Why this notice
This page describes how the website www.healthupproject.eu is managed with reference to Articles 13 to 22 of the European Regulation 2016/679 (GDPR), concerning the protection of natural persons with regard to the processing of personal data and the free movement of such data, which substantially reforms privacy regulations. This privacy policy is provided solely for personal data processed by Lula Consulting, including through its website. Please note that this policy does not apply to other websites accessed by the user via links.
The data controller
The Data Controller is Lula Consulting S.r.l., with registered office at Via Giacinta Pezzana, 72 – 00197 Rome, Italy. The list of subjects exercising the powers of the Controller on behalf of the Company and those appointed as Data Processors is available at the registered office and the operational offices of the Company. The contact details of the Data Controller are as follows: Tel: +39 06 4554 3824 | Email: info@lulaconsulting.eu
Purposes and legal bases of the processing
Personal data are processed for the following purposes:
- Fulfillment of obligations related to services requested from the company (software supply, system assistance, consulting, websites, hardware, etc.) – contractual legal basis pursuant to Art. 6(1)(b) of the GDPR;
- Fulfillment of obligations related to the administrative and financial management of the established contractual relationship – legal obligation basis pursuant to Art. 6(1)(c) of the GDPR;
- Sending of informative material on company services and promotional material by the company, as well as its subsidiaries and affiliates – consent legal basis pursuant to Art. 6(1)(a) of the GDPR, which the data subject may choose to grant or withhold.
Optional nature of data provision
The provision of data referred to in points 1 and 2 of the previous section is mandatory, failing which it will be impossible to provide the requested services or supplies. The provision of data referred to in point 3 is optional. For website navigation data, please see the following section.
Types of data processed
Navigation data
The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified data subjects, but by its very nature could, through processing and association with data held by third parties, allow users to be identified.
This category of data includes the IP addresses or domain names of the computers used by users connecting to the site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and computer environment.
These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning, and are deleted immediately after processing. The data could be used toคู่ ascertain responsibility in the event of hypothetical computer crimes against the site: except for this possibility, at present, data on web contacts do not persist for more than seven days.
Data provided voluntarily by the user
The optional, explicit, and voluntary sending of e-mails to the addresses indicated on this site involves the subsequent acquisition of the sender’s address, which is necessary to respond to requests for services and/or information, as well as any other personal data included in the message.
Cookies
No personal data of users is acquired by the site in this regard. No use is made of cookies for the transmission of personal information, nor are so-called persistent cookies of any kind or systems for tracking users used.
The use of so-called session cookies (which are not stored persistently on the user’s computer and disappear when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to allow safe and efficient exploration of the site. The so-called session cookies used on this site avoid the use of other computer techniques that could potentially compromise the confidentiality of users’ navigation and do not allow the acquisition of personal data identifying the user.
Recipients of the data
The processing operations connected to the web services of this site are carried out by personnel employed by Lula Consulting S.r.l., authorized for this purpose. The personal data provided by users who submit requests for services, performances, or information are used for the sole purpose of performing the service or performance requested or providing the information required.
In the event that it becomes necessary to use personnel external to Lula Consulting S.r.l. within the scope of fulfilling the services requested by users, such personnel shall be appointed as Data Processor (pursuant to Art. 28 of the GDPR). The updated list of Data Processors of Lula Consulting S.r.l. is available upon request.
Furthermore, the data of Lula Consulting S.r.l.’s clients may be communicated to consultants in matters of administrative, tax, and social security accounting, to banking and financial institutions, as well as to subjects appointed for the protection of the company’s interests in judicial, administrative, and extrajudicial proceedings and for debt collection, to those in charge of dispatching documents and corporate auditing, or to subjects whose right to access the data is recognized by law.
Methods of processing and retention period
Personal data are processed using computer and paper tools for the time strictly necessary, in accordance with the purposes and relevant legal bases illustrated above; as a rule, data relating to the services provided are deleted or destroyed at the latest within 10 years. Data collected on a consensual basis are deleted at the request of the data subject.
Data transfer abroad
Personal data subject to processing by the Company may be transferred or transit through servers in EU countries for the performance of commercial activities.
Rights of the data subjects
Data subjects have the right at any time to obtain confirmation of the existence or otherwise of such data and to know its content and origin, verify its accuracy, or request its integration, updating, or rectification, erasure (deletion), as well as to object to its processing for legitimate reasons. Finally, data subjects have the right to lodge a complaint with the Supervisory Authority.
Requests for the exercise of one’s rights can be sent, according to the contact methods previously reported, to Lula Consulting S.r.l., Data Controller.