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Privacy Policy

Information on the processing of personal data

Last revision: 08 September 2023 

  1. Foreword
    1. LOCMAN S.P.A. (C.F. 08504700157 and P.IVA 01190380491, PEC amministrazione.locman@pec.locman.it), with registered office in 57034 – Campo nell’Elba (LI), Piazza Giovanni da Verrazzano, n. 7, Italy (hereinafter, “Locman“), as owner of the website linked to the internet domain name “locman.it” (hereinafter, the “Site“), hereby discloses the information on the processing of personal data (hereinafter, “Privacy Policy“), made pursuant to EU Regulation 679/2016 and ss.mm.ii. (hereinafter, “GDPR“) and the applicable national data protection legislation, informs the users browsing the Site (hereinafter, the “User” or the “Users“) how their personal data (hereinafter, the “Data“) are managed and allows them to give their express and informed consent to the processing of the Data where required.
    2. The Privacy Policy is made only for the Site and not for any third-party websites that the User may consult through links on the Site’s pages.
    3. By accessing and using the Site, the User acknowledges that he/she has carefully read this Privacy Policy, and that he/she accepts its purposes and methods of Data processing. If the User does not agree with the contents of this Privacy Policy, he/she is invited to leave the Site and, in any case, not to use its contents and/or services.
    4. All Data sent by the User (name, surname, e-mail address, telephone number, etc.) are acquired, saved, and processed exclusively in accordance with the GDPR.
    5. Processing of Data shall mean any operation or set of operations, carried out with or without the help of electronic means, concerning the collection, recording, organisation, keeping, interrogation, elaboration, modification, selection, retrieval, comparison, utilization, interconnection, blocking, communication, dissemination, erasure and destruction of data, whether the latter are contained or not in a data bank (hereinafter referred to as “Processing”).

 

  1. Data controller
    1. Locman is the Data Controller of the Data collected through Cookies.
    2. Locman’s contact details can be found below:
      1. Company name: LOCMAN. S.P.A.;
      2. Registered office address: 57034 – Campo nell’Elba (LI), Piazza Giovanni da Verrazzano, n. 7, Italy;
      3. Certified E-mail address: amministrazione.locman@pec.locman.it;
      4. E-mail address: info@locman.it;
      5. Fiscal Code: 08504700157;
      6. VAT no.: 01190380491.

 

  1. Data Subject to Processing
    1. The following Data are processed:
      1. Navigation data: the Site’s hardware and software acquire certain Data whose transmission is implicit in the use of Internet communication protocols. This is information that could, through processing and association with data held by third parties, allow Users to be identified. This category of data includes the IP addresses of the devices used by Users who connect to the Site, 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. We may also receive information regarding the User’s geographical location and his electronic device. This Data is used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning and is deleted immediately after processing. The Data could be used to ascertain responsibility in case of hypothetical computer crimes to the detriment of the Site. Data relating to the User’s geographical location may be used to provide information, proposals and other personalised content based on location. If the User does not wish to share information on his/her geographical location, he/she should deactivate the location services on his/her device;
      2. Data provided voluntarily by the User: the Data entered on the Site by the User (when registering the User profile on the Site and/or purchasing products on the e-commerce linked to the Site) as well as the Data sent by the User by e-mail to the e-mail addresses indicated on the Site (including the sender’s e-mail address and any other Data included in the message);
      3. Purchase Data: when purchasing products via the e-commerce platform linked to the Site, the Data provided by the User as part of the purchase process;
      4. Cookies: the Site uses cookies to make the User’s navigation easier, faster, more intuitive and to allow the Site to function better. For further information on the cookies present on the Site, please refer to the Extended Cookie Policy (https://locman.it/cookie-policy/, hereinafter “Cookie Policy”).

 

  1. Purpose of Processing
    1. Locman processes User Data for the following purposes (hereinafter, “Purposes”):
      1. to enable the creation of User profiles and the sending of e-mails confirming the registration of the User profile with the Site;
      2. to enable the purchase of products via the e-commerce platform linked to the Site and thus, finalise the transaction, deliver the purchased products, handle any exchange and/or return requests or make refunds;
      3. for the creation of a database of Users interested in the Site and its services;
      4. for the handling of Users’ requests of a technical, commercial and other nature;
      5. to comply with legal obligations (including tax obligations) and protect its prerogatives;
      6. to forward e-mail communications to Users for products and services similar to those requested by the User (so-called “soft spam”);
      7. for marketing purposes, including sending newsletters and/or other promotional messages by e-mail;
      8. for profiling purposes, i.e. the analysis of preferences aimed at creating customised content and offers.

 

  1. Legal basis for processing
    1. Locman treats Data:
      1. for the fulfilment of contracts to which the User is a party and for the execution of pre-contractual measures taken at the User’s request, as provided for in Article 6(1)(b) of the GDPR;
      2. for the fulfilment of a legal obligation to which Locman is subject, pursuant to Article 6(c) of the GDPR;
      3. on the basis of Locman’s legitimate interest, pursuant to Article 6(f) of the GDPR;
      4. with the User’s consent, pursuant to Article 6(a) of the GDPR, for marketing and profiling purposes.

 

  1. Method and Place of Data Processing
    1. Data are processed by automated means for the time strictly necessary to achieve the Purpose for which they were collected.
    2. Locman has adopted technical solutions and security measures that guarantee the security of the Data and prevent their alteration, loss, incorrect processing or unauthorised access.
    3. Processing related to the services of the Site may take place on servers of third party companies offering hosting services on behalf of Locman, including in the cloud.
    4. In the event of data being transferred outside the European Union, such transfers will take place ensuring adequate levels of Data protection, in accordance with the applicable data protection provisions, pursuant to Articles 45 and 46 of the GDPR.

 

  1. Disclosure of Data to Third Parties
    1. The Data collected and stored in Locman’s databases will be processed by its employees and/or collaborators (as well as employees of the companies operating all points of sale on behalf of Locman) as authorised to process such Data pursuant to Article 4, no. 10 of the GDPR
    2. The User’s data may also be processed by third party companies, which Locman uses to carry out activities on its behalf (e.g., analysing data, archiving data, sending newsletters or other commercial or non-commercial communications, providing marketing assistance, carrying out market analysis, delivering purchased goods, managing the credit card payment platform and other customer services).
    3. Locman provides these parties only with the Data necessary to perform the agreed activities and they act as data processors within the meaning of Article 4(8) of the GDPR (hereinafter, the “Data Processors“). These parties have been selected because they are deemed to have adequate experience, capacity and reliability as well as to be able to guarantee full compliance with current privacy regulations. The User may request the list of Data Processors by writing to “privacy@locman.it”.
    4. With reference to the scope of communication of the Data, the Data provided by the User or otherwise collected may be communicated to the following subjects or categories of subjects:
      1. public administrations, for the fulfilment of obligations laid down by law, regulations or national or EU legislation;
      2. parent, subsidiary and/or associated companies of Locman;
      3. other companies or natural persons contractually linked to Locman and specifically appointed to process the Data on behalf of Locman.

 

  1. Nature of data provision
    1. Certain fields required on the Site (which may be marked with an asterisk or other symbol) may be mandatory, for example, to enable valid registration on the Site, to provide the products you wish to purchase and to process any requests.
    2. By entering their Data on the Site, the User warrants that the personal information provided is correct and up-to-date. Furthermore, the User acknowledges that he/she is solely responsible for the Data provided, whether personal data, photos, comments or otherwise, releasing Locman from any liability.
    3. The provision of Data that Locman may process for marketing and profiling purposes is absolutely optional. Failure to consent to the Processing of Data for such purposes or the subsequent withdrawal of consent shall not prevent the possibility of browsing the Site and/or making purchases through it.

 

  1. Withdrawal of consent
    1. The User may revoke consent for the conduct of marketing activities (including the sending of newsletters) and/or profiling by Locman by sending an e-mail to “privacy@locman.it”. Revocation of consent shall not affect the lawfulness of the processing based on the consent prior to revocation.
    2. With regard to the management of cookies, please refer to the sections “Managing Cookies” and “How to Disable and/or Delete Cookies via Browser Configuration” of the Cookie Policy (https://locman.it/cookie-policy/).

 

  1. Minors
    1. The newsletter service is not intended for minors under 16 years of age or for minors whose age makes it illegal to process their Data or requires parental consent for the processing of their Data under other local laws (hereinafter, “Age Limit”).
    2. Locman does not knowingly collect Data from children under the Age Limit. Locman therefore requests those under the Age Limit not to subscribe to the newsletter and not to provide any personal data.
    3. If you are a parent of a child under the Age Limit and you become aware that your child has provided Data to Locman, please contact us by sending an e-mail to “privacy@locman.it”. We also remind you that you may exercise the rights described in the “Users’ Rights” section of the Privacy Policy.
    4. If Locman becomes aware that it has collected Data from a child below the Age Limit, it shall take reasonable steps to delete the relevant Data.
    5. In any event, by registering on the Site or by any voluntary provision of Data to the Site, the User confirms that he/she is above the Age Limit.

 

  1. Period of Data Retention
    1. The Data processed in the course of the activity are kept by Locman for the period of time necessary to pursue the specific purposes of each Processing and to ensure compliance with the applicable legal provisions.
    2. The Data processed for the fulfilment of contractual commitments, including pre-contractual activity, are archived by Locman for 10 (ten) years from the execution of the contract for the sale of goods through the Site or, if the latter is not concluded, for the time necessary to respond to the User’s requests.
    3. Data processed in the context of the management and keeping of company accounts are kept for the time necessary to fulfil tax and record keeping obligations.
    4. The Data processed by Locman for “soft spam” activities will be processed until the User objects to the processing, which he may exercise by sending an email to “privacy@locman.it”.
    5. The Product purchase Data from the Site collected by Locman, subject to the User’s consent, for marketing and profiling purposes may be retained for up to 7 (seven) years, following the data protection impact assessment conducted by Locman itself and in accordance with the provisions of the Italian Data Protection Authority in similar areas. Beyond this period, Locman shall take steps to obtain a new consent and, failing this, the Data shall be deleted from its database.
    6. The e-mail address collected for subscription to the newsletter will be retained until the User’s consent is revoked, to be exercised in accordance with the provisions of the “Revocation of consent” section of the Privacy Policy.
    7. With regard to the storage of data collected through cookies placed on the Site, please refer to the section “Cookies installed on the Site” of the Cookie Policy (https://locman.it/cookie-policy/).

 

  1. Users’ Rights
    1. Users may at any time exercise their rights under data protection legislation, pursuant to Articles 15 – 22 of the GDPR, including the right to:
      1. to obtain from the Data Controller confirmation as to whether or not Data concerning him/her is being processed and, if so, to obtain access to the Personal Data, to know the purposes of the processing, the categories of Data processed, the recipients or categories of recipients to whom the Data has been or will be communicated, the period of retention of the Data (if this is not possible, the criteria used to determine the period of retention), if the Data is not collected from the data subject, all available information on its origin, the existence of an automated decision-making process, including profiling (art. 15 GDPR);
      2. obtain from the Data Controller, without undue delay, the rectification of inaccurate Personal Data concerning him/her and the integration of incomplete Personal Data (Art. 16 GDPR);
      3. obtain from the Data Controller, without justified delay, the deletion of personal Data concerning him/her (Art. 17 GDPR);
      4. obtain from the Data Controller the restriction of the processing if the Data Subject contests the accuracy of the Personal Data pending verification by the Data Controller of the accuracy of such Personal Data; the processing is unlawful and the Data Subject has objected to the deletion of the Personal Data and requests that its use be restricted the Personal Data is necessary to the Data Subject for the establishment, exercise or defence of legal claims; the Data Subject has objected to the processing pending verification as to whether the Data Controller’s legitimate reasons prevail over those of the Data Subject (Art. 18 GDPR);
      5. receive from the Data Controller personal Data concerning him/her and to transmit such Data to another Data Controller without hindrance from the Data Controller (Art. 20 GDPR);
      6. object at any time, on grounds relating to his or her particular situation, to the processing of Personal Data concerning him or her in accordance with Art. 6(1)(e) and (f) and for direct marketing purposes, including profiling on those grounds (Art. 21 GDPR);
      7. not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or significantly affects him in a similar way (Art. 22 GDPR);
      8. file a complaint with the competent supervisory authority.
    2. Requests to exercise rights under Art. 1 should be addressed by writing to the contact e-mail of the Data Controller.
    3. Requests relating to the exercise of rights shall be processed without undue delay and, in any event, within one month of the request. This deadline may be extended by a maximum of 2 (two) months, if necessary, taking into account the complexity and number of requests. In such a case, the Data Controller will inform the data subject of the extension, the reasons for the delay, within one month of receipt of the request. If the Data Controller does not comply with the User’s request, the Data Controller will inform the User without delay, and at the latest within one month of receipt of the request, of the reasons for the non-compliance and of the possibility of lodging a complaint with a supervisory authority and seeking judicial remedy.

 

  1. Changes to the Privacy Policy
    1. The Privacy Policy may be subject to changes and updates. Users are invited to consult it periodically.