| LUBRANO DESIGN FUNERARIO S.R.L. CUPA LAUTREC 1 – 80141 – NAPOLI (NA) Email lubranodesignsrl@pec.it P.IVA 08595561211 |
PRIVACY POLICY
Processing of personal data
LUBRANO DESIGN FUNERARIO S.R.L. (hereinafter the "Company"), as the Data Controller, informs you that access to the website and/or registration in its various sections and/or any requests for information or services require the provision of personal data, which will be processed in full compliance with European Regulation 2016/679 (hereinafter "GDPR") and the provisions of the Data Protection Authority pursuant to Legislative Decree 196/2003 and/or subsequent amendments. Through this notice, users will be able to learn, in advance, the processing methods required for the use of certain areas of the Company's website and/or registration for competitions and/or newsletters.
Pursuant to the aforementioned Law, such processing will be based on the principles of fairness, lawfulness, and transparency, protecting your privacy and your rights.
This information applies exclusively to this site and does not extend to other websites that may be accessed by the user via external links.
Changes to this Policy
The Company reserves the right to make changes to this policy at any time, notifying users on this page. We therefore ask you to check this page often, referring to the last modification date indicated at the bottom. If you do not accept the changes made to this Policy, you must cease using this platform and, using the appropriate function in the reserved area or by requesting the Data Controller directly, remove your personal data. Unless otherwise specified, the previous Policy will continue to apply to personal data collected up to that point.
The Data Controller and the Data Processors
The data controller is LUBRANO DESIGN FUNERARIO S.R.L., with registered office at CUPA LAUTREC 1 – 80141 – NAPLES (NA). The complete list of data processors is available upon written request to the data controller.
Purposes of the processing and legal basis.
Depending on the needs expressed from time to time by the user who accesses the various sections of the Site (and except for specific rules and information for individual operations that require the provision of specific personal data, published from time to time on the Site), the purposes of the processing of personal data are indicated below, namely those provided directly by users by completing online forms or by directly accessing, via a link, the email address of the Company (or its brands) relating to the requested service, or those acquired automatically through navigation (see the following section "Categories of Personal Data subject to Processing") (hereinafter, "Personal Data"):
C1. Registration and access to the "reserved area" sections on the Company's website;
Legal basis for processing: consent.
C2. Any participation in games and/or competitions on the Company's website;
Legal basis for processing: execution of pre-contractual measures.
C3. Subject to the user's prior consent and until such consent is revoked, carry out marketing activities such as, by way of example but not limited to: market research, sending informational and promotional material, sending free product samples, marketing and advertising activities regarding the products and services of this company, as well as other companies in the group, also using the email address provided to us;
Legal basis for processing: consent.
C4. Conduct analyses on consumer habits or choices and define user profiles using the information provided by the user upon registration and/or when completing questionnaires, or based on actions performed or information provided while browsing the Company's website. Specifically, the user can choose, within the reserved area, to receive marketing communications, with the freedom to withdraw consent at any time;
Legal basis for processing: consent.
C5. Respond to requests received (courtesy service, "Contacts" section, if available, on the Company's website, use of direct emails), surveying user satisfaction with the quality of the Company's products, services provided, and activities, carried out directly or through specialized companies through personal or telephone interviews, questionnaires, etc.; In some cases, in order to respond to specific requests, your personal data may be communicated directly to External Data Processors (for example, but not limited to: technical requests regarding issues with access to the reserved area and/or the functioning of a competition).
Legal basis for processing: consent.
C6. Statistical analysis, normally anonymous, including for marketing purposes.
Legal basis for processing: consent.
C7. Where the function is present, allow users to publish news and/or communications (hereinafter "posts") generally directly on the Company's website, or on sites independently managed by third parties with which the Company has reached agreements to this effect, such as, by way of example and not limited to, social networks such as Facebook, Twitter, Pinterest, etc. (hereinafter "Social Networks"); the publication of posts may also take place together with a pseudonym chosen by the user during registration on the Company's website, and possibly with the image associated by the user with his/her nickname. The user will be solely responsible for any choices that could prejudice the interests of third parties. The user is not required to use personal data that allow third parties other than the Company to identify him/her, but the user, via the Company's websites, may also disclose his/her personal data if he/she has included them in his/her nickname, as well as the photo that he/she has associated with his/her profile.
Legal basis for processing: consent.
In this case, consent can be revoked at any time via the reserved area, subject to publication on social media channels.
The processing of your personal data described above, as briefly indicated for each point, is authorized by European Regulation 2016/679, on the basis of the following legal assumptions:
- Consent: if you have consented to their use by giving your consent, which may be revoked at any time through the reserved area of the Website or by contacting the Data Controller at the contact details indicated below;
- Execution of pre-contractual measures or fulfillment of contractual obligations: if it is necessary to conclude or fulfill a contract with the Company or to execute pre-contractual measures;
- Legal obligations: if the Company needs to use your personal data to comply with its legal obligations;
- Legitimate interest: if the Company uses your personal data to pursue a legitimate interest and its reasons outweigh any prejudice to your data protection rights;
- Legitimate interest: where it is necessary for the Company to defend itself, take legal action or make claims against you, its own or third parties.
The methods of processing and its security.
Data processing means any operation or set of operations, performed with or without the aid of electronic or automated means, concerning the collection, recording, organization, storage, processing, modification, extraction, comparison, use, communication, dissemination, interconnection, blocking, deletion, destruction, and selection of data.
Personal Data will be processed primarily in automated form but also on paper, using methods strictly related to the aforementioned purposes, using databases, electronic platforms managed by the Company or by third parties appointed as data processors (for an updated list, the user can contact the Data Controller at the address indicated) and/or integrated IT systems and/or websites owned or used by the Company.
The Data Controller has adopted appropriate security measures to protect users against the risk of loss, misuse, or alteration of their data. While it is not possible to guarantee that data transmission via the Internet or websites is completely secure from intrusion, the Company and its suppliers are committed to maintaining physical, electronic, and procedural security measures to protect personal data, in compliance with regulatory requirements. Specifically, the Company has adopted, where possible, the measures referred to in Article 32 of European Regulation 2016/679 and uses secure data transmission protocols known as HTTPS. Furthermore, the Company stores user data on servers located in Europe; they may be transferred to the USA. The servers are subject to an advanced daily backup and disaster recovery system, are protected by firewalls, and access to personal data is strictly restricted based on need and solely for the purposes communicated. The transfer of collected data occurs via encrypted protocols, and there is a permanent monitoring system for access to IT systems to identify and prevent the misuse of personal data.
The duration of the treatment.
The data communicated are saved for the time necessary to fulfill the purposes and specifically:
- The data communicated are saved for the time necessary to fulfill the purposes and specifically:
- For competition registration: for the time necessary to fulfill the regulatory obligation to retain data.
- For profiling purposes: maximum 24 months from the last interaction.
- For information requests: depending on the type of request, for the time necessary to fulfill the regulatory retention obligation and/or for any legal requirements.
For any further information, please contact the Data Controller.
The place of processing and the contact details of the Data Controller.
Personal Data is processed primarily at the Data Controller's headquarters, at CUPA LAUTREC 1 – 80141 – NAPLES (NA). For further information, users can contact the Data Controller by writing an email to lubranodesignsrl@pec.it
The nature and methods of providing users' Personal Data.
Providing personal data is optional, but providing some personal data is mandatory (i.e., necessary for data whose fields are highlighted during entry or otherwise marked as mandatory) so that the Company can meet the user's needs within the scope of the Site's functionality. Failure to provide Personal Data, or partial or incorrect provision of such data, as it is necessary for the performance of the requested service, will prevent such performance; while failure to provide optional Personal Data, or partial or incorrect provision of such data, will have no consequences.
Personal Data may be provided by filling in the appropriate fields in the various sections of the Site or by sending requests via email where applicable.
The Categories of Personal Data subject to processing.
In addition to the Personal Data provided directly by users (such as name, surname, postal address, email address, etc.), when connecting to the Site, the computer systems and software procedures used to operate the Site automatically and indirectly administer and/or acquire certain information that may constitute personal data, the transmission of which is implicit in the use of Internet communication protocols (such as, by way of example but not limited to, so-called "cookies" (as better specified below), "IP" addresses, domain names of computers used by users connecting to the Site, the "URL" addresses of the requested resources, the time of the request to the server, navigation on the Site, geographical location.
If you use the social authentication feature enabled to register on the site, you will be asked to access your social media account information, specified in the pop-up window that appears when the request is made. You will not need to complete any additional forms. Through the social media platform, you can enable or disable the feature that allows you to transfer and share your social media experience to other websites or third-party applications. You can disable the sharing of your social media account data at any time by accessing the settings of the relevant service provider.
Categories of subjects who may become aware of users' Personal Data.
Personal Data may be disclosed to employees or collaborators of the Data Controller who, operating under the direct authority of the latter, process data and are appointed as data processors or persons in charge of data processing pursuant to Articles 24-29 of European Regulation 2016/679, or system administrators, and who will receive appropriate operating instructions from the Data Controller in this regard. The same will be done – by the Data Controller's appointed Data Processors – with respect to the Data Processors' employees or collaborators.
Personal Data may also be disclosed to Data Processors appointed by the Data Controller, such as third-party companies or other entities (for example, but not limited to, entities entrusted with assistance, communication, promotion and sale of products and/or services, organization and management of competitions, IT service providers, managers and/or developers of websites or applications contained therein, managers of electronic platforms, transport companies) who carry out outsourced activities on behalf of the Company.
The complete and updated list of companies in control and connected relationships with the Data Controller pursuant to Art. 2359 of the Italian Civil Code, of third-party companies that carry out data collection operations on behalf of the undersigned, of third-party companies to whom the data may be communicated, and of data processors, is available upon request from the Company.
Learn more about Personal Data.
Scope of communication or dissemination of users' Personal Data.
Personal Data will not be shared with third parties, except for external services used to achieve the purposes set out above. Personal data will not be disseminated.
Transfer of Users' Personal Data outside the EU.
Personal Data may be transferred to non-EU countries, such as the USA, always in compliance with the principles set out in European Regulation 2016/679.
User rights.
Users have the rights set forth in Articles 15-21 of European Regulation 2016/679 (Right to rectification, right to be forgotten, right to restriction of processing, right to data portability, right to object).
Specifically:
- The right of access: to obtain confirmation as to whether or not personal data concerning you is being processed and to obtain access to such data and specific information (e.g., purposes of the processing, categories of data in question, recipients to whom the data will be disclosed);
- The right to rectification: to obtain the rectification of inaccurate data concerning you without undue delay. In this case, the data controller is obliged to communicate the rectification to all recipients to whom the data was disclosed, unless this involves a disproportionate effort;
- The right to erasure: to obtain the erasure of personal data concerning you without undue delay, and the data controller is obliged to erase such data without undue delay if certain reasons exist (e.g., the personal data are no longer necessary for the purposes for which they were collected; the data subject withdraws consent; or a legal obligation requires erasure). In this case, the data controller is obliged to communicate the erasure to all recipients to whom the data were disclosed, unless this would involve a disproportionate effort;
- The right to restrict processing: the data controller may restrict the processing of personal data, for example, to storage only and to exclude any other use, in certain circumstances (e.g., if the processing is unlawful and the data subject opposes the erasure of the data; if the data subject contests the accuracy of the data, within the period for verifying the accuracy). In this case, the data controller is obliged to communicate the restriction of processing to all recipients to whom the data have been disclosed, unless this would involve a disproportionate effort;
- The right to data portability: to obtain the return of the personal data provided and transmit it to others or to request transmission from one controller to another, if technically feasible;
- The right to object: to object at any time to processing for purposes of public interest or legitimate interest; for marketing purposes; or for scientific, historical, or statistical research purposes.
Interested parties may file a complaint with the Data Protection Authority if necessary, or simply contact them for information regarding the exercise of their rights under EU Regulation 2016/679.
Data Controller Information:
LUBRANO DESIGN FUNERARIO S.R.L.
CUPA LAUTREC 1 – 80141 – NAPOLI (NA)
Email lubranodesignsrl@pec.it
P.IVA 08595561211
