GDPR and use of data - Lead Champion

Lead Champion discover

1.1 Data processing

1.1.1 Ownership of data

Neosperience S.p.A. guarantees that the configuration, settings and traffic data collected through the Lead Champion discover service are unique property of the customer on whose site (s) the Lead Champion discover service is active.

The data controller is the customer who uses the Lead Champion discover service.

As the technology provider, Neosperience S.p.A. with registered office in Italy, via Orzinuovi 20, 25125 – Brescia, VAT number: 02792030989, guarantees that the data will be treated according to the principles of confidentiality, transparency and following any applicable principle in accordance with the law, in accordance with the European Regulation on the protection of data and natural persons to whom they refer.

1.1.2 Navigation data and processing purposes

The Lead Champion discover service verifies, solely and exclusively with reference to the data of economic operators, how many visits a site receives, and acquires some 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 allow users, only legal persons, to be identified through processing and association with data held by third parties and published in public registers.

This category of data includes the IP addresses of the servers used by users in Internet browsing that connect to the site, the method used in submitting 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 associated with the software used for access to the Internet and the computer environment used by the user.

These are collected on behalf of Lead Champion discover customers for the following purposes:

carry out web analytics activities to evaluate the profitability of each online activity and understand the behaviors of users in order to improve online communication;
monitor the achievement of its marketing objectives and optimize the functionality of the site;
obtain anonymous statistical information on the use of the site for lead generation purposes or to automatically identify without explicit registration the names of the companies and entities that visit the site;
check the correct functioning of the site.

Lead Champion discover complies with the privacy regulations currently in force in Italy and within the European Union.

In particular, Lead Champion discover complies with Legislative Decree 679/2016 – so-called General Data Protection Regulation (GDPR) as:

does not track personal data that can be traced back to people, but exclusively to economic subjects (companies). In particular, IP addresses are not made available on Lead Champion discover in order to prevent any possible use of personal data
all data is kept within the European Union, in particular in data centers located in Italy and Ireland
each user can access the opt-out link available on the Lead Champion website and block tracking by the service. This opt-out allows you to avoid tracking by Lead Champion discover at the individual user level – therefore the data of the economic subject can be tracked during a website visit made by other users belonging to the same organization.
corporate data are not applicable under the GDPR – which is meant to protect personal data. Therefore, most of the Lead Champion solution and its features are not relevant to the GDPR.

Each site that uses Lead Champion discover must include in its privacy policy the text shown on the cookie information page available at the following link: https://leadchampion.com/cookie-regulations/

1.1.3 Storage and Retention of Data

The data contained in the Lead Champion discover solution are processed and stored within the European Union, in data centers located in Italy and Ireland.

The data of each customer can be deleted promptly at the customer’s request.

Any request for cancellation can be forwarded by the customer to the email address: [email protected] .

1.2 Use of data

1.2.1 Use of data by Neosperience

Neosperience undertakes not to use the data collected for marketing or sales activities and not to transfer such data to third parties for any use.

The processing of the collected data is carried out in a computerized and manual way. The data will not be communicated to other subjects nor will they be disseminated.

The data collected through the Lead Champion discover service is stored through the main cloud computing services located within the European Union.

1.2.2 Use of data by the customer

The data presented through Lead Champion discover are public data referring to economic subjects, therefore prior consent is not required because the legislator wants to protect transparency in the conduct of economic activities. In particular, the personal data protection code – Legislative Decree 30 June 2003, n. 196 updated with the amendments made by Law 27 December 2019, n. 160, by Legislative Decree 14 June 2019, n. 53, by Ministerial Decree 15 March 2019 and by the Decree adapting to the GDPR (Legislative Decree 10 August 2018, n. 101, in article 24 reads:

“…consent is not required when: […]”

c) concerns data from public registers, lists, acts or documents known to anyone, without prejudice to the limits and methods that laws, regulations or Community legislation establish for the knowledgeability and publicity of the data;

“d) concerns data relating to the performance of economic activities, processed in compliance with current legislation on business and industrial secrecy;”

It is therefore specified that the nature and structure of the Lead Champion discover database legitimately dispenses with the collection of consent to allow the use of the data processed by Lead Champion discover.

With regard to the use of data by customers, contact activities can be carried out without the need for prior consent, with regard to emails sent to email addresses referring to functions of legal entities (e.g. info@…. of a limited company).

In addition to the above, it is recalled that regardless of the origin and nature of the data, the Guarantor for the protection of personal data has reminded that consent is not transferable: for this reason to use a contact database acquired from third parties, it is necessary to obtain feedback and consent for the sending of further promotional communications. Consequently, it is possible to send a communication to a list of prospects, taking care to include the information for the processing of personal data (art. 13 of Legislative Decree 196/03 and subsequent amendments and additions), in which consent is required for the sending of promotional material. The message must therefore be purely informative and not markedly commercial (therefore it is not appropriate to enter prices, discounts or slogans), however it can allow:

describe your company;
connote the message with your corporate image;
introduce the services that you can propose;
allow further details through a link to the website or products;
include all the ways in which you can be contacted.

The form of anonymous contact is obviously not allowed and the user must have the possibility to request deletion from the list.

The telephone numbers on Lead Champion can always be used for marketing purposes, except those present in the Public Registry of Oppositions, which can be consulted through the following website: http://www.registrodelleopposizioni.it

Lead Champion booster

1.1 Data processing

1.1.1 Ownership of data

The data controller is the customer who uses the Lead Champion booster service.

1.1.2 Consent

Each customer is required to obtain explicit consent from visitors for the processing of data released through Lead Champion booster. In particular, this consent must include the tracking of the actions carried out on the site by the user.

To this end, Lead Champion booster provides in each form the checkbox for the explicit acceptance of the customer’s privacy policy.

Each site that uses Lead Champion booster must include in its privacy policy the text shown on the Lead Champion site on the cookie information page available at the following link: https://leadchampion.com/cookie-regulations/

1.1.3 Storage and Retention of Data

The data contained in the Lead Champion booster solution is processed and stored within the European Union, in data centers located in Italy and Ireland.