In short
- Fees, Measures and the Tax simulator do their calculations in your browser. What you type stays there.
- If you sign up for the newsletter you give us your email address, nothing else.
- We count visits with PostHog. Analytics cookies only start if you accept them. No advertising and no profiling.
Who processes the data
The data controller is Edgardo Maxia, architect, based in Cagliari, Italy. For any request about your data, write to info@lommo.it. We reply within one month. That is the deadline set by Regulation (EU) 2016/679, the GDPR.
The tools run in your browser
Fees, Measures and the Tax simulator run all calculations on your device: the amounts, the client's name and the job location you enter are not sent to any server, ours included. So that you do not lose your work, the browser keeps some information in its local storage (localStorage):
- the quote you are filling in and the ones you file with the "Save" button;
- your Kleckerburg high score;
- three technical reminders for the newsletter box, used to show it at the right time and not to show it again to people who have already signed up.
- your cookie choice, made in the box that appears on your first visit.
They stay on your device. We do not see them, and you can delete them whenever you want from your browser settings, by clearing the site data.
The newsletter
If you sign up, you give us your email address. Nothing else. We use it to send you the Lommo newsletter, usually one email a week, on Thursday.
Your subscription only becomes valid when you confirm it through the link in the first email: until you confirm, we do not write to you again. The legal basis is your consent (Article 6(1)(a) GDPR), which you can withdraw at any time.
The list is managed with Listmonk, an open source program installed on our own server at Hetzner, in Finland. The emails are sent through Brevo (Sendinblue SAS, France), which processes your address only to deliver them, as our data processor.
We count how many times each newsletter is opened, in aggregate and anonymous form. We do not record who opens it, which links you click or the IP address you signed up from.
At the bottom of every email there is a link to unsubscribe. From the same page you can download the data we hold about you or delete it completely. If you unsubscribe without deleting it, your address stays on the list with the status "unsubscribed", for the sole purpose of not writing to you again.
Training and Competitions
The Training and Competitions pages download their listings from one of our servers (cdn.lommo.it), which keeps no record of who downloads them. The listings show public information about courses and calls: when you open one, you move to the website of the body that runs it, which has its own privacy policy.
Visit statistics and cookies
To understand how many people use the site, where they come from and which tools they use, we rely on PostHog (PostHog Inc., United States), which processes the data on our behalf as data processor and stores it on its European Union servers, in Frankfurt. Our contract with PostHog includes the European Commission's standard contractual clauses. On your first visit, a box asks whether you accept analytics cookies.
If you accept, PostHog stores a cookie in your browser (ph_…_posthog, lasting one year) with a random code that recognises you when you come back. We record the pages you open, where you come from (the referring site or campaign), where you click and how long you stay, and we rebuild visits as a recording, to see where the site makes things hard. In the recordings the fields you fill in are hidden; in Fees and the Tax simulator all the text is hidden and clicks do not carry what is written, so amounts and client names do not leave your device. In the CAD, visits are not recorded, because the drawing stays on your computer. The legal basis is your consent (Article 6(1)(a) GDPR and Article 122 of the Italian Privacy Code).
If you decline, or until you choose, we count visits and clicks without cookies and without storing anything on your device. To tell one visit from another, PostHog computes a code that changes every day, starting from the IP address and the browser, and does not keep the IP address. No recordings. We do this on the basis of legitimate interest (Article 6(1)(f) GDPR): knowing how much the site is used, without being able to recognise you.
Statistics stay on PostHog for up to one year, recordings for one month. You can change your choice at any time from the "Cookies" link at the bottom of every page, or from here: change your cookie choices.
Third-party services and technical logs
- Hostinger (Hostinger International Ltd, Cyprus) hosts the site. Like any web server, it records in its logs the IP address, the browser and the time of each request, for security and to fix faults.
- Cloudflare manages the domain's DNS and, in front of the site, filters traffic against abuse: this is why it sees visitors' IP addresses. It is a US company and the data transfer is covered by the EU-US Data Privacy Framework.
- The Fees page loads the library that creates the PDF from cdnjs, also run by Cloudflare: this request carries your IP address too.
- The fonts are hosted by us, so no request goes out to Google Fonts.
- PostHog (PostHog Inc., United States, with the data on its European Union servers in Frankfurt) collects the visit statistics described above.
The site uses no profiling cookies and no advertising pixels. The only cookies are PostHog's analytics cookies, and they only start with your consent.
If you write to us
We keep the emails that reach info@lommo.it for as long as it takes to reply and follow up on the request.
Accounts and sign-up
Sign-up and the personal area are not active yet. When they arrive, this page will be updated before it becomes possible to create an account.
Your rights
At any time you can ask to access your data, correct it, delete it, restrict its use, object to its processing or receive it in a format another service can read (Articles 15 to 22 GDPR). Just send an email to info@lommo.it.
If you believe your data is being processed improperly, you can turn to the Garante per la protezione dei dati personali, the Italian data protection authority.
Changes
When something changes, for example when accounts arrive, we update this page and the date at the top.