Whistleblowing Documentation

ALL-28 - Whistleblowing - Informazioni sul trattamento dei dati personali.pdf

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ALL-29 - Whistleblowing - Segnalazione delle violazioni.pdf

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ALL-31 - Whistleblowing - Istruzioni per segnalazione delle violazioni.pdf

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CORSO FORMAZIONE WHISTLEBLOWING del 17.05.23.pdf

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Divisions

Company

Sede legale: Loc. Molino, 10 - 61026 Belforte all'Isauro (PU) Italy | Sede amministrativa: Via Lago del Conte, 30 - 61023 Pietrarubbia (PU) Italy

Tel. +39 0722 721352 - Fax +39 0722 721963 - Email info@lavorgommagroup.com

CF e PI: 01342930417 | Cap. Soc. 10.000,00 | Ufficio registro: Pesaro Urbino Rea: PS-177587 | Pec: amministrazione@pec.lavorgomma.com

Whistleblowing Documentation

INFORMATION ON THE TREATMENT OF PERSONAL DATA

of users who visit the website https://www.lavorgomma.it

in accordance with Article 13 of Regulation (EU) 2016/679

This privacy policy explains how we use the personal data of users who visit our website, accessible at https://www.lavorgomma.it.

This information does not apply to other websites, pages or online services accessible via hyperlinks that may be published on the Website but refer to resources external to this website.

For ‘off-site’ processing (e.g. customer/supplier management, contracts, accounting, internal HR), specific privacy policies apply.

1. WHO IS THE DATA CONTROLLER?

The data controller is Lavorgomma S.r.l. Unipersonale (01342930417), with registered office in Loc. Molino n. 10 (61026), Belforte all'Isauro (PU) Tel. 0722/721352 - Fax 0722/721963 email: info@lavorgommagroup.com - pec: amministrazione@pec.lavorgomma.com.

2. THE DATA WE COLLECT

2.1. Browsing data (logs and security).

During navigation and use of the site, technical data is collected (e.g. IP addresses, requested resource URIs, request time, user agent, technical logs). This data is necessary for the functioning and protection of the site and is not collected to identify the user, but could allow identification through processing and association with third-party data (typical case: abuse investigations).

2.2. Data provided by the user via the ‘Contact’ form and information requests

The website provides contact forms (present in several sections) through which the user can send a request (e.g. name/surname or company, email, telephone number, message text and other data that may be entered by the user).

2.3. Cookies and tracking tools.

The website uses cookies and/or similar tools. Details (categories, suppliers, duration and purposes) are described in the Cookie Policy and in the cookie preferences management panel.

2.4. Links to third-party websites/group websites.

Some sections of the website contain links to other websites (e.g. group or partner websites). When the user clicks on and visits third-party websites, these operate as independent data controllers and their own privacy and cookie policies apply.

3. PURPOSE OF PROCESSING, LEGAL BASIS AND NATURE OF PROVISION.

a) To enable browsing and ensure security and continuity of service.

Purpose: technical operation of the website, infrastructure management, prevention of abuse/fraud, IT security, diagnosis of malfunctions.

Legal basis: legitimate interest of the Data Controller and, where applicable, compliance with legal obligations.

Provision: necessary, otherwise correct use/security cannot be guaranteed.

b) Management of requests sent by the user via contact forms, email, telephone.

Purpose: responding to requests, providing information, managing requests for quotes and commercial contacts requested by the user.

Legal basis: execution of pre-contractual measures taken at the request of the data subject, and/or legitimate interest in managing communications.

Provision: necessary in order to receive a response; failure to provide data will prevent the request from being managed.

c) Protection of the rights of the Data Controller

Purpose: the User's Personal Data may be used by the Data Controller in a legal proceeding or in the preparatory stages of its possible establishment for the defence against abuse in the use of our website or related Services by the User.

Legal basis: legitimate interest of the Data Controller.

Conferral: necessary.

4. METHOD OF PROCESSING

The processing is carried out using manual and computerised tools, in compliance with the principles of lawfulness, fairness, transparency, minimisation, accuracy, storage limitation and integrity/confidentiality.

Appropriate technical and organisational security measures are adopted to ensure the integrity, confidentiality and availability of the data.

5. HOW LONG WE STORE DATA

The data being processed will be stored for a limited period of time depending on the purpose for which it was collected.

• Browsing data and security logs: for a period proportionate to the purposes and in any case no longer than 12 months, unless necessary for the investigation of crimes/abuses

• Requests via form/email: for the time necessary to manage the request and subsequently for 24 months, unless further obligations or disputes arise.

• Cookies as indicated in the Cookie Policy and in the preferences panel

At the end of this period, the data is irreversibly deleted or anonymised.

6. DATA RECIPIENTS

The recipients of the data collected through browsing our website are:

• collaborators and employees specifically authorised and trained by the Data Controller within the scope of their respective competences and duties;

• service companies within our group;

• suppliers of services offered through the Website or connected to its operation, acting as data processors (e.g. hosting/services);

• companies or consultants responsible for the installation, maintenance, updating and, in general, management of the Website's hardware and software, acting as data processors (e.g. web agencies);

Personal data is not disclosed, transferred or otherwise transferred to third parties for purposes unrelated to those described above.

This is without prejudice to any communication of data at the request of the Judicial Authority or Public Security, in the manner and in the cases provided for by law.

7. TRANSFER OF DATA TO THIRD COUNTRIES

Some suppliers may process data outside the EEA, in which case the transfer will be carried out in compliance with the GDPR (e.g. adequacy decisions or Standard Contractual Clauses and additional measures where necessary).

8. RIGHTS OF DATA SUBJECTS

We want to ensure that you are fully aware of your rights regarding the protection of your personal data.

Data subjects have the right to obtain from the data controller, in the cases provided for:

access to their personal data, i.e. to request copies of their personal data;

rectification, i.e. the correction of any information they consider inaccurate;

the erasure of personal data.

restriction of processing in the cases indicated in Article 18 of the GDPR;

to object to processing for marketing and profiling purposes;

For processing based on consent, you may withdraw your consent at any time without affecting the lawfulness of processing based on consent prior to withdrawal.

The relevant application form is available at the following link https://www.garanteprivacy.it/home/modulistica-e-servizi-online, you may send it to the data controller at the following addresses:

E-mail info@lavorgommagroup.com

Pec amministrazione@pec.lavorgomma.com

9. RIGHT TO COMPLAIN

Data subjects who believe that the processing of their personal data through this website violates the provisions of the Regulation have the right to lodge a complaint with the Data Protection Authority, as provided for in Article 77 of the Regulation, or to take appropriate legal action (Article 79 of the Regulation).

To lodge a complaint, please follow the instructions at the following link

https://www.garanteprivacy.it/home/modulistica-e-servizi-online

10. CHANGES TO OUR PRIVACY POLICY

Our company regularly reviews its privacy policy and posts any updates on this web page.

Specific information will be provided on the pages of the Website in relation to particular services or processing of the Data provided.

Last updated on 2026.01.22

COOKIE POLICY

The website https://www.lavorgomma.it uses ‘cookies’ to ensure that all users have the most pleasant and efficient browsing experience possible.

What are cookies?

Cookies are small text files that visited websites send to the user's terminal, where they are stored before being retransmitted to the same sites on the next visit.

Third-party cookies, on the other hand, are set by a website other than the one the user is visiting. This is because each website may contain elements (images, maps, sounds, specific links to web pages of other domains, etc.) that reside on servers other than that of the website visited.

Types of cookies

Type of cookie	Purpose	Legal basis	Duration
Technical/necessary cookies	They enable the Website to function and the requested services to be used (e.g. session management, shopping cart, language preferences).	Performance of a contract (Art. 6.1.bGDPR)	Session or permanent
Anonymised analytical cookies	They collect aggregated and anonymous information about how the Website is used, in order to improve its performance.	Legitimate interest (if anonymised) or user consent (if not anonymised)	As specified by the supplier
Third-party analytical cookies	They collect aggregate statistics on visits.	User consent (Art. 6.1.a GDPR)	As indicated by the supplier
Profiling/marketing cookies	They allow user browsing to be tracked and personalised advertising to be sent (e.g. Facebook Pixel, Google Ads, Klaviyo/Mailchimp).	User consent (Art. 6.1.a GDPR)	As indicated by the supplier

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