Privacy Policy

Privacy Statement for the processing of Data

This privacy statement sets out the details concerning the processing of personal data collected through the website https://www.twinkly.com/ (the “Website”).

Data controller

The data controller is LEDWORKS S.r.l., with registered office in Via Calabiana 6, 20139 Milan, Tax Code and VAT code 09521280967 (hereinafter the “Controller”).

 

Collection of Data

Data provided by the users

Certain areas of the Website require the users to provide their personal data (the “Data”): in particular, we refer to the section “SUBSCRIBE to our newsletter” and to the section “Support” of the Website. The provision of Data takes place on a voluntary basis: if the users do not provide their Data, they will be able in any case to browse the Website without benefitting from these services.

The users are invited not to provide the Controller with third parties’ personal data, unless the provision is necessary (e.g., the user does not have a personal e-mail address): in this event, we remind the user that she/he has to fulfill all the duties provided for by the laws applicable to the processing of personal data and, in particular, she/he has to inform said third parties’ with regard to the provision of their personal data.

Data automatically collected through the Website

Whenever the users have access to the Website, our systems automatically collect and analyze the access data (e.g. the IP address of your provider, information concerning the browser, website from which the users browse our Website, date, hour and browsing duration). The collected information does not require any action from the users.

 

Purposes, legal basis for the data processing and storage period

Sign up for the newsletter service

The Data provided by filling in the form to sign up for the newsletter service shall be processed to allow the users to benefit from such service and therefore to receive the newsletter.

For the same purpose, the Data shall be notified to the company The Rocket Science Group LLC, having registered seat in 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, Georgia 30308, the supplier of the newsletter service called “MailChimp”, which is included among the list of companies set out by the Privacy Shield, the agreement governing the transfer of data from the European Union to the US. Said company will process the Data as data processor, pursuant to the data processing agreement executed with the Controller.

The provision of Data is optional: any refusal will prevent the Controller from sending the newsletter to the users.

The legal basis of such processing lies in the need to execute the data subject’s specific request.

The users may anyhow cancel their subscription to the newsletter service at any time, by following the procedure indicated in each newsletter or by sending a specific notice to the Controller, to the addresses listed in the section “Users’ rights”, expressing their will to unsubscribe from such newsletter service and to obtain the erasure of the data collected by the Controller.

The Data shall be processed for a period not greater than 24 months after the subscription to the newsletter service. With one month’s notice we will ask the users if they wish to continue to receive the newsletters: in case of refusal, the Data will be canceled; in case of consent, they will be kept and processed for additional 24 months.

Sign up for the customer care service

The Data provided by filling in the form to sign up in section “Support” shall be processed to allow the users to benefit from such service and therefore to raise support tickets and track their status, with regard to the products marketed by the Controller.

For the same purpose, the Data shall be notified to the company Freshworks, Inc., having registered seat in 1250 Bayhill Drive, Suite 315, San Bruno, 94066 California, the supplier of the customer care software called “Freshdesk”, which is included among the list of companies set out by the Privacy Shield, the agreement governing the transfer of data from the European Union to the US. Said company will process the Data as data processor, pursuant to the data processing agreement executed with the Controller.

The provision of Data is necessary: any refusal will prevent the Controller from providing the users with the requested support.

The legal basis of such processing lies in the need to execute the data subject’s specific request.

The Data shall be processed for a period not greater than 30 days after the users raise said support tickets.

Recipients of Data

Other recipients of Data shall be the Controller’s employees, duly identified as persons authorized to the processing (by way of example, the operators working in the Controller’s sales, marketing and support office).

Transfer of Data to third countries

To the extent necessary for the purposes of the processing set out above, the Data shall be transferred to the United States.

The transfer of Data shall take place pursuant to the Commission implementing decision (EU) no. 2016/1250 of 12 July 2016, according to which the Commission considered that the United States ensures an adequate level of protection for personal data transferred from the Union to organizations in the United States under the EU-U.S. Privacy Shield.

Users’ rights

The users can:

  1. obtain access to the Data;
  2. obtain the rectification or cancellation or, where applicable, the limitation on their processing;
  3. where applicable, receive the personal data provided to the Controller in a structured, commonly used and machine-readable format, in addition to sending it to another data controller without any hindrance by the Controller;
  4. lodge a complaint with a supervisory authority.

To exercise your own rights referred to in letters a. -c. above, the users can contact the Controller at the following addresses:

  • by e-mail, at the address: info@ledworks.io
  • by post, at the address: Via Calabiana 6, 20139 Milan – Italy

 

Privacy statement updated on [21/08/2018].