PRIVACY POLICY STATEMENT ON THE PROCESSING OF PERSONAL DATA
Pursuant to article 13 reg. 2016/679 (general data protection regulation, hereinafter GDPR), this page contains the privacy policy statement on the processing of personal data belonging to users intending to visit the site, www.lindameyerhentschel.com (hereinafter “site”), or to register to receive the newsletter.
1- Data controller and data protection officer
The data controller is LMH S.R.L., having its registered office in Viale Gran Sasso 11, 20131 – Milan, vat/tax code number, 11042310968 and it may be contacted at the postal address of the registered office or otherwise at the email address CustomerCare@lindameyerhentschel.com.
The data protection officer is Maria Elena Iafolla and she may be contacted at the email address privacy@lindameyerhentschel.com.
2- Data collected and scope of data processing
A) Data for registering to receive the newsletter
The form for registering to receive the newsletter collects the following personal data:
- Email address (mandatory)
- Male/female (not mandatory)
The purpose of data processing a) is registering for the newsletter service and the data provided shall not be processed for any other purpose. The legal basis of processing is consent granted by the data subject.
The purpose of data processing b) is to offer users a commercial communications service which is more appropriate for their requirements, through an automated profiling decision-making process. The legal basis is consent granted by the data subject who voluntarily decides to provide their data.
B) Data provided voluntarily by users through the contact form
The optional, voluntary sending of messages through the contact form present on the site involves the subsequent acquisition of:
- Name
- Surname
- E-mail address
- Purpose of the message
- Message
The purpose of data processing is to fulfil the request for information and to perform any additional activities requested by the data subject; the legal basis of data processing is therefore the users’ wish to be re-contacted, in addition to the performance of pre-contractual or contractual measures as requested by the data subject.
C) Data provided voluntarily by the user by means of post and email
The optional, voluntary sending of email messages to the address indicated on the site (CustomerCare@lindameyerhentschel.com) or by the hardcopy postal service to the registered office address or, again, with messages sent through the Whatsapp application, gives rise to the acquisition of the sender’s address in addition to all personal data contained in the message. The purpose of data processing is to fulfil the request for information and to perform any additional activities requested by the data subject; the legal basis of processing is therefore the user’s wish to be recontacted, in addition to the performance of pre-contractual measures as requested by the data subject.
D) Browsing data
The systems and procedures designed for the site www.lindameyerhentschel.com to operate acquire certain data which is implicitly sent through the use of internet communication protocols.
This information is not collected in order to be associated to identified individuals, but by its nature it may allow for user identification, by means of association with data held by third parties. Such data includes ip addresses or computer domain names, addresses and names relating to uri (uniform resource identifier) for resources requested and certain information regarding such requests (for example, times and method used for submitting the request to the server, size of the response and numerical code of the response status).
This data is processed in order to check that the site functions properly, to improve the quality of services offered and to process statistical analyses anonymously and in an aggregated manner. It is therefore processed when strictly necessary and proportionate in order to ensure site and information security.
The legal basis of processing is the data controller’s legitimate interest to ensure site security, and to rule out the possibility that it may be used to harm others’ rights or in order to conduct unlawful actions.
Such data may also be used in order to ascertain liability in the event of it offences against the site; the legal basis in such case is the data controller’s legitimate interest to protect and defend its rights.
3- Provision of data
Without prejudice to what has been stated on the use of internet communication technologies and protocols and technical cookies, the provision of data by the data subject wishing to contact the data controller through an email message or hardcopy postal service is voluntary. Provision of data therefore is not mandatory but any refusal shall make it impossible to be recontacted and/or to obtain what is requested.
With regard to registration for the newsletter service, it is done solely on a voluntary basis and accordingly there is no obligation to provide data; any refusal to provide the email address shall make it impossible to register for the service.
4- Manner of data processing
Data for registering for the newsletter – the data shall be processed by means of digital instruments and shall be retained for as long as the newsletter service is provided, unless the data subject withdraws their consent;
Data provided voluntarily by the user through the contact form or email message – the data shall be processed through hardcopy media or digitally and shall be retained for as long as is necessary to perform the activities requested by the data subject;
Browsing data – the data shall be processed digitally and shall be retained for as long as is necessary in order to achieve the purpose of data collection, for no more than 24 months.
Physical and digital security measures have been put in place in order to ensure the integrity, availability and confidentiality of data.
The data controller does not adopt any automated decision taking processes or algorithmic processes, including profiling, as per article 22, paragraphs 1 and 4 of the GDPR, with the exception of indicating male/female in the newsletter registration form, in order to send targeted commercial communications.
5- Special category data
Data has not been collected when it falls into what articles 9 and 10 of the GDPR define as “special categories” (personal data revealing the racial or ethnic origin, the political opinions, the philosophical or religious convictions, trade union membership, genetic or biometric data, data relating to a person’s health or sexual activity or sexual orientation, judicial data or data relating to offences or security measures).
6- Data confidentiality
The data may be stored outside the European union and in such case the data controller ensures that appropriate guarantees will be adopted, including standard contractual data protection clauses.
The data shall not be disseminated but may be provided to parties providing the data controller with consultancy services and legal assistance, site development, marketing and communication consultancy, in addition to parties entitled to access the data in accordance with legal provisions or in accordance with orders issued by relevant authorities.
7- The data subject’s rights
At any time, the data subject may exercise their rights recognised under articles 15 to 22 of the GDPR and, specifically, may:
A) request confirmation as to whether or not their personal data is being held;
B) obtain information as to the purpose of data processing, the categories of personal data, recipients or categories of recipients to whom personal data has been or shall be forwarded and, when possible, the data retention period.
C) obtain the correction and cancellation of data, in addition, where technically possible, to data portability, in other words the right to receive such data from a data controller, in a structured, widely used, machine readable format and to send it to another data controller without any hindrance;
D) obtain restrictions on data processing and object to processing at any time including for purposes of direct marketing;
E) object to an automated decision-making process regarding individuals, including profiling;
F) revoke consent, when granted, without adversely affecting the lawfulness of processing based on consent granted prior to revocation;
G) file a complaint with a supervisory authority, which in Italy is the data protection authority (at the email address garante@gpdp.it, at the fax number 06.696773785 or by means of the postal service to the address: piazza Venezia n. 11 – 00187 Rome)
You may exercise your rights by means of a written request addressed to:
LMH S.R.L.,
viale Gran Sasso, 11
20131 – Milan,
Or to the e-mail address customercare@lindameyerhentschel.com or privacy@lindameyerhentschel.com.
Last updated: June 2021