Privacy Policy

INFORMATION ON THE PROCESSING OF PERSONAL DATA

PURSUANT TO ART. 13 OF EU REGULATION 2016/679 (GDPR)

LE-SA srl, as the Data Controller (hereinafter “Controller”) considers privacy and the protection of Personal Data to be one of the main objectives of its business. This document has been prepared pursuant to Art. 13 of the EU Regulation 2016/679 (hereinafter: “Regulation”) in order to allow you to learn about our privacy policy. Before disclosing any personal data to the Controller, please read this Privacy Policy carefully because it contains important information about the protection of your personal data. This Privacy Policy:

• ➢ is intended to be made for the Site http://www.fonderialesa.it (hereinafter: “Site”) and not also for other websites that may be accessed by the Data Subject through links and is an integral part of the Site and the services we offer;
• ➢ is made pursuant to Art. 13 of the GDPR and the Privacy Code to those who interact with the web services of the Site or who contact by mail or email LE-SA srl.

The processing of your personal data will be based on the principles of fairness, lawfulness, transparency, purpose limitation and storage, minimization and accuracy, integrity and confidentiality, as well as on the principle of accountability under Art. 5 of the GDPR.
Your personal data will therefore be processed in accordance with the legislative provisions of the GDPR and the confidentiality obligations stipulated therein as well as those of the Privacy Code as of today still in force. Processing of personal data means any operation or set of operations, performed with or without the aid of automated processes and applied to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, comparison or interconnection, restriction, erasure or destruction, as defined in Art. 4.2 of the GDPR.

1. DATA CONTROLLER

The Data Controller is LE-SA Ltd. with registered office in Loc. Ponte Cantone – 25010 Pozzolengo (BS), VAT: 00578800989, tel. 030 918159, email: info@fonderialesa.it

2. PERSONAL DATA SUBJECT TO PROCESSING

We inform you that as a result of browsing the Site, the personal data being processed may consist (including depending on your decisions on how to use the services) of an identifier such as a first and last name, a doc. number of identification , location data , an online identifier, ip addresses, cookies, suitable to make the person identified or identifiable, depending on the type of services requested (hereinafter only “personal data”) The personal data processed through the Site are as follows:

• a. Navigation data
  The computer systems and software procedures used to operate the Site acquire, in the course of 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 data subjects, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users connecting to the Site, the URI (Uniform Resource Identifier) notation addresses of the 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. These data are used for the sole purpose of obtaining any anonymous statistical information on the use of the Site to check its correct functioning, to identify anomalies and/or abuses, and are deleted immediately after processing. The data could be used to ascertain liability in case of hypothetical computer crimes against the Site or third parties.
• b. Data voluntarily provided by the user
  The Site offers users the opportunity to voluntarily provide personal information through, for example, the request for services, information or quotes, the optional, explicit and voluntary sending of electronic mail to the addresses indicated on the Site, in the “contact” section, etc. This Privacy Policy is understood to be rendered also for the processing of Personal Information voluntarily provided through the Site.
• c. Third-party data voluntarily provided by the user
  In using some of the Site’s services, processing of Personal Data of third parties submitted by you may occur. With respect to these assumptions, you stand as an autonomous data controller, assuming all legal obligations and responsibilities. In this sense, it confers on this point the widest indemnity with respect to any dispute, claim, request for compensation for damages from processing, etc. that may be received by the Controller from third parties whose Personal Data have been processed through its use of the Site’s functions in violation of the applicable Personal Data protection regulations. In any case, should it provide or otherwise process Personal Data of third parties in the use of the Site, it warrants as of now – assuming all related liability – that this particular hypothesis of processing is based on a suitable legal basis pursuant to Art. 6 of the Regulations legitimizing the processing of such data.
• d. Cookie
  Information on cookies served by the Site is available at the link (cookie policy) on the site.

3. PURPOSE OF PROCESSING

Your personal data will be processed, with your consent where necessary, for the following purposes where applicable:

• 3.1. Enable users to use the services offered by the platform, (e.g., request for contact, for a quote, request for information, request to send documentation, report abuse);
• 3.2. Respond to specific requests, including by telephone, addressed to ‘the company;
• 3.3. Fulfilling any obligations under applicable laws, regulations or EU legislation, or fulfilling requests from the authorities;
• 3.4. Exercise the rights of the Owner;
• 3.5. For statistical purposes, without being able to be traced back to your identity;
• 3.6. Soft opt-in: to carry out direct marketing via e-mail you provide for similar services previously purchased to those you requested as an existing customer (including: demos, downloadable materials or documentation on the Site), unless you expressly decline to receive such communications, which you may express at the time of requesting services or on subsequent occasions. Your personal data will be processed by automated and non-automated means. Specific security measures are observed to prevent data loss, illegal or incorrect use, and unauthorized access.

4. LEGAL BASIS AND MANDATORY OR OPTIONAL NATURE OF PROCESSING

The legal basis for the processing of personal data for the purposes mentioned in Section 3.1. e 3.2. Is Art. 6(1)(b) of the GDPR ([…]the processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures taken at the request of the data subject), as the processing operations are necessary for the provision of services. Providing personal data for these purposes is optional, but failure to do so would make it impossible to activate the services requested.

The legal basis for the purpose of Section 3.3. Is Art. 6(1)(c) of the GDPR ([…]the processing is necessary for compliance with a legal obligation to which the data controller is subject). Once personal data are provided, in fact, processing is indeed necessary to fulfill legal obligations to which The Holder is subject. The legal basis for the purpose of Section 3.4. Is Art. 6(1)(f) of the GDPR (…. Processing is necessary for the pursuit of the legitimate interest of the data controller or third parties, provided that the interests or fundamental rights or freedoms of the Data Subject do not prevail.).

It should also be noted that the treatment referred to in Section 3.5. is not performed on personal data and therefore can be freely performed by the Owner. The processing of your Personal Data for the purpose described in Section 3.6. represents legitimate processing under applicable data protection legislation, which does not require your consent (art. 130 co. 4 Legislative Decree 196/2003). You may object to the processing of your Personal Data for this purpose both when requesting products and services available on the Site and in subsequent communications from the Data Controller.

5. RECIPIENTS OF PERSONAL DATA

Your personal data may be shared, for the purposes set forth in Section 3 of this Privacy Policy, with:

• 5.1. Individuals who typically act as data controllers viz: (a) persons, companies or professional firms that provide assistance and advice to the Controller in administrative and legal matters related to the provision of services; (b) parties with whom it is necessary to interact for the provision of services (e.g. hosting providers); (c) parties delegated to carry out technical maintenance activities (including maintenance of network equipment and electronic communication networks);
• 5.2. persons authorized by the Data Controller to process personal data necessary to carry out activities closely related to the provision of services, who have committed to confidentiality or have an appropriate legal obligation of confidentiality and ensure the Processing of Data in accordance with the GDPR.
• 5.3. subjects, entities or authorities to whom it is mandatory to communicate your Personal Data by virtue of provisions of the law or orders of the authorities or in the case of reports to investigate complaints and identify the source of messages received from users; The complete and updated list of Responsible Parties is kept at the operational headquarters of the Owner.

6. TRANSFER OF PERSONAL DATA

The data provided will in no case be subject to dissemination or communication to third parties, with the exception of subjects whose right to access the data is recognized by provisions of the law or orders of the authorities, as well as subjects, including external and/or foreign, to whom the communication is necessary to carry out fiscal or administrative obligations, or subjects whose activities are instrumental and/or ancillary to the performance of its obligations arising from the conclusion of contracts governed by the General Conditions of Sale and/or otherwise related to the services offered.

We are also advised that in order to carry out the above activities, the collected data may be transferred to servers that may be located in countries outside the EU. In such a case, upon verification that the country in question guarantees an “adequate” level of protection under Art. 46 GDPR 679/16, the Owner will ensure appropriate security measures based on the provisions of the Regulations.

7. STORAGE OF PERSONAL DATA

Personal data processed for the purposes mentioned in Section 3.1. – 3.2. – 3.6. will be retained for the time strictly necessary to achieve those same purposes as well as, being processing carried out for the provision of services, up to the period of time provided for and allowed by the Italian legislation to protect the interests and the right of defense of the Owner, having regard to the statute of limitations provided for by the applicable legislation (Art. 2946 c.c. et seq.).

The Personal Data processed for the purposes mentioned in Section 3.3. will be retained as long as required by the specific obligation or rule of law applicable.
More information regarding the data retention period and the criteria used to determine this period can be requested by sending a written request to the Data Controller at the email address listed in this policy. This is without prejudice, in any case, to the possibility for the Controller to retain your personal data for the period of time provided for and permitted by Italian law to protect its interests (Art. 2947(1)(3) c.c.).

8. RIGHTS OF THE DATA SUBJECT

As a data subject, you are guaranteed all the rights specified in Articles 15 to 22 of Regulation (EU) 2016/679, Art. 7.3 GDPR (free withdrawal of consent); in particular, under the applicable legislation, you have the right to:

• a) obtain: indications about the origin of the personal data, the purposes and methods of processing, the legal basis of the processing, the logic applied in case of processing carried out with the aid of electronic instruments and in case there is an automated decision-making process and in this case the importance and the expected consequences of such processing; indication of the identification details of the Data Controller and the Data Processors; indications about the subjects or categories of subjects to whom the data may be communicated or who may become aware of the data in their capacity as designated representative in the territory of the state, as managers or appointees; indications about the period of storage of personal data or, if this is not possible, the criteria used to determine this period; access, updating, rectification or integration of data concerning him/her; deletion without undue delay or restriction of processing; portability of data, i.e., transmission of data in a commonly used, machine-readable format and the right to transfer them to another data controller (where technically feasible); certification of the fact that the operations referred to in the preceding points have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except where this proves impossible or involves the use of means manifestly disproportionate to the protected right;
• (b) revoke consent where given at any time without affecting the lawfulness of the processing based on the consent given before revocation;
• c ) to object, in whole or in part, at any time, to the processing of personal data concerning him/her, provided for the purposes of commercial information or sending advertising or direct sales material or for carrying out market research or commercial communication.

In order to exercise the rights under the GDPR, the Data Subject may:

• (i ) forward your requests to the Holder, by written communication to be sent by email to: info@fonderialesa.it
• (ii ) express communication at the Controller’s premises In any case, you always have the right to file a complaint with the competent supervisory authority (Data Protection Authority), pursuant to Art. 77 of the GDPR, if you believe that the processing of your data is contrary to applicable law.

9. CHANGES

LE-SA Ltd. reserves the right to modify or simply update the content of this Privacy Policy, in part or in full, including due to changes in applicable regulations. The Data Controller therefore invites you to visit this section regularly to take cognizance of the most recent and updated version of the Privacy Policy so that you are always up-to-date on the data collected and the data controller’s use of it.

10.LINKS TO OTHER WEBSITES AND THIRD PARTIES

Our Web site may include links to and from Web sites of our partner networks, advertisers, and affiliates; if you follow a link to any of these Web sites, you should remember that there are special privacy policies in effect for such sites and that we assume no responsibility for these policies. Check these policies before sending personal data to their Web sites.

Last updated: 06/01/2024