Privacy Policy for the Processing of Customers’ Personal Data
Pursuant to Articles 13 and 14 of Regulation 2016/679/EU (hereinafter referred to as "GDPR"), LPCouplings S.r.l. (hereinafter referred to as the "Controller"), headquartered at Via Palmiro Togliatti, 8 20060 Bussero (MI), in its role as the "Data Controller," informs you that your personal data, collected for the purpose of concluding a contract with the Client and/or in the context of executing and/or signing said contract, will be processed in compliance with the aforementioned regulations. This is to ensure the protection of rights, fundamental freedoms, and the dignity of individuals, with particular regard to privacy and personal identity. We also inform you that if the activities provided to you involve the processing of personal data of third parties under your ownership, it will be your responsibility to ensure compliance with the relevant regulations concerning the rights of the Data Subjects to legitimize the processing of such data by us.
Origin, Purposes, Legal Basis, and Nature of the Processed Data
The processing of your personal data, which you have directly provided, is carried out by LPCouplings S.r.l. for the purpose of concluding a contract with the Client and/or executing and/or signing the same.
Additionally, there may be processing of personal data of third parties provided by the Client to the Company. In such a case, the Client acts as an independent data controller and assumes the resulting legal obligations and responsibilities, indemnifying the Company against any complaints, claims, and/or compensation requests from third parties due to data processing issues that may arise.
In compliance with current regulations regarding personal data protection and without requiring specific consent from the Data Subject, the data will be stored, collected, and processed by the Company for the following purposes:
- Compliance with contractual obligations, execution, and/or signing of the contract with the Client and/or management of any pre-contractual measures;
- Fulfillment of any regulatory obligations, including fiscal and tax provisions related to business activities and obligations related to administrative-accounting activities;
- Direct marketing communications, such as newsletters, emails, SMS, MMS, push notifications, fax, paper mail, phone calls, sent either by the Company or third-party marketing and communication service providers, pursuant to Article 130(1) and (2) of Legislative Decree 196/03 (hereinafter referred to as the "Code");
- Disclosure of Data to third-party companies for sending newsletters and marketing communications through email, SMS, MMS, push notifications, fax, paper mail, phone calls pursuant to Article 130(1) and (2) of the Code.
The legal basis for processing for purposes (a) and (b) mentioned above are Articles 6.1.b) and 6.1.c) of the Regulation.
Providing the Data for the above purposes is optional, but failure to provide such data or refusal to do so would make it impossible for the Company to execute and/or sign the contract and provide the services requested.
The legal basis for processing personal data for purposes (c) and (d) is Article 6.1.a) of the GDPR, as the processing is based on consent. The Data Controller may collect a single consent for the marketing purposes described here, as permitted by the General Provision of the Data Protection Authority, "Guidelines on Promotional Activities and Spam Prevention" of July 4, 2013. Providing consent to the use of data for marketing purposes is optional, and if the Data Subject wishes to object to the processing of their data for marketing purposes as described here, or revoke the consent given, they may do so at any time without consequences (except for no longer receiving marketing communications) by following the instructions in the "Rights of the Data Subject" section of this notice.
Finally, it should be noted that for processing aimed at sending direct marketing materials, conducting direct sales, carrying out market research, or commercial communications related to products or services similar to those used by the Client, the Company may use email or contact details in accordance with and within the limits allowed by Article 130(4) of the Code and the provision of the Data Protection Authority dated June 19, 2008, even without explicit consent. The legal basis for processing data for this purpose is Article 6(1)(f) of the GDPR, without prejudice to the possibility of objecting to such processing at any time by following the instructions in the "Rights of the Data Subject" section of this notice.
Communication
The data may be communicated to third parties appointed as data processors pursuant to Article 28 of the GDPR, particularly to banks, insurance companies, service providers necessary for business operations, or company consultants, where required for fiscal, administrative, contractual, or legally protected needs.
Your personal data, or third-party data under your control, may also be communicated to external companies selected by LPCouplings S.r.l. from time to time, to whom LPCouplings S.r.l. entrusts the execution of tasks related to the engagement, transmitting only the data necessary for the requested activities. All employees, consultants, temporary workers, and/or any other "natural person" performing activities based on LPCouplings S.r.l.'s instructions are designated as "Data Processors" under Article 29 of the GDPR. LPCouplings S.r.l. provides the Data Processors with operational instructions, especially concerning the adoption and compliance with security measures, to ensure the confidentiality and security of the data. Regarding personal data protection, the Client is invited, under Article 33 of the GDPR, to report to LPCouplings S.r.l. any circumstances or events that may lead to a potential "personal data breach" in order to enable an immediate assessment and the adoption of necessary measures to counter such an event by sending a communication to LPCouplings S.r.l. at the contact details provided below.
The Data will not be disclosed.
LPCouplings is obliged to communicate data to Public Authorities upon specific request.
Transfer Abroad
The transfer of your personal data abroad may occur if necessary for managing the assigned tasks. For processing information and data that will be communicated to these entities, LPCouplings S.r.l. will require the equivalent levels of protection adopted for the processing of personal data of its employees. In any case, only the data necessary for the intended purposes will be communicated, and the legal instruments provided for under Chapter V of the GDPR will be applied.
Methods, Processing Logics, and Retention Period
Your data are collected and recorded lawfully and fairly for the purposes outlined above, in compliance with the principles and provisions of Article 5(1) of the GDPR.
The processing of personal data is carried out using manual, IT, and telematic tools strictly related to the purposes, ensuring their security and confidentiality.
Personal data will be processed by LPCouplings S.r.l. for the entire duration of the engagement and subsequently for the assertion or defense of its rights, for administrative purposes, and/or to comply with obligations arising from the applicable regulatory framework, pro tempore with respect for specific legal obligations regarding data retention.
Rights of the Data Subject
In accordance with, and within the limits of, the data protection regulations regarding the rights of Data Subjects, [1] you have the right to request confirmation of whether your personal data is being processed, access the personal data concerning you, and request their rectification, deletion, notification of rectifications and deletions to those to whom the data has been transmitted, restriction of processing in the cases provided by law, data portability – of the data you provided – in the cases indicated by law, to object to the processing of your data, and, specifically, the right to object to decisions based solely on automated processing of your data, including profiling. If you believe that the processing of your data violates the provisions of the GDPR, you have the right to file a complaint with the Data Protection Authority pursuant to Article 77 of the GDPR.
If you wish to request further information about the processing of your personal data or to exercise your rights, you may contact LPCouplings S.r.l. in writing at info@lpcouplings.com.
Data Controller
The Data Controller, under Article 4 of the GDPR, is LPCouplings S.r.l.,
headquartered at Via Palmiro Togliatti, 8 20060 Bussero (MI).
[1] ex Art.12 e Art. 15-22 of Regulation 2016/679/UE
