Privacy Policy

The information on the LUPOLI S.p.A website (hereinafter, “Site”) is provided pursuant to art. 13 EU Reg. 2016/679 (General Data Protection Regulation) and Legislative Decree 196/2003 (Privacy Code) and subsequent amendments of the law.

Note: Please also read the Cookies Policy

1. Data controller

The data controller is LUPOLI S.p.A, based in via Appia km 57,400 04012 - Cisterna di Latina (LT) - Italy, C.F. / P. Iva 01231150598 (hereinafter, the “Data Controller” or the “Data Controller”).

2. Purpose of processing and legal basis

Personal data (hereinafter also “Data”) provided by the data subject through the Site will be processed for the following purposes:

1. in performance of the requested service (hereinafter referred to as “Service”: e.g., provision of web interface-based services, user master registration, provision of information related to those who have voluntarily registered with the site's database, provision of information related to training activities, internal statistical analysis).
2. subject to your specific consent, for
   1. Send commercial and/or promotional communications about products and services to the data subject as well as conduct market research (“Direct Marketing”) in the manner described in Section 8 of this policy;
   2. Management of surveys and questionnaires including those related to customer satisfaction;
   3. Organization of events, meetings, conferences seminars also aimed at professional training.
3. transfer of collected data to third parties, established within the European Union (companies operating in the fields of design and provision of consulting services and product development for business information systems and development and integration of management applications for businesses), which will process them for direct marketing purposes and for sending promotional and advertising communications in the forms referred to in point (b) (hereinafter “Data transfer to third parties”).

For data submitted through the “work with us” form, the processing of personal data provided for the purpose of applying for any job openings will be for the sole purpose of fulfilling your specific request.

For data sent through the “contact us” form, the processing of personal data provided will be processed solely for the purpose of fulfilling your specific request.

3.Types of data handled

3.1 Navigation data

This category of data includes IP addresses or domain names of computers used by users who connect to the site, addresses of requested resources, the time of the request, the method used in submitting 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 related to the user's operating system and computer environment.

3.2 Data provided voluntarily by the user

The optional, explicit and voluntary sending of electronic mail to the addresses indicated on this site or the completion of the published forms involves the subsequent acquisition of the sender's address in order to respond to requests, as well as any other data entered in the form.

4. Categories of personal data recipients

The Data will be processed by employees and/or collaborators of the Data Controller appointed as authorized processors.

Where consent has been provided in accordance with Art. 2 letter c), the Data may be disclosed to third parties operating in the areas of design and provision of consulting services and product development for business information systems; software integration development for business management within the European Union.

Under no circumstances will the Data be subject to dissemination.

The Data Controller may communicate your Data to judicial, or supervisory Authorities, administrations, bodies and public bodies. These entities will process the Data in their capacity as autonomous data controllers.

The updated list of data processors and data processors is kept at the registered office of the Data Controller.

5. Data retention time

Personal Data about you collected through the forms on our site will be kept for as long as necessary to respond to your requests.

Data collected for direct marketing purposes will be processed for a maximum period of 24 months.

Data collected through cookies will be kept for the time period set by the individual cookie. Please refer to the site's cookie policy for more information.

6. Nature of data provision and consequences of refusal to respond

The provision of the data necessary for the performance of the treatments listed under (a) is optional, but it is a necessary and indispensable condition for the use of the service: any refusal to provide the data determines, therefore, the impossibility of performing the requested service.

Consent to the processing for further purposes is optional.

7. Treatment mode

The processing of Data for each of the above purposes is carried out by paper, automated or electronic means and, in particular, by regular mail or e-mail, telephone (e.g., automated calls, SMS, MMS), fax and any other computer channel (e.g., websites, mobile, app) suitable to ensure security and confidentiality according to the so-called data protection by default i.e., the application of measures to minimize the risks of dissemination of Data.

8. Rights of the data subject

With reference to Articles 15-16-17-18-19-20-21 and 77-79 of the GDPR, you may exercise the rights stated therein and in particular:

1. the right of access, i.e., the right to obtain confirmation from the Company that Data is or is not being processed and, if so, to obtain access to it;
2. the right to rectification and erasure, i.e., the right to obtain rectification of inaccurate Data and/or supplementation of incomplete Data or erasure of Data for legitimate reasons;
3. The right to restriction of processing, i.e., the right to request the suspension of processing if there are legitimate grounds;
4. the right to Data portability, i.e., the right to receive in a structured, commonly used and readable format the Data, as well as the right to transmit the Data to another data controller;
5. The right to object, i.e., the right to object to the processing of Data where there are legitimate grounds, including the processing of Data for marketing and profiling purposes, if any;
6. The right to revoke consent at any time without affecting the lawfulness of the processing based on the consent provided prior to revocation;
7. The right to lodge a complaint with the competent supervisory authority in case of unlawful processing of Data or to take appropriate legal action.

9. Ways to exercise rights

You may exercise these rights by simply sending:

• a registered letter A/R a LUPOLI S.p.A, via Appia km 57,400 04012 - Cisterna di Latina (LT) - Italia

The Data Controller will take care to keep this policy updated.