PURSUANT TO ARTICLES 13 AND 14, RECITALS 60-62, EU GENERAL DATA PROTECTION REGULATION 2016/679 (EU-GDPR)
|Lincotek Rubbiano S.p.A. | Surface Solutions Division
Address of its Registered office and Administrative headquarters:Via Mistrali 7, 43046 Rubbiano di Solignano PR, Italy
Business sector and activities:
|WEB PAGES – MISSION|
|www.lincotek.com owned by Lincotek Rubbiano S.p.A., aims to transparently and clearly provide the Users with detailed and specific information on Lincotek Group S.p.A. products and services to suit all requirements, in particular on those products and services offered by its product Strategic Business Unit (SBU)namely Surface Solutions (www.lincoteksurfacesolutions.com), Equipment (www.lincotekequipment.com), Additive(www.lincotek.com/additive/) and Medical (www.lincotekmedical.com), web pages owned by Lincotek Rubbiano S.p.A., undertakings belonging to the same group (Lincotek Group S.p.A.).
The User has arrived at these web pages via an advertisement on the internet or via an informational or promotional communication, upon prior specific consent given to:
The User can:
The User can also contact the company by sending an email to the email address specified on the website Contact us page.
|One of our main goals is to protect personal data.
Personal data are processed lawfully, fairly and in a transparent manner, and they shall be adequate, relevant and limited to the minimum necessary and, where necessary, kept up to date and collected for specified, explicit and legitimate purposes pursuant to Articles 5 and 6 of EU General Data Protection Regulation 2016/679 (GDPR) following consent if so required.
Personal Data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing, and against accidental loss, destruction or damage, by taking suitable technical and organisational measures (Integrity and Confidentiality).
|SOURCES OF PRERSONAL DATA|
|Personal data collected from the Data Subject:
Personal data NOT collected from the Data Subject:
|CATEGORIES OF DATA SUBJECTS|
|CATEGORIES AND PERSONAL DATA PROCESSED WEBSITE|
|COMMON PERSONAL DATA:
Personally identifiable information, contact details and other information: Name and Surname, Company Name, Country, City, Phone, E-mail address, Occupation and Capacity, Reason for the request, IP, Date and Time of the recording, IMEI number, MAC ADDRESS, where applicable, and any further information associated to the Data Subject’s device
|PURPOSE OF DATA PROCESSING||DESCRIPTION OF PURPOSE AND LAWFULNESS OF PROCESSING||DURATION OF THE PROCESSING AND DATA RETENTION PERIOD|
|1.Implementation of pre-contractual measures
||Purposes connected with the imposition and implementation of pre-contractual measures (Request for information and quote):
Lawfulness of processing:
|2.Communication between the Group companies||Transfer ofTransfer of personal data for administrative-accounting purposes, including sales within the companies of the multinational group.
Lawfulness of processing:
|3.Direct Marketing||Advertising campaigns (initiatives, events, newsletters, new products and new offers, etc.)-with traditional and automated contact methods –as well as customer satisfaction measurements and marketstudies.
Lawfulness of processing:
||Advertising campaigns relating to our services / products through Suppliers (Lead or List Provider) -with automated contact methods that enable to reach Forms and/or Chatof Web pages and/or Social Media Profiles of our company or of our Suppliers.
Lawfulness of processing:
|CONTACT METHODS FOR MARKETING PURPOSES|
|Traditional contact methods:
Automated contact methods:
|MONITORING OF THE COMMUNICATIONS SENT|
|We implement technological solutions that enable us to monitor the whole process of sending commercial or marketing communications.
Thanks to these technological tools we candeliver the same promotional communication to many recipients simultaneously by means of the above-mentionedcontact methods for marketing purposes.
These technical tools also allow us to know how advertising campaigns are performing by monitoring all visitors’ interactions and the storage of statistical information about the user’s web navigation in anonymous and aggregate form: for example we can find out how many users clicked a link and opened the message, the content of the message that aroused the greatest interest, the users’ geographical location when they sent the email, etc.
|Data may be shared with and processed by external parties acting as Data Controller such as, by way of example:
a.Supervisory and monitoring Authorities and Bodies;
g.Companies, even foreign ones, that are associated or belong to the Group or to the Parent company LINCOTEK GROUP S.P.A. (Italy), also considering the existence of telematic IT links or of correspondence (Lincotek Surface Solution –Lincotek Medical –Lincotek Equipment);
k.Companies, even foreign ones, that are associated or belong to the Group or to theParent company.
l.Companies, even foreign ones, that are associated or belong to the Group or to theParent company.
m.Companies, even foreign ones, that are associated or belong to the Group or to theParent company.
n.Other commercial parties authorized to distribute our products based ontheir territorial competence corresponding to the same area to which the customer or the prospective customer belongs
Personal data may also be processed by external parties appointed as Data Processors acting in the name and on behalf of the Data Controller. The appointed external Data Processor shall receive adequate operative instructions. The above-mentionedexternal parties are included in the following categories:
o.Persons/entities providingcompliance support services on a continuous basis;
w.Agents or other commercial parties authorized to distribute our products based ontheir territorial competence corresponding to the same area to which the customer or the prospective customer belongs;
|OBLIGATION TO PROVIDE PERSONAL DATA|
|The provision of personal data is a statutory requirement necessary to enter into a contract. For this reason, failure to provide such data as well as incorrect, incomplete or inaccurate data will cause the impossibility to finalize the contract, thus leading to its termination.|
|PARTIES AUTHORIZED TO PROCESS THE PERSONAL DATA|
|Personal data may be processed by employees and collaborators in their functions, including the sales network and the people responsible for the fulfilment of the above mentioned purposes, that have been expressly authorised to process the personal data after having been informed and appropriately trained and after having received adequate operative instructions|
|TRANSFER OF PERSONAL DATA TO NON-EU COUNTRIES|
|Personal data may be transferred to countries outside the EEA, in particular to:
A copy of your personal data maybe obtained by following the instructions provided in the following section “Rights of the Data subject-Lodge a complaint with a Supervisory Authority”
|RIGHTS OF THE DATA SUBJECT -LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY|
|By writing an e-mail to firstname.lastname@example.org, Data subjects have the right to obtain from the Data controller access to their personal data, blocking of personal data and subsequent data anonymization, as well as rectification of inaccurate personal data, completion of incomplete personal data, restriction of their processingin the cases provided for in Art. 18 of GDPR, and finally objection to data processing in the event of Legitimate interest of the Data Controller.
As regards Indirect Marketing, Data subjects can exercise their rights against us and/or the Supplier (Lead or List Provider). In order to guarantee these Rights and Claims, the Data Controller shall duly and immediately inform the Supplier about any Data Subject Access Request received by us or by the Supplier or by both, in particular when Data subjects object to processing of their personal data.
The Data Controller shall provide Data subjects with all relevant information on their requests to exercise their rights (pursuant to Articles 15 to 22 of GDPR) without undue delay and, in any case, no later than one month after the receipt of such request,as provided for by Article12 of GDPR.
|Furthermore, when processing is based on consent or on the contract and occurs by means of automatic data processing equipment, the Data subject shall have the right to receive the personal data concerning him or her in a structured, commonly used and machine-readable format and have the right to transmit those data to another Data controller without hindrance, where technically feasible, (Right to data portability) as well as to obtain the permanent erasure of such data (Right to erasure /”Right to be forgotten”).|
|Data subjects shall have the right to withdraw consent at any time for marketing purposes, and to object to the processing by sending an email to the email address specified above, writing the following statement in the subject header: “please erase my personal data -contact mode in use”.
If Data subjects no longer want to receive further advertisements,they shall write following statement in the subject header: “please erase my personal data -marketing”. In case of promotional advertising (Targeted Advertising) on websites and/or internet search engines and/or social networks, through the platform in use it is possible to know the reason why a Data subject is part of a target audience or a custom audience, in case he/she sees a promotional advertisement, and also how it is possible to get out of such audience: objection is possible at any time, consent is revocable by removing “Follow” or “Like” or “Hide ad or advertiser” in the section “Why you see this advertisement”, that can be selected directly from the Promotional Post
|Where processing is based on consent for one or more than one purposes (Art. 6, Paragraph 1, Letter A of GDPR) or for processing special category data (Art. 9, Paragraph 2, Letter A of GDPR) withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.|
|Data subjects shall have the right to lodge a complaint with a Supervisory Authority of the Member State in which they are habitually resident or work, or of the place where the alleged violation took place.|