Configurator Privacy Policy

LAGO S.p.A. Via Artigianato II 21 35010 Villa del Conte (PD) Tax code and VAT no. 01508340286 (“Lago”) sole shareholder company subject to the management and coordination of Giuseppe Lago S.p.A. is fully committed to protecting the on-line privacy of users of the website www.configurator.lago.it (hereinafter the “Website”). This privacy policy refers to the processing carried out once after browsing the website www.lago.it you land on this Website which will enable you to configure your Lago products.

This document (the “Privacy Policy”) has been drawn up to help you understand how your Personal Data as defined below shall be processed as regards use of the Website.

In general any information or personal data you provide to Lago through the Website or that is collected in any other way through the Website in the context of use of the services offered (the “Services”) as defined in detail in the Paragraph 3 below will be processed in accordance with the internationally recognised principles of lawfulness fairness transparency purpose limitation and retention data minimisation accuracy integrity and confidentiality.

CONTENTS

1. Data Controller

2. Personal data subject to processing

a. Personal Data that you provide

b. Navigation data

c. Third-party data

d. Cookies

3. Purpose of the data processing

4. Optional/compulsory data processing and legal basis

5. Recipients of the personal data

6. Transferring personal data

7. Storing Personal Data

8. Rights of the Data Subject

9. Amendments

1. Data Controller

Lago as identified at the start of this Policy is the Data Controller for all the personal data processed via the Website and can be contacted via the following email address: privacy@lago.it.

2. Personal data subject to processing

After browsing the Website Lago will process your Personal Data which may comprise – in accordance with how you decide to use the Services – an identifier such as a name, surname, address, telephone number, e-mail address, an online identifier or one or more characteristic elements of your identity (hereinafter only “Personal Data”).

Your Personal Data may be collected either because you voluntarily provide it (e.g. when you fill out an online form in order to receive the Services offered) or simply by analysing your behaviour on the Website.

The Personal Data subject to processing via the Website are as follows:

a. Personal Data that you provide

In some sections of the Website such as “How much does it cost” and “Buy your product” you will be asked to fill out a form with information such as your name, surname, telephone number, e-mail address and residence address in order to report your Personal Data to the Lago retailers in your area so they can provide you with further commercial information about the configured product you would like to purchase.

When you send your request Lago will also store the technical information relating to your configured product and for which you asked for further information on its systems.

b. Navigation data

The IT systems and software used by this Website acquire as part of their normal operation some Personal Data the transmission of which is implicit in the use of Internet communication protocols. This information is not collected in order to be associated with identified users but which could by its very nature make it possible to identify the Website users if processed and associated with data held by third parties. This category of data includes IP addresses or the domain names of computers used by users who connect to the Website, addresses in URI (Uniform Resource Identifier) notation of requested resources, the time the request is made, the method used to submit the request to the server, the file size obtained in response, the numerical code indicating the response status from the server (successful, error, etc.) and other parameters related to the user’s operating system and computer environment. These data are only used in order to obtain anonymous statistical information concerning the use of the Website and to check its correct operation as well as to identify any anomalies and/or abuse and are deleted immediately after processing. The data may be used to ascertain liability in the event of hypothetical computer crimes against the Website or third parties unless web contact data is currently stored for no more than seven days.

c. Third-party data

When using some of the Website services the Personal Data of third parties that you sent to Lago may be processed. For example this could occur when you provide the e-mail address of a friend/relative/acquaintance/colleague to recommend one or more Lago products or to be contacted again. In such situations you act as an independent data controller assuming all legal obligations and responsibilities. In this sense you provide us with the broadest possible indemnity in respect of any dispute, claim, request for compensation for damage caused by processing, etc. of Personal Data received by Lago from third parties that has been processed through use of the Website in breach of applicable legislation on the protection of personal data. Therefore please provide correct and true Personal Data (whether yours or those of third parties) and do not make any illegal use of the Website or the services offered. In any case if you provide or otherwise process Personal Data relating to third parties when using the Website you hereby guarantee – taking on all associated responsibility – that any such potential processing is based on an appropriate legal basis pursuant to article 6 of the Regulation that legitimises processing of the data in question.

Any third party data subject may ask at any time for information on the origin of the Personal Data or ask for it to be erased by writing to the contact parties indicated in section 8. Rights of the Data Subjects as set out below.

d. Cookies

Information on the use of cookies is available in the Website’s Cookie Policy.

3. Purpose of the data processing

Lago will use your Personal Data collected through the Website for the following purposes:

- to enable provision of the services requested (such as configuring your product, obtaining a PDF that you may use to purchase your Lago product and enabling you to recommend our products with your contacts) and enable you to browse the Website (“Provision of services”);

- to send you marketing messages, promotional and advertising content and market research and surveys via email, SMS, MMS, apps, post, telephone and/or the official Lago social media accounts; as well as to send you Lago’s newsletter and more broadly for other forms of marketing – including games, contests and competitions with prizes – of products and/or services associated with Lago and/or products and/or services associated with third parties (“Marketing”);

- to send you marketing communications via e-mail regarding products and services similar to those you purchased (“Soft Marketing”);

- to create your profile including through the use of profile cookies where accepted therefore collecting and analysing information on the selections and choices that you make through the use of this Website and the website www.lago.it. This profile will be used to provide you with information about other products and/or services that Lago believes may be of interest to you and to display ads that may match your tastes (“Profiling”);

- to satisfy Lago’s legal obligations imposing the gathering and/or further processing of specific types of personal data (“Compliance”);

- to prevent or identify any abuse in using the Website or any fraudulent activity and therefore allow Lago to protect itself legally (“Abuse/Fraud”);

- communicate your Personal Data to the Lago retailers filling out the forms on the website in the section “Do you wish to purchase” in order to receive the PDF of the product that you configured and to contact you to make an appointment (“Communication”).

4. Optional/compulsory data processing and legal basis

The legal basis for processing your Data in accordance with the purposes laid out in section 3 above is as follows:

- Provision of services and Communication: the processing for this purpose is necessary to provide you with the Services and therefore to respond to your request. You do not have to provide your Personal Data to Lago for this purpose. However if you choose not to we will be unable to provide you with the Service.

- Marketing: processing for this purpose is based on your consent. You do not have to provide your consent for this purpose and you are free to withdraw your consent at any time without any consequences (other than that you will no longer receive marketing messages from Lago). You may also revoke your consent by following the indications in section 8 of this Policy.

- Soft Marketing: processing for this purpose is based on Lago’s interest in sending you marketing communications via e-mail regarding products and services similar to those you have already purchased. You can discontinue your receipt these communications without any consequences for you (other than the fact that you will no longer receive further communications of this kind from Lago) by using the link at the bottom of each of these e-mails.

- Profiling: processing for this purpose is based on your consent including where given via the cookies used on the Website. Provision of your consent for this purpose is not mandatory and you are free to revoke it at any time without any consequences (except being unable to benefit from personalisation of the commercial offers you receive). You may also revoke your consent by following the indications in section 8 of this Policy.

- Compliance: processing personal data for this purpose is required in order to meet any legal obligations. When you provide your Personal Data to Lago they shall be processed according to the applicable legislation which may require their storage and communication to the authorities for accounting, tax or other obligations.

- Abuse/Fraud: the information gathered for this purpose shall be used exclusively to prevent and/or identify any fraudulent activity or abuse in using the Website and shall therefore allow Lago to protect itself legally.

5. Recipients of the personal data

Your Personal Data may be shared with the parties listed below (“Recipients”):

- parties with whom it is necessary to interact to provide the Services for example retailers or platform suppliers;

- subjects assigned to technical maintenance (including servicing network equipment and electronic communications networks);

- persons authorised by Lago to process Personal Data required to perform the activities strictly related to Service provision who have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality (e.g. employees);

- persons, bodies or authorities to whom your Personal Data must be disclosed for Compliance, Abuse or Fraud purposes or by order of the authorities;

- Lago distributors for the Communication purpose described above.

6. Transferring personal data

Some Personal Data may be shared with recipients which may be located outside the European Economic Area. Lago guarantees that processing of Personal Data by these recipients shall be carried out in compliance with the applicable legislation. The transfers may be based on adequacy decisions or Standard Contractual Clauses approved by the European Commission. More information can be obtained by writing to privacy@lago.it.

7. Storing Personal Data

The Personal Data processed in order to Provide the services and for Communication will be retained for the time strictly necessary to fulfil said purpose and in any case no more than 4 years from sending the request. However as these Personal Data are processed to provide you with Services Lago may store them for longer specifically insofar as may be necessary to protect its own interests against any claims made in relation to the Services.

Personal Data processed for the purposes of Marketing and Profiling will be kept until you revoke the consent(s) provided for these purposes. Once you have revoked your consent Lago shall no longer use your Personal Data for these purposes but may nonetheless store them specifically insofar as may be necessary to protect its own interests against any claims made based on this processing.

Personal Data processed for the purpose of Soft Marketing will be kept until you object to any such processing through the link at the bottom of each of the Soft Marketing e-mails.

The Personal Data processed for the purpose of Compliance shall be stored for the time provided for by specific legal obligations or by the applicable legislation.

The Personal Data processed for the purposes of preventing Abuse/Fraud shall be stored for the time strictly needed for the above purpose and therefore until such a time as Lago shall be held to store them to protect itself legally and communicate said data to the relevant authorities.

For information on the retention period of personal data gathered via cookies please see our Cookie Policy.

8. Rights of the Data Subject

You have the right to ask Lago at any time for:

- access to your Personal Data (or a copy of said Personal Data) as well as to further information regarding the processing being carried out on the same;

- your processed Personal Data to be amended or updated where the data are incomplete or not up to date;

- your Personal Data to be deleted from Lago’s databases;

- the processing of your Personal Data by Lago to be limited;

- the Personal Data relating to you in a structured commonly used format readable from an automatic device;

and you may also:

- oppose the processing of your Personal Data (e.g. Profiling);

- revoke your consent for the purposes of Marketing and Profiling.

When requesting the Services you may have selected the communication channels you wish to be contacted through for Marketing purposes (i.e. e-mail, SMS, MMS, app, post, telephone and/or through Lago’s official social media pages).

You can withdraw your consent to being contacted for Marketing purposes in relation to each of these communication channels by means of the methods indicated below.

You can also withdraw your consent to being contacted for Marketing purposes by e-mail, including the newsletter, and stop receiving Soft Marketing using the specific link at the bottom of each e-mail received.

Consent to Profiling through cookies can be revoked via the methods indicated in the Cookie Policy set out in paragraph 2.d. above.

In addition to the above you can also exercise your rights by writing to Lago at the following e-mail address: privacy@lago.it.

You are further entitled to lodge a complaint with the competent supervisory authority (the Italian Personal Data Protection Supervisory Authority) should you believe that your Personal Data has been processed in breach of the legislation in force.

9. Amendments

This Privacy Policy is effective from 01/11/2022. Lago reserves the right to modify or simply update the content of this privacy policy in full or in part including in the event of amendments to applicable legislation. Lago will inform you of such changes as soon as they are introduced and they will be binding as soon as they are published on the Website. We invite you to regularly visit this section so that you are aware of the most recent and updated version of the Privacy Policy in order to remain up to date on the data collected and the use of the data.