Privacy Policy

 

LAGO SpA, Via Artigianato II, 21, 35010 Villa del Conte (PD), Tax code and VAT no. 01508340286 (“Lago”), a sole shareholder company under the management and coordination of Giuseppe Lago

SpA, constantly undertakes to protect the online privacy of website users www.lago.it, casalagomilano.com, www.contract-lab.it, paris.lago.it, palazzotrevisi.it (hereinafter, unless otherwise indicated, jointly, the “Website”).

 

This document (the “Privacy Policy”) has been drawn up to help you understand how your Personal Data, as defined below, shall be processed as regards use of the Website. The Privacy Policy is intended to provide you with the necessary information to enable you to express explicit and informed consent to the data processing carried out through the Website, if you deem this to be appropriate.

 

In general, any information or personal data you provide to Lago through the Website, or that is collected in any other way through the Website, in the context of use of the services offered (the “Services”), as defined in detail in the Paragraph 3 below, will be processed in accordance with the internationally recognised principles of lawfulness, fairness, transparency, purpose limitation and retention, data minimisation, accuracy, integrity and confidentiality.

 

CONTENTS

1.Data Controller

2.Personal data subject to processing

a)Name, contact details and other Personal Data

b)Applications

c)Special categories of personal data

d)Data provided voluntarily by the data subject and data relating to minors

e)Navigation data

f)Cookies

3.Purpose of the data processing

4.Optional/compulsory data processing and legal basis

5.Recipients of the personal data

6.Transferring personal data

7.Storing Personal Data

8.Rights of the Data Subject

9.Amendments

 

1)Data Controller

 

Lago, as identified at the start of this Policy, is the Data Controller for all the Personal Data processed via the Website, and can be contacted via the following email address: privacy@lago.it.

 

2)Personal data subject to processing

 

We inform you that, subsequent to browsing the Website, Lago will process your Personal Data, which may include—in accordance with your decisions on how to use the Services—an identifier such as a name, surname, tax code, province of residence, telephone number, e-mail address, an identification number such as a customer code, an online identifier or one or more characteristic elements of your physical, physiological, psychological, economic, cultural or social identity that could identify you or make you identifiable (hereinafter only “Personal Data”).

Your Personal Data may be collected either because you voluntarily provide it (e.g. when you fill out an online form in order to receive the Services offered) or simply by analysing your behaviour on the Website.

The Personal Data subject to processing via the Website are as follows:

 

 

  • a) Name, contact details and other Personal Data

 

In various sections of the Website (for example, in the “Contacts” or “Contact Us” sections of the websites www.lago.it, casalagomilano.com, www.contract-lab.it, paris.lago.it, palazzotrevisi.it), you will be asked to enter information such as a name, surname, telephone number, e-mail address, etc.

Furthermore, if you participate in surveys or any promotions made available through the Website, as well as when you communicate with Lago through the contact details listed on the Website or with its Customer Service, Lago may collect any additional information you decide to provide.

 

 

  • b) Applications

 

By registering in the “Work with us” section of the Website www.lago.it relating to applications to work at Lago, you will be redirected to jobs.lagodesign.eu (“Jobs”), where you will be able to access a reserved area through which you will be able to provide Lago with various types of Personal Data, such as professional/employment details (e.g. university attended, knowledge of foreign languages, professional qualifications, applicant’s expectations and place of desired job, link to your professional profiles on social networks, etc.) and attach your photo, your CV and your cover letter (hereinafter the “Application”).

Upon receiving your Application, Lago will be able to evaluate your professional profiles on social networks (e.g. LinkedIn) or professional sites referable to you, if publicly accessible (even if you have not indicated them in the Application), in order to gain further information that may be useful to evaluate your compatibility with the position you are applying for.

 

 

  • c) Special categories of personal data

 

Through the Website (for example, in the “Contacts” or “Contact Us” sections of the websites www.lago.it, casalagomilano.com, www.contract-lab.it, paris.lago.it, palazzotrevisi.it) you may potentially provide Lago with certain information containing Personal Data.

Since these fields are empty, you may use them to communicate (voluntarily or not) even certain categories of sensitive Personal Data, such as data capable of revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data intended to uniquely identify a natural person, data relating to health or sex life or sexual orientation of the person.

 

Lago invites you not to send any such Personal Data unless it is strictly necessary. Indeed, these special categories of Personal Data may only be processed with your explicit consent and in compliance with current applicable legislation. Lago therefore underlines the importance of providing your explicit consent to the processing of special categories of Personal Data, should you decide to share such information.

 

 

  • d) Data provided voluntarily by the Data Subject

 

As already mentioned above, you may provide information of various kinds to Lago through the Website, which may contain Personal Data of other people.

 

In situations of this type, you act as an independent data controller, assuming all legal obligations and responsibilities. In this sense, you provide us with the broadest possible indemnity in respect of any dispute, claim, request for compensation for damage caused by processing, etc., of Personal Data received by Lago from third parties that has been processed through

your use of the Website in breach of applicable legislation on the protection of personal data. In any case, if you provide or otherwise process Personal Data relating to third parties when using the Website, you hereby guarantee—assuming all associated liability—that any such potential processing is based on the consent of said third party or on another suitable legal basis that legitimises the processing of the information in question.

 

 

  • e) Navigation data

 

The IT systems and software used by this Website acquire, as part of their normal operation, some Personal Data, the transmission of which is implicit in the use of Internet communication protocols. This information is not collected in order to be associated with identified users, but which could, by its very nature, make it possible to identify the Website users if processed and associated with data held by third parties. This category of data includes IP addresses or the domain names of computers used by users who connect to the Website, addresses in URI (Uniform Resource Identifier) notation of requested resources, the time the request is made, the method used to submit the request to the server, the file size obtained in response, the numerical code indicating the response status from the server (successful, error, etc.) and other parameters related to the user’s operating system and computer environment. These data are only used in order to obtain anonymous statistical information concerning the use of the Website and to check its correct operation, as well as to identify any anomalies and/or abuse, and are deleted immediately after processing. The data may be used to ascertain liability in the event of hypothetical computer crimes against the Website or third parties, unless web contact data is currently stored for no more than seven days.

 

  • f)Cookies

Information on the use of cookies is available in the Website’s Cookie Policy.

 

3)Purpose of the data processing

 

Lago will use your Personal Data collected through the Website for the following purposes:

 

  • allow you to access and register your personal account on the Website www.lago.it (e.g. via the “Lago Jobs” section), verify your identity and help you, in case you lose or forget the login/password details of your personal account, as well as provide you with any Service you request through the Website including, for example, commercial contacts and collaboration opportunities, requests for after-sales assistance, technical data sheet downloads, 3D model downloads, requests for information relating to properties or spaces indicated on the Website, requests for appointments, etc. (“Provision of the Services”);

 

  • examine Applications and contact individuals who sent their Applications through the “Work with us” section on the Website www.lago.it (“Recruitment”);

 

  • sending you marketing messages, promotional and advertising content, and market research and surveys, via email, SMS, MMS, apps, post, telephone and/or the official Lago social media accounts, as well as sending you Lago’s newsletter, and more broadly for other forms of marketing – including games, contests and competitions with prizes – of products and/or services associated with Lago and/or products and/or services associated with third parties (“Marketing”);

 

  • send you marketing communications via e-mail regarding products and services similar to those you purchased through the Website (“Soft Marketing”);
  • to create your profile through the use of profiling cookies, where accepted, therefore collecting and analysing information on the selections and choices you make when using the Website, as well as your general activities on the Website when you are a registered user, therefore collecting information on any of your questions and browsing, and on the preferences expressed when you download content from the Website. This profile will be used to provide you with information about other products and/or services that Lago believes may be of interest to you and to display ads that may match your tastes; in addition, targeted advertisements may also be proposed by comparing the information collected by Lago with that present on social media, and with respect to which we invite you to read the respective privacy policies to review the protection of personal data policies applied by the same. All the algorithms involved in this process are regularly tested to ensure that you are not offered products that you are not interested in (“Profiling”);

 

  • satisfying Lago’s legal obligations imposing the gathering and/or further processing of specific types of Personal Data (“Compliance”);

 

  • preventing or identifying any abuse in using the Website or any fraudulent activity, and therefore allowing Lago to protect itself legally (“Abuse/Fraud”).

 

4. Optional/compulsory data processing and legal basisThe legal basis for processing your Data, in accordance with the purposes laid out in section 3 above, is as follows:

 

  • Provision of the Service: processing for this purpose is necessary in order to be able to provide you with the Services and, therefore, to perform the contract with you. You do not have to provide your Personal Data to Lago for this purpose. However, if you choose not to, we will be unable to provide you with any Services.

 

  • Recruitment: processing for this purpose is required by Lago to be able to take your Application into consideration and, therefore, it is necessary to be able to start the selection process in order to potentially offer you a work position. The provision of your Personal Data for this purpose is not mandatory, yet we will not be able to consider your Application without your Personal Data. If you wish to provide special categories of Personal Data (e.g. data relating to health, religion, etc.), Lago will need your specific consent.

 

  • Marketing: processing for this purpose is based on your consent. You do not have to provide your consent for this purpose and you are free to withdraw your consent at any time without any consequences (other than that you will no longer receive marketing messages from Lago). You may also revoke your consent by following the indications in section 8 of this Policy.

 

  •     Soft Marketing: processing for this purpose is based on Lago’s interest in sending you marketing communications via e-mail regarding products and services similar to those you have already purchased. You can discontinue your receipt these communications, without any consequences for you (other than the fact that you will no longer receive further communications of this kind from Lago) by using the link at the bottom of each of these e-mails;

 

  • Profiling: processing for this purpose is based on your consent. Provision of your consent for this purpose is not mandatory and you are free to revoke it at any time without any consequences (except being unable to benefit from

personalisation of the commercial offers received by you). You may also revoke your consent by following the indications in section 8 of this Policy.

 

  • Compliance: processing personal data for this purpose is required in order to meet any legal obligations. When you provide your Personal Data to Lago, they shall be processed according to the applicable legislation, which may require their storage and communication to the authorities for accounting, tax or other obligations.

 

Abuse/Fraud: the information gathered for this purpose shall be used exclusively to prevent and/or identify any fraudulent activity or abuse in using the Website and shall therefore allow Lago to protect itself legally.

 

 

 

5.Recipients of the personal data

 

Your Personal Data may be shared with the parties listed below (“Recipients”):

  • subjects typically acting as data processors, i.e. i) individuals, companies or professional practices that provide assistance and advice to Lago regarding accounting, administrative, legal, tax, financial and credit recovery matters relating to the provision of the Services;
  • subjects with whom it is necessary to interact for the provision of the Services (for example platform providers for sending emails, real estate agencies, etc.);
  • subjects assigned to technical maintenance (including servicing network equipment and electronic communications networks);
  • other companies from the Lago Group, including real estate companies, for internal administrative purposes. It should be noted that said companies may act as independent data controllers to process your Personal Data to the extent strictly necessary to potentially conclude a contract should you be interested in purchasing/renting properties owned by the same;
  • persons authorised by Lago to process Personal Data required to perform the activities strictly related to Service provision, who have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality (e.g. employees);
  • persons, bodies or authorities to whom your Personal Data must be disclosed for Compliance, Abuse or Fraud purposes or by order of the authorities.

6.Transferring personal data

 

Some Personal Data may be shared with recipients which may be located outside the European Economic Area. Lago guarantees that processing of Personal Data by these recipients shall be carried out in compliance with the applicable legislation. The transfers may be based on adequacy decisions or Standard Contractual Clauses approved by the European Commission. More information can be obtained by writing to privacy@lago.it.

 

7.Storing Personal Data

 

Personal Data processed for the purpose of the Provision of the Services will be retained for the period of time strictly necessary for the aforementioned purpose (e.g. to manage the contract). However, as these Personal Data are processed to provide you with Services, Lago may store them for longer, specifically insofar as may be necessary to protect its own interests against any claims made in relation to the Services.

Personal Data processed for the purpose of Recruitment will be retained for the entire period of time that the position for which the Application has been sent is open or, if shorter, for 24 (twenty-four) months. Lago reserves the right to contact applicants before this period expires to request that applicants extend the retention period of their Personal Data or to request an update of the Application. If no reply is received, any Personal Data collected will be deleted.

 

Personal Data processed for the purposes of Marketing and Profiling will be kept until you revoke the consent(s) provided for these purposes. Once you have revoked your consent, Lago shall no longer use your Personal Data for these purposes, but may nonetheless store them, specifically insofar as may be necessary to protect its own interests against any claims made based on this processing.

 

Personal Data processed for the purpose of Soft Marketing will be kept until you object to any such processing through the link at the bottom of each of the Soft Marketing e-mails.

 

The Personal Data processed for the purpose of Compliance shall be stored for the time provided for by specific legal obligations or by the applicable legislation.

 

The Personal Data processed for the purposes of preventing Abuse/Fraud shall be stored for the time strictly needed for the above purpose and, therefore, until such a time as Lago shall be held to store them to protect itself legally and communicate said data to the relevant authorities.

 

8.Rights of the Data Subject

 

You have the right to ask Lago at any time for:

  • access to your Personal Data (or a copy of said Personal Data), as well as to further information regarding the processing being carried out on the same;
  • your processed Personal Data to be amended or updated, where the data are incomplete or not up to date;
  • your Personal Data to be deleted from Lago’s databases;
  • the processing of your Personal Data by Lago to be limited;
  • the Personal Data relating to you in a structured, commonly used format, readable from an automatic device;

and you may also:

  • oppose the processing of your Personal Data (e.g. Soft Marketing and Profiling);
  • revoke your consent for the purposes of Marketing.

 

When requesting the Services, you may have selected the communication channels you wish to be contacted through for Marketing purposes (i.e., e-mail, SMS, mms, app, traditional mail, telephone and/or through Lago’s official pages on social networks).

You can withdraw your consent to being contacted for Marketing purposes in relation to each of these communication channels by means of the methods indicated below.

You can also withdraw your consent to being contacted for Marketing purposes by e-mail, including the newsletter, and stop receiving Soft Marketing using the specific link at the bottom of each e-mail received.

 

Consent to Profiling through cookies can be revoked through the methods indicated in the Cookie Policy set out in Paragraph 2.f above.

In addition to the above, you can also exercise your rights by writing to Lago at the following email address: privacy@lago.it

 

You are further entitled to lodge a complaint with the competent supervisory authority (the Italian Personal Data Protection Supervisory Authority), should you believe that your Personal Data has been processed in breach of the legislation in force.

 

9.Amendments

 

This Privacy Policy is effective from 13/07/2021. Lago reserves the right to modify or simply update the content of this privacy policy, in full or in part, including in the event of amendments to applicable legislation. Lago will inform you of such changes as soon as they are introduced and they will be binding as soon as they are published on the Website. We invite you to regularly visit this section, so that you are aware of the most recent and updated version of the Privacy Policy, in order to remain up-to-date on the data collected and the use of the data.