Privacy Policy

Data Protection Information to Data Subject (art 13)

This document discloses Morrow Sodali data protection practices on Personal Identifiable contact data collected on any section of the website (hence on “Website”) or directly supplied by data subject via electronic (email, social network, telephone, etc.) or printed form.

This privacy policy constitutes information to Data Subject as per art. 13 of the European Regulation EU 2016/679 (hence on “GDPR”).

Information Collection, Use, and Sharing

We only collect and use contact information that you voluntarily give us via website form, email message, social network, telephone or other direct form of contact from you, eg. First Name, Last Name, telephone number, email address, social network account etc. We use such information to respond to you, regarding the reason you contacted us.

The legal basis for this data processing is art. 6.b (requests by data subject prior to entering a contract) of the GDPR, which reads “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;”.

We may use your information for direct marketing, i.e. to contact you via email in the future to tell you about specials, new products or services, or changes to this privacy policy.

The legal basis for this data processing is art. 6.e (legitimate interest of Data Controller) of the GDPR, which reads “processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party”.

We will not sell, rent or share your information to any third party outside of our organization. In such case the third party will act as Data processor nominated and instructed by us, the Data Controller.

Your rights of Access and Control

The GDPR (art. 15 to 22) guarantees you the following rights:

  • Know what personal data we process about you, if any.
  • Change/amend/update any data we have about you.
  • Ask us to stop processing your data for direct marketing,
  • Delete any data we have about you.
  • File a complaint to a Control Authority;

Your rights can be exercised by contacting us at the following email address Please be aware that proof of your identity may be requested before processing your request.

We will answer to your request with no undue delay and in any case within 1 calendar month from your request.

Privacy Shield

Morrow Sodali (and its subsidiary Proxy Services Corporation, Morrow Sodali International LLC and DiCosta Partners LLC), comply with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Morrow Sodali (and its subsidiary Proxy Services Corporation, Morrow Sodali Internaltional LLC and DiCosta Partners LLC), has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit

Morrow Sodali commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to data transferred from the EU and Switzerland in the context of the employment relationship.

In compliance with the Privacy Shield Principles, Morrow Sodali commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Morrow Sodali at: Guido Zucchelli

Morrow Sodali is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). For individuals wishing to invoke binding arbitration, the possibility and conditions are part of the Statutury Rights of Data Subject under GDPR, Precisely srt. 77 to 82.

Morrow Sodali’s obligation to disclose personal information in responce to lawful requests by public authorities, including to meet national security or law enforcement requirements are related to European Directive (2016/680) that is converend wuth personal data protection for law enforcement agencies. This is subject to Member State Laws.

Under present conditions, onwards transfer of personal data are not allowed. If Morrow Sodali decides in future to transfer personal data to third party controller and/or agents, Morrow Sodali will enter into a contract that fully reflects the requirements of the relevant standard contractual clauses adopted by the Euporean Commission. More information on Onwards Transfer can be found here:

Security Measures

We take all possible technical and organizational measures to protect your personal data against loss of Confidentiality, Integrity and Availability, as required by art. 32 and al. of the GDPR. Non-exhaustive examples of such measures include:

  • Access to Personal Data is controlled and performed only by trained people
  • Our systems are protected against virus/malware
  • Periodic Backup of personal data

Please contact our Data Privacy Officer at the email below for any further info or query you may have.


This website contains links to other web sites, not controlled and/or managed by Morrow Sodali. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.


Data Controller

Morrow Sodali - Via XXIV Maggio - 00186 Rome (Italy)

Data Protection Officer

Ing. Guido Zucchelli