Lupi believes that your personal data belongs to you. We aim to respect and process your personal data with due care at all times. When visiting our websites and/or connecting with us for general information and business purposes, you shall feel confident that your privacy is respected.
The purpose of this policy is to inform you of the types of Personal Data we collect when you use Lupi web sites and/or you connect with us for business purposes, and the steps we take to protect and safeguard your personal information.
This policy and its principles apply to personal identifiable information we collect and ask for, and that you provide to perform the contract we have entered into with you, to perform the services you asked from us, to comply with a legal obligation. By this we mean information that directly or indirectly identifies you, such as your name, physical address, e-mail address, IP number or other contact details.
We aim to process personal data that is adequate, relevant and not excessive in relation to the purpose for which it has been collected. We believe in being transparent about the types of personal information and why we collect your information. We only collect and process personal information where we have lawful grounds to so, and in accordance with Data Privacy Laws.
On request, Lupi will provide you with further information regarding our processing and protection of your personal data when visiting our websites. Please see the contact section below.
Personal Data collection
We hope the following information will help you make an informed decision about sharing your personal information with us. You are always free to decide if you want to provide your personal identifiable information or not.
Just visiting our website
By accessing and browsing our web site, we do not require personal identifiable information.
Connect for Business
Where you request to receive quotations, marketing and promotional material, general information, newsletters, enter our suppliers’ database or connect with us online, we may (depending on type of contact you request) collect the following personal identifiable information, for example:
- Contact details (e-mail, address, phone, professional title or role), company name, and language preferences;
- Event, meeting (including feedback about content and services at events you attend through surveys), travel Information;
- Where connecting on social platforms, we may also collect information you submit or post to and from our Services.
We may also collect information from business partners, from third parties acting on your behalf, and other platforms that help provide Services. For example, we may receive meeting data from an event registration provider.
We use your personal identifiable information to provide you with the requested services and/or perform the contract we have entered into with you, and may send you marketing and promotional material relevant to you, including invites to events and seminars, product and service offerings, to keep in contact and to provide you with news, updates and other business-to-business related information relevant to you.
You may at any time ask us to delete your personal identifiable information. Please contact firstname.lastname@example.org
Lupi is responsible as controller
Lupi, headquartered in Piazza della Vittoria 9/6, 16121 Genova, Italy, is the data controller of personal information collected and which you entrust to us. We always aim to comply with the General Data Privacy Regulation and other applicable Data privacy laws. If you have any complaints relating to our handling of your personal identifiable information that cannot be resolved with us directly, please contact the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali) at email@example.com
Legal grounds for Collection and Processing of Personal Data.
Depending on what services you request from us and the reasons for connecting with us for business, we only process your personal identifiable information where we have legal grounds to do so. Where we require your consent to collect and process your personal data, the request form will be provided in a clear, specific and expressly manner.
If we have asked for your consent, it can always be revoked at any time by contacting us and we will not use or process your personal identifiable information any more.
Sharing of information
As a general rule, Lupi never rents or sells your personal identifiable information to other companies or individuals, unless we have your consent. We may share such information in any of the following limited circumstances:
- With your consent.
- Where we are required by law or have good faith to believe that access, preservation or disclosure of such information is reasonably necessary to protect the rights, property or safety of Lupi, its users or the public.
Your personal data is stored in databases and paper archives managed by Lupi. We may however store and process personal information collected in any country in which Lupi or our hosting providers maintain facilities. By using our services, you consent to the transfer of your information among these facilities, including those located outside your country and the EU.
Sharing of Account-specific information
When you have submitted personal identifiable information to us, we may share such information submitted among all our services as well as distributors and channel partners to provide you with a seamless experience and to improve the quality of our services. We will not disclose your account information to other people or non-affiliated companies, except in the limited circumstances described in this Policy or with your consent.
We only share your Information with data platforms and cloud providers that perform services on our behalf. We share Information with companies that help us operate and support our Services. Some vendors may be located in a country other than where you live. We may also share Information with analytics and search engine providers who act on our behalf.
We aim to implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and any other unlawful forms of processing. We aim to ensure that the level of security and the measures adopted to protect your personal data are appropriate for the risks presented by the nature and use of your personal data.
We restrict access to your personal data to our employees and suppliers who need to use the information in order to process it on our behalf, and who are contractually required to keep your personal data secure and confidential.
Updating your information
Where we process your personal data, we aim to ensure that it is accurate and up-to-date. We will seek to erase or rectify personal data that is inaccurate or incomplete. If you need to update or correct your personal identifiable information, please contact firstname.lastname@example.org with your request and we will provide you with the mechanism for updating and correcting your personal identifiable information
We will only retain your personal data for as long as it is necessary to fulfil the purposes outlined in this policy or the purposes of which you have otherwise been informed. We will retain your data for as long as permitted under applicable legal grounds, after which it will be deleted.
If our legal grounds rely on your consent, you may revoke your consent at any time. Where you have exercised your right to withdraw your consent we may be required to keep your personal identifiable information for defined period in order for us to meet our legal obligations and defend ourselves in legal disputes under certain circumstances.
Links to third party sites
Your Rights as an individual under this Policy
Since we process your Personal Data you can exercise certain rights during specific circumstances.
In relation to your Personal data you may request to:
- Access your Personal Data (data subject access request)
- Rectify your Personal Data
- Erase your Personal Data
- Restrict the processing of your Personal Data
- Object to the processing of your Personal Data
- Withdraw your consent
All requests must be made in writing and be signed by you, and include information on name, address and, preferably, your e-mail address to verify your identity. Where the applicable law provides for an administrative fee for complying with such a request (including frivolous or excessive requests) such a fee may be charged by Lupi.
All valid requests will be dealt with in a prompt and proper manner and we will respond within no less than 30 days upon receiving your request.
To make your request, please contact email@example.com
If your request has been denied for the stated reasons, you may file a complaint to the local data protection authorities in the jurisdiction of the office in which the services are being provided.
Changes to this Notice
Lupi reserves the right to amend this policy from time to time. We expect most such changes to be minor, but there may be changes that are more significant. The date of the last modification is stated at the end of this document.
If you have any additional questions or wish to exercise your rights, please feel free to contact us any time at firstname.lastname@example.org
This policy was published on 6th may 2020