Lucart S.p.A., with registered office in via Carpi no. 77 (VAT number and Tax Code 00145780466), in the person of its legal representative and in its capacity as Data Controller, has always been very attentive to personal data protection issues and to respect for the principles of confidentiality and personal dignity.
Pursuant to Regulation (EU) 2016/679 ("Regulation" or "GDPR") and in observance of the principle of accountability, any personal data processing must be lawful and proper. The manner in which the personal data of natural persons are collected, consulted or otherwise processed must be transparent, including the extent to which such data are or will be retained.
The principle of transparency requires that information and communications regarding data processing are easy to access and understand and that the language used is simple and clear.
This principle refers specifically to information provided to data subjects regarding the identity of the Data Controller and the purposes of processing, as well as further information to ensure proper and transparent processing with regard to the natural persons concerned and their right to obtain confirmation and disclosure of their personal data.
With this in mind, please take note of the following information.
Lucart S.p.A., with registered office in Via Carpi no. 77 (VAT number and Tax Code 00145780466), in the person of its legal representative (hereafter also "Controller" or "Lucart"), hereby informs the data subject that their personal data collected by the Data Controller, or which will subsequently be requested and/or disclosed to third parties, are necessary and will be used for the purposes set out below.
The information systems and software procedures used to operate the Website collect, as part of their normal operating processes, certain personal information whose transmission is an integral part of Internet communication protocols. This information is not collected to be associated with identified data subjects, but by its very nature could, through processing and association with data held by third parties, make it possible to identify the users concerned. This category of data includes the IP addresses or domain names of the computers used to connect to the Website, the URI (Uniform Resource Identifier) notation addresses of the resources requested, 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 user's operating system and computer environment.
These data are used for the sole purpose of obtaining anonymous statistical information on Website usage, to check that the site is functioning correctly and to identify anomalies and/or abuses; such data are erased immediately after processing. For more information, please see the cookie policy available at the following link: cookie policy.
Pursuant to Regulation (EU) 679/2016, the personal data:
- are processed lawfully, properly and transparently with regard to the data subject (Article 5);
- they are collected for specific, explicit and legitimate purposes and subsequently processed in a manner that is not inconsistent with such purposes (Article 5).
The purposes for which the data are collected are as follows:
- pursuit of purposes that are instrumental and/or complementary to activities required to carry on the existing contractual/precontractual relationship;
- general accounting, invoicing, credit management, obligations under civil and tax law and archive updating;
- measurement of the level of satisfaction of the data subject with the quality of the product or services provided by the undersigned, including statistical analysis;
- marketing activities with specific reference to the sending of newsletters;
- submission of candidate CVs to the "work with us" section.
The data are processed to send service communications and manage requests for clarification, reports and complaints in relation to the contractual relationship established, as well as for the purposes of its fulfilment.
Any personal data referring to the data subject, or collected from same after receiving consent, may be used for marketing purposes (i.e., purely by way of example, for promoting advertising and commercial events and for sending advertising campaigns, promotions and offers) by the Data Controller using both automated and traditional methods.
Data processing is performed using IT and/or paper-based systems by persons committed to confidentiality, applying methods consistent with the stated purposes and in any case in such a way as to ensure the security and confidentiality of the data. The data collected are not disclosed or distributed to third parties in accordance with the law.
Your personal data may be disclosed to third parties known to us exclusively for the aforementioned purposes and, in particular, to the following categories of subject:
- Lucart Group companies;
- external service providers;
- public entities and authorities in relation to legal obligations;
- professionals providing support in relation to the fulfilment of legal obligations;
- companies providing support in relation to the fulfilment of legal and contractual obligations.
These subjects will process personal data in their capacity as External Data Processors or Autonomous Data Controllers.
Pursuant to Article 5 of Regulation (EU) 2016/679 on "Principles applicable to personal data processing", personal data are retained in a form that permits the identification of data subjects for a period of time not exceeding that required to achieve the purposes for which they were collected. Data subjects' personal data may also be retained for longer periods in order to comply with current legal requirements (e.g. for accounting purposes).
Pursuant to current legislation, data subjects may assert their rights with regard to the Data Controller, i.e.:
RIGHT OF ACCESS
Article 15
The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
a) the purposes of the processing;
b) the categories of personal data concerned;
c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
f) the right to lodge a complaint with a supervisory authority;
g) where the personal data are not collected from the data subject, any available information as to their source;
h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.
The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.
RIGHT TO RECTIFICATION
Article 16
The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
RIGHT TO ERASURE
Article 17
1. The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;
c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
d) the personal data have been unlawfully processed;
e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).
2. Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
a) for exercising the right of freedom of expression and information;
b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing;
e) for the establishment, exercise or defence of legal claims.
RIGHT TO RESTRICTION OF PROCESSING
Article 18
1. The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.
2. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
3. A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.
RIGHT TO DATA PORTABILITY
Article 20
1. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
a) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and
b) the processing is carried out by automated means.
2. In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
3. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
4. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.
RIGHT TO OBJECT
Article 21
1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.
5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.
6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In addition to the aforementioned rights, the data subject has the right to withdraw consent on request, as well as to lodge a complaint with the Regulatory Authority pursuant to the law. To exercise his or her rights, the data subject may download the appropriate form (click here to download the form to exercise rights) and send it to email address privacy@lucartgroup.com
This policy may be modified to provide up-to-date information on the processing of personal data on the Website. We therefore invite you to visit this section regularly to check for updates
