Privacy Policy

Privacy Policy of LAGALPI Sagl

This Web Site collects some Personal Data of its Users.

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Data Controller

LAGALPI Sagl.
Via Cantonale 4, Centro Galleria 3
CH-6928 Manno

VAT THAT-482-418-129

Holder’s email address: info@lagalpi.com

Phone +41 91 960 3906

Types of Data Collected

Among the Personal Data collected by this Web Site, either independently or through third parties, are: Cookies; Usage Data; email; unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example); first name; last name; Data disclosed while using the service.

Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific informational texts displayed before the data is collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, automatically collected during the use of this Web Site.
Unless otherwise specified, all Data requested by this Web Site is mandatory. If the User refuses to disclose them, it may be impossible for this Web Site to provide the Service. In cases where this Web Site indicates certain Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.
Users who are in doubt about which Data are mandatory are encouraged to contact the Data Controller.
Any use of Cookies – or other tracking tools – by this Website or the owners of third party services used by this Website, unless otherwise specified, is for the purpose of providing the Service requested by the User, in addition to the additional purposes described herein and in the Cookie Policy, if available.

The User assumes responsibility for third party Personal Data obtained, published or shared through this Web Site and warrants that he or she has the right to communicate or disseminate it, releasing the Owner from any liability to third parties.

Method and place of processing of collected Data

Mode of treatment

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
The processing is carried out by means of computer and/or telematic tools, with organizational methods and logic strictly related to the indicated purposes. In addition to the Data Controller, in some cases, other subjects involved in the organization of this Website (administrative, sales, marketing, legal, system administrators personnel) or external subjects (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Data Controller may have access to the Data. An up-to-date list of Data Processors can always be obtained from the Data Controller.

Legal basis for processing

The Owner processes Personal Data related to the User if one of the following conditions exists:

• the User has given consent for one or more specific purposes; Note: In some jurisdictions, the Data Controller may be authorized to process Personal Data without the need for the User’s consent or another of the legal bases specified below, as long as the User does not object (“opt-out”) to such processing. However, this does not apply if the processing of Personal Data is regulated by European legislation on the protection of Personal Data;
• processing is necessary for the performance of a contract with the User and/or the execution of pre-contractual measures;
• processing is necessary to fulfill a legal obligation to which the Controller is subject;
• the processing is necessary for the performance of a task of public interest or the exercise of public authority vested in the Controller;
• processing is necessary for the pursuit of the legitimate interest of the Owner or third parties.

However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on law, required by a contract or necessary to conclude a contract.

Location

The Data are processed at the Holder’s operational offices and at any other location where the parties involved in the processing are located. For more information, contact the Holder.
The User’s Personal Data may be transferred to a country other than the country in which the User is located. To obtain more information about the location of processing, the User may refer to the section on Personal Data Processing Details.

The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization under public international law or formed by two or more countries, such as the UN, as well as regarding the security measures taken by the Data Controller to protect the Data.

The User may verify whether any of the transfers just described takes place by reviewing the section of this document on details of the processing of Personal Data or request information from the Controller by contacting it at the contact details given at the beginning.

Retention period

Data are processed and kept for the time required by the purposes for which they were collected.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the performance of that contract is completed.
• Personal Data collected for purposes attributable to the legitimate interest of the Data Controller will be retained until that interest is satisfied. The User may obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.

When processing is based on the User’s consent, the Data Controller may keep the Personal Data longer until that consent is revoked. In addition, the Controller may be required to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, upon the expiration of this period, the right of access, deletion, rectification and the right to Data portability can no longer be exercised.

Purposes of the Processing of Collected Data

User Data are collected to enable the Data Controller to provide the Service, comply with legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of Users or third parties), detect any malicious or fraudulent activities, as well as for the following purposes: Traffic optimization and distribution, Displaying content from external platforms, Platform and hosting services, Statistics, Remarketing and behavioral targeting, Tag management, Advertising, Interaction with social networks and external platforms, Management of data collection and online surveys, and Contacting the User.

To obtain detailed information on the purposes of processing and the Personal Data processed for each purpose, the User may refer to the section “Personal Data Processing Details.”

Details of the processing of Personal Data

Personal Data are collected for the following purposes and using the following services:

Contacting the User

MAILING LIST OR NEWSLETTER (THIS WEBSITE)

By registering for a mailing list or newsletter, the User’s email address is automatically added to a list of contacts to whom email messages containing information, including information of a commercial and promotional nature, relating to this Web Site may be sent. The User’s email address may also be added to this list as a result of registering with this Web Site or after making a purchase.

Personal Data Processed: last name; Cookie; Usage Data; email; first name.

Tag management

This type of service is functional for the centralized management of tags or scripts used on this Web Site.
The use of such services involves the flow of User Data through them and, where appropriate, their retention.

GOOGLE TAG MANAGER (GOOGLE IRELAND LIMITED)

Google Tag Manager is a tag management service provided by Google Ireland Limited.

Personal data processed: Usage Data.

Place of processing: Ireland – Privacy Policy.

Management of data collection and online surveys

This type of service allows this Web Site to manage the creation, implementation, administration, distribution, and analysis of online forms and surveys in order to collect, save, and reuse Data from responding Users.
The Personal Data collected depend on the information requested and provided by Users in the corresponding online form.

These services may be integrated with a wide range of third-party services to enable the Data Controller to perform subsequent actions with the processed Data – for example, contact management, messaging, statistics, advertising, and payment processing.

ADS FOR FACEBOOK CONTACT ACQUISITION (FACEBOOK IRELAND LTD)

Facebook’s Contact Acquisition Ads is an advertising and data collection service provided by Facebook Ireland Ltd that allows displaying advertisements to Users in the form of forms already pre-populated with Personal Data from their Facebook profiles, such as names and email addresses. Depending on the type of ad, Users may be asked to provide additional information.

Submission of the form involves the collection and processing of this Data by the Data Controller pursuant to this privacy policy and only for the specific purpose stated in the form and/or within this privacy policy, if any.

You may exercise your rights, at any time, including the right to withdraw your consent to the processing of your Data, as specified in the section containing information about your rights in this privacy policy.

Personal Data Processed: last name; Cookies; Data disclosed while using the service; Usage Data; email; name.

Place of processing: Ireland – Privacy Policy – Opt out.

Interaction with social networks and external platforms

This type of service allows for interactions with social networks, or other external platforms, directly from the pages of this Web Site.
Interactions and information captured by this Web Site are in each case subject to the User’s privacy settings related to each social network.
This type of service may still collect traffic data for pages where the service is installed, even when Users are not using it.
It is recommended that you disconnect from the respective services to ensure that the data processed on this Web Site is not linked back to your profile.

FACEBOOK LIKE BUTTON AND SOCIAL WIDGETS (FACEBOOK IRELAND LTD)

The Facebook “Like” button and social widgets are Facebook social network interaction services, provided by Facebook Ireland Ltd

Personal Data Processed: Cookies; Usage Data.

Place of processing: Ireland – Privacy Policy.

Traffic optimization and distribution

This type of services allows this Web Site to distribute its content through servers located in the territory and optimize its performance.
The Personal Data processed depends on the characteristics and mode of implementation of these services, which by their nature filter communications between this Web Site and the User’s browser.
Given the distributed nature of this system, it is difficult to determine where content is transferred to, which may contain Personal Data of the User.

CLOUDFLARE (CLOUDFLARE INC.)

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all traffic on this Web Site, i.e., communications between this Web Site and the User’s browser, and also allows the collection of statistical data about it.

Personal Data Processed: Cookies; various types of Data as specified by the service’s privacy policy.

Place of processing: United States – Privacy Policy.

Advertisement

This type of service allows User Data to be used for marketing communication purposes. These communications are displayed on this Web Site in the form of banners and other forms of advertising, also related to the User’s interests.
This does not mean that all Personal Data is used for this purpose. Data and conditions of use are given below.
Some of the services below may use Tracking Tools to identify the User or use the technique of behavioral retargeting, i.e. displaying advertisements tailored to the User’s interests and behavior, also detected outside this Website. For more information on this, we suggest you check the privacy policies of the respective services.
Generally, services of this type offer the option to disable such tracking. In addition to any opt-out features provided by any of the services listed in this document, the User can read more about how to turn off interest-based advertisements in the appropriate “How to turn off interest-based advertising” section in this document.

FACEBOOK SIMILAR AUDIENCE (FACEBOOK IRELAND LTD)

Facebook’s Similar Audiences is an advertising and behavioral targeting service provided by Facebook Ireland Ltd that uses Data collected through Facebook’s Custom Audiences service in order to show advertisements to Users with similar behaviors to Users who are already on a Custom Audiences list based on their previous use of this Website or their interaction with relevant content through Facebook applications and services.
Based on this Data, personalized ads will be shown to Users suggested by Facebook’s Similar Audiences.

Users can opt-out of Facebook’s cookies for ad personalization by visiting this opt-out page.

Personal Data Processed: Cookies; Usage Data.

Place of processing: Ireland – Privacy Policy – Opt Out.

FACEBOOK AUDIENCE NETWORK (FACEBOOK IRELAND LTD)

Facebook Audience Network is an advertising service provided by Facebook Ireland Ltd For an understanding of Facebook’s use of data, please see Facebook’s data policy.

To enable Facebook Audience Network to function, this Web Site may use certain mobile device identifiers (including Android Advertising ID or Advertising Identifier for OS) or cookie-like technologies. Among the ways in which Audience Network offers advertisements to the User is through the use of the User’s advertising preferences. Users can control the sharing of their advertising preferences within Facebook’s Ad settings.

The User can opt-out of certain Audience Network targeting features through their device settings. For example, it can change the settings on advertising available for mobile devices, or follow the instructions applicable to Audience Network that may be found within this privacy policy.

Personal Data Processed: Cookies; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example).

Place of processing: Ireland – Privacy Policy – Opt Out.

Remarketing and behavioral targeting

These types of services allow this Web Site and its partners to communicate, optimize, and serve advertisements based on your past use of this Web Site.
This activity is facilitated by tracking Usage Data and using Tracking Tools to collect information that is then transferred to partners that handle remarketing and behavioral targeting activities.
Some services offer an email list-based remarketing option.
In addition to the opt-out features offered by the services below, the User can opt out by visiting the Network Advertising Initiative’s opt-out page.

Users can also opt out of certain advertising features through corresponding device configuration options, such as mobile device advertising configuration options or generic advertising configuration.

REMARKETING WITH GOOGLE ANALYTICS (GOOGLE IRELAND LIMITED)

Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google Ireland Limited that links the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.

Personal Data Processed: Cookies; Usage Data.

Place of processing: Ireland – Privacy Policy – Opt Out Opt Out.

FACEBOOK REMARKETING (FACEBOOK IRELAND LTD)

Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook Ireland Ltd that links this Website’s activity with the Facebook advertising network.

Personal Data Processed: Cookies; Usage Data.

Place of processing: Ireland – Privacy Policy – Opt Out.

FACEBOOK CUSTOM AUDIENCE (FACEBOOK IRELAND LTD)

Facebook Personalized Audiences is a remarketing and behavioral targeting service provided by Facebook Ireland Ltd that connects the activity of this Web Site with Facebook’s advertising network.

Users can opt-out of Facebook’s cookies for ad personalization by visiting this opt-out page.

Personal Data Processed: Cookies; email.

Place of processing: Ireland – Privacy Policy – Opt Out.

Platform and hosting services

These services are intended to host and operate key components of this Web Site, making it possible to deliver this Web Site from a single platform. These platforms provide the Holder with a wide range of tools such as, for example, analytical tools, user registration management, comment and database management, e-commerce, payment processing etc. The use of such tools involves the collection and processing of Personal Data.
Some of these services operate through servers located geographically in different locations, making it difficult to determine the exact location where Personal Data is stored.

SHOPIFY

Shopify is a platform provided by Shopify Inc. which allows the Owner to develop, operate and host a website dedicated to electronic commerce.

Personal Data processed: various types of Data as specified by the privacy policy of the service.

Place of processing: Canada – Privacy Policy; Ireland – Privacy Policy.

Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to track User behavior.

GOOGLE ANALYTICS (GOOGLE IRELAND LIMITED)

Google Analytics is a web analytics service provided by Google Ireland Limited (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports, and sharing them with other services developed by Google.
Google may use Personal Data to contextualize and personalize ads in its ad network.

Personal Data Processed: Cookies; Usage Data.

Place of processing: Ireland – Privacy Policy – Opt Out.

FACEBOOK ADS CONVERSION TRACKING (FACEBOOK PIXEL) (FACEBOOK IRELAND LTD)

Facebook Ads conversion tracking (Facebook pixel) is a statistics service provided by Facebook Ireland Ltd that links data from the Facebook Ads network with actions taken within this Web Site. The Facebook pixel monitors conversions that can be attributed to Facebook, Instagram, and Audience Network ads.

Personal Data Processed: Cookies; Usage Data.

Place of processing: Ireland – Privacy Policy.

Viewing content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Web Site and interact with them.
This type of service may still collect data on web traffic related to pages where the service is installed, even when users are not using it.

GOOGLE FONTS (GOOGLE IRELAND LIMITED)

Google Fonts is a font style display service operated by Google Ireland Limited that allows this Web Site to integrate such content within its pages.

Personal Data Processed: Usage Data; various types of Data as specified by the service’s privacy policy.

Place of processing: Ireland – Privacy Policy.

INSTAGRAM WIDGET (FACEBOOK IRELAND LTD)

Instagram is an image display service operated by Facebook Ireland Ltd that allows this Web Site to integrate such content within its pages.

Personal Data Processed: Cookies; Usage Data.

Place of processing: Ireland – Privacy Policy.

Information on how to turn off interest-based advertisements

In addition to any opt-out features provided by any of the services listed in this document, Users can read more about how to turn off interest-based advertisements in the appropriate section of the Cookie Policy.

User Rights

Users may exercise certain rights with respect to the Data processed by the Data Controller.

In particular, to the extent provided by law, the User has the right to:

• Revoke consent at any time. The User may revoke the previously expressed consent to the processing of his or her Personal Data.
• Object to the processing of their Data. Users may object to the processing of their Data when it is done on a legal basis other than consent. Further details on the right to object are given in the section below.
• access their Data. The User has the right to obtain information about the Data processed by the Data Controller, certain aspects of the processing, and to receive a copy of the processed Data.
• Verify and request rectification. The User can check the accuracy of their Data and request that it be updated or corrected.
• Obtain restriction of processing. The User may request the restriction of the processing of his or her Data. In this case, the Data Controller will not process the Data for any purpose other than its preservation.
• Obtain the deletion or removal of their Personal Data. The User may request the deletion of his or her Data by the Data Controller.
• receive their Data or have it transferred to another owner. You have the right to receive your Data in a structured, commonly used, machine-readable format and, where technically feasible, to have it transferred unimpeded to another data controller.
• Propose complaint. The User may file a complaint with the relevant data protection supervisory authority or take legal action.

Details of the right to object

When Personal Data are processed in the public interest, in the exercise of public authority vested in the Data Controller or in pursuit of a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users are reminded that, should their Data be processed for direct marketing purposes, they may object to the processing at any time, free of charge and without providing any reasons. If Users object to processing for direct marketing purposes, Personal Data are no longer processed for such purposes. To find out whether the Data Controller processes Data for direct marketing purposes, Users may refer to the respective sections of this document.

How to exercise rights

In order to exercise their rights, Users may address a request to the contact details of the Holder indicated in this document. The request can be filed free of charge and the Holder will respond as soon as possible, in any case within one month, providing the User with all the information required by law. Any rectification, deletion or restriction of processing will be communicated by the Controller to each of the recipients, if any, to whom the Personal Data has been transmitted, unless this proves impossible or involves disproportionate effort. The Owner notifies the User of these recipients if he or she so requests.

Cookie Policy

This Web Site makes use of Tracking Tools. To learn more, the User may consult the Cookie Policy.

More information about the treatment

Litigation defense

The User’s Personal Data may be used by the Owner in legal proceedings or in the preparatory stages to its possible establishment for the defense against abuses in the use of this Web Site or related Services by the User.
The User declares that he/she is aware that the Data Controller may be obliged to disclose the Data by order of public authorities.

Specific disclosures

Upon the User’s request, in addition to the information contained in this privacy policy, this Web Site may provide the User with additional and contextual disclosures regarding specific Services, or the collection and processing of Personal Data.

System logs and maintenance

For operation and maintenance purposes, this Web Site and any third-party services it uses may collect system logs, which are files that record interactions and may also contain Personal Data, such as the User IP address.

Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Response to “Do Not Track” requests

This Web Site does not support “Do Not Track” requests.
To find out whether any third-party services used support them, the User is encouraged to consult their respective privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Website as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details it has. Therefore, please consult this page frequently, referring to the date of last modification indicated at the bottom.

If the changes affect processing whose legal basis is consent, the Owner will re-collect the User’s consent, if necessary.

Definitions and legal references

PERSONAL DATA (OR DATA)

Personal data is any information that, directly or indirectly, including in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

USAGE DATA

This is the information collected automatically through this Web Site (including by third party applications integrated into this Web Site), including: the IP addresses or domain names of the computers used by the User who connects with this Web Site, the addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method used in forwarding the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc..) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (e.g. the length of time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the User’s operating system and computer environment.

USER

The individual using this Web Site who, except where otherwise specified, coincides with the Data Subject.

INTERESTED

The natural person to whom the Personal Data refers.

DATA CONTROLLER (OR MANAGER)

The natural person, legal entity, public administration and any other entity that processes personal data on behalf of the Controller, as set forth in this privacy policy.

DATA CONTROLLER (OR OWNER)

The natural or legal person, public authority, service or other body which, individually or jointly with others, determines the purposes and means of the processing of personal data and the means adopted, including the security measures relating to the operation and use of this Web Site. The Data Controller, unless otherwise specified, is the owner of this Web Site.

THIS WEBSITE (OR THIS APPLICATION)

The hardware or software tool by which Users’ Personal Data are collected and processed.

SERVICE

The Service provided by this Web Site as defined in the relevant terms (if any) on this site/application.

EUROPEAN UNION (OR EU)

Unless otherwise specified, any reference to the European Union in this document is understood to extend to all current member states of the European Union and the European Economic Area.

COOKIE

Cookies are Tracking Tools that consist of small portions of data stored within the User’s browser.

TRACKING TOOL

Tracking Tool means any technology – e.g., cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting – that allows tracking Users, for example, by collecting or storing information on the User’s device.

LEGAL REFERENCES

This privacy policy is prepared based on multiple legislative orders, including Articles 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy policy covers this Web Site only.

Last modified: March 16, 2021

iubenda hosts this content and collects only the Personal Data strictly necessary for its provision.