Privacy Policy

Disclosure Art.13 of EU Regulation No. 2016/679

1. Data Controller

The Data Controller is Lenovys SRL with registered office based in Livorno (LI), via Aurelio Lampredi 3 and can be contacted at the email and pec contacts: [email protected]; [email protected]

Data Protection Officer (DPO)

The Data Protection Officer ex art. 37 et seq. of the Regulation can be contacted at Lenovys SRL in Milan (MI), Viale Sarca 336/F - Building 16 - staircase H or at the mail contact: [email protected]

2. Categories of data processed

The personal data collected or obtained by Lenovys through the website may include: first and last name, age, date of birth, gender, e-mail address, country of residence, company role, information regarding the level of enjoyment of interaction with the company and other similar information.

When using the "Work with Us" section of the website, there may be a provision of personal data falling under the special categories of personal data referred to in Article 9 of the Regulations, i.e., "data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as dealing with genetic data, biometric data intended to uniquely identify a natural person, data concerning a person's health or sex life or sexual orientation." We urge our users not to publish such data unless strictly necessary. In the event of transmission of special categories of personal data, Lenovys cannot be held liable in any way, nor can it receive any objections whatsoever, since in such a case the processing will be permitted insofar as it relates to data manifestly made public by the data subject, in accordance with Article 9.1.e) of the Regulations. However, it is specified the importance, as mentioned above - to manifest explicit consent to the processing of special categories of Personal Data, should the user decide to share such information. Lenovys for the purpose of selection, may analyze social profiles of a professional nature made freely available on the Internet (e.g.: via LinkedIn).

Data related to allergies, food intolerances or disability data are requested only for the management of organized events.

Navigation data are also collected. The computer systems and software procedures responsible for the operation of the data, automatically acquire, in the normal course of operation, certain information inherent in web browsing, the transmission of which is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties but which by its nature could, through association and processing with data held by third parties, allow users or surfers to be identified. This category includes information relating to IP addresses, domain names of computers used by users who connect to the site, addresses in URI (Uniform Resource Identifier) notation of the resources requested, time of the request, the method used in submitting the request to the web server, the size of the file obtained in response, numeric code indicating the status of the response given by the web server (successful, error, etc.) and other parameters relating to the user's operating system and computer environment.

These data are used for the sole purpose of obtaining anonymous statistical information on the use of this website and to check its correct functioning, to identify anomalies and/or abuses, and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the website or third parties.

3. Data collected through cookies
See Cookie Policy at the following link https://www.lenovys.com/cookie-policy/

4. Purposes and legal basis of the processing

Lenovys SRL processes personal data exclusively for purposes strictly related and instrumental to the management of customer relationships (for example, acquisition of information prior to the conclusion of a contract and/or the need to execute contracts). In particular, the processing takes place for:

• the promotion and sale of products and services related to consulting, online and classroom training communicated through the website and through newsletters;
• the communication of invitations to free and/or paid training events;
• personal interviews, questionnaires and surveys related to the work activity of the interested party as well as the detection of the degree of customer satisfaction on the quality of services and the activity carried out by Lenovys;
• the organization of training and informational events or networking activities with partner entities, sometimes even funded. It should be noted that in the case of enrollment in training courses funded by public and private entities, the data will also be processed for purposes of management and reporting of the same activities and to comply with the provisions of laws and/or regulations (by way of example D.G.R. 948/2016, European Social Fund in synergy with the European Regional Development Fund, POR FSE 2014 2020 -Ob. "investments in growth and employment").
• the legal basis that legitimizes the aforementioned treatments is art. 6.1.a) of the Regulations in that the treatments are based on the user's consent, which he/she is free to give or not and can, in any case, revoke at any time. The provision of data necessary for these purposes is not mandatory and the refusal to provide it does not determine any negative consequence, except the impossibility of performing the purposes for which it is required: e.g. receiving commercial communications, participating in events and/or activities, concluding contracts;
• fulfilling any obligations under current laws, regulations or EU legislation, or fulfilling requests from the authorities; this need represents the legal basis that legitimizes the resulting processing. The provision of data necessary for these purposes represents a legal obligation. On the other hand, the legal basis for the processing of personal data for the purposes mentioned in section 3.2 is Article 6.1.c) of the Regulations.

5. Recipients or categories of recipients of data

The personal data provided by users are communicated to third parties in order to perform the service, the requested performance and the purposes expressed in the previous paragraph of this policy and only if it is necessary for that purpose. By way of example, the following are communicated: to software managers for email marketing activities; to software managers of e-learning platforms; to software managers for cloud data management; to software managers for customer relationship management; to public and private entities that finance the courses organized by Lenovys; to Italian and foreign partners for the joint management of training and/or information events.

These data are communicated to those parties to whom such communication must be made in fulfillment of an obligation required by law, regulation or EU legislation.

6. Rights of the interested parties

Pursuant to Articles 15 et seq. of the Regulation, the data subject has the right to ask Lenovys, at any time, for access to his or her personal data, to rectify or erase them or to object to their processing, to request the restriction of processing in the cases provided for by Article 18 of the Regulation, as well as to obtain in a structured, commonly used and machine-readable format the data concerning him or her, in the cases provided for by Article 20 of the Regulation.
Requests should be addressed in writing to the Data Controller or to the DPO at the contact details indicated in this policy.
In any case, the data subject always has the right to lodge a complaint with the competent Supervisory Authority (Guarantor for the Protection of Personal Data), pursuant to art. 77 of the Regulation, if he or she believes that the processing of his or her Personal Data is contrary to the legislation in force.

7. Changes

The Owner reserves the right to modify or simply update the content of this policy, in part or in full, including due to changes in applicable legislation. The Data Controller therefore invites its users to regularly visit this section to take cognizance of the most recent and updated version of the privacy policy so that they are always up to date on the data collected and the use made of it by Lenovys. To exercise the above rights or for any other request you can write to the Data Controller at the above physical address or through the dedicated email contact and contact the DPO directly preferably by including the words "Request to exercise privacy rights" in the subject line of the communication.

Date of last revision of the document: 25/5/2018