Privacy Policy – Information for users of the website www.luccapromos.it

[Art. 13 European Union Regulation 2016/679 concerning the protection of individuals with regard to the processing of personal data and the free circulation of such data (hereinafter, Eu Regulation)]

The information and data provided by you or otherwise acquired in the context of the use of the services provided by the site www.luccapromos.it will be processed in compliance with the provisions of the Regulations and the confidentiality obligations that inspire the activity of LUCCAPROMOS Srlu (hereinafter LUCCAPROMOS).

According to the rules of the Regulation, the treatments carried out will be based on the principles of lawfulness, correctness, transparency, purpose limitation and storage, data minimization, accuracy, integrity and confidentiality.
This Privacy Policy applies only to the Site as defined above. The Site may contain links to other sites (so-called third party sites). LUCCAPROMOS does not carry out any checks on the relative methods of processing the user’s personal data, and expressly disclaims any related liability. The user is required to check the privacy policies of third party sites accessed through the Site and to inquire about the conditions applicable to the processing of their personal data.

1. The Personal Data object of the treatment.

Following navigation of the Site, we inform you that LUCCAPROMOS will process your Personal Data which may consist of an identifier such as your name, an identification number, an online identifier or one or more characteristic elements of your physical, economic, cultural or social suitable to make the interested party identified or identifiable.

Reference is made to navigation data, cookies, data voluntarily provided by the user as specified below.

a. Navigation data. The computer systems and software procedures used to operate the Site acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the Site, the URI (Uniform Resource Identifier) ​​addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user’s IT environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning, to identify anomalies and / or abuses, and are deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the site or third parties.

b. Cookies. The use of Cookies – or of other tracking tools – by the LUCCAPROMOS Site or by the owners of third party services that LUCCAPROMOS uses, unless otherwise specified, has the purpose of identifying the User and recording their preferences for purposes. strictly related to the performance of the requested service. Failure by the User to provide some Personal Data, and in particular the Browsing Data by disabling the site’s Cookies, could make it impossible to provide some services or to browse. For detailed information on the cookies used by the LUCCAPROMOS site, please refer to the appropriate section (section 10).

c. Data provided voluntarily by the interested party including: Sending e-mails to the addresses indicated on the site. The optional, explicit and voluntary sending of e-mails to the addresses indicated on the LUCCAPROMOS website entails the subsequent acquisition of the sender’s address, necessary to respond to requests as well as any other personal data included in the message.

Compilation of data collection forms for registration to events / conferences. The site allows interested parties to register for events, conferences, seminars that LUCCAPROMOS periodically organizes. The forms for collecting the data necessary for participation will be periodically made available on the site.

These data will be processed exclusively to allow participation in the event and for organizational purposes. Further information will be made available when the events are organized.

2. Purpose of the processing, basis of legitimacy and mandatory or optional nature of the processing.

The data processing we intend to carry out may have the following purposes:
a. to Allow the provision of the Services requested by you such as:

  • The generic request for information. The legal basis for the processing of Personal Data for the purposes indicated above is art. 6.1.b) (i.e. the execution of a contract of which the interested party is a party or execution of pre-contractual measures adopted at the request of the same) of the Regulation as the processing is necessary for the provision of the Services or for the response of requests from the ‘interested. The provision of Personal Data for these purposes is optional but failure to provide it would make it impossible to activate the Services provided by the Site.

b. fulfill any legal obligations. This purpose represents a processing of Personal Data carried out pursuant to art. 6.1.c) of the Regulations, for compliance with a legal obligation. Once the Personal Data has been provided, the processing is indeed necessary to fulfill a legal obligation to which LUCCAPROMOS is subject.

c. assert or defend rights in court, in the event of abuse in the use of the Site and / or our Services. The treatment would be carried out pursuant to art. 6.1.f) of the Regulations (legitimate interest of the owner)

3. Processing methods.

Data processing may be carried out through the use of electronic, telematic or automated tools, in compliance with the technical and organizational security measures referred to in art. 32 of the EU Regulation, by persons authorized to process and duly instructed and trained, in compliance with the provisions of art. 29 of the aforementioned Regulation

4. Recipients of Personal Data.

Your Personal Data may be shared, for the purposes indicated above, with:
a. to subjects who typically act as data processors pursuant to art. 28 of the Regulation, that is:

  1.  people, companies or professional firms that provide assistance and consultancy to LUCCAPROMOS in relation to the provision of the Services;
  2. subjects with whom it is necessary to interact for the provision of the Services (for example hosting providers);
  3. or subjects delegated to carry out technical maintenance activities (including maintenance of network equipment and electronic communication networks);
  4. the Chamber of Commerce also by virtue of the role of parent company; (collectively “Recipients”); the list of data processors who process data can be requested from the Data Controller.

b. subjects, bodies or authorities, independent data controllers, to whom it is mandatory to communicate your Personal Data by virtue of legal provisions or orders of the authorities;

5. Data retention.

The Personal Data processed for the purposes referred to in the section will be kept for the time strictly necessary to achieve those same purposes in compliance with the principles of minimization and limitation of conservation pursuant to art. 5.1.e) of the Regulations. If the processing requires the consent of the interested party, the Personal Data processed until the consent is revoked. More information about the data retention period and the criteria used to determine this period can be requested by writing to the Data Controller. Regarding the retention times of cookies, please refer to the specific section.

6. Transfer of data abroad.

The data will not be transferred outside the EU.

7. Rights of interested parties.

Pursuant to Articles 15 and following of the Regulation, you have the right to request access to your Personal Data, rectification or cancellation of the same, the limitation of processing in the cases provided for by art. 18 of the Regulation, obtain the data concerning you in a structured format, commonly used and readable by an automatic device, in the cases provided for by art. 20 of the Regulation. At any time, you can revoke pursuant to art. 7 of the Regulation the consent given; propose a complaint to the competent supervisory authority pursuant to article 77 of the
Regulation (Guarantor for the Protection of Personal Data (www.garanteprivacy.it) pursuant to art.77 of the Regulation, if it considers that the processing of your data is contrary to the law in force. You can formulate a request for opposition to the processing of your data pursuant to article 21 of the Regulation in which to highlight the reasons justifying the opposition: the Data Controller reserves the right to evaluate the request, which would not be accepted in case of existence of compelling legitimate reasons to proceed with the processing that prevail over your interests, rights and freedoms Requests must be sent in writing to the Data Controller.

8. Holder of the treatment.

The owner of the processing of personal data is LUCCAPROMOS Srlu, with registered office in Lucca, Corte Campana 10 – 55100 Lucca; Mail: lucca.promos@lu.camcom.it

9. Changes.

LUCCAPROMOS reserves the right to modify or simply update the content of this information, in part or completely, also due to changes in the applicable legislation. LUCCAPROMOS will inform you of these changes as soon as they are introduced and they will be binding as soon as they are published on the Site. LUCCAPROMOS therefore invites you to regularly visit this section to become aware of the most recent and updated version of the privacy policy in order to always be updated on the data. collected and the use that LUCCAPROMOS makes of them

10. Cookies and other online tracking tools.

This cookie policy refers exclusively to the website www.luccapromos.it and must be understood as an integral part of its Privacy Policy.

10.1. Definitions, characteristics and application of the legislation

Cookies are usually text strings that the websites (so-called publisher or “first party”) visited by the user or different sites or web servers (so-called “third parties”) place and store within a terminal device in the user’s availability (so-called “active” identifiers). Similar functions can be performed by other tools which, while using a different technology (so-called “passive” identifiers), allow for processing similar to those carried out through cookies.
Cookies and other technical identifiers. They are used for the sole purpose of “carrying out the transmission of a communication over an electronic communications network, or to the extent strictly necessary for the provider of an information society service explicitly requested by the contractor or by the user to provide this service” (cf. . art. 122, paragraph 1 of the Code). They do not require the acquisition of consent, but must be indicated in the information.
First and third party analytics cookies. They are comparable to cookies and other technical identifiers only if:

  • they are used only to produce aggregate statistics and in relation to a single site or a single mobile
    application;
  • for those of third parties, at least the fourth component of the IP address is masked;
  • third parties refrain from combining analytics cookies, thus minimized, with other processing (customer
    files or statistics of visits to other sites, for example) or from transmitting them to other third parties.
    However, third parties are allowed to produce statistics with data relating to multiple domains, websites
    or apps that can be traced back to the same publisher or business group.

The owner who carries out on his own the mere statistical processing of data relating to multiple domains, websites or apps related to it can also use the data in clear text, in compliance with the purpose constraint.

Cookies and other tracking identifiers with a non-technical function. Used to bring back to specific, identified or identifiable subjects, specific actions or behavioral patterns recurring in the use of the functions offered (pattern) in order to group the different profiles within homogeneous clusters of different size, so that it is also possible to modulate the provision of the service in an increasingly personalized way, as well as sending targeted advertising messages, i.e. in line with the preferences expressed by the user in the context of surfing the net.

The applicable cookie law is as follows: Articles 122 of the Code and 4, point 11), 7, 12, 13 and 25 of the Regulation. Provision Identification of simplified procedures for the information and the acquisition of consent for the use of cookies of 8 May 2014, hereinafter only “Provision”) and Guidelines for cookies and other tracking tools – 10 June 2021 of the Authority Guarantor.

10.2. Types of cookies used by the Site

The website www.luccapromos.it does not currently use any type of cookie. It does not use first-party (or proprietary) cookies or third-party cookies or profiling cookies.

10.3. cookie banner.

Currently on the site there is no cookie banner as there are no cookies that require it or other tracking tools.

update Octobre 14th, 2021