Privacy Policy

Information Notice on the Processing of Personal Data

Last revised: September 15, 2026

1. Introduction

1.1. LOCMAN S.P.A. (Tax Code 08504700157 and VAT No. 01190380491, Certified Email/PEC: locman@pec.locman.live), with registered office at Piazza Giovanni da Verrazzano, no. 7, 57034 – Campo nell’Elba (LI), Italy (hereinafter, “Locman”), in its capacity as the owner and operator of the website linked to the internet domain name “www.locman.live” (hereinafter, the “Website”). This document is provided for informational purposes only and does not constitute an instrument for granting consent, but is intended to fulfill the disclosure obligations regarding the processing of personal data (hereinafter, the “Privacy Policy”), pursuant to EU Regulation 2016/679 as amended (hereinafter, the “GDPR”) and applicable national legislation on personal data protection. Consent is collected through the cookie banner, which likewise informs users browsing the Website (hereinafter, the “User” or “Users”) about how their personal data (hereinafter, the “Data”) is managed, allowing them to provide express and informed consent to the processing of Data where required.
1.2. This Privacy Policy applies exclusively to this Website and does not extend to third-party websites that may be accessed by the User via links present on the pages of the Website.
1.3. By accepting cookie consent, the User acknowledges having carefully read this Privacy Policy, applicable both to browsing the Website and to any purchases, and accepts the purposes and methods of Data processing set forth herein. If the User does not agree to accept, at least, the strictly necessary cookies for the proper functioning of the Website, the User is invited to leave the Website and, in any event, not to use its content and/or services.
1.4. All Data submitted by the User (first name, last name, email address, telephone number, etc.) is collected, stored, and processed exclusively in accordance with the GDPR.
1.5. “Processing” of personal data means any operation or set of operations, performed with or without the aid of automated processes, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of Data, even if not recorded in a database (hereinafter, “Processing”).

2. Data Controller

2.1. Locman is the Data Controller for the Processing activities described herein.
2.2. Locman’s contact details are as follows:
2.2.1. Company Name: LOCMAN S.P.A.;
2.2.2. Registered Office Address: Piazza Giovanni da Verrazzano, no. 7, 57034 – Campo nell’Elba (LI), Italy;
2.2.3. Certified Email (PEC): amministrazione.locman@pec.locman.live;
2.2.4. Email: info@locman.live;
2.2.5. Tax Code: 08504700157;
2.2.6. VAT No.: 01190380491.

3. Data Subject to Processing

3.1. The following Data is subject to Processing:
3.1.1. Browsing Data: The hardware and software systems of the Website acquire certain Data whose transmission is implicit in the use of Internet communication protocols. This information could, through processing and association with data held by third parties, allow Users to be identified. This category includes the IP addresses of the devices used by Users connecting to the Website, 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 server response (successful, error, etc.), and other parameters related to the User’s operating system and IT environment. We may also receive information regarding the geographical location (in particular continent and country) of the User and their electronic device. This Data is used solely to obtain anonymous statistical information on Website usage and to verify its proper functioning, and is deleted immediately after processing. The Data may be used to establish liability in the event of hypothetical cybercrimes against the Website. Geographical location Data may be used to provide location-based information, proposals, and personalized content. Users who do not wish to share geographical location information must disable location services on their devices;
3.1.2. Data provided voluntarily by the User: Data entered on the Website by the User (when registering a user profile on the Website and/or purchasing products on the e-commerce platform linked to the Website), as well as Data sent by the User via email to the email addresses indicated on the Website (including the sender’s email address and any other Data included in the communication);
3.1.3. Purchase Data: When purchasing products via the e-commerce platform linked to the Website, Data provided by the User during the checkout and purchasing process;
3.1.4. Cookies: The Website uses cookies to make User browsing easier, faster, and more intuitive, and to ensure optimal Website operation. For more information regarding cookies used on the Website, please refer to the comprehensive Cookie Policy.

4. Purposes of Processing

4.1. Locman processes Users' Data for the following purposes (hereinafter, “Purposes”):
4.1.1. To enable the creation of User profiles and send confirmation emails upon registration on the Website;
4.1.2. To enable the purchase of products via the e-commerce platform linked to the Website and, therefore, finalize transactions, deliver purchased products, handle exchange/return requests, or issue refunds;
4.1.3. To create a database containing information regarding location (as indicated above), access times, browser type, and actions performed on the Website. The primary use of this Data is to improve the User’s experience on subsequent visits and enhance promotional and marketing activities both on and off the Website;
4.1.4. To manage technical, commercial, and general User inquiries;
4.1.5. To comply with legal obligations (including tax and accounting duties) and protect legitimate rights;
4.1.6. To send email communications to Users regarding products and services similar to those already requested/purchased by the User (so-called "soft spam");
4.1.7. For marketing purposes, including sending newsletters and/or other promotional communications via email;
4.1.8. For profiling purposes, namely the analysis of preferences aimed at creating personalized content and offers.

5. Legal Basis for Processing

5.1. In accordance with EU Regulation 2016/679 (GDPR), Locman processes your personal data only when one of the legal grounds established by Article 6 applies. The legal bases applicable to our e-commerce operations are as follows:
5.1.1. Performance of a contract or pre-contractual measures (Art. 6(1)(b) GDPR): We process your Data (such as name, shipping address, and email) to process orders, manage delivery of purchased products, handle payments via payment gateways on the Website, and provide customer support (after-sales service).
5.1.2. Compliance with a legal obligation (Art. 6(1)(c) GDPR): We process your billing and transaction data to comply with statutory legal obligations of a tax, civil, and accounting nature (e.g., issuing electronic invoices or tax receipts, maintaining accounting records).
5.1.3. Legitimate interest of the Data Controller (Art. 6(1)(f) GDPR): We process data related to transactions and browsing to guarantee platform cybersecurity, prevent fraud or scams in online payments, and send email communications regarding products similar to those already purchased (soft spam, unless you object).
5.1.4. Consent of the Data Subject (Art. 6(1)(a) GDPR): We request your explicit consent for optional activities not strictly necessary for purchase completion, such as subscribing to our promotional newsletter, sending targeted marketing offers, or using profiling and tracking cookies.

6. Methods and Place of Data Processing

6.1. Data processing is carried out primarily using electronic and telematic tools, with logics strictly related to the purposes indicated above and in such a way as to guarantee the security and confidentiality of the Data in compliance with the GDPR.
6.2. Locman has implemented technical solutions and security measures to ensure Data security and prevent alteration, loss, improper processing, or unauthorized access.
6.3. Processing related to Website services may take place on servers of third-party companies providing hosting and cloud services on behalf of Locman.
6.4. In the event of Data transfers outside the European Union, such transfers will take place ensuring adequate levels of Data protection, in accordance with applicable personal data protection regulations pursuant to Articles 45 and 46 of the GDPR.

7. Disclosure of Data to Third Parties

7.1. Data collected and stored in Locman’s databases will be processed by its employees and/or collaborators (as well as employees of companies managing retail points of sale on behalf of Locman) designated as authorized persons to process Data pursuant to Art. 4(10) of the GDPR.
7.2. User Data may also be processed by third-party companies that Locman engages to perform activities on its behalf (e.g., data analysis, data hosting/storage, sending newsletters or other commercial/non-commercial communications, marketing support, market research, delivering purchased goods, managing credit card payment platforms, and customer care services).
7.3. Locman provides these entities solely with the Data necessary to perform agreed activities; such entities act as Data Processors pursuant to Art. 4(8) of the GDPR (hereinafter, “Data Processors”). These providers have been selected as they possess suitable experience, capacity, and reliability, and are capable of ensuring full compliance with current privacy laws. The User may request the updated list of Data Processors by writing to “privacy@locman.live”.
7.4. Regarding the scope of Data communication, Data provided by the User or otherwise collected may be disclosed to the following entities or categories of entities:
7.4.1. Public authorities and bodies, in fulfillment of statutory legal obligations, regulations, or national/EU laws;
7.4.2. Parent companies, subsidiaries, and/or affiliates of Locman;
7.4.3. Other companies or individuals contractually bound to Locman and specifically appointed to process Data on Locman’s behalf.

8. Nature of Data Provision

8.1. Certain fields requested on the Website (which may be marked with an asterisk or other symbol) may be mandatory, for instance, to allow valid registration on the Website, to supply products to be purchased, and to process user inquiries.
8.2. By entering Data on the Website, the User guarantees that the personal information provided is accurate and up to date. Furthermore, the User acknowledges being solely responsible for the Data provided (whether personal data, photos, comments, etc.), holding Locman harmless from any liability.
8.3. Providing Data that Locman may process for marketing and profiling purposes is entirely optional. Failure to provide consent for such purposes, or subsequent withdrawal thereof, does not affect the User's ability to browse the Website and/or make purchases.

9. Withdrawal of Consent

9.1. The User may withdraw consent for marketing activities (including newsletter delivery) and/or profiling at any time by sending an email to “privacy@locman.live”. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
9.2. For cookie management, please refer to the sections “Cookie Management” and “How to disable and/or delete cookies through browser settings” in our Cookie Policy.

10. Minors

10.1. The newsletter service is not intended for minors under 16 years of age, or minors whose age makes processing of their Data unlawful or requires parental consent under local laws (hereinafter, “Age Limit”).
10.2. Locman does not knowingly collect Data from minors below the Age Limit. Locman requests that anyone under the Age Limit refrain from subscribing to the newsletter and from providing any personal data.
10.3. If you are a parent or legal guardian of a minor below the Age Limit and become aware that your child has provided Data to Locman, please contact us by email at “privacy@locman.live”. We also remind you that you may exercise the rights described in the "Users' Rights" section of this Privacy Policy.
10.4. If Locman becomes aware that it has collected Data from a minor below the Age Limit, it will take reasonable steps to delete the relevant Data promptly.
10.5. In any event, by registering on the Website or voluntarily submitting Data to the Website, the User confirms that they are above the Age Limit.

11. Data Retention Period

11.1. Data processed in the course of business is retained by Locman for the time strictly necessary to achieve the specific purposes of each Processing activity and to ensure compliance with applicable legal provisions.
11.2. Data processed for the performance of contractual obligations, including pre-contractual activities, is stored by Locman for 10 (ten) years following performance of the sale contract via the Website or, if the contract is not finalized, for the time necessary to respond to User inquiries.
11.3. Data processed in the context of corporate accounting management and record-keeping is retained for the time necessary to fulfill statutory tax, statutory, and accounting retention requirements.
11.4. Data processed by Locman for "soft spam" activities will be processed until the User objects to processing, which may be exercised by sending an email to “privacy@locman.live”.
11.5. Purchase Data collected for marketing and profiling purposes with the User’s consent may be retained for up to 7 (seven) years, following a Data Protection Impact Assessment (DPIA) conducted by Locman and in accordance with guidelines issued by the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali) in comparable sectors. Beyond this period, Locman will seek renewed consent or delete the Data from its databases.
11.6. Email addresses collected for newsletter subscription will be retained until the User withdraws consent, in accordance with the “Withdrawal of Consent” section of this Privacy Policy.
11.7. Regarding retention periods for data collected via cookies installed on the Website, please refer to the section “Cookies installed on the Website” in our Cookie Policy.

12. Users' Rights

12.1. Users may at any time exercise their statutory rights under personal data protection legislation pursuant to Articles 15–22 of the GDPR, including the right to:
12.1.1. Obtain confirmation from the Data Controller as to whether personal data concerning them is being processed, and where that is the case, obtain access to the personal data, the purposes of processing, the categories of data concerned, the recipients or categories of recipients to whom data has been or will be disclosed, the retention period (or criteria used to determine it), and where data is not collected from the data subject, all available information as to its source, and the existence of automated decision-making, including profiling (Art. 15 GDPR);
12.1.2. Obtain from the Data Controller without undue delay the rectification of inaccurate personal data concerning them, and have incomplete personal data completed (Art. 16 GDPR);
12.1.3. Obtain from the Data Controller the erasure of personal data concerning them without undue delay (Art. 17 GDPR);
12.1.4. Obtain restriction of processing where the accuracy of the data is contested; where processing is unlawful and the User opposes erasure; where the User requires the data for legal claims; or where the User has objected to processing pending verification of legitimate grounds (Art. 18 GDPR);
12.1.5. Receive personal data concerning them in a structured, commonly used, and machine-readable format, and transmit those data to another controller without hindrance (Art. 20 GDPR);
12.1.6. Object at any time, on grounds relating to their particular situation, to processing of personal data based on Art. 6(1)(e) or (f), and object at any time to processing for direct marketing purposes, including profiling (Art. 21 GDPR);
12.1.7. Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them (Art. 22 GDPR);
12.1.8. Lodge a complaint with the competent supervisory authority (in Italy, the Garante per la Protezione dei Dati Personali – www.garanteprivacy.it).
12.2. Requests to exercise rights should be addressed in writing to the Data Controller's email contact: privacy@locman.live.
12.3. Requests will be handled without undue delay and, in any case, within one month of receipt. This period may be extended by up to 2 (two) additional months where necessary, taking into account the complexity and number of requests. In such cases, the Data Controller will inform the User of any such extension and reasons for delay within one month of receipt. If the Data Controller does not take action on the request, it will inform the User without delay, and at the latest within one month, of the reasons for not taking action and of the possibility of lodging a complaint with a supervisory authority.

13. Amendments to this Privacy Policy

13.1. This Privacy Policy may be subject to amendments and updates. Users are encouraged to review it periodically.