Privacy

1. Introduction

The professional studio LICCIARDELLO PER. IND. SEBASTIANO takes the user’s privacy seriously and undertakes to respect it. This privacy policy (“Privacy Policy”) describes the processing of personal data carried out by the professional studio Licciardello Per. Ind. Sebastiano through the website www.lsengineering.eu (Site), and the related commitments undertaken in this direction by the Studio. Licciardello Per. Ind. Sebastiano may process the personal data of the user when he visits the Website and uses the services and functionalities available on the Website. In the sections of the Website where the user’s personal data are collected, a specific information is normally published according to the art. 13⁄15 of the EU Reg. 2016⁄679. If required by the EU Reg. 2016⁄679 the user’s approval will be required before proceeding to the processing of his / her personal data. If the user provides personal data of third parties, he must ensure that the communication of the data to the professional studio Licciardello Per. Ind. Sebastiano and the subsequent processing for the purposes specified in the applicable privacy information complies with the EU Reg. 2016⁄679 and the applicable legislation.

2) Identification data of the owner, manager and Privacy Officer

Licciardello Sebastiano, Via Vardese n. 16 - 13878 Candelo (BI) - Italy, e-mail studio@lsengineering.eu

3) Type of data processed

The visit and consultation of the Site generally do not involve the collection and processing of personal data of the user, except for navigation data and cookies as specified below. In addition to the so-called “navigation data” (see below), personal data voluntarily provided by the user may be processed when the latter interacts with the functionality of the Website or requests to use the services offered on the Website. In compliance with the Privacy Policy, Licciardello Per. Ind. Sebastiano could also collect the user’s personal data from third parties in the implementation of his activities.

4) Cookies and browsing data

The site uses “cookies”. By using the Website, you approve the use of cookies in accordance with this Privacy Policy. Cookies are small files stored on the hard disk of the user’s computer. There are two macro-categories of cookies: technical cookies and profiling cookies. Technical cookies are necessary for the proper working of a website and to allow user navigation; without them the user may not be able to view the pages correctly or use some services.

Profiling cookies have the task of creating user profiles in order to send advertising messages according to the preferences expressed by the user during navigation. Cookies can also be classified as:

_ “session” cookies, which are deleted immediately when the browser is closed; _ “persistent” cookies, which remain in the browser for a certain period of time. They are used, for example, to recognize the device that connects to a site facilitating authentication operations for the user;

_ “own” cookies, generated and managed directly by the manager of the website on which the user is browsing;

 _ “third-party” cookies, generated and managed by other parties different from the manager of the website, on which the user is browsing.

5) Cookies used on the site

The Website uses the following types of cookies:

Own, session and persistent cookies, necessary to allow the navigation on the Site, for purposes of internal security and system administration. The Site may contain links to other sites (e.g. third party websites). Licciardello Per. Ind. Sebastiano does not make any access or control over cookies, web beacons and other user tracking technologies that could be used by third party sites that the user can access from the Site. Licciardello Per. Ind. Sebastiano does not carry out any control on contents and materials published by or obtained through third-party websites, nor on the relative methods of processing of the user’s personal data, and expressly disclaims any related liability for such eventualities. The user is required to verify the privacy policy of third party sites accessed through the Site and to inquire about the conditions applicable to the processing of his/her personal data. This Privacy Policy applies only to the Site as defined above.

6) How to disable cookies using the various browsers

Internet Explorer http://support.microsoft.com/kb/196955

Firefox http://support.mozilla.org/it/kb/Gestione%20dei%20cookie?redirectlocale=en-US&redirectslug=Cookies

Google Chrome https://support.google.com/chrome/answer/95647?hl=it

Opera http://www.opera.com/browser/tutorials/security/privacy/

Safari http://support.apple.com/kb/PH5042

Safari iOS (iPhone, iPad, iPod touch) http://support.apple.com/kb/HT1677?viewlocale=it_IT

Warning: some sections of the site are accessible only by enabling cookies; deactivating them, it is possible that the user has no longer the possibility to access to some content and cannot appreciate the features of our website fully. To learn more about managing cookies on mobile device browsers, refer to the specific user manual. By using the site without rejecting cookies and similar online technologies, users approve the use of such technologies on our part for the collection and processing of information.

7) Storage of personal data

Personal data are stored and processed through computer systems owned by the professional studio Licciardello Per. Ind. Sebastiano and managed by the professional studio Licciardello Per. Ind. Sebastiano or by third party technical service providers; for more details, please refer to the section “Scope of communication and accessibility of personal data” below. The data are processed exclusively by specifically authorized personnel, including personnel designated to carry out extraordinary maintenance operations.

8) Purposes and methods of data processing

The professional studio Licciardello Per. Ind. Sebastiano may process the user’s common and sensitive personal data for the following purposes: application by users of services and functionalities available on the Site, management of requests and reports from their users, sending of newsletters, management of applications received through the Website, etc.

Moreover, with the further and specific optional approval of the user, Licciardello Per. Ind. Sebastiano may process personal data for marketing purposes, i.e. to send promotional material and / or commercial communications relating to the studio’s services, to the addresses indicated, either through traditional methods and / or contact means (such as documents through the postal services, phone calls with operator, etc.) that automated (such as internet communications, fax, e-mail, SMS, applications for mobile devices such as smartphones and tablets -cd. APPS-, social network accounts – e.g. via Facebook or Twitter-, phone calls with automatic answering service, etc.).

Personal data are processed both in paper and electronic means and entered into the studio information system in full compliance with EU Reg. 2016⁄679, including security and confidentiality profiles, basing on principles of correctness and lawfulness of processing. In accordance with EU Reg. 2016⁄679 the data are kept and stored for 6 months.

9) Security and quality of personal data

Licciardello Per. Ind. Sebastiano undertakes to protect the security of the user’s personal data and complies with the security provisions of the applicable law in order to avoid data loss, illicit or illegal use of data and unauthorized access to the same, with particular reference to the Technical Specifications Guide concerning minimum security measures. In addition, the information systems and computer programs used by the professional studio Licciardello Per. Ind. Sebastiano are configured in such a way as to minimize the use of personal and identifying data; these data are processed only for the achievement of the specific purposes from time to time pursued. Licciardello Per. Ind. Sebastiano adopts procedures to promote the protection of users’ personal data; personal data are stored on secure servers located in places with safe and controlled access. The user can help the professional studio Licciardello Per. Ind. Sebastiano to update and keep correct his/her personal data communicating any changes related to the address, the qualification, contact information, etc. 10) Scope of communication and accessibility of personal data Your personal data may be communicated to:

• all the entities to whom the right of access to such data is recognized by virtue of regulatory provisions;

• to our collaborators, employees, as part of their duties;

• to all those natural and / or legal persons, public and / or private, when the communication is necessary or functional to the performance of our activities and in the manner and for the purposes illustrated above.

11) Nature of the provision of personal data

The provision of some personal data by the user is mandatory to allow the studio to manage communications, requests received by the user or to contact the user himself to respond to his request. The provision of personal data by the user for marketing purposes, as specified in the section “Purposes and methods of data processing” is optional, and the refusal to provide them will have no consequences. The approval granted for marketing purposes is intended to be extended to the sending of communications carried out through automated and traditional methods and / or contact means, as above mentioned.

12) Rights of the interested party

12.1 Article 15 (right of access), 16 (right of correction) of EU Reg. 2016⁄679

The interested party has the right to obtain confirmation, from the data controller, that it is or is not undergoing the processing of personal data concerning him and in this case, to obtain access to personal data and the following information:

a) the purposes of the processing;

b) the categories of personal data involved;

c) the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular if recipients of third Countries or international organizations;

d) the retention period of the personal data provided or, if not possible, the criteria used to determine this period;

e) the existence of the right of the interested party to request the data controller to modify or delete personal data or limit the processing of personal data concerning him or to oppose their treatment;

f) the right to lodge a complaint with a supervisory authority;

h) the existence of an automated decision-making process, including profiling and, at least in such cases, significant information on the logic used, as well as the importance and expected consequences of such processing for the data subject.

12.2 Right pursuant to art. 17 of EU Reg. 2016⁄679 - right to cancellation (“right to be forgotten”)

The interested party has the right to obtain from the data controller the deletion of personal data concerning him without undue delay, and the data controller is obliged to cancel the personal data without undue delay if one of the following reasons exists:

a) personal data are no longer necessary with respect to the purposes for which they were collected or otherwise processed;

b) the party involved revokes the approval on which the processing is based in accordance with Article 6 (1) (a) or Article 9 (2) (a) and whether there is no other legal basis for the processing;

c) the party involved opposes the processing pursuant to Article 21 (1) and there is no legitimate overriding reason to proceed with the processing, or opposes the processing pursuant to Article 21 (2);

d) personal data have been processed unlawfully;

e) personal data must be deleted to fulfill a legal obligation under Union or Member State law to which the controller is subject;

f) personal data have been collected in relation to the information society service offer referred to Article 8, paragraph 1 of EU Reg. 2016⁄679.

12.3 Right referred to art. 18 - Right of limitation of the treatment

The interested party has the right to obtain from the data controller the limitation of processing when one of the following hypotheses occurs:

a) the interested party disputes the accuracy of personal data for the period necessary for the data controller to verify the accuracy of such personal data;

b) the processing is illegal and the interested party opposes the cancellation of personal data and asks instead that its use is limited;

c) although the data controller no longer needs them for processing purposes, personal data are necessary for the interested party to verify, exercise or defend a right in courts;

d) the interested party has opposed the treatment pursuant to article 21, paragraph 1, Reg EU 2016⁄679 awaiting for the verification of the possible prevalence of the legitimate reasons of the data controller, with respect to the ones of the interested party.

12.4 Right pursuant to Article 20 - Right to data portability

The interested party has the right to receive, in a structured, commonly used and automatically readable form, the personal data concerning him / her provided to a data controller and has the right to transmit such data to another data controller without impediments from part of the data controller.

The interested party has the right to withdraw the consent to the processing of his/her personal data by sending a registered letter to the following address: Licciardello Per. Ind. Sebastiano, Via Vardese n. 16 - 13878 Candelo (BI) – Italy, accompanied by a photocopy of his identity document, with the following text: “revocation of consent to the processing of all my personal data”. At the end of this operation his/her personal data will be removed from the archives as soon as possible.

If the interested party would like to receive more information on the processing of his/her personal data, or to exercise the rights referred to paragraph no.7 above described, he/she can send a registered letter to the following address: Licciardello Per. Ind. Sebastiano, Via Vardese n. 16 - 13878 Candelo (BI) - Italy. Before providing or modifying any information, it could be necessary to verify his/her identity and answer to some questions.