Privacy Policy

Pursuant to Legislative Decree 30 June 2003, n. 196 and following (“Privacy Code“) and the European Regulation 2016/679 (“Privacy Regulation“), Ledworks S.r.l. intends to inform you and all users and / or visitors to the web site https://twinkly.com (respectively, the “Users” and the “Website“), regarding the use of personal data, log files and cookies collected through the Website.

1. Data Controller, Data Processors and Data Protection Officer

The Data Controller of the processing of personal data is Ledworks S.r.l. (VAT 07477880962), with head office in 20139 Milano, via Tortona n. 37, e-mail [email protected] (hereinafter, the “Data Controller“).

The updated list of designated Data Processors may be provided upon request by data subjects and / or Users.

Where appointed, the contact details of the Data Protection Officer will be disclosed through publication on the Website.

2. Information collected automatically from the Website

As all websites, our Website also uses log files, in which information collected in an automated manner is kept during your visits. The information systems and the software procedures used to operate the Website, in fact, acquire automatically some information during use, the transmission of which is implicit in the use of Internet communication protocols.

The information collected is the following:

This information is processed in an automated form and collected exclusively in aggregate form in order to verify the correct functioning of the Website.

3. Social networks plugins

The Website may contain social network plug-ins (e.g. Facebook, Instagram, Twitter, etc.). If you access one of our web pages equipped with such a plug-in, your Internet browser connects directly to the social network servers and the plug-in is displayed on your screen via your browser connection. The plug-in tells the social network server which pages you have visited. If the user of a social network visits our web pages while logged into your social account, your personal data may be associated with your social account. Even if you use the plug-in functions (for example, by clicking on the “Like” button or posting a comment), your information will be associated with your social network account. Further information about the collection and use of data by social networks in general, as well as the rights and ways available to protect your privacy in this context, can be found on social network pages. If you do not wish to associate your use of the Websites with your social network account, you should log out of the social network before visiting them.

4. The personal data you provide us using the Website: to which end we treat them

We need your data to enable you:

– to access the Website and make the relative navigation;

– to proceed with registration and access to the services offered therein (e.g. contacts, newsletter, local store, etc.), as requested by you.

Your data are processed for the following purposes:

In compliance with the Italian “Guidelines on promotional activity and contrast to spam” of 4 July 2013, we point out that any consent given by you for sending commercial, promotional and marketing communications through automated tools will also extend to traditional methods of contact.

Through the “Local Store” service, the Website can process geolocation data by sending it or storing it on its servers: activating the search function of a retailer near its position involves the management of data relating to the position of the device (smartphone, tablet, laptop, etc.) of the User only on the device itself, as they are supplied to any programs (e.g. Google Maps, Waze and similar) installed on the device.

The data provided by you will be processed mainly with IT tools under the authority of the Data Controller, by specifically appointed, designated and instructed to process, pursuant to Articles 28 and 29 of the Privacy Regulations. We inform you that appropriate security measures are observed, also pursuant to Articles 5 and 32 of the Privacy Regulations to prevent the loss of data, illicit or incorrect use and unauthorized access.

5. Nature of the provision of data

With reference to the purposes referred to points (iv) and (v) of the previous paragraphs 4, please refer to what is expressly indicated in the specific information referred to in this Privacy Policy.

For the purposes referred to in points (i), (ii) and (iii) of the previous paragraphs 4, the provision of your personal data is necessary because in your absence you will not be able to use the services offered by the Website. Consequently, for the point (i) the legal basis of the processing is the fulfillment of legal obligations, to pursuant to Article 6, paragraph 1, lett. c) of the Privacy Regulation, while for the purposes referred to in points (ii) and (iii) the legal basis of the processing is the execution of the services provided through the Website and requested by you, pursuant to Article 6, paragraph 1, lett. b) of the Privacy Regulation.

More details on the foregoing are contained in the specific information provided or displayed on the Website and prepared for the related services on request.

6. To whom and in which cases we can transmit your data.

Your data may be communicated to the structures, subjects and external companies within the EU (including consultants and service providers) which the Data Controller uses to manage the Website and to carry out related activities, instrumental or consequent to the execution of the services offered by the Website.

More details on the foregoing are contained in the specific information provided or displayed on the Website and prepared for the related services on request.

7. Your rights

At any time, you can exercise the rights referred to in Articles 15 and following of the Privacy Regulation, for access, rectification, transformation, blocking, cancellation, limitation of processing, in the manner established by Article 12 of the Privacy Regulation.

In the event of failure to promptly reply or an inadequate response from the Data Controller, or if you believe there is a violation of the Privacy Code and / or the Privacy Regulation, you can appeal to the Authority of the protection of personal data, at the following coordinates: www.gpdp.itwww.garanteprivacy.it, Email: [email protected], Fax: (+39) 06.69677.3785, Telephone switchboard: (+39) 06.69677.1.

8. Duration of the Treatment

Subject to legal obligations, personal data will be stored for a specified period, based on criteria based on the nature of the services provided.

More details on the foregoing are contained in the specific information provided or displayed on the Website and prepared for the related services on request.

9. Security measures

Through the Website your data will be processed with applicable law and using appropriate security measures, in compliance with the legislation in force also pursuant to Articles 5 and 32 of the Privacy Regulation, aimed at preventing unauthorized access, theft, disclosure, modification or unauthorized destruction of your data.

10. Changes to Privacy Policy

The Data Controller reserves the right to make changes to this Privacy Policy. In this case you will be informed promptly when you use the Website again.