PRIVACY POLICY

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pursuant to Articles 13 EU Regulation 2016/679 (GDPR)

 

1.DATA CONTROLLER

LINCOTEK BOLOGNA S.R.L.

Address: Via Bruno Buozzi, 13-15 – 40057 - Cadriano di Granarolo Emilia, Bologna (BO) - Italy

Telephone: +39 051 0954552

Email: info@recon-i.com

VAT no. and tax code and ITVAT: IT 03277221200

Economic and Administrative Index No. IT 01305350223

Authorised Share Capital and Paid-up Share Capital € 1.806.000,00

www.recon-i.info

privacy@lincotek.com

Sector and Activity: Manufacturing company, belonging to a multinational group, specialized in treatment and coating of metals and, in particular, provision of special services for the orthopaedic industry.

 

2.GROUP DATA PROTECTION OFFICER (DPO)

Microell s.r.l. – Referent: Francesco Traficante - dpo@lincotek.com

 

 

3.MISSION

The web site aims to provide the user with detailed and specific information on our products and services.

The user can:

• Be constantly updated about the services and products offered through our catalogues;

• Request free information and/or quotes for our products by contacting the company by email or telephone specified in “CONTACT” section.

 

4.PRINCIPLES

One of our fundamental objectives is the protection of personal data. Personal data are processed lawfully, fairly and in a transparent manner, and they shall be adequate, relevant and limited to the minimum necessary and, where necessary, kept up to date and collected for specified, explicit and legitimate purposes pursuant to Articles 5 and 6 of EU General Data Protection Regulation 2016/679 (GDPR) following consent if so required. Personal Data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing, and against accidental loss, destruction or damage, by taking suitable technical and organisational measures (Integrity and Confidentiality). In case of substantial modification to this Privacy Policy and to the related data processing the User shall be informed and shall have the right to decide whether or not to continue to use our services.

 

5.SOURCES OF THE PERSONAL DATA

Personal Data collected from the Data Subject:

• Offices of the Data Controller or Data Subject.

 

6.CATEGORIES OF DATA SUBJECT

USERS: legal entities, herein including the personal data of the workers and persons treated as such, corporate representatives, shareholders of the companies that are already customers of ours.

 

7.CATEGORIES AND PERSONAL DATA PROCESSED

Personal data may be acquired, in whole or in part, during the first phase of collection or subsequently through traditional and automated contact methods.

COMMON PERSONAL DATA: Company Name, Name and Surname, Country, City, Address, Email, Telephone.

 

8.PURPOSE OF DATA PROCESSING – LAWFULNESS OF PROCESSING & NATURE OF THE DATA PROVISION - PROCESSING DURATION & DATA RETENTION

 

PURPOSE DESCRIPTION

LAWFULNESS OF PROCESSING & NATURE OF THE DATA PROVISION

PROCESSING DURATION & DATA RETENTION

IMPLEMENTATION OF PRE-CONTRACTUAL MEASURES:

Information, consulting, feasibility, quotations, assistance, monitoring of quotation status and check and assessments on the performance of the pr-contractual relationship.

Implementation of pre-contractual measures.

 

Data provision is optional but necessary for the management of your request.

 

Duration for a period strictly necessary for the correct and complete management of the request; further processing and retention at the request of the Data Subject.

 

COMMUNICATION BETWEEN GROUP COMPANY:

Transfer of personal data for administrative- accounting purposes, including sales within the companies of the multinational group.                                                                                                                                          

Data Controller Legitimate Interest.

 

Data provision is necessary for the management of the relationship between Group Company.

Duration of the contract (for the Data Controller).

 

Upon termination, data retention occurs in compliance with the legal requirements in force in the Country where data are stored (of the Recipient of the communication or Parent Company).

 

 

9.COOKIE

Cookies are small text files that a website stores on the user’s device during the navigation.

We use exclusively technical cookies, in order to offer the user easier navigation and for internal security and system administration purposes. Technical cookies are divided into several types:

• Session cookies: allow the site to link the user’s actions during a browser session allowing a faster navigation;

• Functionality cookies: used to store the preferences set by the user while browsing and to facilitate the use of certain services, for example on our website are used to identify the type of navigation tool, whether fixed or mobile, to direct the customer to its compatible version (web responsive).

There are no other cookies, first or third party, that allow you to analyse the navigation of users for statistical purposes, nor to propose targeted promotional content.

 

 

10.DATA RECIPIENTS

Data may be shared with and processed by external parties acting as Data Controller such as, by way of example:

Italy:

• Authorities and monitoring Bodies;

• Police and Judical Authorities;

• Business transferees, transferees of a business branch, of legal relationships in bulk or of single legal relationships (for example the assignment of receivables or the transfer of contracts);

• Persons/entities providing professional consultancy services also in partnership.

 

European Union:

• Companies, even foreign ones, that are associated or belong to the Group or to the Parent company LINCOTEK GROUP S.p.A., also considering the existence of telematic IT links.

Extra EU (Switzerland, USA, China, Singapore):

• Companies, even foreign ones, that are associated or belong to the Group or to the parent company;

• Other commercial parties authorized to distribute our products based on their territorial competence corresponding to the same area to which the customer or the prospective customer belongs.[NAMs2] 

 

 

 

Personal data may also be processed by external parties appointed as Data Processors acting in the name and on behalf of the Data Controller. The appointed external Data Processor shall receive adequate operative instructions. The above-mentioned external parties are included in the following categories:

Italia:

• Persons/entities providing compliance support services on a continuous basis;

• Persons/entities providing IT, ICT, Cloud, Web and Digital Marketing services;

• Persons/entities providing digital and physical archiving services and electronic storage;

• Persons/entities providing mailing services and electronic mail services;

• Persons/entities providing market research support services;

• Companies or professional consultants providing other services;

• Persons/entities providing ICT services (Hosting/Data Center).

European Union:

• Persons/entities providing IT, ICT, Cloud, Web and Digital Marketing services;

• Persons/entities providing ICT services (Hosting/Data Center).

 

11.PARTHIES AUTHORIZED TO PROCESS THE PERSONAL DATA

Personal data may be processed by employees and collaborators in their functions, including the sales network and the people responsible for the fulfilment of the above mentioned purposes, that have been expressly authorised to process the personal data after having been informed and appropriately trained and after having received adequate operative instructions.

 

12.TRANSFER OF PERSONAL DATA TO NON-EU COUNTRIES

Your personal data will be transferred to non-EU countries or international organisations, in particular to:

• Switzerland: Level of personal data protection being considered as adequate by a decision of the European Commission (Art. 25, paragraph 6, Directive 95/46/EC and Art. 45, paragraph 3 GDPR);

• USA, China and Singapore: the personal data of Data subjects who are outside the EU/EEA shall be transferred to other commercial parties authorized to distribute our products within their territory, specifically to those customers or potential ones located in the same geographical area. For this reason, pursuant to Art. 3, paragraph 2 of GDPR, the European Regulation is not applicable and the personal data protection law in force in the States where the Data Recipients reside shall therefore apply.

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