Introduction

Lubrimetal has always paid the utmost attention to the issue of privacy by integrating the security of personal data in its certified Management Systems for many years.

To improve the protection of personal data and ensure maximum transparency of its treatment, we have updated our Privacy Policy, to make it compliant with the new European Data Protection Regulation (GDPR), in force from May 25 2018.

Remaining available for any clarification, we invite you to read carefully this information, made pursuant to Chapter III, sections 2 and 3 of the European Regulation on the protection of personal carefully data 679/2016.

Owner and contacts

The owner of  and the body responsible for the processing of this data is Lubrimetal Spa, based in via Lido Moggio 19, 23808 Vercurago, (Lecco), Italy.

Lubrimetal is the owner of the website www.lubrimetal.com for which it is responsible, except for other sites which can be consulted by the user through links that may be present on the pages of the aforementioned site.

We remind you that you can contact Lubrimetal and send an application or request regarding personal data and respect for privacy by writing to: privacy@lubrimetal.com

Type of data processed

Lubrimetal deals with various types of personal data in the context of relations with its interlocutors, including its current and potential customers, suppliers, employees, collaborators, partners and other stakeholders.

1) Data acquired in normal business management

Data qualified as personal by law also acquired verbally, directly or through third parties, to achieve effective management of business relationships.

2) Browsing data and cookies

You can browse the site without having to provide any personal data. The site is divided into separate sections, some of which may require data entry, while in others it is not necessary.

The computer systems used to operate the site acquire, in normal operation, some data that is then transmitted implicitly in the use of Internet communication protocols. This may include information on the geographic area from which you are browsing, on the device used, on the type of browser and/or on user behaviour during the session.

It has been decided not to store the user’s IP address, effectively imposing a subsequent identification of the same.

The navigation data is used mainly for statistical information, to check the correct operation of the site and to improve its usability.

For more details about cookies, please refer to the appropriate section.

3) Data provided voluntarily by visitors by filling out the contact form

Lubrimetal acquires such data and processes it exclusively to identify the sender and respond to his requests.

Purposes of processing and legal basis

Lubrimetal can handle data for the following purposes:

1. To respect contractual obligations and conditions (legal basis: execution of a contract).
2. To improve and optimize the management of business relationships, the characteristics of their products and services (legal basis: legitimate interest).
3. To manage accounting, administrative, fiscal, etc. obligations, provided for by Italian, European or international law (legal basis: legal obligation).
4. To manage credit protection, manage any disputes and assert the rights of the owner (legal basis: legal obligations, contract execution, legitimate interest).
5. To send appropriate communications on its products and services, on its initiatives or to detect customer satisfaction (legal basis: legitimate interest or consent when required).
6. To respond to requests received, also to examine in depth any complaints (legal basis: legitimate interest).

Consent is necessary for processing certain types of data and for some purposes (e.g. profiling, large-scale treatments, etc.). Should Lubrimetal be in one of these conditions, it will inform users appropriately and request consent to such processing in the most appropriate manner.

The user will always have the possibility to withdraw consent and remove himself from any direct marketing activity.

Mode and duration of treatment

The data is recorded on electronic or paper supports and kept for the time strictly necessary to achieve the purposes for which the data was collected and, in any event, in compliance with the current regulations in force. The data is stored within the corporate infrastructure which guarantees all security measures provided for by European Regulations and subsequent provisions.

In addition, the company is required to retain certain information on the basis of legal requirements and for a reasonably necessary time to meet those legal requirements, resolve disputes, avoid fraud and abuse and apply its own terms and conditions.

Optional provision of data

The provision of data processed due to legal obligations and contractual performance is essential and any opposition to the treatment in whole or in part will result in the impossibility for Lubrimetal to enter into contractual relationships.

For all other purposes, apart from that already specified for navigation data, visitors are free to choose whether to provide their personal data. Failure to provide such data may result in the impossibility of obtaining what is requested or remaining informed in the best possible way.

Communication and Transfer of Personal Data

Lubrimetal will be able to communicate data to:

• Third parties in charge of carrying out activities connected and instrumental to the supply of products and/or the provision of services with which the owner has entered into specific agreements;
• Third parties for the performance of the obligations established by law or by the contract (e.g. public authorities, supervisory authorities, police forces, banking institutions, etc.);
• Subsidiaries, investee companies, associates, as well as partners and / or affiliated companies.

For technical-or practical needs related to the processing of the information itself, some personal data may be located on the suppliers ‘and subcontractors’ servers or only processed by third parties, who in any case have fully adhered to the Lubrimetal standards for the protection of the processing of personal data.

The data will not be disclosed. They may be transferred abroad to other companies of the business group, in accordance with articles 44-47 of the European Regulation.

Rights of the interested parties

European Regulations recognize numerous individual rights which we ask you to consider carefully. We stress in particular the rights of

• access by the interested party:
• confirms that the processing of personal data concerning him is underway;
• communication of the transfer of data to a third country or to an international organization;
• obtain a copy of the personal data processed (if and only if no rights and freedom of others are infringed);
• Rectification;
• Total cancellation (right to be forgotten);
• Treatment limitation;
• Obligation to notify in case of rectification or cancellation of personal data or limitation of processing;
• Data portability;

The data subject also has the right to receive prompt communication in the event of a personal data breach that could damage his or her dignity and freedom.