PRIVACY POLICY
Information on the processing of personal data
PURSUANT TO ARTICLES 13-14 EU REGULATION 2016/679
DATA SUBJECTS: WEB USERS - CONTACTS SECTION
www.promolakes.com, in its capacity as Data Controller of your personal data, pursuant to and for the effects of EU Regulation 2016/679, hereinafter 'GDPR', hereby informs you that the aforementioned legislation provides for the protection of data subjects with regard to the processing of personal data and that such processing will be based on principles of correctness, lawfulness, transparency and protection of your privacy and your rights.
Your personal data will be processed in accordance with the legislative provisions of the aforementioned regulation and the confidentiality obligations provided therein.
TYPES OF DATA COLLECTED
Among the Personal Data collected by this Application, either independently or through third parties, there are: Tracking Tool; email; Usage Data.
Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific informative texts displayed before the data collection itself. Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application. Unless otherwise specified, all Data requested by this Application are mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. In cases where this Application indicates certain Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability or operation of the Service. Users who have doubts about which Data are mandatory are encouraged to contact the Data Controller. The possible use of Cookies – or other tracking tools – by this Application or by the controllers of third-party services used by this Application, unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to the further purposes described in this document and in the Cookie Policy, if available.
The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application and guarantees that they have the right to communicate or disseminate them, releasing the Data Controller from any liability towards third parties.
METHODS AND PLACE OF PROCESSING OF COLLECTED DATA
Processing Methods
The Data Controller adopts appropriate security measures aimed at preventing unauthorized access, disclosure, modification or destruction of Personal Data. The processing is carried out using IT and/or telematic tools, with organizational methods and logics strictly related to the indicated purposes. In addition to the Data Controller, in some cases, other parties involved in the organization of this Application (administrative, commercial, marketing, legal personnel, system administrators) or external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) may have access to the Data, also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Data Processors can always be requested from the Data Controller.
Legal Basis of Processing
The Data Controller processes Personal Data relating to the User if one of the following conditions exists:
The User has given consent for one or more specific purposes; Note: in some jurisdictions, the Data Controller may be authorized to process Personal Data without the User's consent or another of the legal bases specified below, until the User objects ("opt-out") to such processing. This is not applicable, however, where the processing of Personal Data is governed by European legislation on Personal Data protection;
Processing is necessary for the performance of a contract with the User and/or for the execution of pre-contractual measures;
Processing is necessary to comply with a legal obligation to which the Data Controller is subject;
Processing is necessary for the performance of a task carried out in the public interest or for the exercise of official authority vested in the Data Controller;
Processing is necessary for the pursuit of the legitimate interest of the Data Controller or of third parties.
It is always possible to ask the Data Controller to clarify the concrete legal basis of each processing operation and in particular to specify whether the processing is based on law, provided for by a contract or necessary to conclude a contract.
Place
The Data is processed at the Data Controller's operating offices and in any other place where the parties involved in the processing are located. For more information, please contact the Data Controller. The User's Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of processing, the User can refer to the section relating to the details on the processing of Personal Data.
The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization of public international law or constituted by two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data. The User can verify if any of the transfers just described take place by examining the section of this document relating to the details on the processing of Personal Data or by asking the Data Controller for information by contacting them at the contact details provided at the beginning.
Retention Period
The Data is processed and stored for the time required by the purposes for which it was collected.
Therefore:
Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the completion of such contract.
Personal Data collected for purposes attributable to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.
When the processing is based on the User's consent, the Data Controller may retain Personal Data for a longer period until such consent is revoked. Furthermore, the Data Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority. At the end of the retention period, Personal Data will be deleted. Therefore, upon expiration of this term, the right of access, erasure, rectification and the right to data portability can no longer be exercised.
PURPOSES OF PROCESSING COLLECTED DATA
The User's Data is collected to allow the Data Controller to provide the Service, fulfill legal obligations, respond to requests or executive actions, protect their rights and interests (or those of Users or third parties), identify any malicious or fraudulent activities, as well as for the following purposes: Tag management, Contact management and message sending, Statistics and Display of content from external platforms.
To obtain detailed information on the purposes of processing and on the Personal Data processed for each purpose, the User can refer to the "Details on the processing of Personal Data" section.
Contact management and message sending
This type of service allows the management of a database of email contacts, telephone contacts or contacts of any other type, used to communicate with the User. These services may also allow the collection of data relating to the date and time of viewing of messages by the User, as well as the User's interaction with them, such as information on clicks on links included in the messages.
Tag management
This type of service is functional to the centralized management of tags or scripts used on this Application. The use of such services involves the flow of User Data through them and, if necessary, their retention.
Google Tag Manager (Google Ireland Limited) Google Tag Manager is a tag management service provided by Google Ireland Limited. Personal Data processed: Tracking Tool. Place of processing: Ireland – Privacy Policy.
Statistics
The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behavior.
Google Analytics with anonymized IP (Google Ireland Limited) Google Analytics is a web analysis service provided by Google Ireland Limited ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google. Google may use the Personal Data to contextualize and personalize the ads of its advertising network. This integration of Google Analytics anonymizes your IP address. Anonymization works by shortening the User's IP address within the borders of the member states of the European Union or in other countries adhering to the agreement on the European Economic Area. Only in exceptional cases, the IP address will be sent to Google's servers and shortened within the United States. Personal Data processed: Usage Data; Tracking Tool. Place of processing: Ireland – Privacy Policy – Opt Out.
Display of content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Application and to interact with them. This type of service may still collect web traffic data relating to the pages where the service is installed, even when users do not use it.
Google Fonts (Google Ireland Limited) Google Fonts is a character style display service managed by Google Ireland Limited that allows this Application to integrate such content within its pages. Personal Data processed: Usage Data; Tracking Tool. Place of processing: Ireland – Privacy Policy.
INFORMATION ON HOW TO DISABLE INTEREST-BASED ADVERTISING
In addition to any opt-out function provided by any of the services listed in this document, Users can read more about how to disable interest-based advertising in the specific section of the Cookie Policy.
USER RIGHTS
Users can exercise certain rights with reference to the Data processed by the Data Controller.
In particular, the User has the right to:
Withdraw consent at any time. The User can withdraw consent to the processing of their Personal Data previously expressed.
Object to the processing of their Data. The User can object to the processing of their Data when it occurs on a legal basis other than consent. Further details on the right to object are indicated in the section below.
Access their Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.
Verify and request rectification. The User can verify the correctness of their Data and request its updating or correction.
Obtain the restriction of processing. When certain conditions apply, the User can request the restriction of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose than their storage.
Obtain the erasure or removal of their Personal Data. When certain conditions apply, the User can request the erasure of their Data by the Data Controller.
Receive their Data or have it transferred to another controller. The User has the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to obtain its transfer without hindrance to another controller. This provision is applicable when the Data is processed by automated means and the processing is based on the User's consent, on a contract of which the User is a party or on contractual measures related thereto.
Lodge a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or act in court.
Details on the right to object
When Personal Data is processed in the public interest, in the exercise of official authority vested in the Data Controller, or for the pursuit of a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.
Users are reminded that, if their Data is processed for direct marketing purposes, they can object to the processing without providing any reason. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.
How to exercise rights
To exercise their rights, Users can address a request to the contact details of the Data Controller indicated in this document. Requests are filed free of charge and processed by the Data Controller as quickly as possible, in any case within one month.
COOKIE POLICY
This Application uses Tracking Tools. To learn more, the User can consult the page http://www.allaboutcookies.org.
FURTHER INFORMATION ON PROCESSING
Defense in court
The User's Personal Data may be used by the Data Controller in court or in the preparatory stages of its possible establishment for defense against abuses in the use of this Application or related Services by the User. The User declares to be aware that the Data Controller may be obliged to disclose the Data by order of public authorities.
Specific information
Upon the User's request, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.
System logs and maintenance
For needs related to operation and maintenance, this Application and any third-party services it uses may collect system logs, i.e. files that record interactions and may also contain Personal Data, such as the User's IP address.
Information not contained in this policy
Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.
Response to "Do Not Track" requests
This Application does not support "Do Not Track" requests. To find out if any third-party services used support them, the User is invited to consult their respective privacy policies.
Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Application and, if technically and legally feasible, by sending a notification to Users through one of the contact details in their possession. Users are therefore kindly requested to consult this page frequently, referring to the date of the last modification indicated at the bottom. If the changes affect processing operations whose legal basis is consent, the Data Controller will obtain new consent from the User, if necessary.
DEFINITIONS AND LEGAL REFERENCES
Personal Data (or Data)
Personal data means any information that, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.
Usage Data
This is information collected automatically through this Application (also from third-party applications integrated into this Application), including: the IP addresses or domain names of the computers used by the User who connects with this Application, the URI (Uniform Resource Identifier) addresses, the time of the request, the method used in forwarding the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (e.g. the time spent on each page) and the details relating to the itinerary followed within the Application, with particular reference to the sequence of pages consulted, to the parameters relating to the operating system and the User's IT environment.
User
The individual who uses this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural person, legal person, public administration and any other entity that processes personal data on behalf of the Data Controller, as set out in this privacy policy.
Data Controller (or Controller)
The natural or legal person, public authority, service or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data and the tools adopted, including the security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.
Service
The Service provided by this Application as defined in the relevant terms (if any) on this site/application.
European Union (or EU)
Unless otherwise specified, any reference to the European Union contained in this document is intended to extend to all current member states of the European Union and the European Economic Area.
Cookie
Cookies are Tracking Tools that consist of small portions of data stored within the User's browser.
Tracking Tool
A Tracking Tool means any technology – e.g. Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that allows Users to be tracked, for example by collecting or saving information on the User's device.
Legal References
This privacy policy is drawn up on the basis of multiple legislative systems, including Articles 13 and 14 of Regulation (EU) 2016/679.
