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LEGALESS® – TERMS AND CONDITIONS
Version of 1 October 2026
Legaless® is a digital platform that provides a structured technological space enabling the User to get in touch with independent lawyers and manage their case online. The service is operated by Top Consulting Ltd. (the "Operator"), which uses the Platform and the Legaless® trademark under licence. The Operator does not provide legal services and assumes no professional liability for the work of the lawyers, who act with full autonomy in their relationship with the User, under their own exclusive ethical and professional responsibility.
Art. 1 – Preliminary provisions and purpose
1.1. This document ("T&C") governs the general terms of use of the Legaless® digital platform (hereinafter also the "Platform"), accessible at www.legaless.it, as well as the rights and obligations of the User who accesses it, pursuant to Legislative Decree no. 70 of 9 April 2003 (implementing Directive 2000/31/EC on electronic commerce), Regulation (EU) 2022/2065 (Digital Services Act), the Consumer Code (Legislative Decree 206/2005) and all other applicable legislation.
1.2. These T&C govern exclusively the relationship between the User and the Operator. They do not in any way govern the professional relationship between the User and the Lawyer, which is established by separate agreements between the parties and is governed by the relevant legislation and by the rules of professional conduct for lawyers.
1.3. The T&C are accepted by ticking the relevant box (checkbox) when registering the Account or sending a Service request. If they are not accepted, the Platform cannot be used.
Art. 2 – Definitions
Account means the User's personal profile on the Platform, containing the related Data, through which the User can request the Services, monitor their Case and communicate with the Lawyer in charge.
AML means the rules on the prevention of money laundering and terrorist financing under Legislative Decree no. 231 of 21 November 2007 as amended.
Lawyer (both singular and plural) refers to the legal professional registered with the relevant Bar Association, who operates with full professional and tax autonomy and who may be engaged by the User through the Platform. The Lawyer is independent of the Operator and the Licensor and assumes in their own name every professional obligation towards the User.
Data means all information, documents and copies of documents shared by the User on the Platform or generated during its use.
IP Rights means the intellectual property rights relating to the Platform and the Legaless® trademark. This definition includes, by way of example and without limitation, all trademarks, copyright in the software, source code, graphical interface and editorial content, image rights, patents, rights in confidential information or innovative ideas, know-how, rights in business activities and trade names, domain names, whether registered or unregistered, and any other right or form of protection of a nature analogous or similar to any of them.
Fee means the consideration owed by the User to the Operator for the technological and organisational services offered through the Platform, included in the total price stated in the Quote.
Operator is Top Consulting Ltd., whose details are set out in art. 18, which operates the Platform in its own name and on its own behalf and is the User's contractual counterparty.
Licensor is Alessio D'Ascenzo, author and owner of the Platform and of the Legaless® trademark, who has granted the Operator a licence to use them. The Licensor does not operate the Service and is not a party to the relationship with the User.
Professional Mandate means the separate document, signed directly between the User and the Lawyer, by which the User engages the Lawyer to provide legal assistance for specific activities. The Operator is not a party to the Professional Mandate.
Service Packages means the various plans offering legal services, in multiple or ongoing form, requested by the User through Legaless® and agreed with one or more Lawyers by means of specific agreements.
Case means the request for which the User has confirmed the engagement of the Lawyer and which is handled within the Platform.
Quote means the total price of the Service, including the Lawyer's fee and the Fee, generated automatically by the Platform on the basis of the parameters entered by the User or prepared manually by the Lawyer.
Third-party Providers are the technology service providers used by the Platform:
– Third-party provider of electronic signature services on the Platform: Openapi S.p.A. (qualified service under Regulation (EU) 910/2014 — eIDAS, as amended by Regulation (EU) 2024/1183). Terms and conditions available at: https://legal.openapi.com/terms-and-conditions/term-and-condition-general-it.pdf
– Third-party provider of online payment services on the Platform: Stripe Payments Europe Ltd. Terms and conditions available at: https://stripe.com/en-it/legal/ssa/it-it
– Third-party provider of cloud hosting services for the Platform: Hostinger International Ltd. Terms and conditions available at: https://www.hostinger.it/legal/termini-del-servizio-universali
By accepting these T&C the User confirms that they have read, understood and fully accepted the terms and conditions of each of the Third-party Providers, available at the links above.
Service (both singular and plural) means the specific legal assistance service requested by the User through Legaless® from one or more Lawyers.
T&C refers to this Terms and Conditions document, as updated from time to time.
User (both singular and plural) refers to the person (an adult natural person or a legal entity), resident in the European Economic Area (EEA), who uses Legaless®.
Art. 3 – Legal nature of the Platform
3.1 Legaless® is an information society service, within the meaning of Legislative Decree 70/2003 and Reg. (EU) 2022/2065, provided by the Operator, which makes available to the User a structured digital space to:
a) get in touch with one or more independent Lawyers;
b) receive Quotes, formalise engagements and sign documents electronically;
c) make online payments for the Services;
d) follow the progress of the Case and communicate with the engaged Lawyer;
e) store the Data relating to the Case confidentially.
3.2 Unless otherwise provided, the Operator's activity is limited to providing and managing the technological and organisational tool. Every professional service is provided exclusively by the Lawyer engaged by the User, with full autonomy.
3.3 The Lawyers on the Platform are professionals who are independent of the Operator for tax, organisational and professional purposes.
There is no employment, quasi-employment, professional partnership, commercial agency or brokerage relationship between the Operator and the Lawyers. Each Lawyer:
a) invoices the User independently for their professional services;
b) is an independent controller of the User's personal data for the performance of the engagement received;
c) is covered by their own professional liability insurance policy pursuant to art. 12 of Law 247/2012;
d) is personally responsible for compliance with professional conduct, tax, social security and anti-money-laundering obligations.
3.4 The Fee paid to the Operator is consideration for technological and organisational services. A Case is assigned to a particular Lawyer either directly by the User or through neutral organisational criteria (area of expertise, availability, language) and in no case constitutes a recommendation, advice or guarantee as to the quality of the professional service.
Art. 4 – How the Platform works
4.1 Registration and Account. The User creates an Account by providing truthful, accurate and complete data. The User keeps their credentials safe with due care and is solely and directly responsible for every activity carried out through their Account. The Operator is not liable for unauthorised access or misuse attributable, even only indirectly, to the User's conduct.
4.2 Service request and Quote. By filling in the relevant form, the User receives, where possible, an automatic Quote calculated on the basis of the information provided. For Services of variable complexity the Quote is prepared manually by the Lawyer after reviewing the case.
4.3 Validity of the Quote. Unless otherwise expressly stated in the Quote itself, the Quote is valid for 30 (thirty) days from the date of issue, after which it lapses automatically. The Operator and the Lawyer reserve the right to withdraw or amend the Quote in the event of a substantial change in the underlying circumstances (e.g. facts not disclosed by the User coming to light, changes in the applicable lawyers' fee scales, supervening conflicts of interest). The automatic calculation of the Quote is based on the information provided by the User: if that information is untrue or incomplete, the Lawyer may redetermine the fee before the professional engagement is accepted and assigned.
4.4 Acceptance of the Quote and engagement. Having received the Quote, the User may accept it by making payment through the channels provided by the Platform. The assignment of the professional engagement, whether by accepting the quote or by signing the Professional Mandate, where required, concerns exclusively the relationship between the User and the Lawyer.
A signature applied electronically through the Platform's system has evidential value under Reg. (EU) 910/2014 and Legislative Decree 82/2005 (CAD).
4.5 Subcontracting and use of the Lawyer's associates. The User acknowledges and accepts that the engaged Lawyer, in performing the professional engagement, may make use of their own office associates, qualified trainees, substitute counsel at hearings and local agents, under their own exclusive direction and responsibility. The Lawyer remains the User's sole point of contact and sole controller of the related data, unless otherwise agreed. Any sub-engagements of specialist colleagues or lawyers from other courts are arranged by the Lawyer independently and notified to the User in advance where they entail additional costs.
4.6 Performance of the Service. The Lawyer performs the Service in accordance with the conditions agreed in the quote and/or in the professional engagement.
Communications and updates on the status of the Case take place through the Platform's tools (internal chat, timeline, notifications). The User acknowledges that the Platform stores these communications for evidential and security purposes (see art. 16.3).
4.7 Payments. Payments are made through Stripe, to the Operator's account or, for Quotes prepared manually by the Lawyer, where provided, directly to the Lawyer's Stripe account linked to the Platform.
a) The sums paid by the User are processed by Stripe. The Lawyer receives the consideration for the professional service rendered to the User; the Operator is entitled to the Fee.
b) In any event, the Lawyer remains the sole provider of the legal service and the only party responsible for its performance and invoicing to the User; the Operator is responsible for the tax treatment of the Fee.
4.8 Service Packages. Service Packages are governed by the specific conditions agreed between the User and the Lawyer and set out in the offer. Any provision of continuous or recurring services is governed by the individual agreement between the User and the Lawyer, including duration, cancellation terms and any unused hours.
Art. 5 – Consumer's right of withdrawal
5.1 A User acting as a consumer under the Consumer Code has the right to withdraw from the contract concluded with the Operator within 14 (fourteen) days of its conclusion, without giving any reason and without any charge other than those provided for in art. 5.3 (arts. 52 et seq., Legislative Decree 206/2005), by sending an explicit statement to supporto@legaless.it.
5.2 Pursuant to arts. 51, paragraph 8, and 59, paragraph 1, letter a), of the Consumer Code, the consumer User – when accepting the Quote and in any case when the engagement is assigned – confirms their wish for performance of the Service to begin before the 14-day withdrawal period expires; if the consumer User intends to exercise the right of withdrawal under the Consumer Code, they must expressly request that performance be postponed by 14 days. Full performance of the Service results in the loss of the right of withdrawal.
5.3 If the Service has been only partially performed at the time of withdrawal, the User will be required to pay an amount proportionate to the services rendered up to that point, including the Fee, without prejudice to any further consequences arising from professional work already under way (e.g. pending court action).
5.4 This article does not apply to a User who is a legal entity or a professional acting in the course of their commercial, business, craft or professional activity.
Art. 6 – User obligations and warranties
6.1 The User undertakes to:
a) use the Platform in good faith, properly and in compliance with Italian and European law;
b) provide truthful, accurate, complete and up-to-date information, including for the correct calculation of the Quote;
c) not create false identities or impersonate others;
d) keep their credentials safe and promptly inform the Operator of any unauthorised access;
e) ensure that the Data shared do not infringe third-party rights (including intellectual property rights, privacy and professional confidentiality);
f) refrain from any conduct that may harm the Platform, the Operator, the Licensor, the Lawyers or other Users;
g) refrain from transmitting unlawful, fraudulent, obscene, discriminatory, defamatory or threatening content, or content containing viruses, malware or harmful code;
h) refrain from using the Platform for unlawful purposes or to develop competing services;
i) cooperate with the Lawyer by promptly providing the information, documents and elements needed to perform the Service and for any AML obligations incumbent on the Lawyer.
6.2 Indemnity. The User indemnifies and holds harmless the Operator and the Licensor against any claim, complaint, dispute, legal action or penalty, and against any damage, cost, charge and expense (including legal fees) arising, even indirectly, from the breach of the obligations set out in this article, from unlawful use of the Platform or from the dissemination of unlawful content.
6.3 Notice & Action (DSA). Pursuant to arts. 16 et seq. of Reg. (EU) 2022/2065, anyone who believes that content on the Platform is unlawful may send a reasoned notice to supporto@legaless.it, indicating the content, its location and the reasons for the notice. The Operator assesses the notice and, where the conditions are met, takes measures to remove or disable access, informing the notifier and the recipient.
Art. 7 – Anti-money laundering and conflicts of interest
7.1 The User acknowledges that, under Legislative Decree 231/2007, the Lawyer is subject to customer due diligence, record-keeping and suspicious transaction reporting obligations for services falling within their scope (in particular those listed in art. 12 of the same decree). AML obligations are the exclusive responsibility of the Lawyer, as the obliged entity, who fulfils them as independent controller of the related personal data and keeps the relevant documentation for the statutory period (10 years). The Platform only provides the technological tools for collecting the data and documents requested by the Lawyer, without the Operator taking on the role of obliged entity. The User undertakes to provide the Lawyer, truthfully and promptly, with all the elements requested for due diligence purposes; failure to do so, or incomplete compliance, may lead the Lawyer to abstain from performing the Service pursuant to art. 42 of Legislative Decree 231/2007.
7.2 The prior check for potential conflicts of interest under arts. 24 and 68 of the Italian Code of Professional Conduct for Lawyers is the exclusive competence and responsibility of the engaged Lawyer, before accepting the professional engagement. The Operator does not carry out, and is not required to carry out, any substantive check on the existence of conflicts of interest between the Cases handled on the Platform and is not liable for any conflicts not identified by the Lawyer. If the Lawyer, even after accepting the engagement, identifies a conflict of interest or another ethical reason to abstain, they must promptly inform the User and withdraw from the engagement in the manner provided for by the rules of professional conduct; in that case the Operator, with the User's consent, may make the Case available for assignment to another available Lawyer.
Art. 8 – Obligations and liability of the Operator
8.1 The Operator undertakes to provide the Platform with the technical diligence that can reasonably be expected, as an obligation of means and not of result.
The Operator does not guarantee that the Platform will be free of errors, interruptions or malfunctions, but will endeavour to ensure that these are resolved within a reasonable time.
8.2 The Operator assumes no liability, direct or indirect, for the professional work of the Lawyers, for the quality, timeliness, accuracy, completeness or outcome of the legal services, for any errors, omissions, delays or breaches by the Lawyer, for the Lawyer's professional conduct, for any undetected conflicts of interest, for failed or incorrect AML compliance, or for any consequence arising from the professional engagement assigned. Any claim relating to the professional work must be addressed exclusively to the engaged Lawyer.
8.3 The Operator is not liable for malfunctions, interruptions, errors or breaches attributable to Third-party Providers (Stripe, Openapi, Hostinger, telecommunications operators, etc.), save for wilful misconduct or gross negligence in selecting them. The relationship between the User and each Third-party Provider is governed by the respective terms of use, which the User declares to have read, understood and accepted by accepting the T&C.
8.4 Limitation of liability. Save in cases of wilful misconduct or gross negligence, and without prejudice to the consumer's mandatory rights, the Operator's total liability towards the User, on any basis (contractual, non-contractual, restitutionary), is in any case limited to the total amount of the Fee actually received by the Operator in relation to the User's Cases in the 6 (six) months preceding the event giving rise to the liability.
8.5 Indirect damages, loss of profit, loss of opportunity, loss of data not attributable to the Operator, reputational damage and business interruption damage are excluded in all cases.
8.6 The Operator is not liable for failures to perform due to force majeure, fortuitous events, acts of third parties or of the User, orders of the authorities, or cyber attacks despite the adoption of adequate security measures.
8.7 The Licensor is not a party to the relationship with the User and assumes no obligation or liability towards the User or the Lawyers in relation to the Service, without prejudice to mandatory legal limits. Any claim relating to the Service must be addressed to the Operator.
Art. 9 – Maintenance, suspension and modification of the Platform
9.1 The Operator, including through the Licensor, may carry out maintenance, update and security work on the Platform, minimising the impact on the User as far as possible. Where the work entails a significant suspension, the Operator gives notice of it with reasonable advance warning.
9.2 The Operator may unilaterally suspend or modify the Platform's features, in whole or in part:
a) to comply with legal or regulatory obligations or orders of the authorities;
b) to address security threats, fraud, cyber attacks or data breaches;
c) due to supervening technical, economic or organisational needs.
9.3 The Operator reserves the right to discontinue the Platform permanently with no less than 20 (twenty) days' notice, during which the User may download their Data.
9.4 Amendments to the T&C, justified by regulatory, technical or organisational reasons, are notified to the User with 10 (ten) days' notice via the Account and/or email. The User may withdraw without charge within that period; if they do not withdraw, the amendments are deemed accepted.
Art. 10 – Intellectual property
10.1 All IP Rights relating to the Platform, the "Legaless®" trademark (European Union trademark no. 018727049, registered with the EUIPO), the software, source code, design, editorial content, template documents and every other element are exclusively owned by the Licensor and are used by the Operator under licence. Nothing in these T&C entails any assignment or grant to the User, even partial or temporary, of such rights, except as provided in art. 10.2.
10.2 The Operator grants the User, within the limits of the licence available to it, a personal, temporary, non-exclusive, non-transferable, non-sublicensable and revocable right to use the Platform, limited to the duration of the relationship.
10.3 The User undertakes not to:
a) reproduce, modify, decompile, disassemble, reverse engineer, translate or adapt the software or create derivative works;
b) license, sell, rent, distribute or transfer access to the Platform to third parties;
c) carry out penetration or vulnerability tests or DoS/DDoS attacks;
d) use Legaless® trademarks, logos or distinctive signs without prior written authorisation.
10.4 The User retains ownership of the content uploaded. However, the User grants the Operator a non-exclusive, free and limited licence, valid for the duration of the relationship and for the time needed to comply with statutory retention obligations, to use such content exclusively for providing the Platform and for related technical and operational purposes.
10.5 Any opinions, comments, suggestions or feedback sent spontaneously by the User may be used to improve the Platform, without any obligation to pay or give credit.
Art. 11 – Processing of personal data
11.1 The processing of the User's personal data is governed by the Privacy Policy, which forms an integral part of these T&C.
11.2 The User acknowledges and accepts that:
a) the Operator processes the data as independent controller for the technical and organisational purposes of the Platform, using the Licensor as processor for hosting, backup, maintenance and technical support;
b) the engaged Lawyer processes the data as independent controller for the performance of the professional engagement and for the professional conduct, AML and legal obligations incumbent on them;
c) the transmission of the Data to the Lawyer is a necessary condition for providing the requested Service.
11.3 Retention after the relationship ends. The Operator and the Lawyer are independent controllers with separate and non-overlapping retention obligations. The end of the relationship between the User and the Operator, or a deletion request addressed to the Operator, does not affect the retention periods binding on the Lawyer under professional conduct obligations (arts. 33 and 50 of the Code of Professional Conduct for Lawyers), AML (art. 31 of Legislative Decree 231/2007), tax obligations (art. 2220 of the Civil Code) and for the defence of their own rights (art. 9.2.f GDPR). Likewise, the end of the professional engagement between the User and the Lawyer does not affect the retention periods binding on the Operator for its own obligations. Data subject rights must be exercised separately against each controller for the data within their respective competence.
11.4 Continuity of the Service. If the licence granted by the Licensor to the Operator ends for any reason, the Data are communicated to the Licensor or to the party designated by the Licensor, which becomes their independent controller in order to ensure the continuation of the Service and of the Cases in progress, within the limits of the GDPR and as set out in the Privacy Policy.
Art. 12 – Suspension of the User
12.1 The Operator may suspend or restrict the User's access to the Platform, even without notice, in the event of:
a) breach of the T&C or of applicable law;
b) conduct that may harm the Operator, the Licensor, the Lawyers, other Users or the security of the Platform;
c) late payment or non-payment for the Services;
d) orders or requests from the competent authorities;
e) supervening impossibility of supply.
12.2 The suspension is notified to the User, stating the reasons and, where possible, the actions needed to restore access.
Art. 13 – Termination of the relationship
13.1 The relationship governed by the T&C is of indefinite duration from the date of acceptance.
13.2 Withdrawal by the User. The User may withdraw at any time using the account closure function in their private area, or by writing to supporto@legaless.it. After 5 (five) days from the request, the Account and the Data pertaining to the Operator are removed within the limits set out in the Privacy Policy (§7) and in art. 11.3 (subject to statutory retention obligations). The User is responsible for downloading the Data before removal. For Service Packages in progress, the specific notice periods provided for therein apply.
13.3 Withdrawal by the Operator. The Operator may withdraw at any time, without giving reasons and without compensation, by giving the User at least 20 (twenty) days' written notice.
13.4 Termination. In the event of a serious breach of the T&C or of applicable law by the User, the Operator may terminate the relationship pursuant to art. 1456 of the Civil Code with immediate effect, by written notice, without prejudice to the right to compensation for damage.
13.5 Once the relationship has ended, access to the Account is disabled and the Data are removed within the periods set out in art. 11.3.
The end of the relationship with the Operator does not affect the professional engagement in place with the Lawyer, which remains independently governed by its own terms.
Art. 14 – Assignment of the contract
14.1 The Operator may assign, in whole or in part, the relationship governed by the T&C, provided that the User's rights are not prejudiced. The assignment is notified to the User with reasonable notice.
14.2 The User acknowledges and specifically accepts, for all purposes of arts. 1406 et seq. of the Civil Code, that if the licence granted by the Licensor to the Operator ends for any reason, the relationship governed by the T&C, the User's Account and the related contractual relationships in place may be assigned to the Licensor or to the party designated by the Licensor. This article constitutes the User's prior consent to the assignment pursuant to art. 1407 of the Civil Code, subject to the following conditions:
a) the assignee fully takes over the rights and obligations of the Operator towards the User, on the same conditions;
b) the assignment does not entail any reduction in the protection of the rights of the consumer User (art. 33, paragraph 2, letter s), Legislative Decree 206/2005);
c) the assignment is notified to the User with at least 20 days' notice via the Account and/or email; within that period the User may withdraw without charge.
Art. 15 – Force majeure
In the event of force majeure (natural events, conflicts, acts of authorities, pandemics, massive cyber attacks, large-scale network outages, etc.), the Operator's obligations are suspended for the duration of the event. If the event lasts more than 30 (thirty) consecutive days, either party may withdraw without compensation.
Art. 16 – Final provisions
16.1 The User declares that they have the legal capacity and powers needed to enter into these T&C, that they are of age (≥ 18 years) and, if a legal entity, that they operate in the course of their professional or business activity, with the consequent exclusion of the Consumer Code rules. When creating their account and/or when requesting the Service, the User declares whether they are acting as a consumer or in the course of their business or professional activity.
16.2 The parties are independent contractors. The T&C do not create an employment, mandate, agency, partnership, joint venture or franchising relationship.
16.3 The User expressly accepts that the electronic records kept in the systems of the Platform and of the Third-party Providers, including communications, access logs, electronic signatures and payment confirmations, constitute evidence of the transactions and agreements concluded, provided that the party from which they originate can be identified and their integrity is guaranteed.
16.4 Failure to exercise a right does not constitute a waiver. The invalidity or ineffectiveness of a clause does not affect the validity of the remaining clauses.
16.5 The User may submit complaints or requests for assistance to supporto@legaless.it. Indicative response time: 5 working days.
16.6 ADR. The consumer User may also contact the mediation bodies accredited under Legislative Decree 28/2010 and Legislative Decree 130/2015.
16.7 The following articles survive the end of the relationship: 6.2 (indemnity), 7 (AML and conflicts), 8 (liability), 10 (intellectual property), 11.3 and 11.4 (retention and continuity), 14.2 (assignment), 16.3 (evidence), 16.7, 17 (law and jurisdiction).
16.8 Words in the singular include the plural and vice versa; references to legislation are to the text in force; amounts are in euro.
Art. 17 – Governing law and jurisdiction
17.1 The relationship is governed by Italian law, without prejudice to the mandatory consumer protection provisions of the State of habitual residence of the consumer User.
17.2 The parties will attempt to settle any dispute amicably. Failing that:
a) for the consumer User, the court of the consumer's place of residence or elected domicile has jurisdiction, pursuant to art. 66-bis of the Consumer Code;
b) for a User acting as a company or professional, the Court of Rome has exclusive jurisdiction, unless another mandatory forum applies by law.
Art. 18 – Operator's details (art. 7 of Legislative Decree 70/2003)
Operator of Legaless®: Top Consulting Ltd., a company incorporated under Maltese law, represented by its legal representative pro tempore, with registered office at Triq L-Imsida, GZR 1400, Gzira, Malta, registered with the Malta Business Registry under no. C 115432, VAT number MT3273-4036, email: supporto@legaless.it.
Art. 19 – Transitional provision
From 1 October 2026 the Platform is operated by Top Consulting Ltd. For Users who accepted a previous version of the T&C, the relationship is transferred to Top Consulting Ltd. under art. 14.2 of that version, with effect from the date stated in the notice of transfer sent via the Account and/or by email; unless expressly refused, these T&C apply from that date. Cases in progress continue without interruption with the same Lawyer and on the same financial terms.
Clauses specifically approved under arts. 1341 and 1342 of the Civil Code
The User, for all purposes of arts. 1341 and 1342 of the Civil Code, declares that they have read, understood and specifically approved the following clauses: Art. 3 (Legal nature of the Platform – exclusion of legal services by the Operator and independence of the Lawyers); Art. 4.3 (Validity and withdrawal of the Quote); Art. 4.5 (Subcontracting and use of the Lawyer's associates); Art. 4.7 (Payments – nature of the Fee); Arts. 5.3-5.4 (Early performance, loss and exclusions of the right of withdrawal); Art. 6 (User obligations and indemnity); Art. 7 (Anti-money laundering and conflicts of interest — exclusion of the Operator's liability); Art. 8 (Exclusion and limitation of liability, capped at 6 months of Fees; exclusion of the Licensor's liability); Art. 9 (Maintenance, suspension, unilateral modification); Art. 10 (Intellectual property and licences); Arts. 11.3-11.4 (Separate retention periods for Operator and Lawyer; communication of Data to the Licensor when the licence ends); Art. 12 (Suspension of the User); Art. 13 (End of the relationship and withdrawal); Art. 14.2 (Prior consent to assignment to the Licensor or to the party designated by the Licensor); Art. 16.3 (Evidential value of electronic records); Art. 16.7 (Survival of clauses); Art. 17 (Governing law and jurisdiction).
PRIVACY POLICY
Version of 1 October 2026
Notice provided pursuant to arts. 13 and 14 of Regulation (EU) 2016/679 ("GDPR") and, where applicable, art. 122 of Legislative Decree 196/2003 ("Privacy Code"), as amended by Legislative Decree 101/2018.
1. Data controller
Data controller: Top Consulting Ltd., operator of the Legaless® platform, represented by its legal representative pro tempore, with registered office at Triq L-Imsida, GZR 1400, Gzira, Malta, registered with the Malta Business Registry under no. C 115432, VAT number MT3273-4036, email: supporto@legaless.it.
No Data Protection Officer (DPO) has been appointed, as the conditions of art. 37 GDPR do not apply.
The Platform and the Legaless® trademark are owned by Alessio D'Ascenzo (the "Licensor") and are used by the Controller under licence.
2. Roles and structure of the processing
The Legaless® Platform puts the User in touch with independent lawyers. It is important that the User understands who processes their data and for what purposes:
| Party | Role | Scope of processing |
|---|---|---|
| Top Consulting Ltd. (operator of Legaless®) | Independent controller and Processor (art. 28 GDPR) | Operation of the Platform, Account management, security, invoicing of the Fee, legal obligations incumbent on it; receipt, storage and transmission of the Case data (requests, documents, chat) for the drafting of Quotes, the assignment of engagements and communication between User and Lawyer.
Hosting, backup, maintenance and technical support of the Platform, on the Controller's documented instructions; does not use the data for its own purposes or to train artificial intelligence systems |
| Assigned lawyer | Independent controller | Performance of the Professional Engagement, drafting of documents, legal defence, ethical and anti-money-laundering (AML) obligations under Legislative Decree 231/2007 |
| Third-party Providers (Stripe, Openapi, Hostinger, etc.) | Processors or sub-processors, or independent controllers (see § 9) | Technical operation of the related features |
The Controller accesses Case data only to the extent necessary to prepare Quotes, assign engagements, provide assistance and ensure the security of the Platform, through authorised staff bound by confidentiality. The Lawyer is an independent controller and handles directly with the User their own privacy notice for professional, ethical and anti-money-laundering purposes.
Requests to exercise rights must be addressed to the competent controller according to the purpose of the processing (see § 7 and § 10).
3. Categories of data processed
Depending on the interaction with the Platform, the Controller processes:
a) Personal and contact details: first name, surname, email, telephone, residence, tax code, VAT number;
b) Identification data: copy of an identity document, where necessary to perform the Service or for the Lawyer's anti-money-laundering obligations (in that case the data are transmitted to the Lawyer, who processes them as independent controller under Legislative Decree 231/2007);
c) Account data: login credentials (encrypted), settings, preferences;
d) Case data: description of the case, uploaded documents, chat communications, quotes, mandates. They may include special categories of data (art. 9 GDPR) – e.g. data concerning health, sex life, racial or ethnic origin, political opinions, religious beliefs – where relevant to the legal case; and data relating to criminal convictions and offences (art. 10 GDPR);
e) Payment data: handled entirely by Stripe; the Controller only receives transaction data (amount, outcome, identifier);
f) Electronic signature data: handled by Openapi (telephone number for OTP, signature logs);
g) Usage data: IP address, access logs, browser type, operating system, pages visited, timestamps;
h) Communication data: messages sent through the internal chat and by email.
The User is responsible for the accuracy, completeness and updating of the data provided, and for the lawfulness of communicating third-party data.
4. Purposes and legal bases of the processing
| # | Purpose | Legal basis (art. 6 GDPR) | Legal basis for special categories (art. 9) |
|---|---|---|---|
| 4.1 | Creating and managing the Account | Performance of the contract (art. 6(1)(b)) | — |
| 4.2 | Providing the Platform's features (requests, quotes, chat, signature, payments) | Performance of the contract (art. 6(1)(b)) | Explicit consent where special categories of data are involved (art. 9(2)(a)); or the establishment, exercise or defence of legal claims (art. 9(2)(f)) |
| 4.3 | Compliance with the Controller's legal obligations (tax, accounting, orders from authorities, DSA) | Legal obligation (art. 6(1)(c)) | Art. 9(2)(g) (reasons of substantial public interest) where applicable |
| 4.4 | Platform security, fraud prevention, access logs | Legitimate interest (art. 6(1)(f)) | — |
| 4.5 | Customer support and complaint handling | Performance of the contract / legitimate interest | — |
| 4.6 | Sending service communications (notifications, Case updates) | Performance of the contract (art. 6(1)(b)) | — |
| 4.7 | Sending the Controller's newsletters / promotional communications | Consent (art. 6(1)(a)), which can be withdrawn at any time | — |
| 4.8 | Soft spam about similar Services already requested (art. 130(4), Legislative Decree 196/2003) | Legitimate interest, with the right to object | — |
| 4.9 | Defence of a right in court or out of court | Legitimate interest (art. 6(1)(f)) | Art. 9(2)(f) |
| 4.10 | Aggregate statistics and service improvement | Legitimate interest (art. 6(1)(f)) | — |
| 4.11 | Continuity of the Service if the Platform licence ends: communication of the data to the Licensor or to the party designated by the Licensor (see § 8) | Performance of the contract (art. 6.1.b) and legitimate interest in continuing the Cases in progress (art. 6.1.f) | Art. 9.2.f, limited to what is necessary to continue the Cases |
Mandatory or optional provision. Providing the data under points 4.1–4.6 is necessary to perform the Service: failure to provide it prevents use of the Platform. Providing data for purpose 4.7 is optional and does not affect use of the Platform.
AML processing. Processing related to anti-money-laundering due diligence, record-keeping and reporting obligations is carried out by the Lawyer as the obliged entity and independent controller under Legislative Decree 231/2007 (see § 7). The Controller does not act as an AML obliged entity.
5. Technological tools and artificial intelligence
The Controller may use automation tools and artificial intelligence models solely for internal editorial, organisational and management support purposes (e.g. drafting internal drafts, classifying requests, helping write standard quotes). These tools are not fed with Case data, nor used to take automated decisions producing legal effects on the User, nor to profile the User within the meaning of art. 22 GDPR. The Lawyer remains solely responsible for the professional assessments and for the content delivered to the User.
6. Processing methods and security
Data are processed using electronic tools and organisational procedures suitable for ensuring their security, integrity and confidentiality, in accordance with art. 32 GDPR. The measures adopted, including through the processor, include among others:
– encryption of sensitive data in transit (TLS) and at rest;
– two-factor authentication for privileged access;
– segregation of roles and the principle of least privilege;
– web application firewall (WAF), intrusion detection systems, anti-malware;
– periodic backups and disaster recovery procedures;
– incident management and data breach notification procedures under arts. 33-34 GDPR;
– periodic security audits.
Despite these measures, no IT system is entirely free of risk. The Controller undertakes to notify the competent supervisory authority and — where required — the User of any data breaches in accordance with applicable law.
7. Retention periods
The Controller and the Lawyer are independent controllers with separate retention obligations. This section governs retention by the Controller; for retention by the Lawyer, please refer to the Lawyer's own privacy notice, which the Lawyer provides directly to the User.
7.1 Retention by the Controller
| Category | Retention period |
|---|---|
| Data of Accounts in use | For the duration of the relationship |
| Data relating to completed Cases (Platform side) | Documents and chats of completed Cases: 24 months from completion. Quotes, mandates and transaction data: 10 years from completion of the Case (consistent with the limitation periods under art. 2946 of the Civil Code and with document retention obligations) |
| The Controller's tax and accounting records | For the period required by the tax and accounting rules applicable to the Controller, and in any case no longer than 10 years |
| Technical and security logs | Up to 12 months, unless retention is needed for investigations |
| Marketing data (consent) | Until consent is withdrawn, and in any case no longer than 24 months after the last interaction |
| Inactive account | After 24 months of inactivity, the User is asked to confirm whether they wish to keep the Account; if there is no reply within 30 days of the message, the Account is closed and the data deleted or anonymised (subject to the retention obligations above) |
7.2 Retention by the Lawyer
The Lawyer, as independent controller, retains the User's data for the periods and within the limits set by their own legal obligations, in particular:
– documentation in the professional file: for the time needed to defend the rights of the client and of the Lawyer, consistent with the applicable limitation periods (generally, at least 10 years from the end of the mandate, under art. 2946 of the Civil Code);
– AML documentation (customer due diligence, record keeping, reports): 10 years from the end of the ongoing relationship or from the performance of the occasional service, pursuant to art. 31 of Legislative Decree 231/2007;
– tax and accounting documentation: 10 years under art. 2220 of the Civil Code and art. 22 of Presidential Decree 600/1973.
7.3 Effects of the end of the relationship on the separate controllers
The end of the relationship with the Controller, or a deletion request addressed to the Controller, does not automatically affect the retention periods binding on the Lawyer, and vice versa. To obtain full deletion of the data, the User must exercise their rights separately against each controller. In any case, the legal limits on mandatory retention remain unaffected (e.g. AML, tax, defence of a right).
8. Recipients of the data
Data may be communicated to:
a) engaged Lawyers, as independent controllers, for the performance of the Professional Mandate and for the AML, professional conduct and tax obligations incumbent on them;
b) collaborators and authorised staff of the Controller, designated as persons authorised to process data and bound by confidentiality;
c) the Licensor, designated processor under art. 28 GDPR for hosting, backup, maintenance and technical support, and its sub-processors (currently Hostinger International Ltd.);
d) other technical service providers designated as processors under art. 28 GDPR (security, support, automation tools);
e) Third-party Providers for payments (Stripe), electronic signature (Openapi) and hosting (Hostinger), as specified in § 9;
f) Advisers (accountant, the Controller's lawyer) for professional obligations and defence;
g) Judicial and administrative authorities in the event of lawful requests (including the FIU and the Guardia di Finanza for AML purposes, upon lawful request);
h) if the licence to use the Platform ends for any reason, the Licensor or the party designated by the Licensor, which becomes their independent controller solely in order to ensure the continuation of the Service and of the Cases in progress (purpose 4.11). The User is informed of this as described in § 13.
Data are not disclosed to the public and are not transferred to third parties for their own direct marketing purposes.
9. Third-party Providers and transfers outside the EU
| Provider | Function | Location and transfers |
|---|---|---|
| Stripe Payments Europe Ltd. | Online payments, to the Controller's account or, where provided, to the Lawyer's Stripe account linked to the Platform | Based in the EU (Ireland). Any transfers to Stripe Inc. (USA) take place on the basis of the European Commission's Standard Contractual Clauses (Decision 2021/914) and, where applicable, the EU-US Data Privacy Framework. |
| Openapi S.p.A. | eIDAS electronic signature | Registered office in the EU (Italy). |
| Hostinger International Ltd. | Hosting and infrastructure (sub-processor through the Licensor) | Based in the EU/EEA (European data centres). |
Any other providers may be indicated at the User's request by writing to supporto@legaless.it. Data are processed within the European Economic Area; for transfers outside the EU/EEA, where necessary, the Controller adopts the safeguards provided for in arts. 44-49 GDPR (adequacy decisions, Standard Contractual Clauses, supplementary measures).
10. User rights
The User may exercise the following rights at any time, within the limits of the law:
– Access (art. 15 GDPR) – find out which data are processed and obtain a copy;
– Rectification (art. 16) – correct inaccurate data or complete them;
– Erasure / right to be forgotten (art. 17) – request removal of the data, within the limits provided;
– Restriction (art. 18) – temporarily restrict the processing;
– Portability (art. 20) – receive the data in a structured, commonly used, machine-readable format and transmit them to another controller;
– Objection (art. 21) – object to processing based on legitimate interest or for direct marketing;
– Withdrawal of consent (art. 7.3) – at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
– Complaint to the supervisory authority (art. 77) – in the Member State of habitual residence, place of work or place of the alleged infringement. In particular: Garante per la protezione dei dati personali, Piazza Venezia 11, 00187 Rome, garante@gpdp.it, www.garanteprivacy.it; or the authority of the State where the Controller is established, Information and Data Protection Commissioner (IDPC), Malta, www.idpc.org.mt;
– Not to be subject to automated decisions (art. 22) – the Controller does not take automated decisions producing significant legal effects.
Exercising rights against independent controllers
For data processed by the Controller, requests should be sent to supporto@legaless.it. For data processed by the Lawyer (performance of the Mandate, AML, professional conduct), requests should be sent directly to the Lawyer, who provides their own privacy notice.
Legal limits (e.g. AML, tax and right-of-defence retention obligations) may lead to certain requests being refused or deferred, with reasons given for the outcome.
The Controller responds within 30 days of receipt, extendable by a further 60 in complex cases (art. 12 GDPR).
11. Cookies
The use of cookies and similar technologies is governed by the specific Cookie Policy available on legaless.it, drawn up in accordance with the Italian Data Protection Authority's Provision of 10 June 2021.
12. Legal defence
The User's data may be used by the Controller, even after the relationship has ended, to establish, exercise or defend a right in court, within the limits of art. 9.2.f GDPR and of legal obligations.
13. Changes to this notice
The Controller reserves the right to update this notice. Changes will be communicated to the User via the Account and/or email. The current version is always available at legaless.it/privacy-policy/.
14. Minors
The Platform is intended exclusively for adults. The Controller does not knowingly collect data from minors. If the processing of a minor's data is detected, the Controller will delete it, unless otherwise authorised by the holder of parental responsibility pursuant to art. 8 GDPR.
15. Data collected before 1 October 2026
Until 30 September 2026 the controller of the data collected through the Platform was the previous operator. With the transfer of the relationships with Users to Top Consulting Ltd., the related personal data are transferred to Top Consulting Ltd., which becomes their controller from the effective date of the transfer for the same purposes set out in this notice. The previous controller retains only the data necessary to fulfil its legal obligations and to protect its rights, for the time strictly necessary for that purpose.
For definitions (including capitalised terms) in this document, please refer to the T&C.
For the definitions (including capitalised terms) used in this document, please refer to the T&C.
Acceptance of the Terms and conditions and Privacy policy (Company)
To accept, read the whole text by scrolling to the end
LEGALESS® – TERMS AND CONDITIONS
Version of 1 October 2026
Legaless® is a digital platform that provides a structured technological space enabling the User to get in touch with independent lawyers and manage their case online. The service is operated by Top Consulting Ltd. (the "Operator"), which uses the Platform and the Legaless® trademark under licence. The Operator does not provide legal services and assumes no professional liability for the work of the lawyers, who act with full autonomy in their relationship with the User, under their own exclusive ethical and professional responsibility.
Art. 1 – Preliminary provisions and purpose
1.1. This document ("T&C") governs the general terms of use of the Legaless® digital platform (hereinafter also the "Platform"), accessible at www.legaless.it, as well as the rights and obligations of the User who accesses it, pursuant to Legislative Decree no. 70 of 9 April 2003 (implementing Directive 2000/31/EC on electronic commerce), Regulation (EU) 2022/2065 (Digital Services Act), the Consumer Code (Legislative Decree 206/2005) and all other applicable legislation.
1.2. These T&C govern exclusively the relationship between the User and the Operator. They do not in any way govern the professional relationship between the User and the Lawyer, which is established by separate agreements between the parties and is governed by the relevant legislation and by the rules of professional conduct for lawyers.
1.3. The T&C are accepted by ticking the relevant box (checkbox) when registering the Account or sending a Service request. If they are not accepted, the Platform cannot be used.
Art. 2 – Definitions
Account means the User's personal profile on the Platform, containing the related Data, through which the User can request the Services, monitor their Case and communicate with the Lawyer in charge.
AML means the rules on the prevention of money laundering and terrorist financing under Legislative Decree no. 231 of 21 November 2007 as amended.
Lawyer (both singular and plural) refers to the legal professional registered with the relevant Bar Association, who operates with full professional and tax autonomy and who may be engaged by the User through the Platform. The Lawyer is independent of the Operator and the Licensor and assumes in their own name every professional obligation towards the User.
Data means all information, documents and copies of documents shared by the User on the Platform or generated during its use.
IP Rights means the intellectual property rights relating to the Platform and the Legaless® trademark. This definition includes, by way of example and without limitation, all trademarks, copyright in the software, source code, graphical interface and editorial content, image rights, patents, rights in confidential information or innovative ideas, know-how, rights in business activities and trade names, domain names, whether registered or unregistered, and any other right or form of protection of a nature analogous or similar to any of them.
Fee means the consideration owed by the User to the Operator for the technological and organisational services offered through the Platform, included in the total price stated in the Quote.
Operator is Top Consulting Ltd., whose details are set out in art. 18, which operates the Platform in its own name and on its own behalf and is the User's contractual counterparty.
Licensor is Alessio D'Ascenzo, author and owner of the Platform and of the Legaless® trademark, who has granted the Operator a licence to use them. The Licensor does not operate the Service and is not a party to the relationship with the User.
Professional Mandate means the separate document, signed directly between the User and the Lawyer, by which the User engages the Lawyer to provide legal assistance for specific activities. The Operator is not a party to the Professional Mandate.
Service Packages means the various plans offering legal services, in multiple or ongoing form, requested by the User through Legaless® and agreed with one or more Lawyers by means of specific agreements.
Case means the request for which the User has confirmed the engagement of the Lawyer and which is handled within the Platform.
Quote means the total price of the Service, including the Lawyer's fee and the Fee, generated automatically by the Platform on the basis of the parameters entered by the User or prepared manually by the Lawyer.
Third-party Providers are the technology service providers used by the Platform:
– Third-party provider of electronic signature services on the Platform: Openapi S.p.A. (qualified service under Regulation (EU) 910/2014 — eIDAS, as amended by Regulation (EU) 2024/1183). Terms and conditions available at: https://legal.openapi.com/terms-and-conditions/term-and-condition-general-it.pdf
– Third-party provider of online payment services on the Platform: Stripe Payments Europe Ltd. Terms and conditions available at: https://stripe.com/en-it/legal/ssa/it-it
– Third-party provider of cloud hosting services for the Platform: Hostinger International Ltd. Terms and conditions available at: https://www.hostinger.it/legal/termini-del-servizio-universali
By accepting these T&C the User confirms that they have read, understood and fully accepted the terms and conditions of each of the Third-party Providers, available at the links above.
Service (both singular and plural) means the specific legal assistance service requested by the User through Legaless® from one or more Lawyers.
T&C refers to this Terms and Conditions document, as updated from time to time.
User (both singular and plural) refers to the person (an adult natural person or a legal entity), resident in the European Economic Area (EEA), who uses Legaless®.
Art. 3 – Legal nature of the Platform
3.1 Legaless® is an information society service, within the meaning of Legislative Decree 70/2003 and Reg. (EU) 2022/2065, provided by the Operator, which makes available to the User a structured digital space to:
a) get in touch with one or more independent Lawyers;
b) receive Quotes, formalise engagements and sign documents electronically;
c) make online payments for the Services;
d) follow the progress of the Case and communicate with the engaged Lawyer;
e) store the Data relating to the Case confidentially.
3.2 Unless otherwise provided, the Operator's activity is limited to providing and managing the technological and organisational tool. Every professional service is provided exclusively by the Lawyer engaged by the User, with full autonomy.
3.3 The Lawyers on the Platform are professionals who are independent of the Operator for tax, organisational and professional purposes.
There is no employment, quasi-employment, professional partnership, commercial agency or brokerage relationship between the Operator and the Lawyers. Each Lawyer:
a) invoices the User independently for their professional services;
b) is an independent controller of the User's personal data for the performance of the engagement received;
c) is covered by their own professional liability insurance policy pursuant to art. 12 of Law 247/2012;
d) is personally responsible for compliance with professional conduct, tax, social security and anti-money-laundering obligations.
3.4 The Fee paid to the Operator is consideration for technological and organisational services. A Case is assigned to a particular Lawyer either directly by the User or through neutral organisational criteria (area of expertise, availability, language) and in no case constitutes a recommendation, advice or guarantee as to the quality of the professional service.
Art. 4 – How the Platform works
4.1 Registration and Account. The User creates an Account by providing truthful, accurate and complete data. The User keeps their credentials safe with due care and is solely and directly responsible for every activity carried out through their Account. The Operator is not liable for unauthorised access or misuse attributable, even only indirectly, to the User's conduct.
4.2 Service request and Quote. By filling in the relevant form, the User receives, where possible, an automatic Quote calculated on the basis of the information provided. For Services of variable complexity the Quote is prepared manually by the Lawyer after reviewing the case.
4.3 Validity of the Quote. Unless otherwise expressly stated in the Quote itself, the Quote is valid for 30 (thirty) days from the date of issue, after which it lapses automatically. The Operator and the Lawyer reserve the right to withdraw or amend the Quote in the event of a substantial change in the underlying circumstances (e.g. facts not disclosed by the User coming to light, changes in the applicable lawyers' fee scales, supervening conflicts of interest). The automatic calculation of the Quote is based on the information provided by the User: if that information is untrue or incomplete, the Lawyer may redetermine the fee before the professional engagement is accepted and assigned.
4.4 Acceptance of the Quote and engagement. Having received the Quote, the User may accept it by making payment through the channels provided by the Platform. The assignment of the professional engagement, whether by accepting the quote or by signing the Professional Mandate, where required, concerns exclusively the relationship between the User and the Lawyer.
A signature applied electronically through the Platform's system has evidential value under Reg. (EU) 910/2014 and Legislative Decree 82/2005 (CAD).
4.5 Subcontracting and use of the Lawyer's associates. The User acknowledges and accepts that the engaged Lawyer, in performing the professional engagement, may make use of their own office associates, qualified trainees, substitute counsel at hearings and local agents, under their own exclusive direction and responsibility. The Lawyer remains the User's sole point of contact and sole controller of the related data, unless otherwise agreed. Any sub-engagements of specialist colleagues or lawyers from other courts are arranged by the Lawyer independently and notified to the User in advance where they entail additional costs.
4.6 Performance of the Service. The Lawyer performs the Service in accordance with the conditions agreed in the quote and/or in the professional engagement.
Communications and updates on the status of the Case take place through the Platform's tools (internal chat, timeline, notifications). The User acknowledges that the Platform stores these communications for evidential and security purposes (see art. 16.3).
4.7 Payments. Payments are made through Stripe, to the Operator's account or, for Quotes prepared manually by the Lawyer, where provided, directly to the Lawyer's Stripe account linked to the Platform.
a) The sums paid by the User are processed by Stripe. The Lawyer receives the consideration for the professional service rendered to the User; the Operator is entitled to the Fee.
b) In any event, the Lawyer remains the sole provider of the legal service and the only party responsible for its performance and invoicing to the User; the Operator is responsible for the tax treatment of the Fee.
4.8 Service Packages. Service Packages are governed by the specific conditions agreed between the User and the Lawyer and set out in the offer. Any provision of continuous or recurring services is governed by the individual agreement between the User and the Lawyer, including duration, cancellation terms and any unused hours.
Art. 5 – Consumer's right of withdrawal
5.1 A User acting as a consumer under the Consumer Code has the right to withdraw from the contract concluded with the Operator within 14 (fourteen) days of its conclusion, without giving any reason and without any charge other than those provided for in art. 5.3 (arts. 52 et seq., Legislative Decree 206/2005), by sending an explicit statement to supporto@legaless.it.
5.2 Pursuant to arts. 51, paragraph 8, and 59, paragraph 1, letter a), of the Consumer Code, the consumer User – when accepting the Quote and in any case when the engagement is assigned – confirms their wish for performance of the Service to begin before the 14-day withdrawal period expires; if the consumer User intends to exercise the right of withdrawal under the Consumer Code, they must expressly request that performance be postponed by 14 days. Full performance of the Service results in the loss of the right of withdrawal.
5.3 If the Service has been only partially performed at the time of withdrawal, the User will be required to pay an amount proportionate to the services rendered up to that point, including the Fee, without prejudice to any further consequences arising from professional work already under way (e.g. pending court action).
5.4 This article does not apply to a User who is a legal entity or a professional acting in the course of their commercial, business, craft or professional activity.
Art. 6 – User obligations and warranties
6.1 The User undertakes to:
a) use the Platform in good faith, properly and in compliance with Italian and European law;
b) provide truthful, accurate, complete and up-to-date information, including for the correct calculation of the Quote;
c) not create false identities or impersonate others;
d) keep their credentials safe and promptly inform the Operator of any unauthorised access;
e) ensure that the Data shared do not infringe third-party rights (including intellectual property rights, privacy and professional confidentiality);
f) refrain from any conduct that may harm the Platform, the Operator, the Licensor, the Lawyers or other Users;
g) refrain from transmitting unlawful, fraudulent, obscene, discriminatory, defamatory or threatening content, or content containing viruses, malware or harmful code;
h) refrain from using the Platform for unlawful purposes or to develop competing services;
i) cooperate with the Lawyer by promptly providing the information, documents and elements needed to perform the Service and for any AML obligations incumbent on the Lawyer.
6.2 Indemnity. The User indemnifies and holds harmless the Operator and the Licensor against any claim, complaint, dispute, legal action or penalty, and against any damage, cost, charge and expense (including legal fees) arising, even indirectly, from the breach of the obligations set out in this article, from unlawful use of the Platform or from the dissemination of unlawful content.
6.3 Notice & Action (DSA). Pursuant to arts. 16 et seq. of Reg. (EU) 2022/2065, anyone who believes that content on the Platform is unlawful may send a reasoned notice to supporto@legaless.it, indicating the content, its location and the reasons for the notice. The Operator assesses the notice and, where the conditions are met, takes measures to remove or disable access, informing the notifier and the recipient.
Art. 7 – Anti-money laundering and conflicts of interest
7.1 The User acknowledges that, under Legislative Decree 231/2007, the Lawyer is subject to customer due diligence, record-keeping and suspicious transaction reporting obligations for services falling within their scope (in particular those listed in art. 12 of the same decree). AML obligations are the exclusive responsibility of the Lawyer, as the obliged entity, who fulfils them as independent controller of the related personal data and keeps the relevant documentation for the statutory period (10 years). The Platform only provides the technological tools for collecting the data and documents requested by the Lawyer, without the Operator taking on the role of obliged entity. The User undertakes to provide the Lawyer, truthfully and promptly, with all the elements requested for due diligence purposes; failure to do so, or incomplete compliance, may lead the Lawyer to abstain from performing the Service pursuant to art. 42 of Legislative Decree 231/2007.
7.2 The prior check for potential conflicts of interest under arts. 24 and 68 of the Italian Code of Professional Conduct for Lawyers is the exclusive competence and responsibility of the engaged Lawyer, before accepting the professional engagement. The Operator does not carry out, and is not required to carry out, any substantive check on the existence of conflicts of interest between the Cases handled on the Platform and is not liable for any conflicts not identified by the Lawyer. If the Lawyer, even after accepting the engagement, identifies a conflict of interest or another ethical reason to abstain, they must promptly inform the User and withdraw from the engagement in the manner provided for by the rules of professional conduct; in that case the Operator, with the User's consent, may make the Case available for assignment to another available Lawyer.
Art. 8 – Obligations and liability of the Operator
8.1 The Operator undertakes to provide the Platform with the technical diligence that can reasonably be expected, as an obligation of means and not of result.
The Operator does not guarantee that the Platform will be free of errors, interruptions or malfunctions, but will endeavour to ensure that these are resolved within a reasonable time.
8.2 The Operator assumes no liability, direct or indirect, for the professional work of the Lawyers, for the quality, timeliness, accuracy, completeness or outcome of the legal services, for any errors, omissions, delays or breaches by the Lawyer, for the Lawyer's professional conduct, for any undetected conflicts of interest, for failed or incorrect AML compliance, or for any consequence arising from the professional engagement assigned. Any claim relating to the professional work must be addressed exclusively to the engaged Lawyer.
8.3 The Operator is not liable for malfunctions, interruptions, errors or breaches attributable to Third-party Providers (Stripe, Openapi, Hostinger, telecommunications operators, etc.), save for wilful misconduct or gross negligence in selecting them. The relationship between the User and each Third-party Provider is governed by the respective terms of use, which the User declares to have read, understood and accepted by accepting the T&C.
8.4 Limitation of liability. Save in cases of wilful misconduct or gross negligence, and without prejudice to the consumer's mandatory rights, the Operator's total liability towards the User, on any basis (contractual, non-contractual, restitutionary), is in any case limited to the total amount of the Fee actually received by the Operator in relation to the User's Cases in the 6 (six) months preceding the event giving rise to the liability.
8.5 Indirect damages, loss of profit, loss of opportunity, loss of data not attributable to the Operator, reputational damage and business interruption damage are excluded in all cases.
8.6 The Operator is not liable for failures to perform due to force majeure, fortuitous events, acts of third parties or of the User, orders of the authorities, or cyber attacks despite the adoption of adequate security measures.
8.7 The Licensor is not a party to the relationship with the User and assumes no obligation or liability towards the User or the Lawyers in relation to the Service, without prejudice to mandatory legal limits. Any claim relating to the Service must be addressed to the Operator.
Art. 9 – Maintenance, suspension and modification of the Platform
9.1 The Operator, including through the Licensor, may carry out maintenance, update and security work on the Platform, minimising the impact on the User as far as possible. Where the work entails a significant suspension, the Operator gives notice of it with reasonable advance warning.
9.2 The Operator may unilaterally suspend or modify the Platform's features, in whole or in part:
a) to comply with legal or regulatory obligations or orders of the authorities;
b) to address security threats, fraud, cyber attacks or data breaches;
c) due to supervening technical, economic or organisational needs.
9.3 The Operator reserves the right to discontinue the Platform permanently with no less than 20 (twenty) days' notice, during which the User may download their Data.
9.4 Amendments to the T&C, justified by regulatory, technical or organisational reasons, are notified to the User with 10 (ten) days' notice via the Account and/or email. The User may withdraw without charge within that period; if they do not withdraw, the amendments are deemed accepted.
Art. 10 – Intellectual property
10.1 All IP Rights relating to the Platform, the "Legaless®" trademark (European Union trademark no. 018727049, registered with the EUIPO), the software, source code, design, editorial content, template documents and every other element are exclusively owned by the Licensor and are used by the Operator under licence. Nothing in these T&C entails any assignment or grant to the User, even partial or temporary, of such rights, except as provided in art. 10.2.
10.2 The Operator grants the User, within the limits of the licence available to it, a personal, temporary, non-exclusive, non-transferable, non-sublicensable and revocable right to use the Platform, limited to the duration of the relationship.
10.3 The User undertakes not to:
a) reproduce, modify, decompile, disassemble, reverse engineer, translate or adapt the software or create derivative works;
b) license, sell, rent, distribute or transfer access to the Platform to third parties;
c) carry out penetration or vulnerability tests or DoS/DDoS attacks;
d) use Legaless® trademarks, logos or distinctive signs without prior written authorisation.
10.4 The User retains ownership of the content uploaded. However, the User grants the Operator a non-exclusive, free and limited licence, valid for the duration of the relationship and for the time needed to comply with statutory retention obligations, to use such content exclusively for providing the Platform and for related technical and operational purposes.
10.5 Any opinions, comments, suggestions or feedback sent spontaneously by the User may be used to improve the Platform, without any obligation to pay or give credit.
Art. 11 – Processing of personal data
11.1 The processing of the User's personal data is governed by the Privacy Policy, which forms an integral part of these T&C.
11.2 The User acknowledges and accepts that:
a) the Operator processes the data as independent controller for the technical and organisational purposes of the Platform, using the Licensor as processor for hosting, backup, maintenance and technical support;
b) the engaged Lawyer processes the data as independent controller for the performance of the professional engagement and for the professional conduct, AML and legal obligations incumbent on them;
c) the transmission of the Data to the Lawyer is a necessary condition for providing the requested Service.
11.3 Retention after the relationship ends. The Operator and the Lawyer are independent controllers with separate and non-overlapping retention obligations. The end of the relationship between the User and the Operator, or a deletion request addressed to the Operator, does not affect the retention periods binding on the Lawyer under professional conduct obligations (arts. 33 and 50 of the Code of Professional Conduct for Lawyers), AML (art. 31 of Legislative Decree 231/2007), tax obligations (art. 2220 of the Civil Code) and for the defence of their own rights (art. 9.2.f GDPR). Likewise, the end of the professional engagement between the User and the Lawyer does not affect the retention periods binding on the Operator for its own obligations. Data subject rights must be exercised separately against each controller for the data within their respective competence.
11.4 Continuity of the Service. If the licence granted by the Licensor to the Operator ends for any reason, the Data are communicated to the Licensor or to the party designated by the Licensor, which becomes their independent controller in order to ensure the continuation of the Service and of the Cases in progress, within the limits of the GDPR and as set out in the Privacy Policy.
Art. 12 – Suspension of the User
12.1 The Operator may suspend or restrict the User's access to the Platform, even without notice, in the event of:
a) breach of the T&C or of applicable law;
b) conduct that may harm the Operator, the Licensor, the Lawyers, other Users or the security of the Platform;
c) late payment or non-payment for the Services;
d) orders or requests from the competent authorities;
e) supervening impossibility of supply.
12.2 The suspension is notified to the User, stating the reasons and, where possible, the actions needed to restore access.
Art. 13 – Termination of the relationship
13.1 The relationship governed by the T&C is of indefinite duration from the date of acceptance.
13.2 Withdrawal by the User. The User may withdraw at any time using the account closure function in their private area, or by writing to supporto@legaless.it. After 5 (five) days from the request, the Account and the Data pertaining to the Operator are removed within the limits set out in the Privacy Policy (§7) and in art. 11.3 (subject to statutory retention obligations). The User is responsible for downloading the Data before removal. For Service Packages in progress, the specific notice periods provided for therein apply.
13.3 Withdrawal by the Operator. The Operator may withdraw at any time, without giving reasons and without compensation, by giving the User at least 20 (twenty) days' written notice.
13.4 Termination. In the event of a serious breach of the T&C or of applicable law by the User, the Operator may terminate the relationship pursuant to art. 1456 of the Civil Code with immediate effect, by written notice, without prejudice to the right to compensation for damage.
13.5 Once the relationship has ended, access to the Account is disabled and the Data are removed within the periods set out in art. 11.3.
The end of the relationship with the Operator does not affect the professional engagement in place with the Lawyer, which remains independently governed by its own terms.
Art. 14 – Assignment of the contract
14.1 The Operator may assign, in whole or in part, the relationship governed by the T&C, provided that the User's rights are not prejudiced. The assignment is notified to the User with reasonable notice.
14.2 The User acknowledges and specifically accepts, for all purposes of arts. 1406 et seq. of the Civil Code, that if the licence granted by the Licensor to the Operator ends for any reason, the relationship governed by the T&C, the User's Account and the related contractual relationships in place may be assigned to the Licensor or to the party designated by the Licensor. This article constitutes the User's prior consent to the assignment pursuant to art. 1407 of the Civil Code, subject to the following conditions:
a) the assignee fully takes over the rights and obligations of the Operator towards the User, on the same conditions;
b) the assignment does not entail any reduction in the protection of the rights of the consumer User (art. 33, paragraph 2, letter s), Legislative Decree 206/2005);
c) the assignment is notified to the User with at least 20 days' notice via the Account and/or email; within that period the User may withdraw without charge.
Art. 15 – Force majeure
In the event of force majeure (natural events, conflicts, acts of authorities, pandemics, massive cyber attacks, large-scale network outages, etc.), the Operator's obligations are suspended for the duration of the event. If the event lasts more than 30 (thirty) consecutive days, either party may withdraw without compensation.
Art. 16 – Final provisions
16.1 The User declares that they have the legal capacity and powers needed to enter into these T&C, that they are of age (≥ 18 years) and, if a legal entity, that they operate in the course of their professional or business activity, with the consequent exclusion of the Consumer Code rules. When creating their account and/or when requesting the Service, the User declares whether they are acting as a consumer or in the course of their business or professional activity.
16.2 The parties are independent contractors. The T&C do not create an employment, mandate, agency, partnership, joint venture or franchising relationship.
16.3 The User expressly accepts that the electronic records kept in the systems of the Platform and of the Third-party Providers, including communications, access logs, electronic signatures and payment confirmations, constitute evidence of the transactions and agreements concluded, provided that the party from which they originate can be identified and their integrity is guaranteed.
16.4 Failure to exercise a right does not constitute a waiver. The invalidity or ineffectiveness of a clause does not affect the validity of the remaining clauses.
16.5 The User may submit complaints or requests for assistance to supporto@legaless.it. Indicative response time: 5 working days.
16.6 ADR. The consumer User may also contact the mediation bodies accredited under Legislative Decree 28/2010 and Legislative Decree 130/2015.
16.7 The following articles survive the end of the relationship: 6.2 (indemnity), 7 (AML and conflicts), 8 (liability), 10 (intellectual property), 11.3 and 11.4 (retention and continuity), 14.2 (assignment), 16.3 (evidence), 16.7, 17 (law and jurisdiction).
16.8 Words in the singular include the plural and vice versa; references to legislation are to the text in force; amounts are in euro.
Art. 17 – Governing law and jurisdiction
17.1 The relationship is governed by Italian law, without prejudice to the mandatory consumer protection provisions of the State of habitual residence of the consumer User.
17.2 The parties will attempt to settle any dispute amicably. Failing that:
a) for the consumer User, the court of the consumer's place of residence or elected domicile has jurisdiction, pursuant to art. 66-bis of the Consumer Code;
b) for a User acting as a company or professional, the Court of Rome has exclusive jurisdiction, unless another mandatory forum applies by law.
Art. 18 – Operator's details (art. 7 of Legislative Decree 70/2003)
Operator of Legaless®: Top Consulting Ltd., a company incorporated under Maltese law, represented by its legal representative pro tempore, with registered office at Triq L-Imsida, GZR 1400, Gzira, Malta, registered with the Malta Business Registry under no. C 115432, VAT number MT3273-4036, email: supporto@legaless.it.
Art. 19 – Transitional provision
From 1 October 2026 the Platform is operated by Top Consulting Ltd. For Users who accepted a previous version of the T&C, the relationship is transferred to Top Consulting Ltd. under art. 14.2 of that version, with effect from the date stated in the notice of transfer sent via the Account and/or by email; unless expressly refused, these T&C apply from that date. Cases in progress continue without interruption with the same Lawyer and on the same financial terms.
Clauses specifically approved under arts. 1341 and 1342 of the Civil Code
The User, for all purposes of arts. 1341 and 1342 of the Civil Code, declares that they have read, understood and specifically approved the following clauses: Art. 3 (Legal nature of the Platform – exclusion of legal services by the Operator and independence of the Lawyers); Art. 4.3 (Validity and withdrawal of the Quote); Art. 4.5 (Subcontracting and use of the Lawyer's associates); Art. 4.7 (Payments – nature of the Fee); Arts. 5.3-5.4 (Early performance, loss and exclusions of the right of withdrawal); Art. 6 (User obligations and indemnity); Art. 7 (Anti-money laundering and conflicts of interest — exclusion of the Operator's liability); Art. 8 (Exclusion and limitation of liability, capped at 6 months of Fees; exclusion of the Licensor's liability); Art. 9 (Maintenance, suspension, unilateral modification); Art. 10 (Intellectual property and licences); Arts. 11.3-11.4 (Separate retention periods for Operator and Lawyer; communication of Data to the Licensor when the licence ends); Art. 12 (Suspension of the User); Art. 13 (End of the relationship and withdrawal); Art. 14.2 (Prior consent to assignment to the Licensor or to the party designated by the Licensor); Art. 16.3 (Evidential value of electronic records); Art. 16.7 (Survival of clauses); Art. 17 (Governing law and jurisdiction).
PRIVACY POLICY
Version of 1 October 2026
Notice provided pursuant to arts. 13 and 14 of Regulation (EU) 2016/679 ("GDPR") and, where applicable, art. 122 of Legislative Decree 196/2003 ("Privacy Code"), as amended by Legislative Decree 101/2018.
1. Data controller
Data controller: Top Consulting Ltd., operator of the Legaless® platform, represented by its legal representative pro tempore, with registered office at Triq L-Imsida, GZR 1400, Gzira, Malta, registered with the Malta Business Registry under no. C 115432, VAT number MT3273-4036, email: supporto@legaless.it.
No Data Protection Officer (DPO) has been appointed, as the conditions of art. 37 GDPR do not apply.
The Platform and the Legaless® trademark are owned by Alessio D'Ascenzo (the "Licensor") and are used by the Controller under licence.
2. Roles and structure of the processing
The Legaless® Platform puts the User in touch with independent lawyers. It is important that the User understands who processes their data and for what purposes:
| Party | Role | Scope of processing |
|---|---|---|
| Top Consulting Ltd. (operator of Legaless®) | Independent controller and Processor (art. 28 GDPR) | Operation of the Platform, Account management, security, invoicing of the Fee, legal obligations incumbent on it; receipt, storage and transmission of the Case data (requests, documents, chat) for the drafting of Quotes, the assignment of engagements and communication between User and Lawyer.
Hosting, backup, maintenance and technical support of the Platform, on the Controller's documented instructions; does not use the data for its own purposes or to train artificial intelligence systems |
| Assigned lawyer | Independent controller | Performance of the Professional Engagement, drafting of documents, legal defence, ethical and anti-money-laundering (AML) obligations under Legislative Decree 231/2007 |
| Third-party Providers (Stripe, Openapi, Hostinger, etc.) | Processors or sub-processors, or independent controllers (see § 9) | Technical operation of the related features |
The Controller accesses Case data only to the extent necessary to prepare Quotes, assign engagements, provide assistance and ensure the security of the Platform, through authorised staff bound by confidentiality. The Lawyer is an independent controller and handles directly with the User their own privacy notice for professional, ethical and anti-money-laundering purposes.
Requests to exercise rights must be addressed to the competent controller according to the purpose of the processing (see § 7 and § 10).
3. Categories of data processed
Depending on the interaction with the Platform, the Controller processes:
a) Personal and contact details: first name, surname, email, telephone, residence, tax code, VAT number;
b) Identification data: copy of an identity document, where necessary to perform the Service or for the Lawyer's anti-money-laundering obligations (in that case the data are transmitted to the Lawyer, who processes them as independent controller under Legislative Decree 231/2007);
c) Account data: login credentials (encrypted), settings, preferences;
d) Case data: description of the case, uploaded documents, chat communications, quotes, mandates. They may include special categories of data (art. 9 GDPR) – e.g. data concerning health, sex life, racial or ethnic origin, political opinions, religious beliefs – where relevant to the legal case; and data relating to criminal convictions and offences (art. 10 GDPR);
e) Payment data: handled entirely by Stripe; the Controller only receives transaction data (amount, outcome, identifier);
f) Electronic signature data: handled by Openapi (telephone number for OTP, signature logs);
g) Usage data: IP address, access logs, browser type, operating system, pages visited, timestamps;
h) Communication data: messages sent through the internal chat and by email.
The User is responsible for the accuracy, completeness and updating of the data provided, and for the lawfulness of communicating third-party data.
4. Purposes and legal bases of the processing
| # | Purpose | Legal basis (art. 6 GDPR) | Legal basis for special categories (art. 9) |
|---|---|---|---|
| 4.1 | Creating and managing the Account | Performance of the contract (art. 6(1)(b)) | — |
| 4.2 | Providing the Platform's features (requests, quotes, chat, signature, payments) | Performance of the contract (art. 6(1)(b)) | Explicit consent where special categories of data are involved (art. 9(2)(a)); or the establishment, exercise or defence of legal claims (art. 9(2)(f)) |
| 4.3 | Compliance with the Controller's legal obligations (tax, accounting, orders from authorities, DSA) | Legal obligation (art. 6(1)(c)) | Art. 9(2)(g) (reasons of substantial public interest) where applicable |
| 4.4 | Platform security, fraud prevention, access logs | Legitimate interest (art. 6(1)(f)) | — |
| 4.5 | Customer support and complaint handling | Performance of the contract / legitimate interest | — |
| 4.6 | Sending service communications (notifications, Case updates) | Performance of the contract (art. 6(1)(b)) | — |
| 4.7 | Sending the Controller's newsletters / promotional communications | Consent (art. 6(1)(a)), which can be withdrawn at any time | — |
| 4.8 | Soft spam about similar Services already requested (art. 130(4), Legislative Decree 196/2003) | Legitimate interest, with the right to object | — |
| 4.9 | Defence of a right in court or out of court | Legitimate interest (art. 6(1)(f)) | Art. 9(2)(f) |
| 4.10 | Aggregate statistics and service improvement | Legitimate interest (art. 6(1)(f)) | — |
| 4.11 | Continuity of the Service if the Platform licence ends: communication of the data to the Licensor or to the party designated by the Licensor (see § 8) | Performance of the contract (art. 6.1.b) and legitimate interest in continuing the Cases in progress (art. 6.1.f) | Art. 9.2.f, limited to what is necessary to continue the Cases |
Mandatory or optional provision. Providing the data under points 4.1–4.6 is necessary to perform the Service: failure to provide it prevents use of the Platform. Providing data for purpose 4.7 is optional and does not affect use of the Platform.
AML processing. Processing related to anti-money-laundering due diligence, record-keeping and reporting obligations is carried out by the Lawyer as the obliged entity and independent controller under Legislative Decree 231/2007 (see § 7). The Controller does not act as an AML obliged entity.
5. Technological tools and artificial intelligence
The Controller may use automation tools and artificial intelligence models solely for internal editorial, organisational and management support purposes (e.g. drafting internal drafts, classifying requests, helping write standard quotes). These tools are not fed with Case data, nor used to take automated decisions producing legal effects on the User, nor to profile the User within the meaning of art. 22 GDPR. The Lawyer remains solely responsible for the professional assessments and for the content delivered to the User.
6. Processing methods and security
Data are processed using electronic tools and organisational procedures suitable for ensuring their security, integrity and confidentiality, in accordance with art. 32 GDPR. The measures adopted, including through the processor, include among others:
– encryption of sensitive data in transit (TLS) and at rest;
– two-factor authentication for privileged access;
– segregation of roles and the principle of least privilege;
– web application firewall (WAF), intrusion detection systems, anti-malware;
– periodic backups and disaster recovery procedures;
– incident management and data breach notification procedures under arts. 33-34 GDPR;
– periodic security audits.
Despite these measures, no IT system is entirely free of risk. The Controller undertakes to notify the competent supervisory authority and — where required — the User of any data breaches in accordance with applicable law.
7. Retention periods
The Controller and the Lawyer are independent controllers with separate retention obligations. This section governs retention by the Controller; for retention by the Lawyer, please refer to the Lawyer's own privacy notice, which the Lawyer provides directly to the User.
7.1 Retention by the Controller
| Category | Retention period |
|---|---|
| Data of Accounts in use | For the duration of the relationship |
| Data relating to completed Cases (Platform side) | Documents and chats of completed Cases: 24 months from completion. Quotes, mandates and transaction data: 10 years from completion of the Case (consistent with the limitation periods under art. 2946 of the Civil Code and with document retention obligations) |
| The Controller's tax and accounting records | For the period required by the tax and accounting rules applicable to the Controller, and in any case no longer than 10 years |
| Technical and security logs | Up to 12 months, unless retention is needed for investigations |
| Marketing data (consent) | Until consent is withdrawn, and in any case no longer than 24 months after the last interaction |
| Inactive account | After 24 months of inactivity, the User is asked to confirm whether they wish to keep the Account; if there is no reply within 30 days of the message, the Account is closed and the data deleted or anonymised (subject to the retention obligations above) |
7.2 Retention by the Lawyer
The Lawyer, as independent controller, retains the User's data for the periods and within the limits set by their own legal obligations, in particular:
– documentation in the professional file: for the time needed to defend the rights of the client and of the Lawyer, consistent with the applicable limitation periods (generally, at least 10 years from the end of the mandate, under art. 2946 of the Civil Code);
– AML documentation (customer due diligence, record keeping, reports): 10 years from the end of the ongoing relationship or from the performance of the occasional service, pursuant to art. 31 of Legislative Decree 231/2007;
– tax and accounting documentation: 10 years under art. 2220 of the Civil Code and art. 22 of Presidential Decree 600/1973.
7.3 Effects of the end of the relationship on the separate controllers
The end of the relationship with the Controller, or a deletion request addressed to the Controller, does not automatically affect the retention periods binding on the Lawyer, and vice versa. To obtain full deletion of the data, the User must exercise their rights separately against each controller. In any case, the legal limits on mandatory retention remain unaffected (e.g. AML, tax, defence of a right).
8. Recipients of the data
Data may be communicated to:
a) engaged Lawyers, as independent controllers, for the performance of the Professional Mandate and for the AML, professional conduct and tax obligations incumbent on them;
b) collaborators and authorised staff of the Controller, designated as persons authorised to process data and bound by confidentiality;
c) the Licensor, designated processor under art. 28 GDPR for hosting, backup, maintenance and technical support, and its sub-processors (currently Hostinger International Ltd.);
d) other technical service providers designated as processors under art. 28 GDPR (security, support, automation tools);
e) Third-party Providers for payments (Stripe), electronic signature (Openapi) and hosting (Hostinger), as specified in § 9;
f) Advisers (accountant, the Controller's lawyer) for professional obligations and defence;
g) Judicial and administrative authorities in the event of lawful requests (including the FIU and the Guardia di Finanza for AML purposes, upon lawful request);
h) if the licence to use the Platform ends for any reason, the Licensor or the party designated by the Licensor, which becomes their independent controller solely in order to ensure the continuation of the Service and of the Cases in progress (purpose 4.11). The User is informed of this as described in § 13.
Data are not disclosed to the public and are not transferred to third parties for their own direct marketing purposes.
9. Third-party Providers and transfers outside the EU
| Provider | Function | Location and transfers |
|---|---|---|
| Stripe Payments Europe Ltd. | Online payments, to the Controller's account or, where provided, to the Lawyer's Stripe account linked to the Platform | Based in the EU (Ireland). Any transfers to Stripe Inc. (USA) take place on the basis of the European Commission's Standard Contractual Clauses (Decision 2021/914) and, where applicable, the EU-US Data Privacy Framework. |
| Openapi S.p.A. | eIDAS electronic signature | Registered office in the EU (Italy). |
| Hostinger International Ltd. | Hosting and infrastructure (sub-processor through the Licensor) | Based in the EU/EEA (European data centres). |
Any other providers may be indicated at the User's request by writing to supporto@legaless.it. Data are processed within the European Economic Area; for transfers outside the EU/EEA, where necessary, the Controller adopts the safeguards provided for in arts. 44-49 GDPR (adequacy decisions, Standard Contractual Clauses, supplementary measures).
10. User rights
The User may exercise the following rights at any time, within the limits of the law:
– Access (art. 15 GDPR) – find out which data are processed and obtain a copy;
– Rectification (art. 16) – correct inaccurate data or complete them;
– Erasure / right to be forgotten (art. 17) – request removal of the data, within the limits provided;
– Restriction (art. 18) – temporarily restrict the processing;
– Portability (art. 20) – receive the data in a structured, commonly used, machine-readable format and transmit them to another controller;
– Objection (art. 21) – object to processing based on legitimate interest or for direct marketing;
– Withdrawal of consent (art. 7.3) – at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
– Complaint to the supervisory authority (art. 77) – in the Member State of habitual residence, place of work or place of the alleged infringement. In particular: Garante per la protezione dei dati personali, Piazza Venezia 11, 00187 Rome, garante@gpdp.it, www.garanteprivacy.it; or the authority of the State where the Controller is established, Information and Data Protection Commissioner (IDPC), Malta, www.idpc.org.mt;
– Not to be subject to automated decisions (art. 22) – the Controller does not take automated decisions producing significant legal effects.
Exercising rights against independent controllers
For data processed by the Controller, requests should be sent to supporto@legaless.it. For data processed by the Lawyer (performance of the Mandate, AML, professional conduct), requests should be sent directly to the Lawyer, who provides their own privacy notice.
Legal limits (e.g. AML, tax and right-of-defence retention obligations) may lead to certain requests being refused or deferred, with reasons given for the outcome.
The Controller responds within 30 days of receipt, extendable by a further 60 in complex cases (art. 12 GDPR).
11. Cookies
The use of cookies and similar technologies is governed by the specific Cookie Policy available on legaless.it, drawn up in accordance with the Italian Data Protection Authority's Provision of 10 June 2021.
12. Legal defence
The User's data may be used by the Controller, even after the relationship has ended, to establish, exercise or defend a right in court, within the limits of art. 9.2.f GDPR and of legal obligations.
13. Changes to this notice
The Controller reserves the right to update this notice. Changes will be communicated to the User via the Account and/or email. The current version is always available at legaless.it/privacy-policy/.
14. Minors
The Platform is intended exclusively for adults. The Controller does not knowingly collect data from minors. If the processing of a minor's data is detected, the Controller will delete it, unless otherwise authorised by the holder of parental responsibility pursuant to art. 8 GDPR.
15. Data collected before 1 October 2026
Until 30 September 2026 the controller of the data collected through the Platform was the previous operator. With the transfer of the relationships with Users to Top Consulting Ltd., the related personal data are transferred to Top Consulting Ltd., which becomes their controller from the effective date of the transfer for the same purposes set out in this notice. The previous controller retains only the data necessary to fulfil its legal obligations and to protect its rights, for the time strictly necessary for that purpose.
For definitions (including capitalised terms) in this document, please refer to the T&C.
For the definitions (including capitalised terms) used in this document, please refer to the T&C.
