Lubrimetal has always paid the utmost attention to the issue of privacy and, for many years, has integrated the security of personal data into its certified Management Systems.

To improve the protection of personal data and guarantee maximum transparency in their processing, we have made some updates to the Privacy Policy, to make them compliant with the new European Data Protection Regulation (GDPR), in force from 25 May 2018.

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


Ownership  and contacts

The Data Controller and Data Processor is Lubrimetal Spa with registered and operational headquarters in via Lido Moggio 19 – 23808 Vercurago (Lecco), Italy.

Lubrimetal is the owner of the website and is responsible for its contents, with the exception of other websites that can be consulted by the user through links that may be present in the pages of the aforementioned website.

It is possible to contact Lubrimetal and send questions or requests relating to personal data and respect for privacy by writing to:


Type of data processed

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

1) Data acquired in normal business management

Data designated as “personal” according to the provisions of Article 4 of the GDPR including that acquired verbally, directly or through third parties, to achieve effective management of commercial relationships.

2) Browsing data and cookies

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

The computer systems responsible for operating the site acquire, during normal operation, some data which is then transmitted implicitly in the use of internet communication protocols. This may include information on the geographical area from which you are browsing, on the device used, on the type of browser, on the user’s behaviour during the session.

The decision was made to not memorize the user’s IP address thus effectively preventing subsequent identification of the same.

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

For further details relating to cookies, please refer to the appropriate section.

3) Data provided voluntarily by visitors by completing the contact form

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


Purposes of processing and their legal bases

Lubrimetal may process personal 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 commercial relationships, the characteristics of its products and services (legal basis: legitimate interest).
  3. To manage accounting, administrative, fiscal, etc. obligations required by Italian, European or international law (legal basis: legal obligation).
  4. To manage credit protection, manage any disputes and enforce the Owner’s rights (legal basis: legal obligations, contract execution, legitimate interest).
  5. To send adequate communications about its products and services, initiatives or to measure customer satisfaction (legal basis: legitimate interest or consent when required).
  6. To respond to requests received, also to investigate any complaints (legal basis: legitimate interest).

Consent is required to process some types of data and for some purposes (e.g. profiling, large-scale processing, etc.). If Lubrimetal finds itself in one of these conditions, it will adequately inform users and ask for consent to processing in the most appropriate manner.

The user will always have the possibility to revoke consent and unsubscribe from any direct marketing activity.


Method and duration of treatment

The data is recorded on electronic or paper media and kept for the time strictly necessary to achieve the purposes for which the data was collected and, in any case, in compliance with the relevant regulatory provisions in force.

The data is stored in company infrastructures that guarantee all the security measures required by European Regulations and subsequent provisions.

Furthermore, the company is required to retain certain information based on legal requirements and for a time reasonably necessary to satisfy those requirements, resolve disputes, prevent fraud and abuse and enforce its terms and conditions.

In relation to all processing, the Data Controller and any external managers appointed pursuant to art. 28 undertake to adopt adequate physical, logical and organizational security measures in order to guarantee the integrity, confidentiality and availability of the data.


Nature of optional provision of data

The provision of the data processed for legal obligations and contractual execution is necessary and any opposition to the processing, in whole or in part, may render it impossible for Lubrimetal to proceed with a contractual relationship.

For all other purposes, excluding that already specified for navigation data, visitors are free to choose whether to provide their personal data. Failure to provide such data may only make it impossible to obtain what is requested or to remain informed in the most efficient way.


Communication and Transfer of Personal Data

Personal data may be brought to the attention of employees or collaborators of the Data Controller who are formally appointed and authorized to process it and receive adequate operational instructions in this regard.

Lubrimetal may communicate the data to:

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

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

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


Rights of interested parties

The relevant European Regulations recognize numerous rights of interested parties which we request you to consider carefully (art. 15-22 of the GDPR). In particular, please note the rights of:

  • Access of the interested party:
    • confirms whether or not personal data concerning him or her is being processed;
    • communication of the transfer of data to a third country or to an international organisation;
    • obtain a copy of the personal data being processed (if and only if the rights and freedoms of others are not infringed);
  • Rectification;
  • Total deletion (right to be forgotten);
  • Limitation of treatment;
  • Obligation to notify in case of rectification or deletion of personal data or limitation of processing;
  • Data portability
  • Opposition.

The interested party also has the right to receive timely communications in the event of a personal data breach that may damage his or her dignity and freedom.

Finally, the interested party has the right to lodge a complaint with the Italian Supervisory Authority – Guarantor for the protection of personal data – Piazza Venezia 11 – 00187 Rome –


Date of update: 27 November 2023


This Cookie Policy is drawn up in accordance with current legislation relating to the protection of personal data (European Regulation 679/2016 and related guidelines) and integrates the information provided through the Privacy Policy. It aims to describe the types of cookies and any other similar technologies used on the site.



The data controller is Lubrimetal Spa with its registered office and operational headquarters in Lido Moggio 19 – 23808 Vercurago (Lecco). For further information, you can also contact the Data Controller using the email address



Cookies are short text files, made up of letters and/or numbers, which allow the web server to store on the the user’s Internet browser information necessary for browsing the site or to be reused later, on subsequent visits. . Cookies are stored by the browser on the specific device used (computer, tablet, smartphone), based on the preferences expressed by the user.


Types of cookies

It is possible to classify cookies based on their duration:

  • session cookies – expire at the end of a browser session, usually when it is closed, and are used to keep the browsing session on the site and the use of its features active
  • persistent cookies – are stored for a longer period of time (therefore they persist even if the session is closed) and are useful, for example, for remembering browsing preferences (language, device, browser, etc.) or for offering content personalized

Another feature concerns the origin of the cookies, which can be:

  • first party – are installed by the site itself
  • third parties – are installed from a different domain (e.g. if the site includes other services, such as advertising providers or suppliers of analytical tools)

Finally, cookies can be distinguished based on their purpose:

  • technical or necessary cookies
  • functionality or preference cookies
  • analytical, statistical and performance cookies
  • marketing or profiling cookies

Technical cookies can be used without the user’s consent, as they are necessary to carry out certain operations otherwise they would be more complex and/or less secure. First and third party analytical cookies also fall into this category but only under the following  conditions: they are used for aggregate statistics (without identifying the user) and refer to a single site or app; in the case of third-party cookies, at least the fourth component of the IP address must be masked; the third party cannot combine the minimized analytical cookies with other processing (e.g. customer files or statistics of visits to other sites) nor will it be able to transmit them to further third parties.

Functionality or preference cookies allow the user to navigate according to a series of selected criteria (for example: the language, the geographical area, the device used, the type of browser, the products selected for purchase) to in order to improve the service provided. These cookies are not necessary for the functioning of the site, therefore appropriate and prior consent must be requested for their installation.

Analytical or statistical cookies are used to improve navigation on the site through the analysis of user activities in anonymous form (e.g. number of users on a page, number of times the page has been visited by the user, how long you stay on the page, etc.). They are also defined as performance cookies, and as previously mentioned they can be assimilated to technical cookies if configured with reduced identification power (in this case they do not require prior consent and it is possible to keep them always active).

Marketing or profiling cookies allow us to track navigation on the site by identified or identifiable subjects to analyze the way they navigate, their behaviour, the purchases made and thus create a profile of the user or insert them into a homogeneous cluster. In this way, the Data Controller will be able to optimize its site and modulate the service in a more personalized way, as well as send targeted advertising messages, in line with the preferences expressed by the user while browsing. Naturally these cookies are not necessary for the functioning of the site and specific consent is required for their installation.

Finally, there are specific cookies for Social Networks, which allow the user to share the contents of the site on their social profile. When a page contains this command, a direct connection is established with the selected Social Network (e.g. Facebook, Instagram, Twitter, LinkedIn, etc.).


Cookie consent rules

If the site uses cookies other than technical ones, a banner of adequate size and immediate pop-up must be implemented which contains:

  • summary information on the use of cookies on the site
  • link to the complete privacy policy
  • command to close the banner without giving consent
  • command to accept all cookies
  • link to another section to analytically choose which cookies to accept

Cookies could also be completely deactivated at browser level by using the appropriate function provided in most navigation programs. It is good to know, however, that by deactivating cookies some of the features of a site may not be usable, in particular the services provided by third parties such as: YouTube videos (or other video sharing services), social buttons Network, Google maps.

Below are the links to the information of the main browsers for further information on the total deactivation of cookies. (Google Chrome) (Microsoft Edge) (Mozilla Firefox) (Apple Safari)

For settings for any other web browsers not listed above, please refer to the relevant browser’s documentation or online help for further information. We specify that the Owner acts as a technical intermediary for the links reported in this document and cannot assume any responsibility in the event of any modification.



This Site uses technical and functional cookies, both linked to the single session and persistent. These are cookies used to manage the user interface (e.g. to record preferences expressed by the user such as language, page display format, connection area), for better usability of the site and its contents audio-visual, for the correct functioning of the connection. The data managed by these cookies is completely anonymous.

The site does not currently use third-party analytical cookies or marketing and profiling cookies, therefore no consent is required from the user when first accessing the site or at subsequent times.

Should the Owner make changes to the Site that involve the installation of other types of cookies, the Owner will be responsible for adapting this information and activating an appropriate tool for managing consent.


Provision of data

The Site only provides anonymous cookies, therefore the user is not asked to provide any personal data.


Communication and Transfer of Personal Data

In general, personal data may be brought to the attention of employees or collaborators of the Data Controller who are formally appointed and authorized to process it and receive adequate operational instructions in this regard.

Furthermore, the data may be processed by external legal or natural persons who may need to be involved for organizational needs (e.g. IT service providers, consultancy companies). These subjects are appointed, where appropriate, as external data processors.

The Data Controller may also communicate the data to other subjects who will act as independent data controllers, for the execution of obligations established by law or investigation activities (e.g. public bodies, judicial authorities, law enforcement agencies, etc.).


Rights of interested parties

Interested parties can contact the Data Controller by sending an email to  to exercise the rights recognized to interested parties based on the articles. 15-22 of the GDPR. We would like to remind you in particular of the right to access your data, to have it completely erased, to limit processing, to obtain a copy of the data and to withdraw the consent provided. Finally, interested parties have the right to lodge a complaint with the Italian Supervisory Authority – Guarantor for the protection of personal data – Piazza Venezia 11 – 00187 Rome –


Changes to this Policy

This policy may undergo changes over time following the possible entry into force of new regulations, the updating or provision of new services. For this reason the user/visitor is invited to periodically consult this page.


Date of update: 27 November 2023