PRIVACY POLICY

related to the web platform app.lifeed.io owned by L.B.V. S.r.l.
pursuant to the Articles 13 and 14 EU/2016/679 Regulation and del Legislative Decree 101/2018 (modifying and integrated the Legislative Decree 196/2003)

1. Who is the Data Controller?

Pursuant to the Article 4, n. 7)  EU/2016/679 Regulation, the Data Controller of the Data Subject’s data processed with the web platform app.lifeed.io is:

  • name: the Company L.B.V. S.r.l., Vat n. and F.C. 09236350964;
  • registered office: via Cadore n. 2 – 20092 – Milan (MI);
  • legally represented by: Ms. Riccarda Zezza (F.C. ZZZ RCR 72C 58F 839Y);
  • contact: e-mail: info@lifeed.io – phone n.: 373.81.57.081.

For the purposes of this Privacy Policy, Data Subject means each user and his co-obligated person who registers on the web platform app.lifeed.io and uses the same services offered.

Pursuant to and for the purposes of the Article 37 EU/2016/679 Regulation, Data Subject is informed that L.B.V. S.r.l. has appointed a Data Protection Officer, and more specifically:

  • name: Savino Menna
  • registered office: Via Borromei n. 2, 20123, Milano (MI)
  • contacts: e-mail: dpo@lifeed.io – phone n.: +39.379.16.10.212.
2. What Data are processed?

The Data Controller processes the personal data provided by the Data Subject during their registration on the web platform app.lifeed.io and during the usage of this; Data are related to:

  • The Personal Data processed, pursuant to the Article 4, let. 1) UE/2016/679 Regulation, are:
    • Date of Birth and gender;
    • Name and Surname;
    • Mail address and password;
    • ZIP Code and managerial role in the Company;
    • URL, browser and IP address;
    • Pixel and Cookie.
  • The Particular Data, pursuant to the Articles 9 and 10 UE/2016/679 Regulation, are:
    • Parenthood;
    • Data related to the Caregiving situation of Data Subject.

Despite L.B.V. S.r.l. does not need to process further data with respect to the above, the information that the Data Subject provides through the use of our web platform and through the existing messaging form within it, will be processed in accordance with this Privacy Policy, the T&Cs present on the web platform and in full compliance with the provisions of EU and national legislation on the matter (hereinafter personal data and particular data will be jointly referred to and defined as "Data").

3. For what purposes are the Data processed?

Data processing will be performed by L.B.V. S.r.l. for the following purposes:

  1. Contractual Purposes:
    1. to conclude contracts related to the services of L.B.V. Srl through the web platform lifeed.io;
    2. to allow access to the lifeed.io platform;
    3. to carry out advocacy activities (activities with the aim to influence public policies and the allocation of resources within political, economic and social systems);
    4. to carry out reporting activities to Companies and scientific research connected to public institutions and aimed to ensure full respect for equal opportunities in professional and work development;
    5. to fulfill the pre-contractual, contractual and tax obligations deriving from existing relationships with the Data Subject;
    6. to fulfill the obligations established by law, by a regulation, by EU legislation or by an order of the Authority (such as for example in the matter of anti-money laundering, funded training);
    7. to exercise the rights as Data Controller, such as, for example, the right to defense in court.
  2. Legitimate Interest Purposes:
    1. to carry out activities functional to any securitisations, assignments of credit and issue of securities, transfers of business and business unit, acquisitions, mergers, demergers or other transformations and for the execution of such operations;
    2. to carry out checks aimed to prevent any fraud.
4. On what legal basis are the Data processed?

Data processing is carried out in compliance with the conditions of lawfulness referred to the Article 6 EU/2016/679 Regulation and more specifically:

  • Legal basis related to the Contractual Purposes referred to the Article 3, lett. a), n. from 1) to 5) of this Privacy Policy:
    the contract between the L.B.V. Srl and the Data Subject: pursuant to Article 6, lett. b) EU/2016/Regulation, processing is necessary as it is aimed to the execution of the contract between the Data Controller and the Data Subject, the supply of the products and services requested and any information relating to them;
  • Legal basis related to the Contractual Purposes referred to the Article 3, lett. a), n. 6) and 7) of this Privacy Policy:
    fulfillment of a legal obligation: pursuant to the Article art. 6, lett. c) of EU/2016/679 Regulation, the processing is necessary to fulfill the legal obligations to which the Data Controller is subject.

With particular reference to the purposes of advocacy, reporting and scientific research pursuant to Article 3) lett. a), n. 3) and 4), the Data processing is performed in accordance with the provisions of the Article 9 § 2 lett. h) and j) EU/2016/679 Regulation, Article 89 EU/2016/679 Regulation and by Chapter III of Legislative Decree n. 101/2018 modifying and integrated the Legislative Decree 196/2003.

The provision of Data for contractual purposes is mandatory: if the Data Subject does not provide such Data, the Data Controller will not be able to proceed with the registration of the Data Subject on the app.lifeed.io web platform nor to provide the services offered.

  • Legal basis related to the Legitimate Interest Purposes referred to the Article 3, lett. b), n. 6) and 7):
    the legitimate interest of the Data Controller or third parties: according to the Article 6, lett. f) EU/2016/679 Regulation, the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties, adequately balanced with the interests of the Data Subject in light of the limits imposed on such processing and the circumstances specific rooms where the processing takes place, illustrated in the Article 3 of the present Privacy Policy.

The processing of Data for legitimate interest purposes is not mandatory and the Data Subject may object by contacting the Data protection officer appointed by L.B.V. S.r.l.: if theData Subject opposes said processing, his Data cannot be used for the purposes of legitimate interest, unless the Data Controller demonstrates the presence of prevailing binding legitimate reasons or the exercise or defense of a right pursuant to the Article 21 EU/2016/679 Regulation.

5. How are the Data Processed?

The processing of Data is carried out pursuant with the operations indicated in the Art. 4 n. 2) of the 2016/679/EU Regulation and, more precisely, through: collection, recording, organization, storage, consultation, processing, modification, extraction, use, communication, deleting and destruction of data.

The Data may be processed using manual or IT tools, suitable to guarantee security, confidentiality and to prevent unauthorized access and violation of the Data processed.

The Data processed are stored using cloud computing tools on servers located within the EU territory (Germany): for more information on safety standards and compliance with the requirements set by the 2016/679/EU Regulation adopted by the selected external providers, consult the web page https://aws.amazon.com/it/privacy/.

The Data processing necessary to the reporting, advocacy and research purposes, pursuant to the Article 3 lett. A) n. 3) and 4), will be anonymized before their processing and processed solely in aggregate way.

6. To whom are the Data communicated?

The Data may be communicated for Contractual Purposes to subjects who perform services connected and functional to the management of the existing contractual relationship or to be stipulated and, in particular, to the following categories of subjects located within the European Union:

  • service providers connected to the activities of the Data Controller and public institutions;
  • assistance, tax and legal advice;
  • IT or storage service providers and external service providers.

The Data may be disclosed for Legitimate Interest Purposes, to suppliers of assistance services, technical, tax and legal consultancy, assignees of receivables in the context of credit securitization or credit assignment operations for strictly connected and instrumental purposes to the management of the relationship with the transferred Data Subject, as well as to the issue of securities, assignees of Company or business unit, potential buyers of LBV S.r.l. and Companies resulting from possible mergers, divisions or other transformations of the L.B.V. S.r.l., also in the context of the activities functional to these operations, and to competent authorities.

The Data, if the direct customer Company of the L.B.V. S.r.l. –  employer of the user / Data Subject – needs to receive a report containing the Data of the Data Subject in a non-anonymous form, the Data Controller will communicate only name, surname, date of use of the course, total hours of course duration and certification of results upon passing the course undertaken. These Data will be communicated only to the "customer" Company as better explained above and only if there is evidence of the latter's willingness to participate in the "formazione finanziata - FondoImpresa" and / or in the "fondo banche assicurazioni".

In any case, L.B.V. S.r.l. reserves the possibility to communicate to the "Client" Company –  employer of the user / Data Subject – the Data of the Data Subject related to name, surname, work e-mail and date of registration on the app.lifeed.io web platform, in order to allow the correct performance of the agreement signed with L.B.V. S.r.l.

7. Are Data trasferred abroad?

The Data may be freely transferred outside the national territory to countries located in the European Union.

The Data Subject will have the right to obtain a copy of the Data held abroad and to obtain information about the place where such data are stored, sending a specific request to the Data Controller contacting the Data Protection Officer designed by L.B.V. S.r.l.

8. What are the rights of the Data Subject?

The Data Subject, pursuant to the Articles from 15 to 22 EU/2016/679 Regulation, has the right to:

  • obtain confirmation from the Data Controller that a processing of Data concerning him is in progress;
  • obtain access to Data and information relating to the processing of Data concerning him;
  • obtain from the Data Controller the correction of inaccurate Data concerning him without undue delay;
  • obtain the integration of incomplete Data, also by providing an additional declaration;
  • obtain from the Data Controller the cancellation of the Data concerning him without undue delay;
  • obtain the limitation of processing from the Data Controller:
  1. for the period necessary to verify the accuracy of such Data by the Data Controller, when the Data Subject disputes its accuracy;
  2. when the processing is unlawful and the Data Subject opposes the deletion of the Data, requesting instead that its use be limited;
  3. when the Data are necessary for the Data Subject to ascertain, exercise or defend a right in court, although the Data Controller no longer needs it for processing purposes;
  4. when the Data Subject has opposed the processing pursuant to Article 21, paragraph 1 EU/2016/679 Regulation and for the whole period in which it remains pending verification of the possible prevalence of the legitimate reasons of the Data Controller with respect to those of the Data Subject;
  • receive in a structured format, commonly used and readable by an automatic device, the Data concerning him provided to the Data Controller;
  • transmit this Data to another Data controller without hindrance by the Data Controller to whom it has provided them;
  • obtain the direct transmission of Data from one Data Controller to another, if technically feasible;
  • object at any time, for reasons connected with your particular situation, to the processing of the Data that concern you pursuant to Article 6, paragraph 1, letters e) or f), including profiling;
  • not be subjected to a decision based solely on automated processing, including profiling, which produces legal effects that concern him or which similarly significantly affects his person;
  • propose a complaint directly to the Guarantor Authority if there is a violation of the data protection legislation by the Data Controller.

Requests for the exercise of the above rights can be sent to the Data Controller by contacting the Data Protection Officer designated by the L.B.V. S.r.l.

The right of complaint, however, can be freely exercised by the Data Subject sending an act of claim to the Privacy Authority in the way deemed most appropriate:

  • letter A/R addressed to the "Guarantor for the protection of personal data, Piazza Venezia n. 11, 00187, Rome";
  • certified e-mail message to the address "“protocollo@pec.gpdp.it”.
9. Who are the external Data Processor?

The complete list of data processors is available by sending a written request to the Data Controller and/or the Data Protection Officer designated by L.B.V. S.r.l.

10. How long will the processed data be stored?

The Data processed by the Data Controller:

  • for the Contractual Purposes and for the Legitimate Interest Purpose referred to Article 3, lett. b) n. 1), will be kept for a period equal to the duration of the Contract and/or service offered (including any renewals), except in cases where the retention for a subsequent period is required for any disputes, requests from the competent authorities or pursuant to applicable legislation;
  • as regards, specifically, the purposes of advocacy, reporting and scientific research, will be kept in compliance with the terms set out in this chapter and processed solely by means of anonymization and aggregate form;
  • for the Legitimate Interest Purposes referred to the Article 3, lett. b) n. 2), will be kept for the duration strictly necessary to ensure the reliability of the checks indicated therein.
11. Modifications and Updates.

This Privacy Policy is effective from the date indicated below. The Data Controller may also make changes and/or additions to this privacy policy, also as a consequence of any subsequent amendments and supplements of applicable laws/regulations. If substantial, the changes will be notified in advance and the Data Subject can find the text of it constantly updated on the website https://app.lifeed.io/it/privacy/privacy-policy or sending a specific to the Data Controller and/or the Data Protection Officer designated by L.B.V. S.r.l.


COOKIE POLICY

This Cookie Policy refers to the use of cookies and web analytics into the web platform app.lifeed.io owned by L.B.V. S.r.l.

L.B.V. Srl uses cookies to make the use of app.lifeed.io easier and to better adapt the web platform and the products and services to the interests and needs of users. Cookies can also be used to speed up future experiences and activities on this web platform.

Using the app.lifeed.io web platform and registering you consent to the use of cookies in accordance with this Cookie Policy: the consent given may be revoked at any time, through the instructions indicated in the section "how to deactivate cookies" of this Policy.

If you do not want to accept our use of cookies, you can refuse to give your consent: we also inform you that if you disable the cookies we use, this may affect your best user experience on the app.lifeed.io web platform.

What is a Cookie?

Cookies are small strings of text downloaded to your device when you visit a website. At each subsequent visit, cookies are sent to the website that originated them (first-party cookies) or to another website that recognizes them (third-party cookies). Cookies are useful because they allow a website to recognize the user's device. They have different purposes such as, for example, allowing you to efficiently navigate between pages, remembering your favorite sites and, in general, improving the browsing experience. They also help ensure that the advertising content displayed online is more targeted to a user and his interests. Depending on the function and use, cookies can be divided into technical cookies, analysis and profiling cookies and third-party cookies

Technical cookies

Technical cookies are those whose use does not require the user's consent. These cookies are essential to allow you to browse through a website and use all its functions. Without these cookies, which are absolutely necessary, a website cannot provide certain services or functions and browsing would not be as smooth and easy as it should be. A cookie of this type is also used to store a user's decision on the use of cookies on the website. Also the performance cookies belong to this category and are often called analytics cookies: these are cookies that collect information about the use of a website's user experience and improve its operation. For example, performance cookies show the most visited pages, allow you to check which are the recurring patterns of use of a website, help to understand all the difficulties encountered in using the website and to show the effectiveness of the advertising that is published on the website. Technical cookies are essential and cannot be deactivated using the functions of this website. In general, cookies can be completely disabled in your browser at any time.

Profiling cookies

These cookies allow you to remember the choices users on the website and the services specifically requested to provide the most advanced and personalized services. The use of these cookies requires the acquisition of the user's consent in accordance with the data protection laws (Art. 6 § 1 letter A of the 2016/679/EU Regulation). Consent is acquired through a banner visible to users on the first visit to the website. This consent can be revoked at any time by following the instructions in the "how to disable cookies" section of this Cookie Policy. The refusal to consent to the use of profiling cookies does not interfere with the possibility of accessing the site, with the exception of the impossibility of accessing these functions or functions that use these cookies.

Third-party cookies

It is also possible to use cookies from different sites or servers: this is because the site could include elements, for example, images, maps, sounds, links to web pages in other domains that reside in different servers from the requested page. In other words, these cookies are managed by site operators or different servers from the website visited. Third-party cookies are used for advertising purposes depending on the user’s interest. This information could be shared with other parties, such as advertisers, that could could use cookies to gather information about the activities performed by users on the website. Advertisers can use the information to measure the effectiveness of their advertising. The use of these cookies requires the prior acquisition of the user's informed consent. These cookies are not controlled directly by the website operator and are in line with the instructions in the "how to disable cookies" section of this cookie policy.

Duration of cookies

Some cookies (session cookies) are active only until the browser is closed or if there is a logout command. Other cookies "survive" when the browser is closed and are also available for subsequent visits by the user. These cookies are called persistent and their duration is set by the server at the time of their creation. In some cases a deadline is set, in other cases the duration is unlimited.

Which cookies we use

To ensure a more efficient operation of our platform we could use: i) technical and analytical first-party cookies and ii) third-party analytical cookies.

In particular, we may use cookies for the following services/platforms:

  • Google;
  • Intercom;
  • Addthis
  • Full Story
  • Mix Panel.
How to disable cookies from your browser

You can manage cookies through your browser settings or follow the links below to disable cookies:

Most browsers automatically accept cookies but the user can accept or refuse cookies or decide to set a notice before accepting a cookie from the websites visited at any time. The procedures for managing cookies are differents and depend on the browser: the "Help" section of the toolbar in most browsers illustrates how to avoid receiving cookies, web beacons and other tracking technologies, how to get notification from the browser or how to disable them completely.

Keep in mind that changing settings will only impact that particular browser and PC. The operation is repeated on each browser and device on which you want to change the settings. Please also note that, by disabling cookies, some websites will not be able to provide profiled services.

This cookie policy may be changed over time: the user/visitor is invited to consult periodically this Cookie Policy.