UPDATED ON 13/01/2022
This policy is written and personalised for visitors of https://www.lowell.it/ . websites. This document annuls and replaces in its entirety the previous cookies document.
WEBSITE POLICY PURSUANT TO THE PROVISIONS OF ART. 13 AND 14 OF EUROPEAN REGULATION 2016/679 (GDPR)
Specific summary information will progressively be indicated or displayed on website pages dedicated to particular services on request requiring the submission of data collection forms. We also inform you that, to provide a complete service, our website may contain links to other websites, not managed by Lowell SRL. Lowell SRL is not responsible for errors, contents, cookies, publication of illegal moral content, advertising, banners or files that do not comply with the laws in force and the respect of Privacy laws by sites not managed by the Controller.
Lowell SRL, in its capacity as Data Controller of your personal data, pursuant to and in accordance with articles 13 and 14 of European Regulation 2016/679, hereby informs you that the aforementioned regulation establishes the protection of data subjects as regards personal data processing and that said processing shall be grounded in the principles of propriety, lawfulness, transparency and shall ensure the protection of your confidentiality and rights. Personal data and information submitted by you or otherwise acquired while using the website shall be processed in compliance with provisions set forth in the aforementioned legislation and confidentiality requirements established therein.
DATA SUBJECTS AND STORAGE TIME
A) users (navigators) of the https://www.lowell.it/ websites
Type of data processed
Navigation Data: IP addresses or domain names of computers and other devices used by users who connect to the site; URI (Uniform Resource Identifier) addresses of requested resources and any time indications thereof; parameters relating to the user's operating system and IT environment; start and finish pages; Navigation index and identification behaviour during display of website pages.
Personal data provided voluntarily by the user: the optional, explicit, voluntary sending of emails to the addresses provided on this website and the compilation of forms it contains implies the subsequent acquisition of the sender’s personal data (for example, name, surname and email address). Specific, summarised information is provided on the pages where forms are available.
Purpose of processing: your data collected during browsing will be processed for the following purposes.
1) performance of operations closely related and instrumental to the management of relations with users or with visitors of the website;
2) collection, storage and processing of your data for statistical analyses, also in anonymous and/or aggregate form; statistical analyses aimed at verifying the quality of the services offered by the site;
3) sharing with social network managers the interaction achieved and the Usage Data relating to the pages where cookies are installed which integrate software functions or products
4) improving browsing experiences in order to send advertising messages and services in line with the preferences expressed during browsing.
COOKIES AND OTHER TRACKING SYSTEMS
C) “Contacts” user section
By filling out the forms accessible in the “Contacts” section, your personal data (name, surname, e-mail address, country, etc.) will be used to respond to your information request. Provision of data for this purpose is the fulfilment of your request. The legal basis for the processing is Article 6.1.b) of the GDPR. Your data, provided you have provided your consent by checking the dedicated marketing box, will be used to send you personalised commercial and advertising information containing information messages and commercial and promotional communication relating to Lowell SRL activities and products using traditional methods (e.g. phone calls, snail mail, individual e-mails, etc.) or automated contact methods (e.g. automated campaigns involving sending e-mails), also through the insertion of the same in the company CRM of the Controller in full compliance with the principles of correctness and lawfulness in compliance with legal provisions. The legal basis for the processing is Article 6.1.a) of the GDPR. You may object to processing at any time by using the “Unsubscribe from this list” link at the foot of the e-mail, or by sending a request to the Controller, using the contact details provided in this policy.
Your data will be stored for the time frames necessary to provide the service you have requested and for marketing purposes until you decide to unsubscribe from the service.
PERSONAL DATA PROCESSING METHODS
In order to compare and possibly improve the results of communications, the Data Controller uses systems for the sending of newsletters and promotional notifications with reports.
By means of said reports, the Controller can find out, for example: the number of readers, openings, one-time "clickers" and clicks, devices (iPhone, Blackberry, Nokia ...) and operating systems (Windows, Apple, Linux, Android ...) used to read the communication; details on the activity of individual users; details of e-mails sent according to date/time/minute; details of emails delivered and otherwise, of forwarded e-mails; the list of those who unsubscribed from the newsletter; who opened an e-mail or clicked on a single link; users who experienced problems in viewing the message; link tracking (i.e. the number of clicks on the links in the message); click tracking (which links were clicked and by whom). All these data are used for the purpose of comparing, and possibly improving, the results of communications.
RECIPIENTS OF PERSONAL DATA AND DATA DISSEMINATION
Your data will be processed by duly authorised staff and will be disclosed to companies acting in their capacity as autonomous Controller or Data processor:
external entities providing in-cloud services;
technical assistance providers;
companies of the group providing IT service management services, including server hosting and backup services;
within the scope of public and/or private entities to which data disclosure is compulsory for the fulfilment of legal requirements, or functional for relations administration purposes.
You may request the full list by writing to the Controller
Your data will not be distributed.
TRANSFER OF PERSONAL DATA:
Your personal data may also be transferred, limited to the above mentioned purposes, to non-EU countries. Such transfer for sending company reports is legitimate insofar as it is guaranteed by the existence of adequacy decisions issued by the European Commission and/or protection clauses based on models adopted by the European Commission pursuant to art. 46 of the GDPR. You can request the Controller a copy of data protection measures implemented for the transfer of your personal data outside the EU, as well as information on the place where said data has been made available, by submitting a specific request to the Controller to the following email address: firstname.lastname@example.org
The Website is not intended for use by minors and no data from minors is collected by the Controller. In the event that the Data Controller is aware of the collection of such data (e.g. via the contact form) it will delete it immediately. The Controller will respond to requests for information in accordance with applicable laws. Please note that the person exercising parental responsibility is obliged, in the case of requests for information, to provide us with consent to the collection of the minor's personal data.
The Data Controller is Lowell SRL, with registered office via Cassiani 173- 41122 Modena (Mo) Italy, email@example.com, in the person of its pro tempore Legal Representative
You have the right to obtain from the Data Controller the erasure (right to be forgotten), limitation, updating, rectification, portability, objection to the processing of personal data concerning you, and in general you can exercise all the rights provided for in Articles 15, 16, 17, 18, 19, 20, 21, 22 of European Regulation 2016/679 by sending an e-mail to firstname.lastname@example.org
You also have the right to lodge a complaint with the Supervisory Authority
APPLICATION OF THE POLICY HEREIN
If you have any doubts regarding this Policy, please contact Lowell SRL by sending an e-mail to email@example.com
AMENDMENTS TO THIS POLICY
RIGHTS OF DATA SUBJECTS
EU Reg. 2016/679: Articles 15, 16, 17, 18, 19, 20, 21, 22 - Rights of the data subject
1. The data subject is entitled to obtain confirmation as to the existence or otherwise of personal data concerning them, even if said data is yet to be recorded, and the disclosure of said data in an intelligible form, as well as to lodge a complaint with the Supervisory Authority.
2. The data subject has the right to receive the following information:
the source of personal data;
the purposes and processing methods;
the logic applied in the event processing is carried out by electronic instruments;
the identification details of the data controller, of the processors and of the appointed representative according to art. 5, para. 2;
the subjects and categories of subjects to whom the personal data may be disclosed or who may become aware of said data in their capacity as designated representative in the country, as data processors or personnel authorised to process personal data.
3. The data subject is entitled to obtain:
the updating, rectification or, if interested, the integration of data;
the erasure and transformation into anonymous form of any unlawfully processed data or data blocks, including those whose retention is not required in relation to purposes for which data were collected or successively processed;
certification that operations specified in letters a) and b) have been disclosed, together with their content, to the people to which data has been disclosed or provided, unless this proves impossible or requires the use of means clearly disproportionate to the right being protected;
4. The data subject is entitled to raise a total or partial objection:
for legitimate reasons, to the processing of the personal data concerning them, even if pertaining to the purpose of collection;
to the processing of personal data for the purpose of sending advertising materials or making direct sales or for carrying out market surveys or sales communications.