PRIVACY POLICY DI WWW.LECKY.IT

Welcome to our website www.lecky.it (hereinafter the "Website").

Below, the main information on the processing of users' personal data in relation to browsing the Site and using the services offered. The processing is always based on principles of lawfulness and correctness in compliance with all current regulations and with the adoption of appropriate security measures to protect data.

For detailed information on how we process personal data, we invite you to carefully read this document (Privacy policy) which also contains detailed information on, respectively, the use of cookies and similar technologies on the Website and the conditions relating to our services. Some services may be subject to specific legal terms, in which case we will give you all the appropriate information from time to time.

This information refers exclusively to the Website, and does not concern any third-party websites referred to within the pages of the Website. They are independent data controllers and therefore please refer to their privacy policy.

The information is also inspired by Recommendation no. 2/2001 that the European authorities for the protection of personal data, gathered in the Group established by art. 29 of Directive no. 95-46-EC, adopted on 17 May 2001 to identify some minimum requirements for the collection of personal data online and, in particular, the methods, timing and nature of the information that the data controllers must provide to users when they connect to web pages, regardless of the purpose of the connection.

Finally, the information is also drawn up in the light of the Cookie Guidelines and other tracking tools adopted by the Guarantor for the protection of personal data (published in the Gazzetta Ufficiale no. 163 of 9 July 2021) Register of measures no. 231 of 10 June 2021.

The server on which the website resides is in Italy.

1. Data Controller

The Data Controller of the acquired  data is the company Lecky Lavorazioni Artistiche in Ferro Battuto Srl based in San Donà di Piave (VE) Via Gianni Agnelli n. 4

2. Types of data processed

The computer systems and software procedures used to operate this Website acquire, during their normal operation, some personal data whose transmission is implicit in the use of internet communication protocols. This information is not collected to be associated with identified interested parties, but by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of the computers used by users who connect to the Website and other parameters relating to the operating system and the user's computer environment.

With reference to the processing purposes indicated in point 3 below, the personal data voluntarily provided to the owner are subject to processing, including:

• personal data, contact details (e-mail address and telephone number), shipping address and billing address, payment data.

For customer service activities, the information that the user chooses to provide in his communications is also processed:

• in the case of registration on the Website ("My Account / reserved area"): identification data, e-mail address and password, as well as the data necessary to provide services reserved for registered users (for example: My orders, Fast Purchase, etc.).

• identification and contact data may be processed when you have consented to receive, by telephone, e-mail or other means, marketing communications from Lecky Srl, or communications from or on behalf of business partners with whom, subject to express consent, we have shared personal data in accordance with this Privacy Policy;

The data provided by the user are processed, subject to his consent:

• data relating to preferences and interests, such as the products purchased or that are included in the wish list, age and gender, the country of belonging, the preferred language and currency, the newsletters to which the user has subscribed. We process this data to analyze your habits and preferences to offer services and communications that are personalized and in line with your interests;

• personal data of third parties (such as name, surname and postal address, as well as contact details) provided by a user of the Website who communicates such data to us to deliver to the third party some products purchased on the Website. We process such data only to fulfill our user's request, and never for further purposes (for example, marketing). When we are provided with personal data of third parties, the user must do what is necessary so that the communication of data and our subsequent processing for the purposes specified in this Privacy Policy take place in compliance with the applicable legislation, so that, for example, before providing us with the personal data of third parties the user must inform them and obtain their consent to the processing, when required.

Personal data will be processed by the company Lecky Srl in accordance with the Regulation and current legislation, including any provisions issued by the Supervisory Authority (Guarantor for the protection of personal data), where applicable.

The data may be processed in paper, computer and telematics mode.

3. Purpose and legal basis of the processing

3.1 Purposes related to the online sale of products

We process personal data freely transmitted for the online sale of our products In particular, for:

 

• the conclusion and execution of the purchase contract on the Website of one or more products, for payment, shipment of the product, any management of the right of withdrawal, return and legal guarantee. This processing is necessary for the execution of a contract (contract of sale). The provision of personal data is mandatory; failing this, it will not be possible to make a purchase on the Website or manage any requests relating to the right of withdrawal, return and legal guarantee or receive assistance dedicated to customers;

• customer support. The processing is necessary for the execution of a contract (supply, assistance). The provision of personal data is mandatory; failing this, it will not be possible to receive the requested supply/assistance;

• for administrative purposes in any case connected with the fulfillment of the related contractual obligations, such as those of an accounting and tax nature. This processing is necessary to fulfill a legal obligation to which the company Lecky Srl is subject. The provision of personal data is, therefore, mandatory; failing this, it will not be possible to make a purchase on the Website;

• registration on the Website and use of services reserved for registered users. This processing is necessary for the execution of a contract (registration on the Website and related supply of products / services). The provision of personal data is mandatory; failing this, it will not be possible to register on the Website and use the services dedicated to registered users;

• the prevention and repression of fraud and abusive behavior (including by third parties) contrary to current regulations, applicable contractual provisions, rules of fairness and good faith. The lawfulness of such processing is based on the legitimate interest of the company Lecky Srl, to carry out checks and security activities for the purpose of prevention and protection from fraudulent activities and abusive behavior;

• the use of the following services offered through the Website and related to online sales: (i) delivery of products purchased online; (ii) return of products purchased online. This processing is necessary for the execution of a contract (provision of the related service). The provision of personal data is mandatory; failing this it will not be possible to use the service.

3.2 Marketing purposes

We may use your personal data for marketing purposes. We may, in fact, send promotions, commercial or advertising communications on our products through channels such as e-mails and / or newsletters and social networks. Marketing activities may include carrying out market research and surveys to detect customer satisfaction or to carry out statistical analysis, even with anonymous data organized in aggregate form.

The processing of data is based on freely expressed consent and the provision of personal data is optional. In case of refusal, in fact, there will be no consequences on the possibility of buying our products online.

3.3 Analysis of consumption habits and choices

We may use the data collected online in combination with the information and preferences expressed during purchases for the creation of group and / or individual profiles that allow us to send personalized communications.

The processing of data is based on freely expressed consent and the provision of data is optional. In case of refusal, in fact, there will be no consequences on the possibility of buying our products online.

3.4 Further purposes

Personal data are also processed for:

• the management of requests to exercise the rights regarding the protection of personal data (more information in point 6). This processing is necessary to fulfill a legal obligation to which the data controller is subject;

• other obligations regarding the protection of personal data. In certain circumstances, the legislation on the protection of personal data obliges the data controller to use the contact details to provide specific information on the processing of data such as, for example, to inform of any security breaches that have affected the personal data of the interested party and the measures taken to deal with them (so-said data breach), as well as to communicate any significant updates to this privacy policy. This processing is, therefore, necessary to fulfill a legal obligation to which the data controller is subject.

4. Scope of communication and dissemination

Personal data may be accessed by personnel (employees and collaborators) of the company Lecky Srl, duly trained, as well as third parties (suppliers and / or business partners) who have been adequately selected by the owner and offer a suitable guarantee of compliance with the rules on the processing of personal data. These third parties can carry out, on the basis of a specific designation by the owner (from each of them for the treatments of their own ownership), their activity as "data processors" (therefore under the direct responsibility of the data controller who has designated them: for example, internet providers, companies specialized in IT and telematics services, customer service companies, companies that carry out marketing activities, companies specialized in market research and data processing) or as "independent data controllers" (for example, couriers and shippers, banking operators, freelancers or legal or tax consulting and assistance companies).

Personal data may also be disclosed to third parties in the following cases: (i) when the communication is required by laws and regulations applicable to legitimate third party recipients of communications, such as authorities and public bodies that process the data as independent data controllers for their respective institutional purposes; (ii) in the case of extraordinary transactions (e.g. mergers, acquisitions, sale of business, etc.).

The updated list of the subjects to whom we communicate the data is available at the headquarters of the data controller.

5. Data retention

We retain personal data for a limited period of time, strictly related to the purpose for which it was collected and in accordance with applicable legal or regulatory obligations. At the end of the established retention period, personal data will be deleted or otherwise made anonymous irreversibly, unless the company Lecky Srl is required to keep the data for a further period to comply with legal or regulatory obligations or to exercise or defend a right in court.

The retention period is different depending on the purpose of the processing, in particular:

• With reference to the purposes referred to in point 3.1, personal data will be processed for the entire duration of the relationship and necessary to achieve the aforementioned purposes. The functional data for the fulfillment of any legal obligations will also be kept subsequently, in compliance with these obligations and in compliance with the retention times provided for by the applicable rules from time to time, except for registration on the Website ("My Account") and the use of services reserved for registered users, in relation to which personal data will be kept until the cancellation of the personal account is requested;

• for the purposes referred to in points 3.2. and 3.3., the data are kept for a maximum period of 10 (ten) years from the moment of consent for the aforementioned purposes, considering this time frame to be congruous and proportionate both to the purposes to be achieved and to the type of personal data being processed. Upon expiry of this period, the data will be deleted or made anonymous. In case of withdrawal of consent to the processing for the aforementioned purposes, the data will be immediately deleted.

• for generic marketing activities, the data are kept by the company Lecky Srl until the request for cancellation, revocation of consent or opposition to the processing. In any case, the company Lecky Srl will delete the data after 10 (ten) years from the last interaction of the interested party with the company itself, for example through online purchases or interaction with the newsletter;

• to fulfill the legal obligations regarding the processing of personal data referred to in point 3.4, personal data will be processed for the period necessary to manage the request to exercise the rights recognized by the GDPR or to fulfill the legal obligation to which the data controller is subject.

The data necessary to demonstrate compliance with the legal obligations to which the owner is subject will be kept for 10 (ten) years;

• in the event of a judicial or administrative dispute, the data will be kept for the term necessary for the protection in court of a right by the company Lecky Srl or a third party or within the limits imposed by the judicial or administrative authority.

6. Rights

You can contact the data controller at any time, at the addresses specified in point 9, to exercise the rights recognized by the GDPR and, in particular:

• have confirmation as to whether or not personal data directly concerning the data subject are being processed and, in this case, to obtain access to and a copy of such personal data ("right of access");

• rectification of personal data, i.e. to obtain the correction, modification or updating of any inaccurate or no longer correct data, as well as to obtain the integration of incomplete personal data, also by providing a supplementary declaration ("right of rectification");

• revoke at any time the consent given for the processing of personal data, including in relation to any activity ("right to withdraw consent"). The withdrawal of consent does not affect the lawfulness of the processing based on the consent given before the revocation;

• request the cancellation of personal data when these, in particular, (i) are no longer necessary with respect to the purposes for which they were collected or processed, or (ii) have been processed unlawfully, or (iii) must be deleted to fulfill a legal obligation, or, finally, (iv) in case of opposition to their processing (see below "right of opposition") and there is no overt legitimate reason that allows the owner to proceed with the processing in any case ("right to erasure" or "right to be forgotten");

• obtain the limitation of the processing of personal data, that is, that the owner retains such data without being able to use them without prejudice to any requests and exceptions provided for by law. This right can be exercised only when, in particular, (i) the accuracy of the personal data is ought, for the period necessary for the owner to verify the accuracy of such personal data, or (ii) the processing of the data is unlawful and the limitation of their use is requested, instead of cancellation, or (iii) although the owner no longer needs it for the purposes of the processing, the personal data are necessary for the interested party to ascertain, exercise or defend a right in court or (iv) there is opposition to their processing (see below "right of opposition"), pending verification of the possible prevalence of the legitimate reasons of the owner over those of the interested party (right of limitation);

• request the data or transfer them to a person other than the owner ("right to data portability"). Where technically possible, we may on request transfer the data directly to a third party expressly indicated to us;

• lodge a complaint with one of the competent supervisory authorities for compliance with the rules on the protection of personal data, if you believe that the processing of your personal data has been carried out in an unlawful manner ("right to lodge a complaint").

 

In addition, the interested party also enjoys the "right to object", that is: • oppose at any time the processing of their personal data carried out for the pursuit of a legitimate interest of the owner or for marketing purposes, including profiling. The data controller will refrain from further processing personal data unless it demonstrates the existence of binding legitimate reasons to proceed with the processing that prevail over the interests, rights and freedoms of the interested party or for the assessment, exercise or defense of a right in court. To ensure full respect for the rights described above and that the data of our users are not subject to violations or illegitimate access by third parties, before accepting a request to exercise one of the rights indicated, we may ask for some information to ascertain the identity of the applicant or to have clarifications on the request made.

7. Cookies

Cookies are small text files that are sent to the computer of each user who connects to the Website.

The Website in question uses the following types of cookies:

• Technical cookies session

The use of so-called session cookies is strictly limited to the transmission of session identifiers (consisting of causal numbers generated by the server) necessary to allow the safe and efficient exploration of the Website.

The so-call session cookies used by this Website avoid the use of other COMPUTER techniques potentially prejudicial to the confidentiality of users' browsing and do not allow the acquisition of personal identification data of the user.

These cookies are processed in computer mode and are:

Cookie

Cookie Type

Platform

Description

. ASPXANONYMOUS

Technician

 

ASP.NET

This cookie is set by ASP.NET. The cookie is used for a unique ID to allow users to store tracking data within a session, anonymously.

ASP.NET_SessionId

Technician

 

ASP.NET

This cookie is used on sites developed with Microsoft.Net. When a user starts browsing, a unique session ID is created, which keeps track of all the information related to that session. This information is stored on the Web server and is identified through a GUID. The GUID is essential for any site ASP.NET to function properly.

 

• Analytics cookies

This Website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). ("Google"). Google Analytics uses "cookies", which are text files that are stored on users' computers to allow the website to analyze how they use the Website. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google (independent data controller) will use this information for the purpose of tracking and examining the use of the Website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law or where such third parties process the information on Google's behalf. Google will not associate the IP address with any other data held by Google.

These cookies are:

Cookie

Cookie Type

Platform

Description

_ga

Analytical

Google Analytics

Cookie installed by Google Analytics. The cookie is used to calculate the data of visitors, sessions, campaigns and track the use of the site for the site analysis report. Cookies store information anonymously and assign a randomly generated number to identify unique visitors.

_gid

Analytical

Google Analytics

Cookie installed by Google Analytics. The cookie is used to store information about how visitors use a website and helps create an analytical report on how the website is doing. The data collected includes the number of visitors, the source from which they come and the pages visited anonymously.

 

You can refuse to use these cookies by selecting the appropriate settings on your browser, but this may prevent you from using all the features of this Website.

For more information, please refer to the page http://www.google.com/policies/privacy/.

8. Changes to the Privacy Policy

The features, functionalities and services offered by the Website may change in the future, as a result, this Privacy Policy may undergo changes and additions over time. We will appropriately report any significant changes made but we invite you, in any case, to periodically check the contents.

9. Contacts of the data controller

The data controller, the company Lecky Lavorazioni Artistiche in Ferro Battuto Srl, can be contacted at the following email address: info.it@leckymetal.com for any clarification, question or requirement related to the processing of personal data or to exercise the rights recognized by the GDPR (see point 6).

 

Information updated to 23 September 2021

 

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