VERSION 3.0 (JULY 21, 2020)
Laservall SpA with registered office in P-4/2, 2ND FLOOR , 1ST CROSS, ” A ” MAIN ROAD , PEENYA 3RD STAGE , PEENYA INDUSTRIAL ESTATE , BANGALORE – 560058, INDIA (hereafter “Laservall“) is constantly committed to protecting the online privacy of its users. This document was drafted pursuant to art. 13 of EU Regulation 2016/679 (hereafter: “Regulations“) in order to let you know our privacy policy, to understand how your personal information is handled when you use our site (hereafter collectively “Site“) and, where appropriate, to expressly and consciously consent to the processing of your personal data. The information and data supplied by you or otherwise acquired as part of the use of services for information request, technical assistance, promotion and sending of commercial newsletters, qualification of the network of Laservall partners, – for example: access to the reserved area of the site, hereafter “Services“-, will be processed in compliance with the provisions of the Regulations and the confidentiality obligations that inspire Laservall’s activities.
According to the rules of the Regulations, the processing carried out by Laservall will be based on the principles of lawfulness, correctness, transparency, purpose and retention limitations, data minimisation, accuracy, integrity and confidentiality.
TABLE OF CONTENTS
- 1. Data Controller
- 2. The personal data subject to processing
- a. Web browsing data
- b. Special categories of personal data
- c. Data provided voluntarily by the interested party
- d. Cookies
- 3. Purpose of data processing
- 4. Legal basis and mandatory or optional nature of the processing
- 5. Recipient of personal data
- 6. Transfers of personal data
- 7. Conservation of personal data
- 8. Rights of the interested party
- 9. Modifications
1. DATA CONTROLLER
The holder of the processing carried out through the Site is Laservall as defined above. For any information concerning the processing of personal data by Laservall, including the list of data processors who process data, you can write to the following address: rajeev@laservall.com
2. THE PERSONAL DATA SUBJECT TO PROCESSING
Following the navigation of the Site, we inform you that Laservall will process personal data that may consist of an identifier such as the name, an identification number, an online ID or one or more elements characteristic of your physical, physiological, psychological, economic, cultural or social identity suitable to make the interested party identified or identifiable (hereafter only “Personal Data “).
The Personal Data processed through the Site are as follows:
A. NAVIGATION DATA
During their normal operation, the computer systems and software procedures used to operate this Site acquire certain personal data whose transmission is implicit in the use of internet communication protocols. This information is not collected with the intention of linking it to an identifiable user, but, by its own very nature, could lead to the identification of users by processing it in association with data held by third parties. This category of data includes IP addresses or domain names of computers used by persons who connect to the site, the URI (Uniform Resource Identifier) of requested resources, the time of request, the method used to submit the request to the server, the size of the file received in reply, the numerical code indicating the status of the reply given by the server (successful, error, etc.) and other parameters regarding the user’s operating system and computer environment. These data are only used to obtain anonymous statistical information about website usage and to check its correct functioning; they are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the website: currently, except for this possibility, data concerning web contacts are not kept for more than seven days.
B. SPECIAL CATEGORIES OF PERSONAL DATA
In the use of the “Work with us/Job Offers” section of the Site, personal data may be entered in the category of Personal Data referred to in art. 9 of the Regulations, the “data […] suitable to reveal the racial or ethnic origin, political opinions, religious or philosophical convictions, or union membership, as well as to process genetic data, biometric data intended to uniquely identify a natural person, data relating to the health or sexual life or sexual orientation of the person”.We invite you not to publish these data unless strictly necessary. In fact, we remind you that in the event of the transmission of special categories of Personal Data, but in the absence of specific manifestation of consent to process such data (eventuality that obviously allows you to send a curriculum vitae), Laservall cannot be held responsible for any claim, nor can receive any kind of complaints, because in this case the processing will be allowed as the subject data were made manifestly public by the interested party, in accordance with art. 9(1)(e) of the Regulations.However, we specify the importance, as already indicated above – of declaring your explicit consent to the processing of the special categories of Personal Data, where you decide to share such information.
We also inform you that, for the purposes of selection, Laservall may analyse the professional social profiles you have freely made available on the Internet (eg LinkedIn).
C. DATA PROVIDED VOLUNTARILY BY THE INTERESTED PARTY
In the use of some Site Services, Personal Data may be processed by third parties sent by you to Laservall. With respect to these hypotheses, you are the independent data controller, assuming all the legal obligations and responsibilities.In this sense, you are conferred with the widest indemnity with respect to any objection, claim, request for compensation for damage from processing, etc. that should reach the owner from third parties whose personal data have been processed through your spontaneous submission in violation of the rules on the protection of applicable personal data. In any case, if you provide or otherwise process Personal Data of third parties in the use of the Site, you guarantee from now on – assuming all related liability – that this particular hypothesis of processing is based on an appropriate legal basis pursuant to art. 6 of the Regulations that legitimises the processing of the information in question.
D. COOKIES
Definitions, characteristics and application of the legislation
Cookies are small text files that the sites visited by the user send and record on their personal computer or any other device, even mobile, to then be re-transmitted to the same sites at the next visit. Thanks to cookies, a site remembers the user’s actions and preferences (such as login data, the chosen language, font size, other display settings, etc.) so that they do not have to be re-indicated when the user returns to visit said site or browse from one page to another. Cookies, therefore, are used to perform computer authentication, monitoring sessions and storing information regarding the activities of users accessing a site, and may also contain a unique identification code that allows for tracking the user’s navigation within the site itself for statistical or advertising purposes. During navigation on a site, the user can also receive, on his/her computer or mobile device, cookies from websites or web servers other than the one he/she is visiting (so-called “third-party” cookies). Some operations may not be able to be performed without the use of cookies, which in some cases are therefore technically necessary for the functioning of said site.
There are various types of cookies, depending on their characteristics and functions, and these can remain in the user’s computer or mobile device for different periods of time: so-called session cookies, which are automatically deleted when the browser is closed; so-called persistent cookies, which remain on the user’s equipment until a predetermined deadline.
According to the legislation in force in Italy, the user’s express consent is not always required for the use of cookies. In particular, “technical cookies”, namely those used for the sole purpose of transmitting a communication over an electronic communications network, or to the extent strictly necessary to provide a service explicitly requested by the user, do not require such consent. In other words, these are cookies that are essential for the operation of the site or are necessary to perform activities requested by the user.
Among the technical cookies, which do not require express consent for their use, the Italian Data Protection Authority (see Provision Identification of the simplified procedures for the information and the acquisition of consent for the use of cookies 8 May 2014 and subsequent clarifications, hereafter only “Provision“) also includes:
- “analytics cookies” where used directly by the site operator to collect information, in aggregate form, on the number of users and how they visit the site,
- browsing or session cookies (to authenticate the user),
- functional cookies, that allow the user to browse based on a set of selected criteria (for example, the language, the products selected for purchase) in order to improve the service provided to the user.
For “profiling cookies”, on the other hand, namely those aimed at creating profiles related to the user and used to send advertising messages in line with the preferences expressed by the same in the context of surfing the net, a prior consent of the user is required.
Types of cookies used by the Site and the possibility of (de)selection
The Site uses the following cookies that can be deselected, except for third-party cookies for which they must refer directly to the relative methods of selection and deselection of the respective cookies, indicated by means of links:
- Technical cookies for navigation or session and which are strictly necessary for the operation of the site or to allow it to use the content and services requested.
- Functionality cookies, used to activate specific functions of the Site and a series of selected criteria (for example, the language, the products selected for purchase) in order to improve the service provided.
ATTENTION: by disabling technical and/or functional cookies, the Site may not be available or certain services or certain functions of the Site may be unavailable or may not work properly, and the user may be forced to change or manually enter certain information or preferences every time they visit the Site.
- Third-party cookies, ie cookies of sites or web servers other than those of Laservall, used for the purposes of these third parties. It should be noted that these third parties, listed below with the related links to privacy policies, are typically independent data controllers collected through the cookies they serve; therefore, the user must refer to their policies regarding the processing of personal data, information and consent forms (selection and deselection of the respective cookies), as specified in the aforementioned provision. For completeness, please note that Laservall does its utmost to track cookies on its Site. These are updated regularly in the table below, where we give transparency on the cookies directly sent by Laservall and their purpose.Regarding the third parties that send cookies through our site, we provide below the links to the respective privacy policies: to these third parties we demand, as already specified, the responsibility to provide the information and collect your consent, as provided by the Provision. This responsibility is to be referred not only to cookies that third parties send directly, but also to any additional cookies that are sent via our site by virtue of the use of services that the third parties themselves enjoy. In fact, with respect to these cookies, sent by service providers of the aforementioned third parties, Laservall does not have the possibility to exercise any control and does not know its characteristics or purposes.
Below are links to information on third-party cookies:
- Google: https://policies.google.com/technologies/partner-sites
- Google Adwords: https://policies.google.com/technologies/cookies
- Facebook: https://www.facebook.com/policies/cookies/
- Bing: https://privacy.microsoft.com/en-en/privacystatement
- Hotjar: https://help.hotjar.com/hc/en-us/articles/115011789248-Hotjar-Cookies
In detail, the cookies sent by Laservall through the site are shown below:
Cookies on the Site (SEE PDF LIST ATTACHED “Cookie_www.Laservall.com“)
COOKIE SETTINGS
You can block or delete (in whole or in part) technical and functional cookies through the specific functions of your browser.We inform you, however, that not allowing technical cookies may make it impossible to use the site, view the contents and take advantage of the related services. Inhibiting cookies of functionality could mean that some services or certain functions of the Site are not available or do not work properly and the user may be forced to change or manually enter some information or preferences each time they visit the Site.
The choices made in reference to cookies on the Site will be in turn registered in a special cookie. This cookie may, however, in some circumstances not work properly: in such cases, we advise you to delete unwanted cookies and to inhibit their use through the functionality of your browsers.
Your preferences regarding cookies will be reset if you use different devices or browsers to access the site.
How to view and modify cookies through the Browser
You can block or delete (in whole or in part) technical and functional cookies through the specific functions of your browser. For more information on how to set preferences on the use of cookies through your navigation browser, you may consult the instructions:
3. PURPOSE OF DATA PROCESSING
The processing we intend to carry out, with your specific consent where necessary, has the following purposes:
a) Registration and access to reserved area of the Site | Contractual obligationart. 6.1(b) GDPR | We may process Personal Data in order to register You to the reserved area of the Site and to enable you to log in.We may also process Personal Data to send You important information regarding the status of your account (for example if some of the services You are registered to are about to expire or if Your account is about to be closed according to the terms and conditions of the service You accepted). |
b) Support and Customer Care | Contractual obligationart. 6.1(b) GDPR | We may process Personal Data to provide You with the information about our products, services, documents and to respond to Your enquiries and complaints. |
c) Discussion board | Contractual obligationart. 6.1(b) GDPR | We may process Personal Data to allow You to take part in the discussions in our board. |
d) Recruiting | – Contractual obligationart. 6.1(b) GDPR – Legitimate interestart. 6.1(f) GDPR | We may process Personal Data to analyse the CVs and recontact the candidates who submitted their application through the “Work with us” section.We may also analyse the professional social profiles freely available on the Internet as per section 2.b in order to to verify any risks on the suitability of the candidate to cover the specific open position. |
e) WebSentinel™ Predict | Contractual obligationart. 6.1(b) GDPR | We may process Personal Data to allow You to join “WebSentinel™ Predict”, the Laservall webservice which offers the possibility for the registered enterprises users to monitor the status and the performance of the Laservall products and, to the extent it is necessary, requesting their replacement. Within this service, the Regulations shall apply solely for the processing of personal data related to the registered enterprises users as deemed necessary for the access to the “WebSentinel™ Predict” (e.g. name, surname, email, pwd). |
f) Participation in contests and/or promotional initiatives of Laservall | Contractual obligationart. 6.1(b) GDPR | We may process Personal Data to allow You to take part in our contests. |
g) Newsletter, marketing | Consentart. 6.1(a) GDPR | We may process Personal Data to send You newsletters, offers and other marketing communications through automated tools (SMS, MMS, email, push notifications) and non‐automated tools (paper mail, telephone with operator) to keep you up to date with our news, products, services and events that may be of interest.You always have the right to amend Your marketing preferences at any time.In the case of direct marketing sent by electronic communications You shall be given an easy way of opting out (or unsubscribing) from any such communications. |
h) Communication to Business Partners for marketing purposes | Consentart. 6.1(a) GDPR | We may share personal data with our trusted partners to send You marketing communications through automated tools (SMS, MMS, email, push notifications, fax) and non‐automated tools (paper mail, telephone with operator).You have the right to amend your marketing preferences at any time. |
i) Administrative and tax purposes | Legal obligationart. 6.1(c) GDPR | We may process your Personal Data to fulfill any legal, accounting, administrative and tax obligation directly related to the business of Laservall. |
4. LEGAL BASIS AND MANDATORY OR OPTIONAL NATURE OF THE PROCESSING
The provision of Personal Data for the purposes set out in Section 3 (a-b-c-d-e-f) is optional, but failure to provide it would make it impossible to active the Services provided by the Site.
The provision of Personal for the purposes set out in Section 3 (g-h) is optional; failure to provide consent for these purposes will not affect the use of the Services.
The provision of Personal for the purposes set out in Section 3 (i) and the processing is mandatory to fulfill a legal obligation which Laservall is subject.
5. RECIPIENT OF PERSONAL DATA
Your Personal Data may be shared, for the purposes referred to in Section 3 above, with:
a. Subjects that typically act as data controllers, that is: i) persons, companies or professional firms that provide Laservall assistance and advice in accounting, administrative, legal, tax, financial and credit recovery matters relating to the provision of the Services; ii) subjects with whom it is necessary to interact for the provision of the Services (for example hosting provider) or iii) subjects delegated to perform technical maintenance activities (including maintenance of network equipment and electronic communications networks); (collectively “Recipients“);
b. Subjects, bodies or authorities to whom it is mandatory to communicate your personal data in accordance with the provisions of law or orders of the authorities;
c. Persons authorised by Laservall to process Personal Data necessary to carry out activities strictly related to the provision of the Services, whether they are committed to confidentiality or have an adequate legal obligation of confidentiality, as well as employees of other companies of the group (eg employees of Laservall Srl).
d. Laservall’s authorized distributors and reseller belonging to the Laservall channel partner program, for their commercial and marketing initiatives, through automated tools (SMS, MMS, e-mail, push notifications) and non-automated tools (paper mail, telephone with operator).
Some of your Personal Data may eventually be disseminated via publication on the Site for the purposes set out in Section 3 (g).
6. TRANSFERS OF PERSONAL DATA
Some of your Personal Data are shared with Recipients that could be located outside the European Economic Area.Laservall ensures that the processing of your Personal Data by these Recipients takes place in compliance with the Regulations. Indeed, transfers can be based on an adequacy decision, on the Standard Contractual Clauses approved by the European Commission or on another appropriate legal basis.Further information is available at Laservall by writing to the following address: rajeev@laservall.com
7. CONSERVATION OF DATA
Personal Data processed for the purposes set out in section 3(a-b) will be kept for the time strictly necessary to achieve those same purposes.In any case, since this is processing carried out for the provision of Services, Laservall will process the Personal Data up to the time allowed by Italian law to protect its own interests (Article 2946 of the Italian Civil Code). With regard to the CVs transmitted through the “Work with us” form referred to in section 3.c, Personal Data will be kept as long as the position for which the CV was sent is available or, in the case of a spontaneous application, up to 1 year.The possibility for Laservall to contact the candidate shortly before the deadline indicated to request an extension of this retention period is reserved.
Personal Data processed for the purposes set out in section 3.d will be kept until the time required by the specific obligation or applicable law.
Further information about the data retention period and the criteria used to determine this period can be requested by writing to Laservall at the following address: rajeev@laservall.com
8. RIGHTS OF INTERESTED PARTIES
Pursuant to articles 15 and following of the Regulations, you have the right to ask Laservall, at any time, for access to your Personal Data, to rectify or cancel them or to oppose their processing, have the right to request the limitation of the processing in the cases foreseen by art.18 of the Regulations, and to obtain them in a structured, commonly-used format which can be read by automated data concerning them, in the cases provided for by art.20 of the Regulations.
Requests must be sent in writing to Laservall at the following address:Laservall Technosolutions Private Ltd. P-4/2, 2ND FLOOR , 1ST CROSS, ” A ” MAIN ROAD , PEENYA 3RD STAGE , PEENYA INDUSTRIAL ESTATE , BANGALORE – 560058.
In any case, you are always entitled to submit a complaint to the competent Supervisory Authority (Guarantor for the Protection of Personal Data), pursuant to art.77 of the Regulations, if you believe that the processing of your Personal Data is contrary to the law in force.
9. MODIFICATIONS
This privacy policy is effective from 21 of July, 2020. Laservall reserves the right to modify or simply update its content, in part or completely, also due to changes in the applicable legislation. Laservall 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 Site. Laservall therefore invites you to regularly visit this section to be aware of the most recent and updated version of the privacy policy in order to be always updated on the data collected and on the use made of them by Laservall.