Lugo Terminal Privacy Policy.

Lugo Terminal Privacy Policy.
Welcome to our website, www.lugoterminal.com
Please read our Privacy Policy carefully; it applies every time you access the website and decide to navigate it and use its services.
Information statement pursuant to art. 13 of Regulation (EU) 679/16, (It.) Legislative Decree 101/2018 as amended by law.

Data controller
The controller of the data that have been collected through this website is Lugo Terminal S.p.A.; the company shall decide independently on the purposes and methods of processing, as well as on the security procedures to be applied to guarantee the confidentiality, integrity and availability of the data.

Purposes of the processing
Lugo Terminal S.p.A. shall process your data in order to provide the service requested or to execute the contractual relationship, be it existing or to be established.
Lugo Terminal S.p.A. shall process your data to send advertising communications only in the case you asked for them or you have explicitly authorized us to do so.

Mandatory nature of the provision of data
The provision of your data to Lugo Terminal S.p.A. is mandatory to allow Lugo Terminal S.p.A. to perform the service requested, point A.

Duration of the processing
Your data will be stored for the time needed to attend to your contact request, point A.
For the purposes under point B, your data will be stored in our database until such time as you might withdraw your consent.

Mandatory nature of consent and disclosure of the data
Any refusal on your part to disclose to Lugo Terminal S.p.A. some of your data marked as mandatory, point A, for the contact request, which, in this case, include but are not limited to e-mail address, mobile phone or landline number, shall make the pursuit of the main purpose of the specific collection impossible.

Your rights
You shall always have the right to obtain from Lugo Terminal S.p.A. confirmation of the processing or otherwise of personal data concerning you, even if they have not yet been recorded, and their communication in an intelligible form.
You shall also have the right to obtain from Lugo Terminal S.p.A. information regarding the origin of your personal data; the purposes and methods of processing of your personal data; the logic applied in case of processing performed with the help of electronic tools; the identification details of the controller and of the processors; the indication of the subjects or categories of subjects to whom the personal data may be disclosed or who may become aware thereof, for example in their capacity as data processors.
In addition, you shall always have the right, pursuant to and for the effects of articles 15 et seq. of Regulation (EU) 679/16, to obtain:
a) the update, rectification and integration of your personal data;
b) the erasure, the anonymisation or the restriction of your personal data whose processing violates the law, including those whose storage is not necessary for the purposes for which the data have been collected or subsequently processed;
c) the proof that the operations under letters a) and b) were communicated, also with regard to their content, to those to whom the data were disclosed or disseminated, except where this is impossible or entails a use of means manifestly disproportionate to the right protected.
However, you shall have the right to object, in whole or in part:
a) for legitimate reasons, to the processing of the personal data concerning you, even if they are pertinent to the purpose of the collection;
b) to the processing of personal data concerning you for the purpose of sending advertising or
marketing material.
You may freely exercise your rights at any time, with a written request addressed to Lugo Terminal S.p.A. – to its postal address or to the e-mail address privacy@lugoterminal.com; we will reply to your request promptly.
To guarantee that your personal data are always correct, updated, pertinent and complete, please inform us – using the address privacy@lugoterminal.com – of any changes thereto.

Decree of the Italian Data Protection Authority of 19 June 2008, on the simplification of measures concerning processing operations for administrative and accounting purposes
We would also like to point out that the Italian Data Protection Authority has, by decree, allowed Lugo Terminal S.p.A. to use your postal address to send you – as well as administrative and accounting documents – advertising relating to products similar to those that you have purchased in the past, on the condition that you do not object to such use of the postal address provided.
This is the minimum information that Lugo Terminal S.p.A. is obliged to provide you with. For more details on the processing of your personal data by Lugo Terminal S.p.A. please read this Privacy Policy in its entirety.

The principles of our privacy policy
Our privacy policy is based on the following principles:
1. the data shall be processed solely for the purposes and by the means described in the information statement that is provided upon their collection;
2. the data will be used for additional purposes to those for which the data were specifically provided only with the user’s express consent;
3. the data will be made available to third-party companies only for purposes that are essential for the provision of the service requested and in the context of an appointment as data processor; the data will not be disclosed, sold or transferred to third parties so that they may be processed by the latter without first informing the users, who must have granted their consent;
4. we will provide a reply to requests for erasure, amendment, integration of the data provided, objection to the processing of the data for sending commercial and advertising communications;
5. we will ensure that the data are managed fairly and lawfully, safeguarding the privacy of users, and we will apply suitable security measures for the protection of the confidentiality, integrity and availability of the data provided.

How and why we process your personal data
The processing operations on the personal data are performed mainly by electronic and telematic means by Lugo Terminal S.p.A. and by other subjects who, duly selected based on reliability and skill, perform operations that are fundamental for the pursuit of the purposes that are strictly related to the use of the website and of its services (see below, under “Subjects who may process your personal data”).
The specific purposes for which the data shall be processed are summarised, in each case, in the information statement pursuant to art. 13 of Regulation (EU) 679/16, which is presented to the user when he/she releases personal data.
In general, the data shall be processed for the provision of the following services that are available by accessing our website:
1. registration for specific and additional services, such as our newsletter and other similar services that provide information on our activities;
2. management of your requests: technical, commercial, on the progress of your orders and requests for information in general;
3. contact with our contact persons;
While processing data that may, directly or indirectly, identify you, we try to comply with the principle of strict necessity.
For this reason we have configured the website in such a way as to minimise the use of your personal data: therefore, your data will not be processed if the purposes pursued in individual cases may be achieved with the use of anonymous data (e.g. in market surveys aiming to improve services) or by other means that allow the data subject to be identified only in case of need or on request of the authorities and law enforcement (e.g. in the case of data related to traffic and your dwell time on the website or your IP address).
In certain cases, as expressly mentioned in the information statement, your data will be subject – with your express consent – to processing operations aiming to create profiles based on your preferences and purchases. Lugo Terminal S.p.A. may use your data to send you advertisements regarding its products and services only with your consent.
Your data will be disclosed to third parties only with your express consent, except in cases where the disclosure is mandatory by law or is necessary for purposes set forth by law, the pursuit of which does not require the consent of the data subject; in such cases, the data may be made available to third parties that will process them autonomously and solely for the aforementioned purposes (e.g. in case of a request by law enforcement or the courts or other competent bodies, or to fulfil obligations that derive from the contract that we have stipulated with you).
Any purpose of processing other than the specific one for which you provided your personal data will be identified in the information statement and will be pursued by Lugo Terminal S.p.A. only once the company has obtained your express consent.
Furthermore, there are processing operations for which the regulations envisage the exclusion of consent: for example, we would like to inform you that Lugo Terminal S.p.A. may process your personal data without obtaining your consent when such processing is necessary for the fulfilment of a legal obligation or when it is necessary for the fulfilment of obligations towards you undertaken by virtue of a contract (such as in case you have purchased products or have asked to take advantage of specific services through our website).
Lastly, we would like to inform you that your personal data will not be transferred abroad, to non-EU countries that do not guarantee adequate data protection levels. Should such transfer be required for us to provide you with the services or to enter into a contract for the purchase of products, we would like to assure you that the transfer of your personal data to non-EU countries which do not guarantee an adequate level of protection will be carried out only following stipulation between Lugo Terminal S.p.A. and said subjects of specific contracts in compliance with the law and the applicable regulations.

Subjects who may process your personal data
Lugo Terminal S.p.A. has decided to use third parties for the processing of your personal data for specific activities. The third parties who perform these operations have been suitably selected and are experienced, skilful and reliable, while offering suitable guarantees regarding full compliance with the applicable provisions on processing, including data security.
These third parties have been appointed “data processors” for this purpose (by the Controller) and shall perform their activity in accordance with the instructions they have received from Lugo Terminal S.p.A. and under its control. We shall periodically check that the processors have duly performed the tasks with which they have been entrusted and that they continue to provide suitable guarantees regarding full compliance with the provisions on personal data protection.
Your data shall also be processed by our employees assigned to specific services; the categories of employees who shall perform these activities depend on the purpose for which the data were provided.