WHAT IS THE PRIVACY POLICY

This information is provided pursuant to EU Regulation 679/2016 and the subsequent national adaptation legislation (hereinafter, overall (GDPR) and describes how Lemuria S.r.l. owner of the site www.spiritodelgarda.it (indicated in the “Data Controllers” section below, jointly in this information “Lemuria”) collect and process the personal data of users or customers through their website, in particular www.spiritodelgarda.it, or more generally whenever express reference is made to this Privacy Policy.
The expression “personal data” means any information relating to an identified or identifiable natural person. For example, personal data are the name, an identification number, location data, an online identifier.
Lemuria s.r.l. may modify, supplement or periodically update this Information, also in consideration of any changes to the applicable legislation or provisions of the Guarantor for the Protection of Personal Data. Substantial changes and updates to the Privacy Policy will be applied and brought to the attention of interested parties as soon as they are adopted by updating the link to the Privacy Policy in the footer of the Site or by emailing registered users. In case of changes that significantly affect the rights of the registered user, the communication will be made with reasonable notice.

PURPOSE OF THE TREATMENT AND LEGAL BASIS

The data are processed for the following purposes.
a) On the basis of the contractual need in order to:
– manage orders and carry out related activities (eg: sales and after-sales customer assistance, communications with the customer on the status of the order, responses to their requests for information, payment management, etc.);
– manage user accounts in case of registration on the Sites to use the related services;
– allow adherence to specific and additional services requested by the user from time to time (eg enrollment in courses held at the Spirito del Garda shop);
– manage product shipments and create waybills;
– follow up on specific requests

b) Based on the consent expressed by the user, collected from time to time specifically, in order to carry out market research, as well as contact the user and send commercial communications and promotional offers, in addition to the sending of the Newsletter described below, with regard to the products, services and / or events of Spirito del Garda, by SMS, telephone, paper mail or other means, including through a preventive analysis of consumer behavior aimed at personalizing commercial messages.
The user can also modify or enrich his preferences at any time through the appropriate “Newsletter” menu on www.spiritodelgarda.it or in the “My account” section onwww.spiritodelgarda.itexpressing his consent to be contacted in about specific offers, or products of interest The data controller for sending related newsletters is from time to time the company Lemuria s.r.l. to which the website www.spiritodelgarda.it and the Spirito del Garda shop refers. The user may in any case exercise his right to object to the same in the manner indicated above.

c) Based on the legitimate interest of Lemuria S.r.l. , in particular:
– for the analysis and improvement of its services;
– for carrying out statistical and / or research and development activities, including by analyzing data from the use of services and products or consumer behavior;
– in order to defend their rights during the course of judicial, administrative or extrajudicial proceedings, and in the context of disputes arising in relation to the services offered;
– in the case of extraordinary transactions, mergers, sale of a business unit, acquisitions, etc.

d) Based on the need to fulfill the legal obligations to which Lemuria S.r.l. is subject.
The provision of data for the purposes referred to in point (a) above, as necessary to initiate the sale and delivery of the products and services purchased or for registration on the Site is mandatory and the refusal to provide the personal data being processed makes it impossible to perform the services requested in relation to the purchase of goods and services on the Site.

CATEGORIES OF DATA PROCESSED BY LEMURIA

Below is a description of the categories of data we process:
– Data provided directly by the interested party: all personal data entered on the Site (to proceed with online purchases or to register), or which in any case are provided to Lemuria in any way (e.g. in the context of promotional activities in the Spirito del Garda, or on the occasion of participation in courses, etc.). Examples of data provided directly by the interested parties are: the name; the address and telephone number; credit card data (processed only for the time necessary for the purchase, or as necessary in the case of periodic payments and, if the interested party has not opposed the processing by changing their settings from “My account” from the ” Payment Methods “, saved for subsequent purchases). More generally, all the data provided to allow the execution of a purchase order, the carrying out of product searches on the Site, the compilation and use of the profile on the Site, the facilitation of the delivery of products with communication data relating to contact numbers or addresses (eg telephone, email, addresses), participation in courses, etc.

– Data provided by third parties: these are all personal data that Lemuria s.r.l. collects from other sources (e.g. postal service companies, couriers, data entry companies), to perform its services. Examples of data provided by third parties are data relating to updates or corrections received on the occasion of deliveries by couriers or transport partners or third parties, data on the web pages visited that we may receive from other commercial operators with whom Lemuria s.r.l. the names of the recipients of the orders may collaborate in some initiatives, if different from the buyer.
– Data collected automatically: these are navigation data and / or collected through the so-called “Cookies”. The computer systems and software procedures used to operate the Site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is generally not collected to be associated with identified interested parties, but which by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the site, the addresses in the Uniform Resource Identifier (URI) notation of the requested resources, 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 operating system and the user’s computer environment.

COOKIE

A cookie is a small file sent by a website and stored in the user’s browser while using an Internet site. Cookies can be stored only for the time of use of a particular site or for a longer period of time and independent of the session. Cookies work in conjunction with the content of the website and normally have the function of improving the usability and browsing experience on the web. Some types of cookies also make it possible to know the contents displayed, the choices selected and each use of the Site by the user. This feature also makes it possible to offer the most useful and relevant advertising to each individual user. A website can use self-developed cookies or use cookies developed by third-party companies.

In addition to allowing easy use of the Site, Lemuria s.r.l. uses cookies for various purposes, including: (i) identify the user when logging in; (ii) store the products saved in the shopping cart for their purchase; (iii) avoid fraudulent use of accounts or in relation to payments; (iv) profiling the user and then providing him with information on the products of his interest, or other content or personalized offers; (v) provide promotions, content, advertising, related to the user and his preferences and to remember these preferences; (vi) carry out market research; (vii) improve the Site, the product offer of Lemuria s.r.l. and their marketing, etc.


In particular, Lemuria uses:
a) TECHNICAL COOKIES: These are cookies necessary for navigation as they allow correct use of the Site and its full functionality. They include cookies that allow the creation of a personalized account, access, content display in the chosen language at each access, recognizing which country the user is connecting from (and remembering this setting in future accesses), and order management. These cookies are strictly necessary for the operation of the Site and their deactivation could affect the experience and the success of navigation. In particular, we use technical cookies for the following purposes:
– for the management of dynamic web pages, for the geographical identification of users and for the management of last-accessed data;
– to ensure the proper functioning of the web pages;
– for the functioning of the forms (e.g. registration form for courses);
– for the management of data relating to order amounts and products

b) ANALYTICAL COOKIES: used to collect information on the number of users and how they visit the site. For example:
– GOOGLE ANALYTICS: the site uses the Google Analytics tool to collect information, in aggregate form, on the number of users and how they visit the site. This tool uses third-party technical cookies for its operation. Information on the treatment of privacy by Google is available at the following link: http://www.google.com/analytics/learn/privacy.html Information on the cookies used by Google Analytics, collection and use of this data are available at the following link: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage#gajs. Information is also available at the following link to refuse consent to the use of third-party cookies from Google Analytics: http://tools.google.com/dlpage/gaoptout

c) THIRD-PARTY PROFILING COOKIES FOR MARKETING / RETARGETING: these are third-party cookies that allow the collection of user information to allow a more specific and / or personalized promotional communication to the user. They include cookies relating to the insertion on the Sites of advertising banners relating to third-party companies or products chosen or viewed by the user, or similar or similar products. These cookies can be disabled without preventing correct navigation on the Sites, however their deactivation involves the receipt of promotional messages that may not be of interest to the user. For more information on the profiling cookies currently installed in the user’s terminal, review the privacy policies of third parties and change the preferences expressed, users can consult the page http://www.youronlinechoices.com/it/.

Disabling cookies. The user can always decide to block, delete, disable cookies or other similar technologies through the settings of his browser or device. There are many different browsers: each different browser (and in some cases also each different version of the same browser) has its own procedure for deleting cookies. Cookie preferences must be set separately for each browser used, as the features and options offered may vary. It is therefore advisable to visit the support pages of your browser to obtain more information. Furthermore, the user can change the settings relating to Lemuria cookies, including their activation and deactivation, by accessing the dedicated section linked from the footer of the Sites under “Cookie Settings”. The complete deactivation of cookies could preclude many features, or the correct navigation or display of the Sites or other web pages.

Acceptance and Waiver of Cookies. When the user first accesses the Sites and, in any case, until a choice is expressed, the user will be asked to provide his consent to the use of third-party analytical cookies and profiling cookies. In particular, consent can be provided by continuing to browse.

RECIPIENTS OR CATEGORIES OF RECIPIENTS OF THE DATA

The data may be processed by third parties carefully selected for reliability and competence who act, as data processors, in the name and on behalf of Lemuria on the basis of contractual agreements and specific instructions, as this is necessary or appropriate for the purpose. to carry out activities, including instrumental or ancillary, relating to the purposes of the data processing indicated in this information, the main one of which consists in the supply of goods or services requested by the interested party (eg: postal services companies, couriers, data entry companies companies that manage marketing and newsletters, etc.).
Furthermore, the personal data of users can be communicated within the company Lemuria S.r.l. . For example, if the user purchases a course or service on the Site, his data will be processed by the relevant company from time to time.
In any other case, except as provided by the applicable legislation, personal data are not transferred and / or communicated to third parties.

TRANSFER OF DATA TO COUNTRIES NOT BELONGING TO THE EU

If personal data are transferred to countries outside the European Union, the transfers will take place in compliance with the provisions established by the GDPR in order to ensure an adequate level of protection. In particular, the transfers will take place through the conclusion of Standard Contractual Clauses approved by the European Commission, the copy of which can be obtained by means of a specific request to be sent to the contact details contained in this information.

DATA CONSERVATION PERIOD

As soon as the personal data are no longer necessary for the purposes for which they were collected, Lemuria s.rl. will delete them, unless the law requires archiving obligations or if the user has not consented to their processing for a longer time or to their archiving. In particular, following the deactivation of the account or, for unregistered users, the completion of the order, Lemuria s.r.l. will keep personal data that are necessary for:
– to fulfill the requests of the authorities within their competences;
– defend or assert any existing or potential claim;
– manage any complaint concerning the contract or orders concluded.

The retention period of the data necessary to achieve the aforementioned purposes is linked to the limitation period of a claim which in many cases is 10 years. Lemuria S.r.l. will retain personal data after this time has elapsed only when required to comply with legal obligations or in the event of extraordinary claims and complaints that reasonably require to keep personal data.

RIGHTS OF THE INTERESTED PARTIES

Pursuant to art. 7 of the Code, each user has the right to obtain confirmation of the existence or not of his personal data, even if not yet registered, and their communication in an intelligible form.

In particular, each user has the right to obtain from Lemuria S.r.l. any information about:
(i) the origin of personal data;
(ii) the purpose and method of processing;
(iii) the ways in which electronic / IT tools process the data;
(iv) the identification details of the owner and of any designated data processors;
(v) the identification details of the subjects and categories of subjects to whom the data may be communicated.

Furthermore, each user has the right to obtain from Lemuria S.r.l. the updating, rectification or integration of their data as well as the cancellation of the same in the case of illegitimate processing and / or in other cases of law, with the blocking of data processed in violation of the law.

Finally, each user has the right to object, in whole or in part, to the processing of personal data concerning him, even if pertinent to the purpose of the collection, for legitimate reasons and for the purpose of sending advertising material, direct sales and for the fulfillment market research.

The requests referred to in the previous points must be sent by registered letter with return receipt or e-mail to the Data Processor indicated in the following paragraph.

RIGHTS OF THE INTERESTED PARTIES

Under the GDPR, each user has the right to access their personal data and to obtain confirmation of the existence or not of their personal data, even if not yet registered, and their communication in an intelligible form.
In particular, each user has the right to obtain access to their data from Lemuria, as well as any information regarding the methods and characteristics of the processing.

In addition to the above, the user, in the cases provided for by law, has the right to receive their personal data in a structured, commonly used and readable format, as well as the right to transmit such data to another data controller without impediments. Furthermore, each user has the right to obtain from Lemuria the updating, rectification or integration of their data. The user also has the right to have their personal data deleted as well as to limit their processing in the cases provided for by law.

Finally, each user has the right to object, in whole or in part, to the processing of personal data concerning him if the processing is based on the legitimate interest of the owner, as well as for direct marketing purposes.

The requests referred to in the previous points should be addressed to the contacts of the owners indicated in the “Data Controller” section below. Requests must be addressed to the owner of reference for the relevant activities. If you have any doubts or want more information about the data controller relevant from time to time, please contact Customer Service.

HOLDER OF THE TREATMENT

The data controller is:
– Lemuria S.r.l., with registered office in Brescia (BS), Via A. Callegari, 10 25121, Tax Code / VAT number: 03100600984, PEC address auxcom@pec.it, as regards (i) the processing activities on the Site (e.g. operation of the Site, cookies, e-commerce, purchase of products and services from the Lemuria virtual store), as well as (ii) the newsletters relating to the Lemuria virtual store and, if authorized from time to time by the user, other marketing activities;

If you have any doubts or want more information about the data controller relevant from time to time, please contact Customer Service.