Data Controller

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The Data Controller is Ludipendy ® di Luigi di Giusto, with registered office in Traversa Secondo di Via Orzali, 46 - 55100 Lucca (LU), VAT number 02518330465 in the person of Mr. Luigi di Giusto to be contacted at info@ludipendy.com (hereinafter referred to as “ Ludipendy ”).

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Types of data collected

Ludipendy in the exercise of its business (operated online through the SaaS offered by Wix.com Ltd ) , proceeds to collect the following user data , insofar as they are communicated by the users themselves (except for Browsing Data and cookies) :

- Personal data (name, surname, tax code, residential address and / or domicile and / or shipping, billing data);         

- Data contact (address email ) ;         

- Navigation data (web browser, IP address, time zone, log files, web beacons, tags , pixels), in addition to the provisions of cookies (cumulatively the "Usage Data") and detailed in the appropriate sections of the privacy policy or of the dedicated cookie policy.         

NB Ludipendy does not process payment data of any kind and adopts a certified SSL protocol . If required for the conclusion of the service and / or sale, such data are provided by the User exclusively to the payment platform to which the User subscribes autonomously among those made available, without Ludipendy having at any time the availability of such data.

Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data is collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using the website https: // Ludipendy.com / .
Unless otherwise specified, all requested data are mandatory. If the User refuses to communicate them, it may be impossible for Ludipendy to provide the Service. In cases where this Ludipendy indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Services offered . Users who have doubts about which data are mandatory, can freely contact the owner. Any use of Cookies - or of other tracking tools - unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to the additional purposes described in this document and in the specific Cookie Policy.

The User is required to communicate only data to himself that can be immediately traced back and for which he guarantees the truthfulness, as well as to have the right to communicate or disseminate them, freeing the Owner from any liability to third parties.

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Method and place of processing of the collected data

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Processing methods

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The Data Controller adopts the appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
The processing is carried out using IT and / or telematic tools, with organizational methods and with logic strictly related to the indicated purposes of:

- Sale , integral sales support (eg contact, invoicing, shipping, customer care, etc.) and assistance for own brand products in an ecommerce regime ;         

- Direct marketing , subject to explicit and revocable consent, by sending commercial or promotional emails , relating to own brand products or initiatives directly related to them.         

In addition to the Data Controller, in some cases, other subjects involved in the Ludipendy organization (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers, hosting) may have access to the Data. providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller and bound whenever possible by this Privacy Policy . The updated list of Managers can always be requested from the Data Controller.

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Third parties

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Ludipendy also makes use of IT services provided by third-party software (so-called " SaaS " ), which will therefore be able to access the above-mentioned data. Ludipendy undertakes to use only suppliers of primary international standing and committed to compliance with European and Italian legislation on data protection, however it is not able to force these suppliers to adopt their own Privacy Policy, nor to constantly check compliance by the latter with all the pro tempore regulations in force in the User's country of residence and therefore declines all responsibility for violations autonomously committed by said third parties. The User is therefore invited to consult the policies of these suppliers, it being understood that, in the case of suppliers of essential technical services, in the event of lack of consent and / or even potential disputes on the treatments carried out, the User must refrain from continue browsing and / or the request for services or goods by Ludipendy .

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Essential technical suppliers :

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- Wix . - https://it.wix.com/about/privacy         

- Alphabet Inc. ("Google" - Google analytics ) - https://policies.google.com/privacy?hl=it         

Optional service providers activated for marketing purposes on consent:

- Facebook Inc. ( Facebook Comments, Social Widget, Account access , pixel ads, remarketing, public personalization , analytics, audience network, customer chat, lead ads ) - https://www.facebook.com/policy.php         

- Instagram - https://www.facebook.com/help/instagram/519522125107875         

- Pinterest - https://policy.pinterest.com/it/privacy-policy         

- Twitter - https://twitter.com/it/privacy   

     

Legal basis of the processing

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The Data Controller processes Personal Data relating to the User if one of the following conditions exists:

• the processing is necessary for the execution of a contract with the User and / or for the execution of pre-contractual measures;

•  the User has given consent for direct marketing purposes ;

•  the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;

• the processing is necessary for the execution of a task of public interest or for the exercise of public authority vested in the Data Controller;

• the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

In any case, it is always possible to ask the Data Controller to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract, by contacting the Data Controller at the address in epigraph .

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Data Location

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The Data are processed at the registered office of the Data Controller and in any other place where the parties involved in the processing are located, particular and relevant will be the identification of the place chosen by Wix.com Ltd which at the current date must be considered as the headquarters as a priority. Israeli or Irish from the same third company , currently deemed suitable by the European Commission to offer an adequate level of protection of the Personal Information of residents of EU Member States.
The User's Personal Data could therefore be transferred to a country other than the one in which the User is located without Ludipendy being aware of it, according to the provisions of the Third Parties section above .

The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization governed by public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.
The User can check whether one of the transfers described above takes place by examining the section of this document relating to the details on the processing of Personal Data or requesting information from the Data Controller by contacting him at the indicated details in opening.

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Retention period

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The Data are processed and stored for the time required by the purposes for which they were collected.

Therefore:

• The Personal Data collected for purposes related to the execution of a contract between the owner and the user will be held back until he has completed the execution of this contract and until required by statutory regulations and accounting for the time being in force.

• Personal Data collected for purposes attributable to the legitimate interest of the Data Controller will be retained until this interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

When the processing is based on the User's consent (eg marketing purposes ) , the Data Controller may keep the Personal Data longer and until such consent is revoked. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of an Authority.
At the end of the retention period, the Personal Data will be deleted. Therefore, at the end of this term the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

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Rights of the User

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Users can exercise certain rights with reference to the Data processed by the Data Controller. If the User intends to exercise a right with reference to the Data processed by third parties, he can make a request both to the owner and, preferably, directly to the third party.

In particular, the User has the right to:

• withdraw consent at any time. The User can revoke the consent to the processing of their Personal Data previously expressed. 

• oppose the processing of their data. The User can oppose the processing of their data when it occurs on a legal basis other than consent. Further details on the right to object are indicated in the section below. 

• access their data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed. 

• verify and request rectification. The User can verify the correctness of his / her Data and request its updating or correction. 

• obtain the limitation of the treatment. When certain conditions are met, the User may request the limitation of the processing of their Data. In this case the Data Controller will not process the Data for any other purpose than their conservation. 

• obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Owner. 

• receive their data or have them transferred to another owner. The User has the right to receive his / her Data in a structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain the transfer without obstacles to another owner. This provision is applicable when the Data is processed with automated tools and the processing is based on the User's consent, on a contract to which the User is a party or on contractual measures connected to it. 

• propose a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or act in court. 

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Details on the right to object

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Users are reminded that, if their Data are processed for direct marketing purposes, they can oppose the processing without providing any reasons. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document, it being understood that this activity will be carried out only with explicit consent. The User also retains the right to oppose any further processing, but in such cases it must be made aware that Ludipendy may not be in a position to offer the services or fulfill its contractual obligations.

How to exercise your rights

To exercise the User's rights, Users can send a request to the contact details of the Owner indicated in this document and in particular to info@ludipendy.com The requests are filed free of charge and processed by the Owner as soon as possible, in any case within a month. Ludipendy in any case represents that by making full use of the same for the operation of its website of the SaaS offered by Wix.com Ltd , in some cases the User's requests may have to be forwarded directly to the latter company at the address privacy @ wix.com or at the different address indicated on the website https://it.wix.com/about/privacy .

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Further information on the treatment

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Defense in court

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The User's Personal Data may be used by the Owner in court or in the preparatory stages for its eventual establishment for the defense against abuse in the use of this Application or related Services by the User.
The User declares to be aware that the Owner may be obliged to disclose the Data by order of the public authorities.

System log and maintenance

For needs related to operation and maintenance, this Application and any third party services used by it may collect system logs, i.e. files that record the interactions and which may also contain Personal Data, such as the User IP address.

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Information not contained in this policy

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Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details. This policy is supplemented by a specific cookie policy, available separately on the website under the appropriate cookie banner .

Response to "Do Not Track " requests

This application support the requests ”Do Not Track" in the measure  in which they are allowed to https://it.wix.com/about/privacy . To find out if also any third-party services used to support, users are invited to consult the aforementioned privacy policies.
 

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on the site ludipendy.com , if technically and legally feasible, by sending a notification to Users through one of the contact details in its possession. Please therefore consult this page frequently, referring to the date of the last modification indicated at the bottom.
If the changes concern treatments whose legal basis is consent, the Data Controller will collect the User's consent again, if necessary.

 

 

Legal references

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This privacy statement is primarily drawn up on the basis of Regulation (EU) 2016/679 (so-called "GDPR") , which in the event of a conflict between rules must always be considered prevailing.

Ludipendy undertakes to promptly update this information in compliance with the aforementioned legislation, although it cannot guarantee an immediate level of updating . If this information should contain references and provisions that are incompatible with mandatory rules subsequently amended, the same must be considered ab r or gate.

Ludipendy undertakes to make use of third parties outside the EU that comply with the GDPR, however the User must be aware that they could also be subject to national regulations, whose subsequent modification could cause temporary problems of incompatibility between rules.

 

Rev. 1 of May 26, 2021