Personal Data process Information Art.13 of UE Regulation 679/2016

1. Data controller

The Data Controller is Luciano Attolico that can be contacted at the e-mail contacts and: lenovys@pec.it; privacy@lenovys.com

2. The 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), via Viale Sarca 336/F – Edificio 16 – scala H or at the e-mail address: privacy@lenovys.com

3. Categories of data processed

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

When using the “Work with us” section of the website, a provision of personal data may occur that falls within the special categories of personal data referred to in art. 9 of the Regulation, that is “data capable of revealing racial or ethnic origin, political opinions, religious or philosophical convictions, or trade union membership, as well as processing genetic data, biometric data intended to uniquely identify a natural person, data relating to the person’s health or sexual life or sexual orientation”. We encourage our users not to publish such data unless strictly necessary. In the event of transmission of special categories of personal data, Lenovys may not be held responsible for any reason or receive any dispute, because in this case the processing will be allowed as it must object data made public by the interested party, in accordance with art. 9.1.e) of the Regulation. However, it is important, as already mentioned above – to express explicit consent to the processing of special categories of Personal Data, where the user decides to share this information. Lenovys for selection purposes, could analyze the professional social profiles made freely available on the Internet (e.g.: via LinkedIn).

Data relating to allergies, food intolerances or disability are required exclusively for the management of organized events.

Browsing data is also collected. The computer systems and software procedures used to operate the data automatically acquire, in normal operation, some information related to web browsing whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified data subjects but that 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 used by users connecting to the site, addresses in URI (Uniform Resource Identifier) notation of resources requested, time of request, the method used to submit the request to the web server, the size of the file obtained in response, numerical code indicating the status of the response given by the web server (good end, error, etc.) and other parameters related to the user’s operating system and computer environment. These data are used only for the purpose of obtaining anonymous statistical information on the use of this website and to check its proper functioning, to identify anomalies and/ or abuses, and are deleted immediately after processing. The data could be used to establish liability in case of hypothetical computer crimes against the site or third parties.

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

4. Purpose and legal basis of processing

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

• the promotion and sale of products and services related to consultancy, online and in-class training communicated through the website and newsletters;
• invitations to free and/or paid training events;
• personal interviews, questionnaires and surveys relating to the person’s work activity as well as customer satisfaction with the quality of services provided by Lenovys and its activities;
• the organization of training and information events or networking activities with partners, sometimes also funded. It should be noted that in the case of registration for training courses financed by public and private entities, the data will also be processed for management purposes and reporting of the same activities and to comply with the provisions of laws and/ or regulations (as an example D.G.R. 948/2016, European Social Fund in synergy with the European Regional Development Fund, POR FSE 2014 2020 -Ob. “investments for growth and employment”).
• the legal basis that legitimizes the aforementioned processing is art. 6.1.a) of the Regulation in that the treatments are based on the consent of the user, who is free to give or not and who can, however, revoke at any time. The provision of data necessary for these purposes is not mandatory and refusal to provide it does not cause any negative consequences, except the impossibility of performing the purposes for which it is required: e.g. receive commercial communications, participate in events and/or activities, conclude contracts.
• to comply with any obligations provided for by the laws in force, regulations or community legislation, or to satisfy requests from authorities; this need is the legal basis that legitimizes the resulting processing. The provision of data necessary for these purposes is a legal obligation. The legal basis for processing personal data for the purposes set out in section 3.2 is, however, art. 6.1.c) of the Regulation.

5. Recipients or categories of recipients of data

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

Such data shall be disclosed to those people to whom disclosure is required to comply with an obligation laid down by law, regulation or Community legislation.

6. Rights of data subjects

Pursuant to Articles 15 et seq. of the Regulation, the data subject has the right to request from Lenovys, at any time, access to his personal data, the rectification or deletion of the same or to oppose their processing, request the limitation of the processing in the cases provided by art. 18 of the Regulation, as well as to obtain in a structured format, commonly used and readable by automatic device the data concerning it, in the cases provided for by art. 20 of the Regulation.

Requests must be sent in writing to the Data Controller or to the DPO at the addresses indicated in this information.

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 you consider that the processing of your 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, also due to changes in the applicable legislation. The Data Controller therefore invites its users to regularly visit this section to be aware of the most recent and updated version of the privacy policy so that they can always be up to date on the data collected and the use made by Lenovys. To exercise the above rights or for any other request you can write to the Data Controller at the physical address indicated above or through the dedicated email contact and contact the DPO directly, preferably by inserting in the subject of the communication the wording “Request exercise privacy rights”.

Last revision of the document: 07/03/2025