Information regarding Article 13 of Regulation (EU) 2016/679
- Data controller
The Data Controller is Lenovys SRL, with registered office in via Aurelio Lampredi 3, Livorno (LI), who can be contacted at the following email and registered email addresses: [email protected]; [email protected]
- Data Protection Officer (DPO)
The Data Protection Officer, pursuant to Article 37 and the following of the GDPR, can be contacted at Lenovys SRL, via Viserba 20, Milan (MI), or at the email address: [email protected]
- Categories of data processed
The personal Data collected or obtained by Lenovys through their website may include: name and surname, age, date of birth, gender, e-mail address, home address, country of residence, professional role, information concerning the level of satisfaction regarding the interaction with the company and other similar information.
Personal data falling under the “special categories” classification may be provided when completing the “Work with us” section of the site, pursuant to Article 9 of GDPR, for example “data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation”. We would urge our users not to publish these personal data unless strictly necessary. In the event that any special categories of personal data are transmitted, Lenovys cannot be held liable in any way, nor receive any complaints whatsoever, since in this case processing would be permitted insofar as the data has been made manifestly public by the data subject, in compliance with Article 9.1.e) of the Regulation. However, we specify the importance, as already indicated above, of expressing explicit consent to the processing of the special categories of Personal Data, whenever the user decides to share such information. For screening purposes, Lenovys may analyse the professional social profiles freely available on the Internet (through LinkedIn, for example).
Data relating to allergies, food intolerances or to disabilities is requested exclusively for the management of organised events.
Your browsing history is also collected. IT systems and software procedures used to operate the data automatically acquire some information concerning web browsing during normal operation, the transmission of which is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified individuals, but which by its nature could, through associations and processing with data held by third parties, allow users or browsers to be identified. This category includes information on IP addresses, domain names of computers utilized by users connecting to the site, addresses in URI (Uniform Resource Identifier) notation regarding the requested resources, the time of the request, the method used to submit the request to the web server, the file size obtained in response, the numerical code indicating the status of the response given by the web server (success, error, etc.) and other parameters related to the operating system and the user’s computer environment. This data is used for the sole purpose of obtaining anonymous statistical information on the use of this website and to monitor that it is functioning correctly and to identify anomalies and/or inappropriate uses, and are deleted immediately after processing. The data could be used to ascertain liability in the event of hypothetical cybercrimes against the site or third parties.
- Purpose and legal basis of processing
Lenovys SRL processes personal data exclusively for purposes strictly connected with, and instrumental to, the management of client relationships (for example, the acquisition of preliminary information to entering into a contract and/or the need to undertake contracts). Specifically, processing is carried out by:
- the promotion and sale of products and services related to consulting, online training and classroom communication through their website and via newsletters;
- the sending of invitations to free and/or paid training events;
- personal interviews, questionnaires and surveys concerning the work of the data subject as well as recording the degree of customer satisfaction on the quality of the services and activity carried out by Lenovys;
- the organisation of training and informational events or networking activities with partners, which may sometimes be funded. It should be noted that in the case of registration for training courses financed by public and private bodies, the data will also be processed for the purpose of management and reporting of these activities and to comply with the provisions of the law and/or regulation (for example GDPR 948/2016, European Social Fund in synergy with the European Regional Development Fund, POR FSE 2014 2020 – Objective “investments in support of growth and employment”).
- the legal basis legitimising the aforementioned processing is Article 1.a) of GDPR in that processing is based on the user’s consent, which he/she is free to give or deny, and which can, in any event, be withdrawn 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 for limiting the possibility of carrying out the purposes for which it is required: i.e. receiving commercial communications, participating in events and/or activities, entering into contracts,
- fulfilling any obligations under applicable laws, regulations or community legislation, or satisfying requests from the authorities; this necessity represents the legal basis legitimising any subsequent processing. Providing the data necessary for these purposes is a legal obligation. The legal basis for processing personal data for the purposes referred to in section 3.2 is Article 1.a) of GDPR.
- Recipients, or categories of recipients, of the data
Personal data provided by users is communicated to third parties in order to carry out the services, requirements and purposes stated in the previous paragraph of this information, and only in the event that this is necessary to achieving that purpose. By way of example, data may be transmitted to the following: email marketing activity software providers; e-learning platform software providers, cloud data management software providers; customer relationship management software providers; public and private bodies financing courses organised by Lenovys; to Italian and foreign partners to jointly manage training and/or informational events.
These data are communicated to the relevant subjects in compliance with an obligation established by Law, Regulation or EU Legislation.
- Rights of the data subject
Pursuant to Articles 15 and subsequent of GDPR, the data subject has the right to request from Lenovys at any time, access to their personal data, its correction or erasure, or to object to its processing or request the restriction of its processing in the cases provided for by Article 18 of GDPR, as well as to obtain, in a structured, commonly used format, readable by automatic device, the data relating to him/her, in the cases provided for by Article 20 of GDPR.
Requests must be sent in writing to the Data Controller or to the DPO at the addresses specified in this information.
In any case, the data subject is at all times entitled to lodge a complaint with the competent Supervisory Authority (Data Protection Supervisor), pursuant to Article 77 of the Regulation, if the data subject considers that the processing of his or her Personal Data is contrary to existing legislation.
Latest document revision date: 25/05/2018