the Signatory can view them in their entirety, as follows:
upon the affixing of the FEA, the user can download what has been subscribed to.
It's the Studio.
The entire process cannot be modified by the firm. The documents to be signed.
they are produced in a format that prevents insertion into them
of programs or instructions potentially capable of modifying acts, facts or data
represented in the documents themselves.
The unique connection is established by affixing the certificate, not
qualified through OTP, sent via SMS to the Signatory's mobile phone, to whom they are
documents proposed for signature. The signature data is inserted inside the
pdf. Retention and copying of the service agreement.
Copy of these "General Terms and Conditions of Service" and the declaration of acceptance by the Signatory,
executed with an electronic signature, is kept by the Company, as provided for by law, guaranteeing,
during the entire period of preservation, the availability, integrity, readability and authenticity of the same. The
The signatory may request a copy of these General Conditions and the declaration from the Studio at any time.
agreement to the Service.
Revocation
The Signatory may request a copy of the signed documentation, and may revoke their agreement at any time.
to the FEA service, by signing a specific form, available on the company's website.
Responsibilities of the Professional Firm
All obligations and requirements provided for in Article 57 of the DPCM of February 22 remain the sole responsibility of the Studio.
2013.
Personal data processing
By signing the agreement, the Signatory agrees to the processing of data for the purpose of providing the service, including:
the recording of images and sounds for the purpose of recognizing the Signatory. The data processing information.
The personal data protection information required by Article 13 of EU Regulation 2016/679 is available on the website www.studiogenise.com , which includes:
including the methods for exercising the rights of data subjects and the contacts necessary for identifying all suppliers.
service providers.
Civil liability insurance
As required by paragraph 2 of Article 57 of the DPCM of February 22, 2013, the firm has obtained adequate coverage.
liability insurance for civil liability towards third parties.
This Information Notice contains information regarding the characteristics of the electronic signature service.
the advanced version is published on the Studio's website at www.studiogenise.com and is therefore always available for
customers and the general public. INFORMATION
on the processing of personal data
Articles 12 et seq. of Regulation (EU) 2016/679 (GDPR)
Subject: Information on the processing of personal data pursuant to articles 12 et seq. of Regulation (EU) 2016/679 for the
Advanced Electronic Signature
Identifiers of the Data Controller and, if designated, of the Representative in the territory of the State and of the Data Protection Officer.
Data Controller - The data controller is the undersigned: STUDIO GENISE, with registered office in Milan, via Plinio 1, 20129;
Tel: 0229516089; certified email: studiogenise@legalmail.it; email: segreteria@studiogenise.it.
Data Protection Officer - The Data Protection Officer is Dr. Genise Francesco, whose contact details are:
are indicated above.
Introduction - This is to inform you, in compliance with the aforementioned regulation, that in relation to the issuance of the Signature
Advanced Electronics (FEA), the Data Controller, holds certain data relating to you, which have been acquired for the purpose of
of the provision of the aforementioned service.
In accordance with this premise, the following information is provided:
Personal data collected - The undersigned, as Data Controller, uses your personal data to operate optimally in the exercise
of their own activity.
You may be asked for the following information:
- personal and contact information;
- non-biometric personal data via the FEA membership form;
- data relating to the images recorded during the identification interview of the signatory;
- Tax code and identity card.
Data retention period - The collected data will be kept for the entire duration of the relationship or collaboration.
In particular, the files relating to recognition are kept for 20 years, and the signed documents for 10 years. If
during the duration of the contractual relationship, data not related to the administrative and accounting obligations thereof are processed.
connected, such data will be kept for the time necessary to achieve the purpose for which they were collected and then
deleted. The retention period for this data will be communicated to you when the data is collected with information notices.
specifics.
Whether the provision of data is mandatory or optional, and the consequences of any refusal – Must be
the essential data for activating the FEA, as identified above, must be provided to the undersigned; as well as the
data necessary to fulfill obligations required by laws, regulations, Community legislation, or provisions of
Authorities legally entitled to receive such information, and supervisory and control bodies. Data processing methods – Pursuant to and for the purposes of Articles 12 et seq. of the GDPR, we wish to inform you that the personal data
The data you provide to us will be processed in compliance with the appropriate technical and organizational measures referred to in Article 32 of the
GDPR.
Transfer of personal data abroad - The data you provide will be processed in Italy or in another EU member state.
If, during the term of the contractual relationship, your data is processed in a non-EU country, the following guarantees will be ensured:
the rights granted to you by Community legislation, and you will be promptly informed.
Purpose of processing to which personal data are intended – The purpose of processing your personal data that
The purpose of the undersigned is to enable the issuance of the Advanced Electronic Signature.
Scope of knowledge of your data - The following categories of named individuals may become aware of your data.
Data processors or data processers appointed by the undersigned:
- Personnel assigned to identification;
- Zucchetti Spa
Data Processors - External companies with which an agreement has been entered into act as Data Processors.
have established a contractual relationship with you and need to receive your personal data in order to fulfill those agreements.
It should be noted that the person in charge indicated above is not responsible for processing requests to exercise the rights of the
data subjects as referred to in Articles 15 et seq. of the GDPR. This activity is carried out exclusively by the undersigned as Data Controller.
treatment.
Rights pursuant to Articles 15 et seq. of the GDPR - Pursuant to Article 15 of the GDPR, you have the right to obtain confirmation of the existence or
less than a processing of personal data concerning you, even if not yet registered. The exercise of rights is
subject to verification of the identity of the interested party, by presenting a valid identification document, which will not be
kept by the undersigned, but only consulted in order to verify the legitimacy of the request.
You have the right to access your personal data and the following information:
a) the purposes of the processing;
b) the categories of personal data subject to processing;
c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular if
recipients in third countries or international organizations;
d) where possible, the planned period for which personal data will be stored, or, if this is not possible, the criteria used.
to determine such period;
e) if the data is not collected from the data subject, all available information on its origin;
f) the existence of an automated decision-making process, including profiling as referred to in Article 22, paragraphs 1 and 4, and,
at least in such cases, significant information about the logic used, as well as the importance and expected consequences of
such processing for the data subject
If the data is transferred to a third country or an international organization, you have the right to be informed.
regarding the existence of adequate safeguards pursuant to Article 46 of the GDPR.
You have the right to ask the data controller to rectify or erase, even partially, the personal data or to
limiting the processing of personal data concerning you or objecting, in whole or in part, to their processing. Pursuant to Article 2-undicies of Legislative Decree 196/2003, the exercise of your rights may be delayed, limited or excluded, with
communication motivated and delivered without delay, unless the communication may compromise the purpose of the
restriction, for the time and to the extent that this constitutes a necessary and proportionate measure, taking into account the rights
fundamental rights and legitimate interests of the data subject, in order to safeguard the interests referred to in paragraph 1, points (a)
(interests protected in relation to money laundering), e) (to the conduct of defensive investigations or the exercise of a right in
judicial seat) and f) (to the confidentiality of the identity of the employee who reports illegalities that he/she has become aware of in
(due to the nature of their office). In such cases, your rights can also be exercised through the Data Protection Authority in the manner described in
pursuant to Article 160 of the same Decree. In such a case, the Data Protection Authority will inform you that it has carried out all the necessary verifications or
that a review has been carried out and of your right to lodge a judicial appeal.
To exercise these rights, you can contact our organization, the "Data Controller," at the following address:
segreteria@studiogenise.it or by calling 0229516089 or by sending a letter to STUDIO GENISE, via Plinio
1 – 20129 - Milan. The owner will respond to you within 30 days of receiving your formal request.
We remind you that in case of violation of your personal data, you can file a complaint with the competent authority: “Garante
for the protection of personal data”.
The OWNER
OF THE TREATMENT