Privacy policy provided pursuant to articles 13-14 of the GDPR 2016/679

In accordance with the provisions of the regulation EU n. 679/2016, "on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC" (hereafter "regulation" or "GDPR"), this privacy policy is intended to illustrate the methods and the purposes with which the data of users who visit the website (hereafter "website") are collected, recorded and used.

This privacy statement refers only to the site and not to other websites accessed via links on its pages.


  • LELLIMAR Srl – VAT 02377300591 – Largo Albani, 3 04024 Gaeta (LT)
    Email: This e-mail address is being protected from spambots. You need JavaScript enabled to view it – Certified E-mail: This e-mail address is being protected from spambots. You need JavaScript enabled to view it
    Tel. +39.0771.464410 Fax. +39.0771.464055

The controller and responsible of this privacy policy in accordance with the provisions of the regulation EU n. 679/2016 (hereafter "controller"), identified in the person of the sole director of the aforementioned company, is:

  • LUIGI LELLI – Largo Albani, 3-4 04024 Gaeta (LT) – e-mail: This e-mail address is being protected from spambots. You need JavaScript enabled to view it certified e-mail: This e-mail address is being protected from spambots. You need JavaScript enabled to view it

The controller informs that:

  • within the company's employees, sub-processors have been appointed to process personal data in order to fulfil the duties of data controller;
  • the data provided by the interested parties through the various collection channels, directly or indirectly managed by the controller, or acquired from third parties in compliance with legal conditions, will be treated lawfully and fairly, in compliance with the regulations established by the EU and Italian regulations;
  • the site is hosted on machines managed by a third-party company: Aruba S.p.A. – Tax code/VAT: 01879020517.


The collection and the consequent treatment are carried out by the controller at the company's offices, in compliance with the safety measures and prescriptions imposed by the above-mentioned standards, or by subjects delegated by it (specially selected and equipped with the necessary professionalism), with manual procedures and computerized, in order to execute specific requests of the interested party, for contractual and pre-contractual obligations, for ordinary administrative, financial and accounting activities, to ensure the correct management of customers during the marketing and sale of services, for post-sales assistance, for the fulfilment of legal obligations.

Data falling into the definition of "special" (as defined by article 9 clause 1 of the GDPR), will be destined solely to the fulfilment of the contractual obligations and the legal activities required or necessary for the complete fulfilment of the agreement.


The processed data will never be transferred outside of the EU, for no reason whatsoever, unless it's a lawful request by the judicial authority and only in the cases provided for by the law.


The data provided by the users are used for the sole purpose of executing the services requested and stated in the processing purposes and are communicated to third parties only in the case in which such action would be necessary. Data are processed for the whole time necessary to the execution of the service requested by the user, or for the time requested by the purposes described in this document and for the next ten years from the date of acquisition. The user may always request the interruption of the processing or the elimination of the data.


Pursuant to article 6 of the GDPR "lawfulness of processing", the controller will retain Your data, normal and personal, because:

  • the subject has stated his consent to process his data falling into the definition of "special" (as defined by article 9 clause 1 of the GDPR) for one or more specific purposes (clause 1a);
  • its processing is necessary for the performance of a contract to which the data subject is party (clause 1b);
  • its processing is necessary for compliance with a legal obligation (clause 1c).


The controller processes the personal data, the contact details and the bank address, as well as other data necessary to fulfil Your demands or complete any undertaken tasks. The conferment is therefore mandatory, since without granting consent or with its annulment it is not possible to process such data.

It is also necessary to point out that any incorrect or insufficient communication of the requested data may lead to the total or partial impossibility of executing the requests of the interested party or to the obligations connected to the commitments undertaken, with consequent possible mismatch of the results of the processing with the agreements taken or the obligations imposed by rules and regulations.

The other data are instead collected for the sole purpose of adapting the promotional campaigns, the services offered and, in general, the business activity, to the interests of the customers and any other party involved. The conferment of this other data is therefore not mandatory, and any denial of processing or annulment of consent does not affect the establishment or the continuation of the main agreement.


The IT system and the software used for the web portal of the company collect, during their normal operation, some personal data which transmission is implicit in the use of the internet.

This data is not stored to identify the users but, by their own nature, may, through the processing and the association with other data managed by third parties, allow the identification of the user.

This type of data comprises IP addresses and the DNS used by the user to connect to the website, the URL of the requested resource, the time of such request, the method used to send the request to the server, the dimension of the received file, the numeric code used to identify the state of the response given by the server (executed, error, etc.) and other parameters related to the OS and to the user's computer.

This kind of data is used only to gather anonymous statistics about the use of the website and to check its correct functioning. This data is generally erased right after being processed. This data can be used and provided to the police and the tribunal to ascertain liabilities in the event of any damage to the website or any crime committed through the internet.


Compiling any Form on the website entails the acquisition of the data into the memory of the system. This data is protected by an authentication system and can be used only by those who are in possess of the access credentials. Furthermore, this data is adequately updated and protected based on the best procedures available.

Requesting any information via email entails the acquisition of the email address of the user which is necessary to answer to any request from the sender. This includes any data in the message.

the controller suggests to his clients, during their requests for services and information, not to transmit the data or personal information of third parties, unless it is absolutely necessary.


Personal data is collected for the following purposes and to use the following services:

Contact the user

Contact form

The user, by filling in the contact form with his own data, consents to their use to respond to requests for information, quote, or any other nature indicated by the form header. personal data collected: surname, name, email and telephone number.

SPAM protection – Privacy Policy

this type of service analyses the traffic of this site, potentially containing personal data of users, in order to filter it from parts of traffic, messages and contents recognized as SPAM.

Google reCAPTCHA (Google Inc.)

Google reCAPTCHA is a SPAM protection service provided by Google inc.. Use of the reCAPTCHA system is subject to the privacy policy and terms of use of Google.

Personal data collected: Cookies and usage data.

Prosessing location: United States – Privacy Policy.

Statistics – Privacy Policy and disabling

Services included in this section allow the controller to monitor and analyse traffic data and are used to track the user's behaviour.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. ("Google"). Google uses personal data collected with the purpose of tracking and examine this website's usage, draft reports and share them with the other services developed by Google. Google may use this personal data to customise advertisements from its own network. Personal data collected: cookie and usage data.

Processing location: United States – Privacy PolicyOpt Out.

Google Fonts – Privacy Policy

This kind of services allow to visualise content hosted on third party platforms directly from the pages of this website and to interact with them. If this kind of service is installed it is possible that for it to collect traffic data of the pages in which it has been installed even if the users are not using it.

Google Fonts (Google Inc.)

Google Fonts is a font visualisation service managed by Google Inc. which allows its content to be used on the pages of this website. Personal data collected: usage data and various kinds of data as specified by the privacy policy of the service.

Processing location: United States – Privacy Policy.

TAG management – Privacy Policy

This kind of services are used to centralise the management of tags or scripts used on this website. The use of such services entails the flow of the user's data through them and hence their retention.

Google Tag Manager (Google LLC)

Google Tag Manager is a tag management service provided by Google LLC.

Personal data collected: Cookies and usage data.

Processing location: United States – Privacy Policy.


Cookies are files that leave traces on the memory of the user's machine, it is not an executable file nor a virus. The purpose of these cookies is purely statistical, with the purpose to understand which sections of the website are more frequently visited and through which paths, time of stay, ultimately to improve the quality of the service. This data does not identify the user personally. Most browsers automatically accept these cookies, although it is possible to disallow them by changing the browser settings. failure to approve their use may not allow complete navigation within the website.

The website and its administrator do not have any control on the cookies provided by third parties. It is advisable to consult the privacy policy of these third parties as well as the settings to disable the collection of this data.

Cookies are not used to transmit personal data, nor does the website use any kind of "persistent" cookies, which purpose is to track users. The usage of "session" cookies (which are not persistently memorised on the user's computer and vanish after closing the browser) is strictly limited to the transmission of session identity data (composed of random numbers generated by the server) necessary to allow a safe and efficient browsing of the website. "session" cookies used on this website avoid the use of other computer techniques that are detrimental to the privacy of the users' browsing and do not allow the acquisition of the user's personal identification data. However, this website uses third party profiling "cookies" (Google Analytics), described in the previous paragraph. To disable such cookies please consult the section "processing purposes and methods".

It is possible to disable tracking cookies directly from the browser.

For more detailed information about how to disable cookies, below are links to the configuration of the most popular browsers.

Mozilla Firefox
Information on how to disable cookies on Firefox

Google Chrome
Information on how to disable cookies on Chrome

Microsoft Edge
Information on how to disable cookies on Edge

Apple Safari
Information on how to disable cookies on Safari for Mac

Information on how to disable cookies on Opera


Users can exercise certain rights regarding the data processed by the controller. in case of higher protection, the user can exercise all the rights listed below. in any other case, the user can contact the controller to find out what rights are applicable in his case and how to exercise them.

In particular, the user has the right to:

  • Revoke Consent at any time. The user can revoke the consent to the processing of his/her personal data previously expressed.
  • Oppose the processing of their. The user may object to the processing of their data when it occurs on a legal basis other than consent. further details on the opposition right are listed in the section below.
  • Access their data. The user has the right to obtain information on the data processed by the controller, on certain aspects of the processing and to receive a copy of the processed data.
  • Verify and ask for rectification. The user can verify the correctness of their data and request its updating or correction.
  • Obtain the processing limitation. When certain conditions are met, the user can request the limitation of the processing of their personal data. in this case the controller will not process the data for any other purpose than to preserve them.
  • Obtain the cancellation or removal of their personal data. When certain conditions are met, the user can request the deletion of their data by the controller.
  • Receive their data or have it transferred to another controller. The user has the right to receive their data in structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain the transfer without obstacles to another controller. This provision is applicable when the data is processed by automated tools and the processing is based on the user's consent, on a contract of which the user is a party or on contractual measures connected to it.
  • To lodge a complaint. The user can lodge a complaint to the competent personal data protection control authority or act in court.


When personal data are processed in the public interest, in the exercise of public powers vested in the controller or in pursuit of a legitimate interest of the controller, users have the right to oppose the processing for reasons connected to their particular situation. users are reminded that, if their data is processed for direct marketing purposes, they can oppose the processing without giving any reason. to find out if the controller is processing data for direct marketing purposes, users can refer to the respective sections of this document.

How to exercise rights

To exercise their rights, users can send a request to the contact details of the controller indicated in this document. requests are filed free of charge and processed by the controller as soon as possible, in any case within one month.

Applicability of higher protection level

While most of the provisions of this document apply to all users, some are expressly subject to the applicability of a higher level of protection to the processing of personal data.

Such higher level of protection is always guaranteed when the processing:

  • Is executed by a controller based in the EU
  • It concerns personal data of users who are in the EU and is functional to offering goods or services for consideration or free of charge to such users
  • It concerns personal data of users located in the EU and allows the holder to monitor the behaviour of such users insofar as such behaviour takes place within the EU


Defence in court

The user's personal data may be used by the controller in court or during the commencement of the proceedings for the defence against abuse in the use of this website or of the connected services by the user. The user declares to be aware that the controller could be obligated to disclose the data by order of the public authorities.

Specific information

Upon user's request, in addition to the information contained in this privacy policy, this website could provide the user with additional and contextual information regarding specific services, or the collection and processing of personal data.

System log and maintenance

For needs related to operation and maintenance, this website and any third-party services it uses may collect system logs, i.e. files that record interactions and that may also contain personal data, such as the user's IP address.

Information not included in this privacy policy

Further information related to the processing of personal data can be requested at any moment to the controller by using the contact details in this document.

About "Do Not Track" requests

This website does not support "Do Not Track" Requests. To find out if any third-party services used support them, the user is invited to consult the respective privacy policies.

Changes to this privacy policy.

The controller reserves the right to make changes to this privacy policy at any time by informing users on this page as technically and legally feasible, by sending a notification to users through one of the contact details of which the controller is in possession. therefore, please consult this page regularly, referring to the date of the last modification indicated at the bottom.

If the changes involve processing whose legal basis is consent, the holder will again collect the user's consent, if necessary.


Personal Data (Data)
Personal Data is any information that, directly or indirectly, even in connection with any other information, including a personal identification number, makes an individual identified or identifiable.

Usage Data
The usage data is the information automatically collected through this website (also from third-party websites integrated in this website), including: the IP addresses or domain names of the computers used by the user that connects with this website, the URI (Uniform Resource Identifier), the time of the request, the method used in forwarding the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response from the server (successful, error, etc.), the country of origin, the characteristics of the browser and the operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details related to the itinerary followed within the website , with particular reference to the sequence of the pages consulted, the parameters relating to the operating system and the IT environment of the user.

The user is the individual that uses this website that, unless otherwise specified, coincides with the interested party.

Interested Party
The interested party is the individual to which the personal data refer to.

Person in Charge of the Privacy Policy (Person in Charge)
The natural person, legal person, public administration and any other entity that processes personal data on behalf of the controller, according to what is stated in this privacy policy.

Controller of the Privacy Policy (controller)
The controller is the natural or legal person, the public authority, the service or other body that, individually or together with others, determines the purposes and means of the processing of personal data and the instruments adopted, including the security measures relating to the operation and use of this website. The controller of the privacy policy, unless otherwise specified, is the controller of this website.

This Website (Website)
This website is the hardware or software tool through which users' personal data are collected and processed.

Service indicated the various services provided by this website.

European Union (EU)
Unless otherwise specified, any reference to the European Union contained in this document is intended to be extended to all current member states of the European Union and the European Economic Area.

Cookies are a small portion of data stored in the user's machine.


  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 - on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)
  • Legislative decree 196/2003 - regulations regarding the protection of personal data (in the parts not repealed)
  • Guidelines and provisions of the European Data Protection Board (WP29)
  • Legislation 2002/58/CE of the European Parliament, regarding cookies.


The possible entry into force of new sector regulations, as well as the constant updating of services and the site, could entail the need to modify the methods and terms of this information. For that reason, it is possible that this document will change over time. We invite you, therefore, to periodically consult this section of the site.

We will publish any changes to this privacy policy on this page and, if the changes are relevant, we will notify you with visible and appropriate notification.

Previous versions of this privacy policy are archived to allow their consultation.

Gaeta, 08/11/2019 – Version 1

Largo Albani, 3-4 − 04024 Gaeta LT • Tel +39.0771.461750 Fax +39.0771.464055


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