Larry Agency’s Privacy Policy

Introduction

This Privacy and Cookie Policy sets out for what purposes Larry Agency S.r.l. collects personal data from its website users, how it is managed, to whom it may be disclosed, and what rights are granted.
Management and security are always ensured with the utmost care, in accordance with the requirements of the European Data Protection Regulation 679/2016 (hereinafter “GDPR”).

Type of data collected

In relation to users who register on the site of Larry Agency S.r.l. it is necessary to collect and “process” the following personal information from them:
– Contact information, such as: first name, last name, phone number, city, and email address;
– Contact information for customers, such as: first name, last name, customer code, business name/contract holder, phone number, city, and email address;
– Candidate recruiting information such as: first name, last name, date of birth, phone number, residence, home address, email address, resume;
– Cookies and similar technologies to: measure and analyze the use and effectiveness of our services, personalize and optimize advertising targeting for our services on other websites and platforms, provide location services if you choose to share your location
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.
Unless otherwise specified, all data requested by this Web Site are mandatory. If you refuse 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 providing such data, without any consequence on the availability of the Service or its operation.
Any use of Cookies – or other tracking tools – by this Web Site or the owners of third party services used by this Web Site, unless otherwise specified, is for the purpose of providing the Service requested by you, in addition to the additional purposes described herein and in the Cookie Policy.
For more information regarding the Cookies we use, please review our Cookie Policy.
You assume responsibility for third party Personal Data shared through this Web Site and warrant that you have the right to disclose or disseminate it, releasing the Owner from any liability to third parties.

Reasons for data collection

The data will be used exclusively for the following purposes:

1. Contractual relationship management: data will be processed in relation to contractual requirements and the consequent fulfillment of legal and tax obligations, as well as to enable effective management of contractual, financial and commercial relationships. Data will be processed for the duration of the contractual relationship, and also thereafter, for the fulfillment of legal obligations and for administrative and commercial purposes.
2. Marketing: in case of express consent, the data will be processed for marketing activities, market research, statistical analysis, newsletters, sending of advertising/information/promotional material both by automated (electronic mail, sms…) and traditional (telephone, paper mail…) contact methods;
3. Profiling: in case of express consent, data will be processed for profiling purposes, in particular to create a business profile and/or to personalize and optimize our services based on your preferences, including by cross-referencing such personal data with other information collected through the profiling cookies you have accepted.

It follows that the provision of personal data is mandatory for the purposes stated in 1.

Purposes 2 and 3 do not result from a legal obligation and the provision of the relevant consents is optional. Any partial or total failure to provide data will result in the partial or total impossibility of achieving the above purposes.

The extent and adequacy of the data provided will be evaluated on a case-by-case basis in order to determine the consequent decisions and to avoid the processing of data that are excessive in relation to the purposes pursued.

We will not use personal data for purposes other than and in addition to those described in this policy, except by informing you in advance and, where necessary, obtaining your consent.

Legal basis for processing

The legal basis for the collection and use of personal information as described above will depend on the specific context in which it is collected.

The main reason for processing personal information lies in the management of the contract and the proper delivery of services. However, the use of personal information may occur when such activity is within our legitimate business interest. Processing could fulfill a legal obligation (for example, in the case of legal proceedings) and could be processed or shared with other parties to safeguard your interests and those of third parties.

Methods of data use

Personal information will be processed in compliance with the GDPR and the principles of fairness, lawfulness, transparency and confidentiality that inspire the activity of Larry Agency S.r.l. Data may be processed either through the use of archives and paper media, or through the use of digital media and electronic tools, in compliance with the security measures provided for by current European legislation.

Data retention

Personal data will be kept, from the time of their receipt/update, for a maximum period of 10 years (unless otherwise provided by law for longer periods), after which they will be deleted or anonymized.

Place of storage

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.

Data Sharing

Personal information will not be “disseminated”; by this term we mean the giving of it to unspecified parties in any way, including by making it available or consulting it. On the other hand, the data may be “communicated”; by this term we mean the giving of knowledge to one or more specific individuals, in the following terms:

• to individuals entrusted within our Company to process the data, and in particular to the HR area and the sales network;
• to subjects who can access the data by virtue of a provision of the law, regulation or EU legislation, within the limits provided by these rules;
• to parties who need access to the data for purposes auxiliary to the relationship that exists, to the extent strictly necessary to carry out the auxiliary tasks entrusted to them (for example: credit institutions, shippers, etc.);
• to individuals who are our consultants, to the extent necessary to carry out their duties at our Company, subject to our letter of assignment imposing on them the duty of confidentiality and security in the processing of data;
• to related parties, for the tasks and arrangements strictly necessary for the constraints imposed by the related relationship.

A complete and up-to-date list of the companies/external consultants to whom we disclose your data can be obtained directly from the references listed in the “Contact Persons” section.

User Rights

At any time, the user has the right to ask:

• Access to personal data;
• their origin;
• The logic, methods and purposes of processing;
• the updating, rectification, integration, cancellation, transformation into anonymous form, and blocking of data processed in violation of the law, including data no longer necessary to achieve the purposes for which they were collected;
• The restriction or opposition to the processing of data about you;
• The right to their portability, that is, to receive in a structured, commonly used, machine-readable format the personal data you provide;
• a complaint to the Data Protection Authority (Garante Privacy) about the collection and use of your personal information.
• The withdrawal of your consent after you have given it. The latter does not affect the legality of the processing carried out, nor does it affect the processing of your personal information conducted in relation to other legitimate bases for processing other than consent.

Larry Agency S.r.l. will take your request with the utmost effort to ensure the effective exercise of your rights.

Reference subjects

The Data Controller is Larry Agency S.r.l., whose registered office is located at via Gadames 109 – 20151 Milan, Italy, e-mail address [email protected]

To exercise user rights, request information on the purposes of processing and the Personal Data concretely relevant for each purpose or clarifications, users can address a request to the contact details of the Data Controller indicated in this document. Requests are filed free of charge and processed by the Holder as quickly as possible, in any case within one month.

Privacy Policy Updates

This Privacy Policy may be updated from time to time in response to ongoing legal, technical or commercial developments. We encourage you to visit this page periodically to stay up-to-date on the latest information pertaining to the policy.

Larry Agency’s Cookie Policy

Use of cookies on the website https://www.larryagency.com

In accordance with the provision of the Italian Data Protection Authority (hereinafter, the “Guarantor”) of May 8, 2014, on “Identification of simplified procedures for the provision of information and acquisition of consent for the use of cookies” (hereinafter, the “Cookies Provision”), Larry Agency S.r.l., Tax code/VAT number 12238020965, with registered office in Via Gadames 109, 20151- Milano, wishes to inform you of the following.

What are cookies?

Cookies consist of portions of code installed within the browser that assist the Owner in providing the Service in accordance with the purposes described. Some of the purposes of installing Cookies may, in addition, require the user’s consent.

When Cookies are installed on the basis of consent, that consent can be freely revoked at any time by following the instructions in this document.

More information about cookies can be found at the following websites:
www.allaboutcookies.org
www.youronlinechoices.eu.
Cookies can perform a number of functions, such as allowing you to navigate between pages efficiently, remembering your preferences, and in general can improve the user’s stay.

Sabanet S.r.l. reserves the right to use cookies, with your consent where applicable law or regulations so provide, to facilitate navigation on this site and personalize the information that will appear.

Below is a brief illustration of how Sabanet S.r.l. uses cookies and similar tools.

Technical and aggregate statistics cookies

• Activities strictly necessary for operation

This Web Site uses Cookies to save the user’s session and to perform other activities strictly necessary for the operation of this Web Site, such as in relation to traffic distribution.

• Preference saving activities, optimization and statistics

This Web Site uses Cookies to save your browsing preferences and optimize your browsing experience. These Cookies include, for example, those for setting language and currency or for statistics management by the Site Owner.

Other types of Cookies or third-party tools that may install them

Some of the services listed below collect statistics in aggregate and anonymous form and may not require user consent or may be operated directly by the Owner – as described – without the help of third parties.

If among the tools mentioned below are services operated by third parties, these may – in addition to what is specified and also without the knowledge of the Owner – perform user tracking activities. For detailed information on this, please consult the privacy policies of the listed services.

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 log out of the respective services to ensure that the data processed on this Web Site is not linked back to your profile.

Linkedin social button and widgets (LinkedIn Corporation)

The LinkedIn social button and widgets are LinkedIn social network interaction services provided by LinkedIn Corporation.

Personal Data Collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield adherent subject.

Facebook’s Like button and social widgets (Facebook, Inc.).

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

Personal Data Collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield adherent subject.

Instagram button and Instagram social widgets (Instagram, Inc.).

The Instagram button and Instagram social widgets are interaction services with the social network Twitter, provided by Twitter, Inc.

Personal Data Collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield adherent subject.

Protection from SPAM

This type of services analyzes traffic on this Web Site, potentially containing Users’ Personal Data, in order to filter it from parts of traffic, messages and content recognized as SPAM.

Google reCAPTCHA

Google reCAPTCHA is a SPAM protection service provided by Google LLC or Google Ireland Limited, depending on where this Web Site is used.
Use of the reCAPTCHA system is subject to Google’s privacy policy and terms of use.

Personal Data Collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield adherent subject.

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 Analytics is a web analytics service provided by Google LLC or Google Ireland Limited, depending on where this Web Site is used (“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 Collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out. Privacy Shield adherent subject.

How can I disable cookies?

Where you intend to disable one or more of the cookies used by this website, we suggest that you express your choices through the consent forms in this policy statement, as well as through the third-party consent forms that you can view through the links within this disclosure document.
Please also note that most browsers accept cookies automatically, but you can also choose not to accept them through the settings of the browser you use. It is recommended not to disable this feature, since this may prevent you from moving freely from one page to another and enjoying all the peculiarities of the site.
If you do not want your computer to receive and store cookies, you can change the security settings of your browser (Internet Explorer, Google Chrome, Safari etc.). In any case, please note that certain parts of our Site can only be used in their fullness if your browser accepts cookies; your choice to remove and not accept cookies may adversely affect your stay on our Site.
If you wish to change the use of cookies through your browser settings, the following are brief instructions on how to do this in the four most popular browsers:
Microsoft Internet Explorer
Click the ‘Tools’ icon in the upper right corner and select ‘Internet Options’. In the pop-up window, select ‘Privacy. Here you can adjust your cookie settings.
Google Chrome
Click the wrench in the upper right corner and select ‘Settings’. Now select ‘Show advanced settings’ (“Under the hood'”) and change the ‘Privacy’ settings.
Mozilla Firefox
From the drop-down menu in the upper left corner, select ‘Options’. In the pop-up window, select ‘Privacy’. Here you can adjust your cookie settings.
Safari
From the drop-down setting menu in the upper right corner, select ‘Preferences’. Select ‘Security’ and here you can adjust your cookie settings.
To learn more about cookies and how to manage or disable third-party or marketing/retargeting cookies, visit www.youronlinechoices.com.
To disable analytic cookies and to prevent Google Analytics from collecting data about your browsing, you can download the Google Analytics Disable Browser Add-on: https://tools.google.com/dlpage/gaoptout.

Your rights

The identification details of the Owner of the user’s data processing and the co-owner companies can be found in the Privacy information document.
The updated list of Data Processors, appointed for this purpose, can be found at the offices of the joint controllers. Those interested in taking a look at it can request the full list from the following e-mail address [email protected]
The user may, at any time and without any formality, exercise the rights under Art. 7 of Leg. n. 196/2003 – “Personal Data Protection Code” (hereinafter the “Privacy Code”), by sending a communication to the e-mail address [email protected]
For greater comprehensiveness, the text of Art. 7 of the Privacy Code:
Article 7 – Right of access to personal data and other rights
1. The interested party has the right to obtain confirmation of the existence or non-existence of personal data concerning him/her, even if not yet registered, and their communication in an intelligible form.
2. The data subject has the right to obtain the indication:
(a) of the origin of personal data;
(b) of the purposes and methods of processing;
(c) of the logic applied in the case of processing carried out with the aid of electronic instruments;
(d) of the identification details of the owner, managers and designated representative under Article 5(2);
e) of the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of them in their capacity as designated representative in the territory of the State, managers or appointees.
3. The data subject has the right to obtain:
(a) updating, rectification or, when interested, supplementation of data;
(b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including data whose retention is not necessary in relation to the purposes for which the data were collected or subsequently processed;
(c) certification that the transactions referred to in subparagraphs. (a) and (b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except where this proves impossible or involves the use of means manifestly disproportionate to the right protected.
4. The data subject has the right to object, in whole or in part:
(a) for legitimate reasons to process personal data concerning him/her, even if relevant to the purpose of collection;
b) to the processing of personal data concerning him/her for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication.

Read the privacy policy and choose the consents you wish to give Larry Agency. You can always change your choice and object to the processing of your data for sending commercial communications for the legitimate interest purposes described in the notice by contacting us at:

[email protected]