WHY THIS NOTICE
This information is provided pursuant to Art. 13 of EU Regulation 2016/679 on the protection and circulation of personal data (so-called “GDPR”) only for the site www.lef-digital.com (hereinafter also simply “site”) and not also for other websites that may be consulted via links on the site. The purpose of this document is to inform its customers, partners, suppliers and in general the users of its services/web sites and/or social network channels on the processing of their personal data both through the use of the site and in the context of contractual relations with LEF, and in the context of events, courses, exhibitions organised or sponsored by LEF.
THE DATA CONTROLLER
The Data Controller is LEAN EXPERIENCE FACTORY SCARL (hereinafter referred to as “LEF” or “Data Controller”), VAT no. 0169652093, in the person of its legal representative pro tempore, with registered office in Pordenone, Piazzetta del Portello no. 2 and operating office in San Vito Al Tagliamento (Pn), Viale dei Comunali no. 22, Email [email protected].
PURPOSE OF PROCESSING AND LEGAL BASIS
The processing of the data collected by the Controller is carried out in compliance with the rules on confidentiality and protection of personal data in force and with the principles of correctness, lawfulness, transparency, relevance, completeness and non-excessiveness of the information; moreover, the personal data collected, either automatically or by voluntary submission by the user, will be processed only for the purposes indicated below and stored for the period strictly necessary for those purposes. Furthermore, the processing concerns data relating to the conduct of economic activities, which are processed in compliance with current legislation on business and industrial secrecy.
Managing access to the site and preserving its security
Perform obligations arising from a contract to which the data subject is party or to fulfil, prior to the conclusion of the contract, specific requests of the data subject.
Contractual or pre-contractual fulfilment.
Providing customer service and related activities.
Contractual and legal compliance.
Fulfilling tax and accounting obligations required by law.
Legal obligation; Legitimate interest (communication of data to external professional advisers).
Fulfil in general the obligations of law, regulation or EU legislation consequent to and related to the aforementioned contractual relationship.
Consent of the person concerned.
In order to satisfy the legitimate interest of the Controller to maintain a communication channel with the Customer, LEF will use the Customer’s contact data to occasionally carry out communications about its products and business. At any time the Customer may tell the Controller if he no longer wishes to receive such communications.
Legitimate interest of the Holder. Art. 130(4), Legislative Decree 196/2003
AUDIO/VIDEO RECORDINGS.In the course of events, courses, conferences, LEF may take photographs or video recordings of the events, also in the form of video interviews, which will then be published on the LEF website or LEF’s social platforms.
See paragraph “INFORMATION REGARDING IMAGES AND VIDEO SHOTS TAKEN DURING EVENTS ORGANISED BY AND/OR HELD ON LEF premises”.
PROVISION OF DATA
All the personal data collected are essential and necessary for the pursuit of the stated purposes and for the achievement of LEF’s institutional aims, so that failure to provide or incorrect provision of such data may have the consequence of making it impossible to establish or continue the contractual relationship correctly or to process requests received. Data whose provision is mandatory are marked with an asterisk.
PROCESSING METHODS, CATEGORIES OF RECIPIENTS, TRANSFERS TO THIRD COUNTRIES OR INTERNATIONAL ORGANISATIONS.
The computer systems and software procedures used to operate this website acquire, in the course of their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected in order to be associated with identified interested parties, but which by its very nature could, through processing and association with data held by third parties, make it possible to identify users, the computers used by users who connect to the site, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and computer environment.) and other parameters relating to the user’s operating system and computer environment. By visiting the site, the following information is automatically collected:
- HTTPS header, and the ‘user agent’ string including: the type and version of browser used and the operating system under which the browser itself works.
- System date. The date and time of the user’s visit.
The information collected by the Controller, through access to the website, is used in order to improve the quality of the service offered to users of the site. Users are urged to avoid entering sensitive and judicial data on the site, which are considered superfluous with respect to the services and activities of the Controller, as this could lead to the destruction of the message. Apart from what has been specified for navigation data, the user is free to provide personal data in any information request forms. Failure to provide them may make it impossible to obtain what has been requested. Personal data are processed for the time strictly necessary to achieve the purposes for which they were collected. Specific security measures are observed to prevent loss of data, unlawful or incorrect use and unauthorised access. Data processing will be carried out using a combination of manual, computerised and telematic tools, with an organisation and processing logic in line with the purposes, also by entrusting (partial or total) processing to third parties specifically appointed as data processors. Automated decision-making is excluded, as is the dissemination of data, unless, in the latter case, this is required by law. The security, integrity and confidentiality of the data is guaranteed in accordance with appropriate organisational, physical and logical measures; these are periodically reviewed. The data collected and processed will also be communicated, within the limits of the purposes to be pursued, to the Controller’s business partners and consultants in relation to contractual activities, as well as to banking and insurance institutions for the management of payments and to Public Administration bodies for the fulfilment of legal obligations. The transfer of data to countries outside the European Union or to International Organisations for which there is no declaration of adequacy or adequate guarantees for the protection of personal data will not take place without the express and specific consent of the data subject in this regard.
Data are processed and stored for the time required by the purposes for which they were collected. Therefore:
- Personal data collected for purposes related to the performance of a contract or a pre-contractual request between the Controller and the User/Customer will be retained until the full performance of that contract and also thereafter for legal obligations (e.g. 10 years for invoices) or to protect or assert or defend a right of the Controller.
- When the processing is based on the User’s consent, the Controller may keep the Personal Data for a longer period, until such consent is revoked or the service is discontinued by the Controller. In addition, the Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an Authority.
- Data processed in accordance with legal requirements are processed for as long as required by the legal regulations applicable to each individual processing operation.
- Data processed on the basis of a legitimate interest are processed until the data subject objects (e.g. sending commercial communications to its customers – Art. 130 paragraph 4 Legislative Decree 196/2003) or until the data controller ceases to provide the service.
- At the end of the retention period, the personal data will be deleted. Therefore, at the expiry of this period, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.
The Data Controller is at the disposal of the data subject to provide any further information on the storage period.
RIGHTS OF THE DATA SUBJECT
At any time, the data subject (the natural person to whom the personal data refer) may exercise his/her rights vis-à-vis the Data Controller, pursuant to Articles 15 et seq. of the GDPR, in particular to obtain confirmation from the Data Controller as to whether or not personal data relating to him/her are being processed, to know the source of the data, to request access to the personal data, to update, rectify, erase or request the restriction of the processing of the personal data or to object to their processing, to request their portability. These articles also provide for the data subject’s right to lodge a complaint with a European supervisory authority (in Italy this is the Garante per la protezione dei dati personali). Requests should be addressed to [email protected] or to the address of the Controller’s head office, also using the following MODEL prepared by the Controller.
Information relating to the processing of personal data carried out by social networks, such as Twitter, Instagram and Facebook, to whose privacy policies LEF complies, is outside the scope of this statement. In the activity of managing the page or profile, LEF acts as co-processor for the part in which it collects cookies and accesses statistics that can be extracted from each of the social networks through the use of tools provided by the operator (e.g. APIs for viewing and analysing insights).
INFORMATION CONCERNING IMAGES AND VIDEO FOOTAGE TAKEN DURING EVENTS ORGANISED BY AND/OR TAKING PLACE ON THE PREMISES OF LEAN EXPERIENCE FACTORY
Photographs and/or video recordings are taken during events organised by LEF and/or held on its premises. These are published on the LEF website and/or on its so-called “social profiles” (Facebook, Twitter, Instagram, etc.) for the purpose of disseminating and informing about its institutional activities.
TRANSFER OF IMAGE RIGHTS
The events organised by LEF are all public, as they are accessible to anyone, subject to registration and/or payment of any fees.
For this reason, pursuant to Article 97 of Law 633/1941, the consent of the persons portrayed in any images is not required, since it is an event that takes place in public. The rights of exploitation of one’s own image and/or voice portrayed/recorded in these events are assigned free of charge to LEF for an unlimited time and without territorial limitations. LEF will not use the image except for purposes of disseminating its institutional activity.
PROCESSING OF PERSONAL DATA (IMAGES AND VOICE)
In addition to the purpose of dissemination and information on LEF’s institutional activities, images and videos taken during events may also be used for streaming of the event. The processing of data is done for the legitimate interest of LEF in the dissemination of its institutional activities and the storage is for an indefinite period of time unless the data subject requests deletion. It is not possible to refuse the provision of data, as it cannot be guaranteed that one or more persons will not be filmed as part of an LEF event; the provision of personal data is therefore, in this context, obligatory and a condition for participation in the event. This information supplements the general information on the processing of personal data published on this page, which you are invited to read and which also contains the contact details of the data controller.
REQUEST NOT TO BE PHOTOGRAPHED AND/OR FILMED
LEF cannot guarantee that it will not portray the image of a participant, so that such provision of data is compulsory in order to take part in events; nevertheless, LEF undertakes to preserve the confidentiality requirements of its participants as far as possible. In any case, notices are displayed on LEF’s premises indicating that you are accessing an area where video filming is taking place. Those who do not wish to be portrayed are requested to make this known before the start of each event to the event speaker and/or the LEF staff present in the room or at the reception desk at the entrance. While LEF does not guarantee that your image and/or voice will not be used in the filming or photographing of the event, LEF will make every effort to ensure that this is the case. In any event, the right to terminate the processing by simple written request of the data subject to the Data Controller shall remain unaffected.