Professional Secrecy

The professionals and employees of CHREA fulfill their obligation to professional secrecy pursuant to Articles 351 and 342 of the Italian Code of Criminal Procedure and 249 of the Italian Code of Civil Procedure, except with regard to mandatory auditing and certification activities of accounting records and financial statements and those relating to the functions of statutory auditor or independent auditor of companies or institutions, as well as for matters required by current regulations regarding money laundering.

Anti-Money Laundering Legislation, 21 November 2007 Legislative Decree No. 231

In the performance of its professional activities, CHREA applies the provisions contained in Arts. 16 et seq. of Legislative Decree No. 231 of 21 November 2007, as amended and supplemented by Legislative Decree no. 151 of 25 September 2009, which place obligations of customer due diligence on professional accountants. In particular, CHREA has harmonized its procedures with the guidelines of the Italian National Board of Certified Accountants in accordance with the general principles laid down by legislators and with the implementing provisions contained in Ministerial Decree No. 141 of 3 February 2006, and in the U.I.C. provision of 24 February 2006, with respect to the parts not expressly declared to be incompatible by the Ministry of Economy and Finance with the circular of 19 December 2007, prot. 125367 and, therefore, still in force in view of the provisions of Art. 66 of Legislative Decree No. 231/2007 and finally, with the indications given in the document “Risk-Based Approach Guidance for Accountants” released by F.A.T.F. – G.A.F.I..

Safety in the Workplace

CHREA complies with the provisions of Legislative Decree No. 81 of 9 April 2008, issued pursuant to Article 1 of Law No. 123 of 3 August 2007, concerning the protection of health and safety in the workplace for compliance with the essential levels of service concerning civil and social rights, including with regard to gender and age differences and to the condition of female workers and immigrant workers and in order to prevent any risk to the safety and health of workers and to the surrounding environment. The Firm is therefore equipped with a risk assessment document and fulfills the obligations set out in Arts. 17 and 18 of the aforementioned Legislative Decree.

Privacy, ART. 13 e14 REG. UE 2016/679

As provided for by EU Regulation no. 2016/679 relating to the protection of natural persons with regard to the processing of personal data, we hereby inform you that your personal data provided to and acquired by Studio CHIARAVALLI, REALI E ASSOCIATI (the “Firm”) shall be processed pursuant to the rules provided for under the aforementioned Regulation in accordance with all ensuing rights and obligations and that:

a) PURPOSE OF DATA PROCESSING – Data-processing serves solely for purposes of accurately and fully performing our engagement to provide professional services.

b) MANNER OF DATA PROCESSING – Data processing is carried out by means of operations performed with or without the use of electronic instruments and comprises the collection, recording, organisation, storage, consultation, processing, alteration, selection, retrieval, alignment, use, combination, blocking, disclosure, erasure and destruction of data. Processing is performed by the data controller and by the persons expressly authorised to the processing by the data controller.

c) PROVISION OF DATA AND REFUSAL – The provision of ordinary and sensitive personal data is necessary in order to perform the activities as per point a) and refusal on the part of the data subject to provide their personal data makes it impossible to perform the activities as per point a).

d) DISCLOSURE OF DATA – Personal data may only come to the attention of persons in charge of the processing and, for the purposes referred to in point a) may be forwarded to external collaborators, tax authorities in the widest sense inclusive of Tax Commissions at every level and stage, Public Authorities, the Companies Registration Office and, generally, all those for whom the disclosure of this data is necessary in order to correctly perform their professional engagement and for the purposes as per point a) Personal data is not disseminated

e) TRANSFER OF DATA ABROAD. Personal data may be transferred to countries within the European Union or to non-European Union third-party countries or to an international organisation within the scope of the aims referred to in point a).

f) DATA STORAGE – Data is stored for as long as is necessary in order to perform the activities and under no circumstances is it stored for more than ten years.

g) DATA CONTROLLER – The data controllers are the partners of Studio Chiaravalli, Reali e Associati: Giuseppe Chiaravalli, Andrea Chiaravalli, David Reali and Alessandro Maruffi in Milan, Via San Primo 4.

h) DATA SUBJECT’S RIGHTS – the data subject is entitled:

  • to access, rectify, erase, restrict and object to the processing of his/her data
  • to obtain the data from the data controller without hindrance in a commonly used structured format which is legible by automatic devices in order to forward the data to another data controller
  • to withdraw consent to data processing without prejudice to the lawfulness of processing based on consent given prior to withdrawal
  • to file a complaint with the Data Protection Authority.

You may exercise the aforementioned rights by sending a written communication by certified email to the address  or a registered letter with return receipt to the address CHIARAVALLI, REALI E ASSOCIATI – TITOLARE TRATTAMENTO PRIVACY – VIA SAN PRIMO 4 20121 MILAN


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