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Giulia Provini

Giulia Provini

Senior Counsel

FIRST PRIVACY GmbH

Bremen

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Person viewing data profiles on their laptop.

Lusha Fined 2 Million Euros: Important Lessons About Data Enrichment

13.08.2026

Giulia Provini

The Italian Data Protection Authority (Garante) has fined Lusha Systems, a US-based data broker, 2 million euros. The case provides interesting compliance lessons for any company evaluating [...]

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A received email marked as important displayed on a tablet.

Italian DPA Fines Piaggio: Lessons on Employee Rights and Email Backup Management

11.08.2026

Giulia Provini

The Italian data protection authority (Garante) has fined Piaggio & C. S.p.A. €460,000 over its handling of two former employees' company email. The decision is relevant under many aspects […]

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Employee using a chat bot working on a laptop in their office.

AI Act Transparency Obligations Apply From 2 August 2026

30.07.2026

Giulia Provini

The AI Act classifies AI systems into four risk categories. One of them covers systems that pose transparency risks, and those systems are governed by Article 50. The obligations apply [...]

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Person checkt Zahlungsflüsse auf Bankkonto mit dem Smartphone.

The Italian DPA's Fine Against Intesa Sanpaolo: Lessons for Access Management and Data Breach Handling

09.04.2026

Giulia Provini

On 26 March 2026, the Italian data protection authority (Garante per la protezione dei dati personali, "Garante") fined Intesa Sanpaolo S.p.A. €31,800,000. This is one of the largest fines the Garante has ever imposed, and it carries clear lessons for a [...]

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A statue of Lady Justice against a blurred background of law books.

When Access Requests Become Abusive: Key Takeaways from C-526/24 Brillen Rottler

27.03.2026

Giulia Provini

The Court of Justice of the European Union (CJEU) has clarified in Brillen Rottler (C-526/24) that, in exceptional circumstances, even a first data subject access request (DSAR) may be refused as “manifestly unfounded or excessive” under Article 12 para. [...]

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Man making an online bank transfer on a laptop.

Unlawful Profiling and Poor Transparency: Key Takeaways from the Garante’s Fine Against Intesa Sanpaolo

25.03.2026

Giulia Provini

The Italian Data Protection Authority (Garante) has imposed a €17.6 million fine on Intesa Sanpaolo, one of the largest banking groups in Italy, for unlawful processing of personal data affecting approximately 2.4 million customers in the context of their [...]

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View of a soccer match in a stadium at night under floodlights.

Spanish AEDP v FC Barcelona: DPIA Required for Processing Biometric Data

20.03.2026

Giulia Provini

The Spanish Data Protection Authority (AEPD) recently imposed a €500,000 fine on Fútbol Club Barcelona for failing to properly conduct a Data Protection Impact Assessment (DPIA) when implementing biometric systems used during the club’s membership censu [...]

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Woman walking through the city center with a phone in her hand. Facial recognition around her face.

Biometric Data: Key GDPR Lessons from an AEPD Decision

18.03.2026

Giulia Provini

The Spanish Data Protection Authority (AEPD) recently imposed a €950,000 fine on a company offering digital identity and age verification services that rely on facial analysis technology. The decision is particularly relevant for organisations deploying fac [...]

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