Privacy Policy

PRIVACY POLICY OF 13.06.2018

Information pursuant to and for the effects of Articles 13-14, Regulation (EU) 2016/679

(General Data Protection Regulation)

LANDOOR Srl Società Unipersonale, with registered office at Via Copernico 38, 20125 Milan, Italy, VAT no 10009800961, in its capacity as Controller (“Controller”), hereby informs you that EU Regulation no 2016/679 on the protection of personal data provides for the protection of natural persons and other subjects with regard to the processing of personal data.

Pursuant to Articles 13 and 14 of the aforementioned Regulation, please be informed as follows:

1. Purpose, legal basis of data processing

The processing of your personal data is aimed at:

1.a. rendering the services which are the subject matter of the contract between you and the Controller;

1.b. fulfilling the pre-contractual, contractual and fiscal obligations arising from the relationship in force;

1.c. fulfilling the obligations imposed by law, regulation, EU legislation or an order of the Authority (e.g., on anti-money laundering matters)

1.d. exercising the rights of the Controller, e.g., the right to legal defence.

Only after having obtained your specific and explicit consent, your data will be processed for the following purposes:

2. to send you via e-mail, mail and/or telephone the following information of the Controller: invitations to events, informational material, newsletters, communications on products or services and questionnaires measuring level of satisfaction of the quality of the services;
3. to send you via e-mail, mail and/or telephone the following information of third parties (e.g., business partners): invitations to events, informational material, newsletters, communications on products or services.

Please note that if you are already a client, you may receive business communications from us regarding services and products of the Controller similar to those which you have already used, unless you expressly exercise your right to objection, which you may freely do so at any time

2. Personal data sources and purpose

   Only the data provided by you will be used and stored.

3. Method of processing

In relation to the aforementioned purposes, your data will be subject to computer and paper processing. Data processing will ensure the logical and physical security and confidentiality of your personal data.

4. Nature of personal data

The personal data relating to the performance of the service you have requested will be the subject of processing.

During the performance of the service it may be necessary to acquire and carry out processing operations on your data. You will be requested to provide your written consent.

5. Scope of communication and disclosure

Your data may be disclosed to:

• any party with the right to access such data by virtue of regulatory measures;
• our collaborators and employees, within the scope of their tasks, in Italy and the European Union.

An updated list of the processors and persons in charge of processing is held at the registered office of the Controller.

Your personal data is stored on servers located within the European Union. It is understood that, where necessary, the Controller has the right to transfer the servers even outside of the EU. In this case, the Controller guarantees  that the data transfer to non-EU countries will take place in compliance with applicable law, subject to the standard contractual clauses laid down by the European Commission.

6. Period of storage

Your data will be stored for as long as you are our client and any additional time thereafter solely to comply with legislative or fiscal obligations.

7. Rights of the data subject pursuant to EU Regulation 2016/679

7.1 Right of access (Article 15), Right to rectification (Article 16)

The data subject has the right to obtain from the Controller confirmation as to whether or not personal data concerning him or her are being processed and, where that is the case, access to the personal data and the following information:

1. a) the purposes of the processing;
2. b) the categories of the personal data concerned;
3. c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
4. d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
5. e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
6. f) the right to lodge a complaint with a supervisory authority;
7. h) the existence of automated decision-making, including profiling, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

7.2 Right to erasure (“right to be forgotten”) (Article 17)

The data subject shall have the right to obtain from the Controller the erasure of personal data concerning him or her without undue delay and the Controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

1. b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;
2. c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
3. d) the personal data have been unlawfully processed;
4. e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
5. f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of EU Regulation 2016/679.

7.3 Right to restriction of processing (Article 18)

The data subject shall have the right to obtain from the Controller restriction of processing where one of the following applies:

1. a) the accuracy of the personal data is contested by the data subject, for a period enabling the Controller to verify the accuracy of the personal data;;
2. b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
3. c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
4. d) the data subject has objected to processing pursuant to Article 21(1) of EU Regulation 2016/679 pending the verification whether the legitimate grounds of the Controller override those of the data subject.

7.4 Right to data portability (Article 20)

The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to the Controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another Controller without hindrance from the Controller to which the personal data have been provided.

8. Revocation of consent to the processing and exercise of the data subject’s other rights

The data subject may revoke consent to the processing and exercise of all of the other rights envisioned under EU Regulation 2016/679 by writing to the Controller at the following e-mail address: info@landoor.com.

Cookie Policy

The following legal text was drafted by the legal practice Avv Federico Vincenzi, of the Court of Brescia, and by Dr. Luca Comparin, and licensed to Landoor s.r.l. exclusively for publication on this website and on the basis of the information provided by same. The copying, modification, updating or sending of the text to parties other than users, or its replication on websites or apps including those belonging to licensee Landoor, is strictly prohibited.

1: Premises

This notice supplements the first-level notice (“Cookie banner”) as well as the information contained in the Privacy notice and the browsing Terms and Conditions.   In particular, the aim of this Cookie Policy is to illustrate the types and categories of cookies used, the purposes and ways that the cookies are used by Landoor Srl, first party and data controller, with head office at Via Copernico 38, 20125 Milan, VAT number and Tax Code10009800961, phone number +39 0292858400, email info@landoor.com, Certified email landoor@legalmail.it, or by third parties where third-party cookies are installed (for more about third-party cookies see point 3), as well as to provide users with useful information on the actions to take to inhibit or delete cookies present on www.landoor.com.   Users many consent to the use of the cookies proposed to them via Cookie banners (“first-level notices”) in various ways: by continuing to browse the website, by clicking on one of the links on the pages of the website, or by clicking “Accept”.

2: What are cookies?

Cookies are little text files that the website sends to the user’s device and which are memorised in the browser and automatically sent back to the site every time the website is subsequently accessed or whenever the cookie is requested. On one hand they enable the website to communicate more easily with the user’s device (for example by saving their website language preferences) or to track the user’s website activity for various reasons (for example, creating a marketing profile on the basis of their browsing activity). On the other, they enable the user’s device to improve its technical interaction with the website, for example enabling it to be recognised as a registered user when browsing the site so the user doesn’t have reinsert their access credentials every time they open a new page.

3: Types of Cookies used by the site

The types of cookies that can be installed are described below. To find out which cookies are actually used by the website see the table at the bottom of the page.

Time-based cookies:

There are two types of time-based cookies: session cookies and persistent cookies. The former are only stored for the duration of the browsing session and are automatically erased when the browser is closed. The latter are stored persistently in the browser for a period of time that varies from cookie to cookie but which in any case continues after the browser is closed. In other words they have an “expiry date” on which they are automatically erased from the device. It is possible to see the number of cookies installed by the site and their expiry date via the browser (as illustrated in the section Cookie Management Tools further ahead).

Functional cookies:

Functional cookies facilitate the browsing, access and use of the site by the user. Without these cookies, some operations would be more complex and/or less secure, or impossible to complete. For these operations functional cookies, which identify the user for the duration of the session, are essential (for example, for recognising if a user is registered or not).   There are also analytics cookies which are used to collect information in aggregated form (anonymously or not) on the number of users and how they visit the website, in order to optimise the efficacy of the latter.   Finally, there are also advertising or targeting cookies which track the user’s website activity in order to display targeted advertisements on their device, also potentially building a user profile.

First- and third-party cookies:

Some cookies are created and managed by the website developer (first-party cookies), and sent to the user’s device directly by the website. Other cookies are created and managed – also by browsing the website – by third parties.

Anonymous or pseudonymous:

Some cookies are processed in order to be able to identify the user or at least the device or account from which they are browsing. In these cases the cookies are not anonymous. If the cookies are processed in such a way that it isn’t possible to identify the browsing device or account, then they are anonymous.

Table of cookies used by the site

  4: MANAGEMENT OF CONSENT TO THE USE OF COOKIES As suggested by the above table, the website primarily uses functional cookies. For these cookies first-level information does not have to be provided to the user (via banners when landing on the site). However, a second-level notice of this kind is requested to ensure appropriate disclosure to the user. It is mandatory to consent to the use of this type of cookie as without it the browsing experience may be compromised and a number of functions may not be available, inconveniencing the user (for example, in the case of a multilingual website if these cookies aren’t used the user would have to select their preferred language every time they visit the site).   The website also uses pseudonymous third-party analytics cookies. Prior consent of the user is required for the use of these cookies, which is acquired through the acceptance of the first-level notice (banner when landing on the site). The use of these cookies is not strictly necessary for the effective functioning of the website and so consent to their use is optional and can be given and retracted at any time through one of the methods illustrated in the section Cookie Management Tools.  

5: Cookie Management Tools

How to block or inhibit cookies: Every browser has different procedures for managing cookies. Below are links to the specific instructions for the most common browsers:   Internet Explorer: http://windows.microsoft.com/it-it/internet-explorer/delete-manage- cookies#ie=ie-11   Google Chrome: https://support.google.com/accounts/answer/61416?hl=it   Apple Safari: http://support.apple.com/kb/HT1677?viewlocale=it_IT   Mozilla Firefox: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie   Alternatively or in addition to the management of cookie consent via their browser, the user can also use one of the following third-party services (for which we recommend reading the relative Terms and Conditions and Privacy Policies before using):   The website http://www.youronlinechoices.com/it/ enables you to manage your consent to profiling cookies.   Monitoring service Ghostery (a plug-in that can be installed directly on your browser) enables you to see which cookies are present on the website you are visiting and to block them (for one specific site or all websites).   The website https://webcookies.org/ enables you to see which cookies are present on a specific website, who they belong to and how long they last.

6: User Rights

If the user is unable to see which forms of consent they have given to the use of cookies, has doubts over the functioning of these cookies or is unable to revoke one or more forms of consent via the aforementioned procedures, they can contact the Data Controller directly at the following email address: info@landoor.com. In any event, the user is hereby informed that with regard to cookies certain operations cannot be carried out by the Controller in first person but must be necessarily performed by the User (for example, the Controller cannot in any way delete the cookies installed on the User’s device).

7: User Rights II

Users benefit from a series of rights.   First of all, the user has the right to be informed about:

• The categories of processed data: see the types of cookies that the website uses in point 4;
• The origin of the data, i.e. from where the service obtained their data: the service obtains the data from the User’s device, as do the third-party services to which the User has given their consent;
• The purpose of data processing, i.e. the reasons for which their data is processed: as explained, every cookie has a different purpose;
• The data processing method: the data is processed with electronic instruments; The details of the Controller and any Data Supervisors: see point 1;
• The parties to whom the data is communicated: the website, in first person, does not collect user data that is then communicated to third parties even if the installation of third-party pseudonymous cookies constitutes, for all intents and purposes, the communication of data;
• Data storage and processing duration: as illustrated above, cookies have different life spans (see point 3). Users are therefore advised to use one of instruments listed to see the duration of each individual cookie;
• The right to file a complaint with the Italian Data Protection Authority via the following link:http://www.garanteprivacy.it/home/diritti/come-agire-per-tutelare-i-nostri-dati-personali
• The existence or not of profiling processes performed by the Landoor service or third parties: the site does not collect data for its own profiling purposes (not directly, but some third-party sites may);
• The legal basis for processing: functional cookies for the performance of the service, consent for analytics and profiling cookies;
• The right to revoke their consent: see point 5.
• Interests pursued by the Controller via processing: provide the user a simple and efficient browsing experience.

Other rights are connected with actions rather than information:

• cancellation: this right can be exercised if the data is no longer necessary for the purposes for which it was processed, i.e. if it is based on consent, in the forms illustrated in section Cookie Management Tools (point 5);
• objection to processing: this is exercised through the revocation of consent, as illustrated in the section Cookie Management Tools.

The original copy of this Cookie Policy is stored on the server of Sinapto Srl. Terms applicable from 01/05/2018. [1] The options indicated are all those that can be used, according to the provision of the Data Protection Authority, to express first-level consent. You are free to decide which one to use as long as the banner indicates only your chosen option (for example, if you exclude the possibility of consent being given just by browsing the site then this formula must not appear on the banner). Secondly, the operation by which consent is provided (chosen from the listed options) must be demonstrable: we therefore recommend inserting an option that records a log.