Privacy & Cookie Policy

This information is provided pursuant to art. 13 of the EU Regulation n. 2016/679 (“European general regulation on the protection of personal data”)

Flamas SRLS with registered office in Via Yser 8 – 00198 Rome, VAT number. 15326431002 in the person of its Legal Representative, owner of the website www.lupiestrisce.it, as Data Controller (hereinafter, “Owner”), informs pursuant to art. 13, EU Regulation n. 2016/679 (hereinafter, “GDPR”) that your data will be processed in the manner and for the following purposes:

Subject of the processing

Your personal data will be treated confidentially and transferred to third parties solely on the basis of the provisions of this Policy, or with your consent, where necessary, in full compliance with the applicable legislation on the protection of personal data (Privacy Code and GDPR 12016/679).

The information and data that you will provide for registration purposes and during subsequent use of the Site will be used to allow you to access the reserved area, to use the online services offered by the Company to registered users as well as to make purchases.

IIn the event that the processing in question is connected to the registration (or pre-registration) to services aimed at minors, the Data Controller will request both the personal data of users and the personal data of those with parental responsibility.

In particular, the following will be processed:

personal data, identification (in particular, name, surname, tax code, VAT number, email, telephone number – hereinafter, “personal data” or also “data”) directly provided by you, by registering on the site and / o the request to use the individual services offered; strictly nominal data of minor users, when necessary, the particular data, as defined by Article 6, paragraph 1, GDPR data not directly provided by you – and in any case acquired within the limits of the provisions of art. 14, paragraph 5, GDPR – the transmission of which is connected to the use of Internet communication protocols (by way of example, access to the page, amount of data transferred, status message after accesses, session ID numbers, IP addresses , URL addresses, etc.). These data allow to reconstruct the path of your visits to the site.

Marketing

With your consent, the Company may process the personal data you have provided in order to send you advertising material and / or newsletters relating to its own or third party products.

Soft spamming

The Company may use, for the direct sale of the products offered for sale through the Site, the e-mail coordinates provided by you in the context of a purchase on the Site, even without your consent, provided that it is a product similar to the subject of the previous sale (so-called soft spamming). However, you can refuse this process at any time by communicating your opposition to the Company.

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In compliance with the GDPR, we hereby intend to inform you that the Company will process your personal data for the following purposes and conditions.

Art. 1. Purpose and legal basis of the processing. Mandatory or optional conferment. Consequences of refusal to process.

The processing of personal data is aimed at achieving the following purposes:

a. to allow the registration on the Site and access the services reserved for registered users as well as to allow compliance with the obligations deriving from the law or regulations in force, in particular, in the administrative, accounting and public security fields. The legal basis of the processing is the need for the Company to execute pre-contractual measures and process contractual requests at the request of the interested party or to fulfill a legal obligation;

b. in the case of making an online purchase order, to allow the conclusion of the contract and the correct execution of the operations connected to it (and, if necessary, according to sector legislation, to fulfill tax obligations). The legal basis of the processing is the obligation of the Company to execute the contract with the interested party or to fulfill legal obligations;

c. limited to the e-mail coordinates provided by you in the context of a purchase through the Site, to allow the direct offer by the Company of similar products (so-called soft spamming), provided that you do not object to such processing in the manner provided for by this information. The legal basis of the processing is the legitimate interest of the Company to send this type of communication. This legitimate interest can be considered equivalent to the interested party’s interest in receiving “soft-spam” communications;

d. subject to your consent, for sending newsletters and for carrying out market surveys, also aimed at evaluating the degree of user satisfaction, and sending advertising material relating to the Company’s and / or third party products, to means of systems such as email (marketing purposes). The legal basis of the processing is the consent of the interested party;

e. to respond to your requests through the customer care service. The provision is optional, but your refusal will make it impossible for the Company to answer your questions through this service. The legal basis of the processing is the legitimate interest of the Company in following up on the user’s requests. This legitimate interest is equivalent to the user’s interest in receiving replies to communications sent to the Company;

f. to respond by email, telephone your requests. The provision is optional, but your refusal will make it impossible for the Company to respond to your requests. The legal basis of the processing is the legitimate interest of the Company in responding to user requests. This legitimate interest is equivalent to the user’s interest in receiving replies to communications sent to the Company.

The provision of data for the purposes referred to in points a) and b) is purely optional. However, since this processing is necessary to make a purchase on the Site, your refusal to provide the data in question will make it impossible to make such a purchase through the Site.

The consent to the processing of your data for marketing purposes is purely optional. Failure to consent will only imply the consequences described below.

Failure to consent to the processing of data for marketing purposes will make it impossible for you to receive advertising material relating to products of the Company and / or third parties as well as the impossibility for the Company to carry out market surveys, also aimed at assessing the degree of user satisfaction, as well as to send you newsletters.

Without prejudice to the foregoing, it is understood that the Company may in any case use your personal data for the sole purpose of correctly fulfilling the obligations established by the laws in force and the obligations deriving from the contractual relationships in place between you and the Company.

We remind you that you can oppose the processing of your personal data also through the appropriate link at the bottom of any e-mail with promotional content sent by the Company.

Payment card data

To make a payment through one of the payment cards offered on the Site, the user must enter the confidential data of the payment card directly on a page that will communicate through a secure encryption protocol with the payment service provider (who will act as autonomous data controller), without passing through the Company’s server which, therefore, will not process such data in any way. The data will be acquired in encrypted format.

With reference to the payment card data, it is specified that the processing of your personal data is necessary to allow the conclusion of the online purchase contract with the Company. Failure to provide these data, therefore, will not allow you to complete the online purchase process.

Particular or judicial data

The Company does not process particular or judicial data.

Art. 2. Modality of Processing 

The processing of your personal data will be carried out by means of the operations indicated in art. 4, no. 2), GDPR and more precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. The processing of your data will be based on principles of correctness, lawfulness and transparency and can be carried out with the aid of electronic means and also through automated methods designed to store, manage and transmit them and will take place using suitable tools, for what is of reason and state of the art, to guarantee security and confidentiality through the use of suitable procedures that avoid the risk of loss, unauthorized access, illicit use and dissemination.

The information acquired and the methods of processing will be relevant and not excessive in relation to the type of services rendered. The data will also be managed and protected in environments whose access is under constant control.

Art. 3. Communication and dissemination of data

The personal data processed by the Data Controller will not be disclosed, that is, it will not be disclosed to indeterminate subjects, in any possible form, including that of making them available or simple consultation except, in anonymous and aggregate form, for statistical or research purposes.

The processed data may, on the other hand, be communicated and made accessible:

• to all those subjects (including Public Authorities) who have access to personal data by virtue of regulatory or administrative provisions
• to companies or third parties in charge of printing, enveloping, shipping and / or delivery and / or collection of products purchased through the Site
• to post offices, couriers or shippers in charge of delivering the products purchased through the Site
• to banking institutions and companies that manage the national or international payment circuits through which online payments are made for products purchased through the Site
• to companies, consultants or professionals who may be in charge of installation, maintenance, updating and, in general, the management of the Company’s hardware and software or which the Company uses for the provision of its services
• to external companies in charge of sending advertising communications on behalf of the Company
• to the company in charge of carrying out the customer care activity
• to subjects who manage online payment transactions
• to persons in charge of repairing damaged products or those subject to the legal guarantee of conformity
• to all those public and / or private entities, natural and / or legal persons (legal, administrative and tax consultancy firms, Judicial Offices, Chambers of Commerce, Chambers and Labor Offices, etc.), if the communication is necessary or functional to the correct fulfillment of the obligations deriving from the law.

Your data may also be communicated, within the strictly necessary limits, to the subjects entitled to access it by virtue of the provisions of the law, regulations, community regulations.

Without your express consent art. 6 lett. b), c), GDPR), the Data Controller may communicate your data for the purposes indicated to Supervisory Bodies, Judicial Authorities as well as to all other subjects to whom the communication is mandatory by law for the accomplishment of the aforementioned purposes.

Art. 4. Retention of personal data

Personal data will be processed for the time strictly necessary to fulfill the aforementioned purposes, in compliance with the principles of minimization and limitation of conservation pursuant to art. 5, paragraph 1, letters c), e), GDPR.

Personal data will be stored and processed for marketing purposes for a period of 24 months. At the end of this period, the Company may ask the user to renew the consent to the processing of his data for these purposes or make them anonymous and keep them only for statistical or historical purposes.

For all the remaining purposes provided for by the privacy policy, personal data will be kept only for the time necessary to guarantee the correct provision of the services offered. Once this retention period has elapsed, the data will be destroyed or made anonymous and, in any case, will be rendered unusable for the purposes for which the retention terms have elapsed.

IIn the event of closure of the Site account at the initiative of the user, the data contained therein will be kept for administrative purposes for a period not exceeding 90 days, without prejudice to any specific legal obligations on the conservation of accounting documentation or for public purposes. safety.

Art. 5 – Data transfer

The management and storage of personal data will take place on the server of the Data Controller and / or third-party companies appointed and duly appointed as Data Processors, located within the European Union, or in accordance with the provisions of Articles 45 et seq., GDPR. The servers are currently located in the European Union. The data will not be transferred outside the European Union. In any case, it is understood that, should it be necessary to transfer the location of the servers, in Italy and / or the European Union and / or non-EU countries, such movement will always take place in compliance with Articles 45 et seq., GDPR. In this case, however, the Data Controller ensures from now on that the transfer of non-EU data will take place in compliance with the applicable legal provisions by stipulating, if necessary, agreements that guarantee an adequate level of protection and / or adopting the standard contractual clauses. provided by the European Commission.

Art. 6 – Navigation data

The computer systems and software procedures used to operate the site may acquire, during their normal activity, some personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified (i.e. parameters relating to the operating system and the IT environment user). These data are used by the Data Controller for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning and are deleted immediately after processing. These data can also be used to ascertain responsibility in the event of hypothetical computer crimes against the Site.

Art. 7 – Cookies

When you use our site, cookies are stored on your computer. Cookies consist of small text files that are saved on your computer and provide us with certain information. They are widely used in order to make websites work or to make websites work more efficiently to improve the user experience, as well as to provide certain information to the owners of the site. Our site uses cookies that remain on your computer for different times. Some expire at the end of each session and some remain longer so that when you return to our Site, you can benefit from a better user experience. Web browsers allow you to exercise some control over cookies through your browser settings. Most browsers allow you to block cookies or block cookies from certain sites. Browsers can also help you delete cookies when you close your browser. However, you should keep in mind that this could mean that any opt-outs or preferences you have set on the site will be lost. We invite you to consult the technical information relating to your browser for instructions. If you choose to disable the setting of cookies or if you refuse to accept a cookie, some parts of the service may not work properly or may be significantly slower.

Art. 9. Rights of the interested party

Pursuant to art. 13 of the Privacy Regulation, the Company informs you that you have the right to:

obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;

obtain: a) updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those that do not need to be kept for the purposes for which the data were collected or subsequently processed; c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also regarding their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment proves impossible or involves the use of means that are manifestly disproportionate to the protected right; d) withdraw the consent at any time without prejudice to the lawfulness of the processing based on the consent given prior to the revocation;

object, in whole or in part: a) for legitimate reasons to the processing of personal data concerning you, even if pertinent to the purpose of the collection; b) to the processing of personal data concerning you for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by email and / or through traditional marketing methods by telephone and / or paper mail. It should be noted that the right of opposition of the interested party, set out in point b) above, for direct marketing purposes through automated methods extends to traditional ones and that in any case the possibility remains for the interested party to exercise the right of opposition also only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or neither of the two types of communication.

where applicable, you also have the rights referred to in Articles 16 – 21, GDPR (Right of rectification, right to oblivion, right to limitation of processing, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.

The above rights may be exercised by sending a registered letter with return receipt or equivalent communication to the Company to the contacts indicated below.

Art. 10. Data Controller

The Data Controller is Flamas SRLS, with registered office in Via Yser 8 – 00198 Rome VAT number 15326431002 of its Legal Representative.

The updated list of data processors and persons in charge of processing is kept at the headquarters of the Data Controller.

The Company, as Data Controller of personal data, can be contacted at the following addresses:

Via: Via Yser 8, 00198 Roma

Email: info@lupiestrisce.it

Art. 11. Amendments

The Company reserves the right to make changes to this information at any time, giving appropriate publicity to the users of the Site.

COOKIE POLICY

This Cookie Policy is intended to illustrate the types and categories of cookies, the purposes and methods of use of cookies by FLAMAS SRLS with registered office in Piazza Gondor 14, 00199 (Rome), with VAT number 15326431002, as well as to provide information to users about the actions to reject or delete the cookies on the site (the “Sites”). The user may exercise the rights provided for by art. 7 of Legislative Decree 196/03, by writing to info@lupiestrisce.it, while to change the cookie settings you can proceed by following the instructions in this Cookie Policy. The user can express his consent to the use of cookies by continuing to browse the Site, or by performing a scrolling action, by clicking on one of the internal links of the pages of the Site, or by clicking on the “x” button of the short information visible (bottom right) at each first access to the Site, as required by the provision of the Guarantor for the protection of personal data (No. 229 of 8 May 2014). It is understood that, in the case of denial of the use of cookies, this will not prevent navigation on the web page, except for any special cases, such as navigation cookies.

What are cookies?

CCookies consist of portions of code (computer files or partial data) sent by a server to the user’s Internet browser, automatically stored on the user’s computer by said browser and automatically sent back to the server at each occurrence or subsequent access to the site. Usually a cookie contains the name of the website from which the cookie itself comes, the life span of the cookie (i.e. how long it will remain on the user’s device) and a value, which is usually a unique number generated randomly. At each subsequent visit, the cookies are sent back to the website that originated them (first-party cookies) or to another site that recognizes them (third-party cookies). Cookies are useful because they allow a website to recognize the user’s device and have different purposes such as, for example, allowing you to navigate between pages efficiently, remembering your favorite sites and, in general, improving the browsing experience. They also help ensure that the advertising content displayed online is more targeted to a user and her interests. If the user decides to disable cookies, this could affect and / or limit his browsing experience within the Sites, for example he may not be able to visit certain sections of a Site or he may not receive personalized information when he visits. the Sites.

How do cookies work and how can you delete them?

ThThe operating modes as well as the options for limiting or blocking cookies can be adjusted by changing the settings of your internet browser.

Most internet browsers are initially set to accept cookies automatically, however the user can change these settings to block cookies or to be warned whenever cookies are sent to his device. There are several ways to manage cookies, for this purpose it is necessary to refer to the instruction manual or to the help screen of your browser to check how to adjust or change the settings of the same. In fact, the user is enabled to change the default configuration and disable cookies (i.e. block them permanently), by setting the highest level of protection. Below is the path to follow to manage cookies from the following browsers:

Explorer: Explorer Cookie Block

Safari: Safari Cookie Block

Chrome: Chrome Cookie Block

Firefox: Firefox Cookie Block

If the user uses different devices to view and access the Sites (for example, computers, smartphones, tablets, etc.), they must ensure that each browser on each device is adjusted to reflect their cookie preferences. To delete cookies from the Internet browser of your smartphone / tablet, you need to refer to the device’s user manual.

What types and categories of cookies does FLAMAS S.R.L.S use and for what purposes?

The Sites use different types of cookies, each of which has a specific function. FLAMAS S.R.L.S uses cookies to compile anonymous aggregate statistics that allow us to understand how users use the Sites and to improve the structure and content of the Sites themselves. Below is an explanatory list.

Technical cookies

“Technical” cookies are essential for the proper functioning of the Sites and allow users to browse the Sites and take advantage of their features (for example, they allow the storage of previous actions or allow you to save the user’s session and / or perform other activities strictly necessary for the functioning of the Sites).

This category also includes “analytical” cookies that help FLAMAS SRLS to understand how users interact with the Sites by providing information on the last page visited, the number of sections and pages visited, the time spent on the Sites and each event both emerged during navigation, such as an error message, and help to understand any difficulty that the user encounters in using the Sites. This information may be associated with user details such as IP address, domain or browser; however, they are analyzed together with information from other users so as not to identify a particular user with respect to the other. These cookies are collected and aggregated anonymously and allow FLAMAS S.R.L.S to improve the performance of the Sites.

Finally, “functionality” cookies allow the Sites to remember the user’s choices (for example the user name) to provide the latter with a more personalized and optimized navigation. Functional cookies are not essential for the operation of the Sites, but they improve the quality and the browsing experience. If you do not accept these cookies, the yield and functionality of the Sites may be lower and access to the contents of the Sites may be limited.

Profiling cookies

“Targeting” or “profiling” cookies are used to present content that is more suited to the user and to your interests. They can be used to display targeted advertisements, to publish personalized advertisements based on the user’s interests or to limit the number of times the user views an advertisement. In addition, they help measure the effectiveness of advertising campaigns on the Sites; FLAMAS SRLS may use these cookies to remember the sites that the user has visited and share this information with third parties, including agencies and advertisers who may use their cookies to collect information on the activities performed by users on the sites. sharing “(or social networks) are necessary to allow the user to interact with the Sites through their social account and are used, for example, to express appreciation and to share it with their social contacts. The FLAMAS S.R.L.S sites use or may use, even in combination with each other, cookies:

• of “session” that are stored on the user’s computer for mere technical and functional needs, for the transmission of session identifiers necessary to allow safe and efficient exploration of the site; they are deleted at the end of the “session” (hence the name) when the browser is closed;
• “persistent” which remain stored on the hard disk of the computer until their expiration or cancellation by the users. Through persistent cookies, users who access the sites (or any other users who use the same computer) are automatically recognized at each visit.

Third party cookies

When a user uses the Sites, it is possible that some cookies not controlled by FLAMAS S.R.L.S are stored. This happens, for example, if the user visits a page that contains content from a third party website. Consequently, the user will receive cookies from these third-party services. On third-party cookies FLAMAS S.R.L.S has no control over the information provided by the cookie and does not have access to such data. This information is totally controlled by third-party companies as described in their respective privacy policies. The following table shows the third-party cookies present on the FLAMAS S.R.L.S. The latter fall under the direct and exclusive responsibility of the third party manager and are divided into the following macro-categories:

• Analytics: these are cookies used to collect and analyze statistical information on accesses / visits to the website. In some cases, associated with other information such as the credentials entered for access to restricted areas (your e-mail address and password), they can be used to profile the user (personal habits, sites visited, downloaded content, types of interactions made, etc.).
• Widgets. This category includes all those graphic components of a program user interface, which aims to facilitate the user in interacting with the program itself (by way of example, Facebook, Google+, Twitter cookies are widgets).
• Advertising. This category includes cookies used to deliver advertising services within a site.

If the user does not wish to receive third-party cookies on his device, he can, through the links below, access the information and consent forms of these third parties and exclude their receipt. These cookies are not controlled directly by the Sites, therefore, to revoke the consent it is necessary to refer to the websites of third parties or refer to the site www.youronlinechoices.com/it/ to obtain information on how to delete or manage cookies in based on the browser used and to manage preferences on third-party profiling cookies.

Cookie	Primary use	Profiling	Link
DoubleClick	Advertising	Yes	https://www.google.com/ads/preferences/?hl=it
Facebook	Widgets	Yes	https://www.facebook.com/help/cookies/?ref=sitefooter
Google	Widgets/Analytic	Yes	https://tools.google.com/dlpage/gaoptout?hl=it
Share This	Widgets	Yes	http://www.sharethis.com/legal/privacy
Twitter Button	Widgets	Yes

Information update

The information relating to privacy and cookies is subject to change, therefore we invite you to consult them periodically. We reserve the right to amend or modify them at any time, to adapt it to changes in the legislation on the protection of personal data and on privacy in force. In the event of a substantial change, the Company will take care to notify the user of the changes made as soon as possible. These changes will become effective fourteen (14) days after sending the communication and the use of the Services after this change will result in their acceptance. Consent will be required only in specific cases.

For any information, please contact the Company at the e-mail address: info@lupiestrisce.it or mail in

Piazza Gondor 14, 00199 (Rome)
VAT number 15326431002
c/o FLAMAS S.R.L.S – Controller of Data Privacy.

Information updated on 25.05.2018