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Privacy

This page describes the company’s PRIVACY POLICY in relation to the processing of personal data provided by the data subject.
This information notice is also provided to any persons that interact with the company’s web services.

The information applies to this site only and not to any other websites accessed via links thereto.

For greater understanding, the full text of the information notice, drafted in accordance with Art. 13 of the Privacy Code, is given below.

1. The purpose of the processing which shall be applied to the personal information requested or acquired, either prior to the establishment of the employment/business relationship, or over the course thereof, is to meet contractual and statutory requirements, to verify correct fulfilment of these requirements by the company Lacote S.r.l and to enable the said company to engage in business activities strictly related to its corporate purpose.

2. The processing may also be carried out with the aid of electronic or automated means and may consist in any of the operations or set of operations envisaged in Article 4, section 1, subsection a) of the aforesaid code.

3. The provision of personal information is optional, unless required by law or contractual provisions.

4. Refusal to provide the required information shall result in the consequences envisaged by law or contractual provisions.

5. Personal data supplied may be communicated to:

a) companies operating in the same area of business as LACOTE SRL;

b) subsidiaries and/or investee companies, sales networks (agents, dealers, and distributors), sub-suppliers and subcontractors if engaged in the performance of contract or business relationships;

c) service companies operating in the field of finance and/or auditing for EU and national requirements;

d) associates not in the employ of LACOTE SRL, such as tax and/or accounting advisors;

e) national, EU, and international public authorities;

6. Given the international nature of our corporate structure, you are advised that data concerned by this information notice may be transferred abroad, including therein outside the European Union.

7. The data of a strictly business nature concerned by this information notice may be disseminated via the website “guam.tlco.info” and through publication in the specialist press.

8. The data shall be processed using appropriate procedures and tools to ensure confidentiality and may be performed with electronic or automated means (computers linked in a network not accessible to the public) and with non-automated means (paper files), both provided with adequate safety measures, such as personal passwords with exclusive access, personal identification codes and file access control, as envisaged and governed by articles 31 to 36 inclusive of the Privacy Code and in compliance with article 11 of the Privacy Code.

9. In particular, any data revealing racial or ethnic origin, religious, philosophical or other beliefs, political opinions, membership of political parties, trade unions, associations or organisations of a religious, philosophical, political or trade union nature, as well as personal data concerning the subject’s health or sex life, may only be processed with the written consent and in the ways and within the limits of authorisation n.1/2002 issued by Italian data protection institution and subsequent extensions thereof.

 

Provision of the data is compulsory for reasons of standard sales and administration procedures and failure to provide the date required could result in the non-fulfilment of the agreement and/or relationship.

The data controller is LACOTE SRL, with head office located in 41030, San Prospero sulla Secchia (MO), at Via San Geminiano 2/a, represented by the appointed legal representative.

You may contact the data controller in order to exercise your rights, as provided for in Articles 7, 8 9 and 10 of the Privacy Code, which are provided in full hereunder for your convenience:

Article 7 Right to access personal data and other rights

1. The data subject is entitled to obtain confirmation of the existence or otherwise of personal data concerning them, even if not yet recorded, and the communication thereof in intelligible form.

2. The data subject is entitled to the following information:

a) the origin of the personal data;

b) the processing purposes and methods;

c) the logic applied in the event of processing performed using electronic instruments;

d) the identifications details of the data controller, managers, and the designated representative as provided for by article 5, section 2;

e) subjects or categories of persons to whom the data may be communicated or who may gain knowledge thereof in their capacity as designated representative on national soil, or as managers or appointed persons.

3. The data subject is entitled to obtain following:

a) the updating, rectification, and – when interested therein – the integration of the data;

b) the erasure, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which it was collected or subsequently processed;

c) notification from those to whom the data has been communicated or disseminated that the operations described in points a) and b) have been carried out (including specification of content), unless this proves impossible or involves a manifestly disproportionate effort in relation to the rights protected.

4. The data subject is entitled to object, in part or in whole, to the following:

a) on legitimate grounds, to the processing of personal data concerning them, even if related to the purpose for which it is collected;

b) to the processing of personal data relating to them for the purpose of sending advertising or direct sales material or to carry out market research or business communication.

 

Article 8 Exercise of rights
1. The rights referred to in Article 7 may be exercised by means of an informal request to the data controller or manager, which may also be made through an agent, to which an appropriate and timely response shall be given.

2. The rights referred to in Article 7 may not be exercised by means of a request to the data controller or manager, or with the recourse provided for in article 145, if the personal data has been processed:

a) on the basis of the provisions of Decree Law n. 143 of 3rd May 1991, converted, with amendments, into law n. 197 of 5th July 1991, and subsequent amendments thereto, concerning money laundering;

b) on the basis of the provisions of Decree Law n. 419 of 31st December 1991, converted, with amendments, into law n. 172 of 18th February 1992, and subsequent amendments thereto, concerning support for victims of extortion.

c) by parliamentary inquiry committees set up in compliance with article 82 of the Constitution;

d) by a public entity, other than public utility companies, on the basis of an express legal provision, exclusively for purposes related to monetary and currency policy, payment systems, supervision of brokers, and the credit and financial markets, as well as the protection of their stability;

e) in compliance with article 24, section 1, subsection f), solely with reference to the period during which it could result in actual, concrete prejudice to the conduct of investigations by defence counsel or the exercise of the right in court;
f) by suppliers of electronic communication services accessible to the public in relation to incoming telephone calls, unless it could result in actual, concrete prejudice to the conduct of investigations by defence counsel as provided for by law n. 397 of 7th December 2000;

g) for reasons of justice, at court offices dealing with any level or stage of legal proceedings, or the Higher Magistrates’ Council, or other self-regulatory bodies, or the Ministry of Justice;

h) in compliance with article 53, without prejudice to the provisions of the Law N. 121 of 1st April 1981.

3. In the cases stated in section 2, subsections a), b), d), e) and f), the Italian data protection institution shall take steps, in the manner provided for in articles 157, 158 and 159 and, in the cases referred to in subsections c), g) and h) of the same section, it shall take steps, in the manner provided for in Article 160, also in the event that the matter is reported by the data subject.

4. The rights provided for by article 7 may be exercised in relation to data of an objective nature, unless such rights concern the rectification or the integration of personal data of a judgmental nature, relating to views, opinions or other appraisals of a subjective nature, as well any information concerning behaviour to adopt or decisions during data acquisition by the data controller.

Art.9 – Procedure to exercise rights

1. Personal data requests may also be made to the data controller or manager via recorded delivery letter, fax or email. The Italian data protection institution reserves the right to specify another suitable system in relation to any new technological solutions that may arise. When the request regards exercise of the rights envisaged by article 7, sections 1 and 2, it may also be made verbally and in the event, it shall be noted down briefly by the appointed person or the manager.

2. When exercising the rights stated in article 7, the data subject may grant authorisations or powers of attorney, in writing, to natural persons, bodies, associations or organisations. The data subject may also be assisted by a trusted person.

3. The rights stated in article 7, with reference to personal data concerning deceased persons, may be exercised by anyone interested therein, or acting to protect the data subject, or for family reasons rendering it worthy of protection.

4. The data subject’s identity shall be verified on the basis of any suitable items of proof, including available records or documents or by producing or attaching a copy of an identification document. Any person acting on behalf of the data subject shall produce or attach a copy of the power of attorney or the authorisation, signed in the presence of an appointed person or signed and submitted together with a non-authenticated photocopy of an identity document of the subject concerned. If the data subject is a legal person, body or association, the request shall be filed by a natural person entitled to do so by their respective bylaws or regulations.

5. The request envisaged by article 7, sections 1 and 2, shall be formulated freely and without constraint and may be renewed, unless there are justified reasons against this, following an interval of no less than ninety days.

Art.10 – Response to the data subject

1. To ensure the rights provided for by Article 7 are effectively exercised, the data controller is required to take appropriate measures, and more specifically:

a) to facilitate the data subject’s access to the personal data through the use of specific processing programs which allow accurate selection of data concerning the individual subjects identified or identifiable;

b) to simplify the methods and reduce the time taken to respond to the data subject, including therein within public relations departments or services.

2. The data is extracted by the manager or appointed persons and may be communicated orally to the applicant, or displayed by electronic means, provided that, in this case, the data is displayed in an easily comprehensible manner, taking into account the quality and quantity of information concerned. If so requested, the data shall be printed out or converted to computer media, or transmitted via electronic means.

3. Unless the request concerns a particular type of processing or specific personal data or categories thereof, the response to the data subject shall include all the personal data concerning the said data subject processed by the data controller. If the request is addressed to a professional operating in the healthcare sector or to the Department of Health, the provision of article 84, section 1 shall be observed.

4. When data extraction is particularly difficult, the response to the data subject’s request may also consist in the production or delivery of copies of records and documents containing the personal data requested.

5. The right to obtain communication of the data in intelligible form does not apply to personal data concerning third parties, unless breaking down the processed data or eliminating certain items renders the personal data concerning the data subject unintelligible.

6. Communication of the data in intelligible form shall also include the use of legible handwriting. In the event that the communication involves the use of codes or abbreviations, including use by the persons appointed by the data controller, parameters for understanding the said codes or abbreviations shall be provided.

7. Where, following a request filed in compliance with article 7, sections 1 and 2, subsections a), b) and c), the existence of data concerning the data subject is not confirmed, a fee may be charged, which shall not exceed the cost actually incurred for the research done in the specific case.

8. The fee referred to in section 7 may not exceed the amount determined by the Italian data protection institution with a general measure, and the said institution may also stipulate a lump sum in the event of data processed by electronic means and a response provided orally. With the same measure, the Italian data protection institution may also stipulate that the fee may be charged if the personal data appears on special media and the reproduction thereof is specifically requested, or if it is established that considerable use of resources, at one or more data controllers, is required due to the complexity or the number of requests and the existence of data concerning the data subject is confirmed.

9. The fee stated in sections 7 and 8 may also be paid by postal or bank payment, or by debit or credit card, if possible upon receipt of the response and, in any case, within fifteen days of receipt of the said response.

OFF-LINE PERSONAL DATA COLLECTION
In the event that the company processes personal data offline (e.g. on paper forms), an information notice is provided at the same time when the processing consent is requested. This also applies where the data is collected via forms downloaded from the website, in which case the information notice regarding the specific processing is provided with the forms.

ON-LINE PERSONAL DATA COLLECTION
With reference to data collected directly on the website (e.g. registration forms, data provided for the use of online services), essential information concerning the processing shall be provided in each specific situation within the website (e.g. at the end of each registration form). This page, however, is always accessible, to allows users access to the company’s PRIVACY POLICY in its more general terms.
Any optional, express personal data request made voluntarily and submitted via e-mail involves the subsequent acquisition of the sender’s address (necessary for the reply) and any other data included in the message.

BROWSING WITHOUT REGISTRATION
Users may browse the website at their will and free of charge, and are not required to sign up.
Unregistered users’ movements on the site (sites of origin or pages visited) are not monitored.

BROWSING WITH REGISTRATION
Users are required to sign up for the site if they wish to use certain services, such as receiving sales, promotional, and advertising material.

Also in this case, registered users’ movements on the site (sites of origin or pages visited) are not monitored.

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