Based on the provisions of art. 13 of Legislative Decree 196/2003 (“privacy code”), Lem Europe srl, based in Rome, Via Cesare Majoli, n. 9, the owner, (referred to as the “owner” or “Lem”), provides users who wish to subscribe to the newsletter service with information on the data processing acquired.
What data is processed and with what purpose?
The identification data (name, surname and email address) given by the user through the appropriate form are used to allow the user to subscribe to the newsletter service and receive messages of commercial and promotional content sent by the owner to the subscribers. The user is also informed that the platform utilized by the owner for the management of the newsletter service allows, through statistical tracking systems, to detect certain information (such as opening a message, clicks on hyperlinks contained within the email / site, from which IP address or with which type of browser the email / site is opened, and other similar details), whose collection is functional to the use of the platform and is an integral part of the functionality of the message sending system .
Communication and dissemination
The collected data will not be disseminated. The data will not be disclosed to third parties without the express consent of the interested party, except in cases in which communication to third parties (competent authorities, consultants or companies providing IT supply and assistance services, companies providing the management and sending platform) is necessary to fulfil legal obligations or to fulfil the obligations arising from the relationship with the person concerned or third parties (falling within one of the categories indicated) that operate as responsible on privacy.
Methods for data processing
The collected data is processed through the platform and standard IT tools as well as through additional IT tools used by the owner to manage the service. No data managed by the owner is transferred to non-EU countries .The data is kept except upon the request of the interested party in opposition to the data treatment or if the user wishes to renounce the receipt of the newsletter. In any case the data is not kept for more than two years since user registration.
Rights of the interested party
The interested party can assert at any time, without formalities, by contacting the owner, or by sending an email to firstname.lastname@example.org the rights referred to in art. 7 of Legislative Decree 30 June 2003 no. 196, which is reported below.Art. 7 D. Lgs. 196/2003
1. The interested party has the right to obtain confirmation of the existence or not of personal data concerning him / her, even if not yet registered, and have the data rendered to them in intelligible form.
2. The interested party has the right to obtain the indication:
a) of the origin of personal data;
b) of the purposes and methods of data processing;
c) of the logic applied in case of data treatment carried out with the aid of electronic instruments;
d) of the identifying details of the holder, of the responsible and of the designated representative according to article 5, paragraph 2;
e) of the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them
3. The interested party has the right to obtain:
a) updates, rectification or, when interested, integration of data;
b) the cancellation and/or transformation into anonymous form or banning of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data was collected or subsequently processed;
c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also in regard to the content, of those to whom the data has been communicated or disseminated, except in the case where such fulfilment proves impossible or involves a use of means disproportionate to the protective right of the user.
4. The interested party has the right to object, in whole or in part:
a) on legitimate grounds, to the processing of personal data concerning him / her, even if they are relevant to the purpose of the collection;
b) to the processing of personal data concerning him/her for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication.
The owner is Lem Europe Srl.The platform provider used for the newsletter service operates as the privacy manager.The interested party can request from the Owner the list of the appointed privacy managers.
Nature of the provision of data and consent
The provision of data is optional. Any refusal may imply the impossibility for the owner to provide feedback to the requests made by the interested party or user. On the basis of the articles 23, 122 and 130 of the privacy code; consent to the processing of data is necessary as they are used for sending commercial and promotional content emails according to the methods described in this information and for access to information through the systems offered by platform that the owner uses.