PART I - SITE PRIVACY POLICY INFORMATION
1. This section contains information about the Lorenz management procedure in relation to the processing of data of Lorenz users.
2. This privacy policy is also valid under Article 13 of Legislative Decree no. 196/2003, the Personal Data Protection Code, and under Article 13 of EU Regulation no. 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, for individuals interacting with Lorenz and is available on the home page: www.lorenz.it
3. The privacy policy is provided only for Lorenz and not for other websites that may be consulted by the user through links contained therein.
4.The purpose of this document is to provide information on the methods, timing and nature of the information that data controllers must provide users with when connecting to Lorenz's web pages, regardless of the purpose of the connection itself, in accordance with Italian and European legislation.
5. This privacy policy may be subject to change due to the introduction of related new regulations, so please check this page periodically for updates.
6. If the user is under 16 years of age, in accordance with Article 8(1) of EU Regulation 2016/679, he or she will have to legitimise his or her consent through the authorisation of his or her parents or guardian.
PART II - DATA PROCESSING
1. Data Controller
1.1 The data controller is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data and also manages security profiles.
1.2 With regard to this website, the data controller is: Leader Watch Company Srl, and for any clarification or exercise of the user's rights, it can be reached at the following email address: amministrazione@lwco.it.
2. Data Processor
2.1 The data processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
2.2 Pursuant to Article 28 of EU Regulation No. 2016/679, upon appointment by the data controller, the data processor of the Lorenz website is: Aldo Santangelo.
3. Place of data processing
3.1 The data processing arising from the use of Lorenz takes place at Via Pietro Mascagni, 15 - 20122 Milan.
3.2 If necessary, the data connected to the newsletter service may be processed by the data processor or persons appointed by him for this purpose at the relevant offices.
PART III - COOKIES
1. Type of Cookies
1.1 The Lorenz website uses cookies to make the user's browsing experience easier and more intuitive: cookies are small text files used to store certain information that may concern the user, his/her preferences or the Internet access device (computer, tablet or mobile phone) and are mainly used to adapt the operation of the site to the user's expectations, providing a more customised browsing experience and storing previously made choices.
1.2 A cookie is a small data file sent to the user's browser by a web server and can only be read by the server that made the transfer. This is not executable code and does not transmit viruses.
1.3 Cookies do not record any personal information and any identifiable data will not be stored. If you wish, you can prevent some or all cookies from being saved. However, in this case the use of the site and the services offered may be compromised. To proceed without changing the cookies options, simply continue browsing.
Below are the types of cookies that the site uses:
a) Technical cookies
a.1) There are numerous technologies used to store information on your computer, which is then collected by the sites. Among these, the best known and most used is HTML cookies. They are used for browsing and to facilitate access and use of the site by the user. They are necessary for the transmission of communications over an electronic network or to the provider to provide the service requested by the customer.
a.2) The settings for managing or disabling cookies may vary depending on the internet browser used. In any case, users can manage or request the deactivation or deletion of cookies by changing the settings of their internet browser. Such deactivation may slow down or prevent access to certain sections of the site.
a.3) The use of technical cookies allows the safe and efficient use of the site.
a.4) Cookies integrated in the browser and retransmitted through Google Analytics or through the statistical service of bloggers or similar sites can be considered technical cookies only if used for site optimisation purposes directly by the site owner, which may collect information in aggregate form on the number of users and how they visit the site. Under these conditions, the same rules apply to cookie analytics as regards privacy policy and consent as for technical cookies.
a.5) From the point of view of duration, it is possible to distinguish temporary session cookies that are automatically deleted at the end of the browsing session and are used to identify the user and thus avoid the login to each page visited and permanent cookies that remain active in the PC until expiry or cancellation by the user.
a.6) Session cookies may be installed in order to allow access and stay in the reserved area of the portal as an authenticated user.
a.7) They are not stored permanently but only for the duration of the browsing session until the browser is closed and disappear when the browser is closed. Their use is strictly limited to the transmission of session identifiers consisting of random numbers generated by the server necessary to allow the safe and efficient exploration of the site.
b) Third party cookies
b.1) In relation to the source, a distinction is made between cookies sent to the browser directly from the site you are visiting and those of third parties sent to your computer from other sites and not from the site you are visiting.
b.2) Permanent cookies are often third-party cookies.
b.3) Most third-party cookies are tracking cookies used to identify online behaviour, understand interests and then customise advertising proposals for users.
b.4) Third party analytical cookies may be installed. They are sent by third party domains outside the site.
b.5) Third party analytical cookies are used to detect information about user behaviour concerning Lorenz. The reading is carried out anonymously in order to monitor performance and improve the usability of the site. Third party profiling cookies are used to create user profiles in order to propose advertising messages in line with the choices made by users.
b.6) The use of these cookies is governed by the rules set by the third parties themselves; therefore, users are invited to read the privacy policy and the guidelines published on the relevant web pages in order to manage or disable cookies.
c) Profiling cookies
c.1) Profiling cookies are designed to create profiles related to the user and are used to send advertising messages in line with the preferences expressed while surfing internet.
c.2) When using these types of cookies, the user must give explicit consent.
c.3) Article 22 of EU Regulation 2016/679 and Article 122 of the Data Protection Code will apply.
PART IV - PROCESSED DATA
1. Data processing procedure
1.1 Like all websites, this website also makes use of log files in which information collected automatically during users' visits is stored. The information collected could be as follows:
a) Internet protocol (IP) address;
b) type of browser and parameters of the device used to connect to the site;
c) name of the Internet service provider (ISP);
d) date and time of visit;
e) the visitor's web page of origin (referral) and exit;
f) the number of clicks, if any.
1.2 The above information is processed automatically and collected in an exclusively aggregated form in order to verify the correct functioning of the site, and for security reasons. This information will be treated according to the legitimate interests of the data controller.
1.3 For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may also include personal data such as the IP address, which could be used, in accordance with the laws in force, to block attempts to damage the site itself or to cause damage to other users, or in any case harmful or criminal activities. This data is never used for the identification or profiling of the user, but only for the protection of the site and its users; this information will be treated according to the legitimate interests of the data controller.
1.4 If the site allows to enter comments, or in case of specific services requested by the user, including sending Cvs for a possible employment relationship, the site automatically detects and records some identification data of the user, including the email address. This data is understood to be voluntarily provided by the user at the time the service is requested. By entering a comment or other information, the user expressly accepts the privacy policy, and in particular agrees that the contents entered are also freely disclosed to third parties. The data received will be used exclusively for the provision of the requested service and only for the time necessary to provide the service.
1.5 The information that users of the site will consider to make public through the services and tools made available to them, are provided by the user consciously and voluntarily, releasing this site from any liability for any violation of the law. It is up to the user to verify that he or she has permission to enter personal data of third parties or content protected by national and international regulations.
2. Purposes of data processing
2.1 The data collected by the site during its operation is used for the purposes indicated above as well as for the following purposes:
a) Sale of products
b) Marketing purposes
c) Advertising
d) Newsletters
2.2 The data will be stored for the period strictly necessary to achieve the above-mentioned purposes and in any case not exceeding 10 years.
2.3 The data used for security purposes (blocking attempts to damage the site) are stored for the time strictly necessary to achieve the purpose previously indicated.
3. Data provided by the user
3.1 As indicated above, the optional, explicit and voluntary sending of electronic mail to the addresses indicated on this site involves the subsequent acquisition of the sender's address, necessary to respond to requests, as well as any other personal data included in the message.
3.2 Specific summary information will be progressively reported or displayed on the pages of the site prepared for specific services on request.
4. Support in configuring your browser
4.1 You can also manage cookies through your browser settings. However, deleting cookies from your browser may remove the preferences you have set for the site.
4.2 For more information and support you can also visit the specific help page of the web browser you are using:
a) Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
b) Firefox: https://support.mozilla.org/en-us/kb/enable-and-disable-cookies-website-preferences
c) Safari: http://www.apple.com/legal/privacy/en/
d) Chrome: https://support.google.com/accounts/answer/61416?hl=en
e) Opera: http://www.opera.com/help/tutorials/security/cookies/
f) For all web browsers not listed, please refer to the developer's dedicated pages
5. Social Network Plugin
5.1 This website also incorporates plugins and/or buttons for social networks in order to allow easy sharing of content on your favourite social networks. These plugins are programmed so that no cookies are set when accessing the page, in order to safeguard users' privacy. Cookies are only set, as provided by social networks, when the user makes effective and voluntary use of the plugin. Please note that if you are logged into the social network then you have already consented to the use of cookies sent through this site when you signed up to the social network.
5.2 The collection and use of information obtained through the plugin is governed by the relevant privacy policies of social networks, to which you must refer:
a) Facebook: https://www.facebook.com/help/cookies
b) Twitter: https://support.twitter.com/articles/20170519-uso-dei-cookie-e-di-altre-tecnologie-simili-da-parte-di-twitter
c) Google+:http://www.google.com/policies/technologies/cookies
d) Pinterest: https://about.pinterest.com/it/privacy-policy
e) AddThis: http://www.addthis.com/privacy/privacy-policy
f) Linkedin: https://www.linkedin.com/legal/cookie-policy
g) For all social networks not listed, please refer to the developer's dedicated pages
PART IV - PROCESSED DATA
1. Article 13(2) of EU Regulation 2016/679 lists the user's rights.
2. The Lorenz site therefore intends to inform the user about the existence of the site:
a) the right of the data subject to ask the data controller for access to personal data (Art. 15 of EU Regulation), their updating (Art. 7(3), point a) of Legislative Decree 196/2003), rectification (Art. 16 of EU Regulation), integration (Art. 7(3), point a) of Legislative Decree 196/2003) or right to restriction of processing (Art. 18 of EU Regulation) or to object, for legitimate reasons, to their processing (Art. 21 of EU Regulation), in addition to the right to data portability (Art. 20 of EU Regulation);
b) the right to erasure (Art. 17 of EU Regulation), transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data was collected or subsequently processed (Art. 7(3), point b) Legislative Decree no. 196/2003);
c) the right to obtain certification that the operations of updating, rectification, integration of data, erasure, blocking of data, transformation have been notified, also as regards their contents, to those to whom the data was communicated or disclosed, unless this requirement proves impossible or involves a manifestly disproportionate effort to the protected right (Art. 7(3), point c) Legislative Decree no. 196/2003);
3. Requests can be addressed to the data controller, without a formal procedure or, alternatively, using the form provided by the Data Protection Authority, or by sending an email to: amministrazione@lwco.it
4. Where the processing is based on point a of Article 6(1), - explicit consent to the use - or on point a of Article 9(2), - explicit consent to the use of genetic, biometric, health-related data revealing religious or philosophical beliefs or trade-union membership, revealing racial or ethnic origin, political opinions - the user has the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
5. Likewise, in case of violation of the law, the user has the right to lodge a complaint with the Data Protection Authority responsible for monitoring the processing in Italy.
6. For a more detailed examination of your rights, see Articles 15 et seq. of EU Regulation 2016/679 and Art. 7 of Legislative Decree 196/2003.
PART VI - DATA TRANSFER TO COUNTRIES OUTSIDE THE EU
1. This site may share some of the data collected with services located outside the European Union especially with Google, Facebook and Microsoft (LinkedIn) via social plugins and the Google Analytics service. The transfer is authorized and strictly regulated by Article 45(1) of EU Regulation 2016/679, so no further consent is required. The above-mentioned companies guarantee their adherence to the Privacy Shield principles.
2. Data will never be transferred to third countries that do not comply with the conditions laid down in Article 45 et seq. of the EU Regulation.
PART VII - SECURITY OF DATA PROVIDED
1. This site processes user data in a lawful and correct manner, taking appropriate security measures to prevent unauthorized access, disclosure, alteration or destruction of data. The processing is carried out by means of computer and/or telematic tools, with organisational procedures and logics strictly related to the purposes indicated.
2. In addition to the data controller, in some cases, categories of individuals involved in the organisation of the site (administrative, commercial, marketing personnel, counsels, system administrators) or external parties (such as third party technical service providers, postal carriers, hosting providers, computer companies, communication agencies) may have access to the data.
PART VIII - SECURITY OF DATA PROVIDED
1. This document, published on the website: www.lorenz.it, is the privacy policy of this site.
2. It may be subject to changes or updates. Users are invited to periodically consult this page to keep up to date with the new legislative requirements.
3. Previous versions of the document will still be available on this page.
4. The document was updated on 21/05/2020 to comply with the relevant regulatory provisions, and in particular with EU Regulation 2016/679.
Last Update May 2020