1               Introduction

Lextray (IT) Associazione Professionale places great emphasis on protecting your privacy and collects, processes and utilises your personal information only in accordance with this Privacy Policy and the requirements of the European Union Regulation 2016/679 (GDPR).

Generally speaking, under the name “Lextray” fall several entities registered in accordance with the law of different jurisdictions, nevertheless, this Lextray Website is built, updated and managed at the sole responsibility of Lextray (IT) Associazione Professionale (hereinafter – except as provided and specified by this sentence – referred to as “Lextray”).

Lextray considers your privacy of the utmost importance and takes due care of the security, integrity and confidentiality of your personal data. In order for Lextray to provide you with the services required, you must provide Lextray with certain data. This Privacy Policy governs how Lextray deals with and process this information.

By registering with Lextray you agree to this Privacy Policy and allow Lextray to process your data in accordance with this Privacy Policy.

Lextray uses your personal data only in order to provide the services required, in accordance with your informed consent. You can request information and, if necessary, ask for correction or deletion of personal data at any time. Lextray shall keep your personal data confidential and shall not give the personal data to any third party, unless specified otherwise in this Privacy Policy.

At Lextray any worker, consultant, director, manager, is committed to respect your personal privacy. Lextray values the confidence of those who have entrusted Lextray with their personal data. Lextray has developed procedures and practices to periodically review and monitor the use of personal information to ensure that it is used responsibly and complies with internationally recognized standards of privacy protection.

2               Controller

Lextray (IT) Associazione Professionale, entity under Italian law, Via Orazio 30, 00193 Rome – Italy, email privacy@lextray.it , is the controller of any personal data collected and processed on / through / by the Lextray Website.

2.1                 Interest Pursued

The interest pursued by the Controller is the fulfilment of the undertakings arising from the business relationship with Lextray.

Business relationship includes for instance: professional services researching and providing, staff researching and scouting, marketing activities.

3               Area of Applicability

3.1                 Scope and Legal Basis of the Treatment

This Privacy Policy applies to all personal data – sensitive data included – that are collected or processed in context of the business relationship with Lextray triggered through Lextray Website.

By registering with Lextray you expressly agree with this Privacy Policy and give the unambiguous and informed consent provided herein.

The informed consent given herein is valid for all of your personal data – sensitive data included – collected by Lextray.

3.2                 Amendments

This Privacy Policy applies in the version valid at the time of your registration. As long as you are registered with Lextray, you agree to this Privacy Policy.

Lextray may modify or amend this Privacy Policy at any time. For instance, we may need to change this Statement as new privacy legislation is introduced or as existing regulations are amended.

Upon any modification or amendment of this Privacy Policy, you shall be notified about these modifications or amendments in writing, by email, or in any other suitable manner. For instance changes to this Statement will be posted on Lextray Website. Please check back periodically for updates to this Statement.

If you should not agree to the changes, you may terminate your business agreement with Lextray at any time. In case you continue your business agreement with Lextray after such changes to the Privacy Policy have come into effect, it will be considered agreed to and binding.

You can view the current version of this Privacy Policy at any time online at Lextray Website.

3.3                 Data Processing

Personal data means all data concerning personal or factual circumstances of an identified or identifiable natural person. This includes, for example, inventory data such as name, email address or telephone number.

You hereby give Lextray confirmation that you are entitled to have access to the data you disclose to Lextray. If this data is not your personal information (for example, data from a third party), you confirm that you have all necessary consent of the persons concerned to allow Lextray to process such data in accordance with this Privacy Policy.

Personal data may be treated by Lextray manually and/or with automated information technology tools.

3.4                 Data Categories

Generally, all personal data resulting from your registration with Lextray or otherwise within the business relationship with Lextray is collected. This includes in particular:

        All data that you communicate to Lextray (e.g. via customer form, employment form, email, etc.) and data which Lextray makes accessible to you;

        Personal data, such as name, address, telephone number, email address, date of birth, gender, etc.;

        Data that Lextray obtains or receives from third parties;

        Correspondence and communication between you and Lextray, such as messages, email, phone calls, etc.;

        Information collected automatically through Lextray Website.

For the sake of clarity it is noted that the collected data may also be sensitive personal data.

3.5                 Use of Personal Data

Lextray processes and utilises the collected data for the following purposes:

        In order to provide the services required and to respond to your requests and inquiries;

        For statistical purposes;

        For improvement and development of the services offered;

        For customer support as well as the maintenance of customer relationships (e.g. newsletters, etc.);

        For discovery, abatement and prevention of abuse and fraud;

        To process and reply to, or comply with legitimate governmental requests or arrangements, as well as in connection with the enforcement of claims or other litigation concerning Lextray or in which it is involved;

        For possible further purposes, if these are a result of legal obligations, where it is apparent that they arise from the circumstances of data collection, or are to be displayed during the collection of data.

The collected data can be interlinked and used to create customer profiles.

3.6                 Information Collected Automatically

Lextray collects information about visits to Lextray Website, including pages viewed, the number of bytes transferred, the links clicked, the materials accessed and other actions taken within Lextray Website. Lextray may combine this information with personal information to and use the combined information in accordance with this privacy statement.

Lextray also collect certain standard information that every browser sends to every visited website, such as Internet Protocol (IP) address, browser type and language, operating system, the date and time of every access to the site and the external website from which a visitor linked to Lextray Website. Lextray does not combine this standard information with other personal information.

This notice applies only to Lextray Website and does not apply to any other websites that may be accessed by users via links.

3.6.1                      Use of cookies and other web technologies

Browsing data.

The computer systems and software procedures used to run Lextray Website acquire some personal data as part of their normal operating. The transmission of such data is an inherent feature of internet communication protocols. Such information is not collected in order to associate them with identified individuals. However, by their very nature they may allow users to be identified after being processed and matched with data held by third parties. This category of data includes the IP addresses or domain names of the computers used by users connecting to the site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of such requests, the method used for submitting the request to the server, the size of the returned file, the numerical code indicating the server response status (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 extracting anonymous statistical information on website use and to check that it is functioning correctly. They are erased immediately after being processed. The data may be used to ascertain liability in the event that crimes are committed against the website. Except in this circumstance, any data regarding web contact is retained for no longer than thirty days.

Data supplied voluntarily by users.

Sending optional, explicit and voluntary emails to addresses listed on this website allows Lextray to process sender’s address as well as any other personal data included in the message.

Specific summary reports are shown or displayed on the pages that are used for particular on-demand services.

Cookies, embedded web links, and web beacons.

Like many websites, Lextray Website uses automatic data collection tools, such as cookies, embedded web links, and web beacons. Websites must get visitor’s agreement before they set certain types of cookie on visitor’s computer or handheld device.

Cookies are text files containing small amounts of information which are downloaded to visitor’s hard disk or to browser's memory when visitor visits Lextray Website. Cookies help make Lextray Website works. They also provide Lextray with aggregated information about how users interact with Lextray Website. Lextray uses this information to try to improve visitor’s experience on Lextray Website. Cookies do many different jobs, such as allowing Lextray Website to remember visitor’s preference settings and helping to enhance the usability and performance of Lextray Website and visitor’s experience using it.

Lextray Website also may contain electronic images known as web beacons – sometimes called single-pixel gifs – that allow to count the number of users who have visited specific pages. Lextray may include web beacons in promotional email messages or newsletters in order to determine whether messages have been opened and acted upon.

The types of cookies that may be used on Lextray Website can be put into three categories:

1.         Necessary Cookies

These cookies are essential, as they enable visitors to move around Lextray Website and use its features, particularly in connection with information searches. Without these cookies, services visitor has asked for cannot be provided. These cookies do not gather information about visitor that could be used for marketing or remembering where visitor has been on the internet.

2.         Performance Cookies

These cookies collect information about how visitors use Lextray Website, for example which pages visitor goes to most often and if visitor get any error messages from certain pages. These cookies collect only anonymous information that is used to improve how Lextray Website works. These cookies are not used to target visitor with online advertising. Without these cookies Lextray cannot learn how Lextray Website is performing and make relevant improvements.

3.         Authentication Cookies

These cookies allow Lextray Website to store information provided by the visitors such as site language preference and to store technical information useful for visitors’ interactions with Lextray Website. For instance, they remember visitor’s user ID and elements of visitor’s user profile. They also ensure that visitor’s experience using the site and Lextray marketing efforts are relevant to visitor. The information these cookies collect may be anonymous and they cannot track visitor’s browsing activity on other websites.

Without these cookies, Lextray Website cannot remember choices visitor has previously made.

 

Visitor has the right to choose whether or not to accept cookies. However, they are an important part of how Lextray Website works, so Visitor should be aware that if visitor chooses to refuse or remove cookies, this could affect the availability and functionality of Lextray Website.

Most internet browsers automatically accept cookies, but visitors can usually modify their browser settings to decline cookies or to notify them when a cookie is being placed on visitors’ computer. If visitor choose to decline cookies, visitor may not be able to fully experience the features of Lextray Website or other websites.

Lextray Website may provide links to other third-party websites and services that are outside Lextray control and not covered by this Privacy Statement. Lextray is not responsible for the content or privacy practices of such other sites. Lextray encourages visitors of Lextray Website to review the privacy statements posted on those websites.

3.7                 Disclosure to Third Parties

Lextray uses the data collected strictly for its own purposes and only discloses personal data to third parties in the following cases:

        Lextray may disclose data to third parties for their own purposes, if you so choose and/or instruct Lextray accordingly.

        Lextray may disclose personal data to third parties for their own purposes, if this is necessary for providing the services requested by you or if Lextray has expressly informed you of such disclosure.

        Lextray may call upon third parties that process and store personal data on behalf of and for the purposes of Lextray.

        Lextray can disclose anonymous data to third parties. Such data is in such a form, which, to the best knowledge of Lextray, does not allow such third parties to draw conclusions about the identity of the persons concerned.

        Under some circumstances, Lextray may be required to release personal information to law enforcement agencies or judicial authorities.

        In exceptional cases (such as abuse, emergencies, etc.) a disclosure of personal data to third parties may also take place for other purposes specified in this Privacy Policy, or legally prescribed or permitted purposes.

        Third parties, to whom personal data has been disclosed or passed on to, may also be located abroad and especially in countries where, compared to the European Union Regulation 2016/679 (GDPR), no adequate data protection is in place. In this case, Lextray ensures in an appropriate manner that such third parties only process the personal data within a permissible restricted framework.

Unless permitted or required by law, Lextray will not trade or sell, nor release, share or transfer personal information of the individuals for use by any business outside Lextray without making the individual aware of the intended data sharing and/or upon his/her explicit consent.

4               Data Security

Lextray employs reasonable organizational, physical, administrative and technical safeguards to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration, and destruction. For personal information subject to electronic storage or transmission, Lextray maintains a secure network that is protected from computer virus infection and monitored for unauthorized access. Both electronic and paper based records holding personal information is maintained in access controlled facilities.

In addition, Lextray trains its employees about the importance of confidentiality and maintaining the privacy and security of your information. This way, Lextray strives for ensuring that all those who process and/or have access to personal data as part of their regular job functions are fully aware of their individual responsibilities and of Lextray objectives with respect to the protection of data privacy.

You acknowledge that data transferred via the Internet or email is, generally, accessible to anyone. Lextray cannot guarantee the confidentiality of such data. Data may be lost during transmission, or changed or accessed by unauthorised third parties.

5               Methods of Communication

5.1                 Newsletter and Advertising

Lextray can send you newsletters or other promotional communication relating to the offers of Lextray to your email address, (mobile) telephone number or other address registered with Lextray. By registering with Lextray you consent to such distributions. You may reject such newsletters or promotional communications at any time and free of charge.

6               Data Subject’s rights and Complaints

According to GDPR, articles 15 – 21, Lextray grants you the following rights: access, rectification, erasure (right to be forgotten), restriction, portability, right to object.

You may exercise these rights by sending your request with a copy of a legitimate piece of identification of your person to Lextray (IT) Associazione Professionale, Via Orazio 30, 00193 Rome – Italy, specifying the right you are claiming.

In case of breach of any right granted by the GDPR, the data subject is granted the right to lodge a complaint with the competent supervisory authority (Garante della Privacy).

7               Upon Termination of Business Relation

Lextray preserves your personal data at the longest for 10 years after the termination of the business relation only within the scope of Lextray legal storage and archiving obligations.

Your personal data could be preserved for a longer time only if it should be necessary in order to exercise or to grant a right, for a litigation, because requested by a judicial authority.

Any further obligation to preserve and / or archive your personal data does not exist and you expressly acknowledge that Lextray can delete all your personal data that goes beyond the statutory storage and archiving obligations of Lextray or regarding which the appropriate storage and archiving term has expired.

8               Contact

If you have any questions relating to the processing of your personal data, your privacy rights or this Privacy Policy, please contact Lextray by email to privacy@lextray.it or by post to Lextray (IT) Associazione Professionale, Via Orazio 30, 00193 Rome – Italy. Using reasonable efforts, Lextray will promptly respond to any queries or complaints regarding the protection of personal data.