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Privacy Policy

Pursuant to Legislative Decree 30 June 2003, n. 196 and following (“Privacy Code“) and the European Regulation 2016/679 (“Privacy Regulation“), Ledworks S.r.l. intends to inform you and all users and / or visitors to the web site https://twinkly.com (respectively, the “Users” and the “Website“), regarding the use of personal data, log files and cookies collected through the Website.

  1. Data Controller, Data Processors and Data Protection Officer

 

The Data Controller of the processing of personal data is Ledworks S.r.l. (VAT 07477880962), with head office in 20139 Milano, Via Arcivescovo Calabiana n. 6, P.IVA 09521280967, e-mail privacy@ledworks.io (hereinafter, the “Data Controller“).

The updated list of designated Data Processors may be provided upon request by data subjects and / or Users.

Where appointed, the contact details of the Data Protection Officer will be disclosed through publication on the Website.

 

  1. Information collected automatically from the Website – Cookies

a) Information collected automatically

As all websites, our Website also uses log files, in which information collected in an automated manner is kept during your visits. The information systems and the software procedures used to operate the Website, in fact, acquire automatically some information during use, the transmission of which is implicit in the use of Internet communication protocols.

The information collected is the following:

  • Internet Protocol (IP) address or the domain name of the device used by you;
  • type of browser and device parameters used to connect to the Website;
  • the addresses in the Uniform Resource Identifier (URI) notation of the requested resources or the method used in submitting the request to the server;
  • name of the Internet service provider (ISP);
  • date and time of visit;
  • web page of origin (referral) and exit of the User;
  • possibly the number of clicks;
  • the size of the file obtained in response;
  • the numerical code indicating the status of the response given by the server (good order, error, etc.);
  • other parameters relating to the operating system and the IT environment of your device.

This information is processed in an automated form and collected exclusively in aggregate form in order to verify the correct functioning of the Website.

b) Cookies

The Website uses cookies. Cookies are text files recorded on IT support, which allow to record some parameters and data communicated to the IT system, through the browser used by you. Therefore, these tools allow an analysis of your habits in using the Website, for different purposes: execution of IT authentication, monitoring of sessions, storage of information on specific configurations regarding users accessing the server, storing preferences, etc.

Cookies are distinguished in:

  1. Technical cookies: they are used to make browsing or to provide a service requested by you. Without the use of these cookies, some operations could not be completed or would be more complex and/or less secure.
  2. Profiling cookies: they are used to track your browsing and create profiles on your tastes, habits, choices, etc. In this way, advertising messages can be transmitted to your device in line with your preferences already shown in the previous online navigation.

For the installation of technical cookies, your consent is not required. For the installation of profiling cookies your consent is required: if you do not want your device to receive and store profiling cookies, you can change the security settings of your browser. In fact, through the settings of the browser used to navigate, you can decide whether to delete and / or avoid the installation of cookies on the device used.

However, it should be noted that by deactivating the use of profiling cookies you will not be able to take full advantage of certain features of the Website.

While browsing the Website, you can also receive cookies on your terminal that are sent from different websites or web servers (hereinafter, “Third Parties“). The Third Parties, who use cookies on our site, are:

 

By the Website, the use of Cookies is considered accepted and consent to the processing of data collected by Third Parties is accepted.

  1. Facebook social plugins ad other social networks

The Website may contain social network plug-ins (e.g. Facebook, Twitter, etc.). If you access one of our web pages equipped with such a plug-in, the Internet browser connects directly to the social network servers and the plug-in is displayed on the screen, thanks to the connection with the browser. The plug-in communicates to the social network server which pages the data subject has visited. If the user of a social network visits our web pages, while he is connected to his social account, his personal data may be associated with the social account. Even if the plug-in functions are used (for example, by clicking on the “Like” button or by posting a comment), the information will be associated with the social network account. Further information on the collection and use of data by social networks in general, as well as on the rights and methods available to protect the privacy of the person concerned in this context, are present in the pages of the account’s social networks. If the data subject does not wish to associate the use of the Websites with his social network account, he must leave the social network before visiting them.

It should also be noted that the Site interacts with Facebook Insights platform, whose information on the processing of personal data, carried out towards the user, can be found at the following link: https://www.facebook.com/legal/terms/information_about_page_insights_data.

 

  1. The personal data you provide us using the Website: to which end we treat them

We need your data to enable you:

– to access the Website and make the relative navigation;

– to proceed with registration and access to the services offered therein (e.g. contacts, newsletter, local store, etc.), as requested by you.

Your data are processed for the following purposes:

  • to comply with legal obligations;
  • to carry out the technical management of the Website;
  • to use the service “Local Store”, which allows you to identify the Twinkly dealers closest to your position;
  • to use the communication service with the Data Controller, whose information is available at the following link https://twinkly.com/contacts-policy/;
  • to receive the newsletter, whose information is available at the following link https://twinkly.com/newsletter-policy/.

In compliance with the Italian “Guidelines on promotional activity and contrast to spam” of 4 July 2013, we point out that any consent given by you for sending commercial, promotional and marketing communications through automated tools will also extend to traditional methods of contact.

Through the “Local Store” service, the Website can process geolocation data by sending it or storing it on its servers: activating the search function of a retailer near its position involves the management of data relating to the position of the device (smartphone, tablet, laptop, etc.) of the User only on the device itself, as they are supplied to any programs (e.g. Google Maps, Waze and similar) installed on the device.

The data provided by you will be processed mainly with IT tools under the authority of the Data Controller, by specifically appointed, designated and instructed to process, pursuant to Articles 28 and 29 of the Privacy Regulations. We inform you that appropriate security measures are observed, also pursuant to Articles 5 and 32 of the Privacy Regulations to prevent the loss of data, illicit or incorrect use and unauthorized access.

  1. Nature of the provision of data

With reference to the purposes referred to points (iv) and (v) of the previous paragraphs 4, please refer to what is expressly indicated in the specific information referred to in this Privacy Policy.

For the purposes referred to in points (i), (ii) and (iii) of the previous paragraphs 4, the provision of your personal data is necessary because in your absence you will not be able to use the services offered by the Website. Consequently, for the point (i) the legal basis of the processing is the fulfillment of legal obligations, to pursuant to Article 6, paragraph 1, lett. c) of the Privacy Regulation, while for the purposes referred to in points (ii) and (iii) the legal basis of the processing is the execution of the services provided through the Website and requested by you, pursuant to Article 6, paragraph 1, lett. b) of the Privacy Regulation.

More details on the foregoing are contained in the specific information provided or displayed on the Website and prepared for the related services on request.

  1. To whom and in which cases we can transmit your data.

Your data may be communicated to the structures, subjects and external companies within the EU (including consultants and service providers) which the Data Controller uses to manage the Website and to carry out related activities, instrumental or consequent to the execution of the services offered by the Website.

More details on the foregoing are contained in the specific information provided or displayed on the Website and prepared for the related services on request.

  1. Your rights

At any time, you can exercise the rights referred to in Articles 15 and following of the Privacy Regulation, for access, rectification, transformation, blocking, cancellation, limitation of processing, in the manner established by Article 12 of the Privacy Regulation.

In the event of failure to promptly reply or an inadequate response from the Data Controller, or if you believe there is a violation of the Privacy Code and / or the Privacy Regulation, you can appeal to the Authority of the protection of personal data, at the following coordinates: www.gpdp.itwww.garanteprivacy.it, Email: garante@gpdp.it, Fax: (+39) 06.69677.3785, Telephone switchboard: (+39) 06.69677.1.

  1. Duration of the Treatment

Subject to legal obligations, personal data will be stored for a specified period, based on criteria based on the nature of the services provided.

More details on the foregoing are contained in the specific information provided or displayed on the Website and prepared for the related services on request.

  1. Security measures

Through the Website your data will be processed with applicable law and using appropriate security measures, in compliance with the legislation in force also pursuant to Articles 5 and 32 of the Privacy Regulation, aimed at preventing unauthorized access, theft, disclosure, modification or unauthorized destruction of your data.

  1. Changes to Privacy Policy

The Data Controller reserves the right to make changes to this Privacy Policy.