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PRIVACY POLICY
LYRECO ITALIA Srl , with registered office in via Victor Hugo 4,
Milan, and VAT number 11582010150 subject to the management and coordination of
the sole quotaholder Lyreco SAS, a company
incorporated under French law, with registered office in rue du 19 mars 1962,
59770 MARLY (France), has exclusively business-to-business relationships with
its customers and suppliers (hereinafter referred to individually as "Customer / Supplier" and
collectively "Customers / Suppliers").
At Lyreco, we
believe privacy is important. To protect your privacy, Lyreco will ensure that
all personal data is handled securely and used only as described in the
sections below. This privacy policy ("Privacy
Policy") specifies what personal data we collect, how we use it and
what measures we take to keep it safe.
In this Privacy
Policy the terms "you" and
"your"
refer to the interested parties of the Customer / Supplier whose personal data
are processed by or on behalf of Lyreco, while the terms "we" and "our" refer to Lyreco.
“Affiliated Companies” means companies
controlled by, or jointly controlled with, Lyreco.
"Applicable Data Protection Law (s)"
means the laws and regulations regarding the protection of personal data, data
security, data retention, to which Personal Data is subject, including the GDPR
and Italian Legislative Decree 196 / 2003 and subsequent amendments.
"Data Controller" means the natural
or legal person, public authority, agency or other
body which, on its own or in collaboration with others, determines the purposes
and means of the processing of personal data.
“Interested Subjects” means each
employee, consultant, agent or other natural person
authorized to make or receive purchase orders from Lyreco on behalf of the
Customer / Supplier.
"Personal Data" means the personal
data of the Interested Subjects processed by Lyreco as the Data Controller.
"General Data Protection Regulation"
or "GDPR" means Regulation
2016/679 of the European Parliament and of the Council of 27 April 2016
concerning the protection of individuals with regard to
the processing of personal data, as well as the free circulation of such data
and repealing Directive 95/46 / EC.
"Personal data" means any information
concerning an identified or identifiable natural person ("Interested Subject");
the natural person is considered identifiable who can be identified, directly
or indirectly, with particular reference to an
identifier such as the name, an identification number, location data, an online
identifier or one or more characteristic elements of his physical identity,
physiological, genetic, psychic, economic, cultural or social.
"Processing", "process", or "processed" indicate any operation
or set of operations carried out with or without the aid of automated processes
and applied to Personal Data or sets of Personal Data, such as the collection,
registration, organization, structuring, storage, adaptation or modification,
extraction, consultation, use, communication by transmission, dissemination or any other form of making available,
comparison or interconnection, limitation, deletion or destruction.
“Service” means the supply and sale /
purchase of products and all related services offered globally or locally by
Lyreco.
"Third party (s)" means subjects
authorized by Lyreco to process personal data such as, by way of example:
auditors, contractors, transporters, commercial agents, consultants, etc.
This Privacy Policy
applies only to Customer / Supplier Personal Data processed by or on behalf of
Lyreco.
Lyreco treats
Personal Data fairly and lawfully, in accordance with Applicable Data
Protection Laws.
In the event of a
conflict between the Privacy Policy and the applicable Data Protection Laws,
the provisions of the latter will prevail.
Lyreco processes the Personal Data of
Customers / Suppliers in order to provide its
Services. In fact, the interested parties of the Customers / Suppliers are
those who act on behalf of the Customers / Suppliers themselves and who have
commercial relationships with Lyreco.
Lyreco processes the following categories of Personal Data of
Customers / Suppliers:
-
Name, surname,
telephone number and e-mail
-
Company name, VAT
number and company address
-
Information on
payment methods and credit cards
-
IP address
In Annex 1
to this Privacy Policy you will find a detailed
outline of the Personal Data we collect, the related purposes and legal basis.
The GDPR allows us to process Personal Data to
the extent that we have a legal basis or "ground" for doing so. Furthermore,
it requires us to tell you what these fundamentals are. Consequently, when we
process your Personal Data, we will rely on one of the following legal bases:
In Annex 1 to this Privacy Policy
you will find a detailed outline of the Personal Data we collect, the related
purposes and legal basis.
We also use cookies in order to
improve your experience on our website; we invite you to consult the Cookie
Policy section of this information.
We will retain your Personal Data for the
duration of our business relationship and up to 3 years after the last contact
or order with Lyreco, unless applicable law requires us to have different
terms, in particular for archival and tax purposes.
For example, the Personal Data mentioned in the invoices will be kept for a
longer period, in accordance with the applicable legislation.
In the event that the basis for the processing of your Personal
Data is our legitimate interest, we will process your Personal Data for the
purpose of pursuing that interest until the latter ceases or we do not receive
a request to object.
In the event that the basis for processing your Personal Data for
a specific purpose is your consent, we will process your Personal Data for that
purpose until you withdraw your consent. The withdrawal of consent does not
affect the lawfulness of the processing based on consent before the withdrawal.
In the case of sending commercial information
requested by you (newsletter), your Personal Data will be processed until you
unsubscribe from the newsletter, which you can easily do by clicking on the
link contained in each e-mail message containing the newsletter.
Your Personal Data relating to the use of our
social media profiles will be processed for the period that you follow these
profiles. If you have entered a contest organized by us, your Personal Data
will be processed for the time necessary to conduct the contest and identify
the winners, and in the event of a win - for approximately 10 years for tax and
accounting purposes.
Your data is accessed and processed by Lyreco
staff, for the purposes described above.
Lyreco does not share Personal Data with
unaffiliated third parties, except as necessary for its legitimate professional
and business needs, to fulfill your requests and / or as required or permitted
by law. They therefore include:
·
Suppliers - Lyreco may grant access to Customers' Personal Data:
o
to its service
providers or contractors: Lyreco transfers Personal Data to third party
companies, such as systems (IT) providers, hosting providers, consultants and
other suppliers of goods and services or contractors. Lyreco works with these
suppliers to be able to process your Personal Data on its behalf. Lyreco will
only transfer Personal Data to such subjects if they meet the rigorous
standards adopted by Lyreco regarding data processing and security. Lyreco
shares Personal Data for the sole purpose of providing its Services to
Customers.
o
Lyreco will share
information on payment related transactions with relevant parties. In the case
of suppliers chosen by Lyreco, an adequate level of protection of your personal
data will be required.
·
Courts, courts, law enforcement or regulatory
authorities: Lyreco reserves the right
to share your information to respond to duly authorized inquiries from
government authorities or where required by law. In exceptionally rare
circumstances, where national or societal security is concerned (e.g. in the event of a terrorist attack), Lyreco reserves the right
to share its entire database of Customers and Customer Personal Data with
relevant governmental authorities.
·
Auditors, auditors, accountants, legal
consultants can access
documents, such as invoices, which contain Personal Data of Customers, for the
purposes of their respective assignments.
·
Lyreco may transfer
your Personal Data to a prospective
buyer, transferee, merger partner or seller and their advisors, in
connection with an actual or potential, total or partial, transfer or merger of
its companies or businesses, or of any related rights or interests, or to
acquire a company or enter into a merger with it.
Lyreco will never sell your Personal Data to
third parties, for example to marketers.
Lyreco does not provide Personal Data to
"people search", "public lists" or "white pages"
sites.
Lyreco transmits your Personal Data only
within states of the European Economic Area (EEA) and / or to countries that
provide adequate protection, as confirmed by the European Commission, with the exception of the following cases.
If the processing involves a transfer of
Personal Data to a state outside the European Union that does not guarantee
adequate protection, as confirmed by the European Commission, Lyreco undertakes
to protect the transfer with one of the following mechanisms:
-
Standard
Contractual Clauses approved by the European Commission (for example, Standard
Contractual Clauses for Data Controllers 2004/915/EC or Standard Contractual
Clauses for Data Processors 2010/87/EU or any subsequent version);
-
Binding corporate
rules: in the event that the interested third parties
have adopted Binding corporate rules that cover the Personal Data processed by
them.
-
Any other mechanism
officially recognized by the applicable Data Protection Laws as such to ensure
an adequate level of protection of Personal Data.
Lyreco processes, and will ensure that third
parties also process, Personal Data in appropriate jurisdictions, as defined in
the applicable Data Protection Law (s). These jurisdictions include states from
the European Economic Area and countries recognized by the European Commission
as providing an adequate level of protection (for more information, see
European Commission, “Commission Decisions on the
Adequacy of Personal Data Protection in Third Countries. " )
Details
on the transfer of Personal Data to third countries, the guarantees applied to
such transfer, as well as a copy of these guarantees can be obtained by
contacting us by writing to the e-mail address IT.privacy@lyreco.com .
Lyreco performs security, technical and organizational checks,
appropriate from a commercial point of view, to protect Personal Data from
theft, loss or improper use. Personal Data will be
stored in a secure operating environment, not accessible without authorization.
Lyreco applies
mitigation measures following periodic risk assessments, in
order to guarantee an adequate level of protection of Personal Data.
When uploading sensitive information (such as
credit card numbers and passwords):
You are granted the following rights regarding
the processing of Personal Data carried out by or on behalf of Lyreco:
In addition to the information that is available
on the Lyreco website, you have the right to access the Personal Data that
Lyreco retains
on you, subject to the exceptions contemplated in the applicable Data
Protection Laws. Lyreco will endeavor to accommodate your request. Your
identity will need to be confirmed before you are allowed to access your
Personal Data. In general, Lyreco does not charge any cost to provide the requested
information, but if the request is manifestly unfounded or excessive, in particular, due to its repetitive nature, Lyreco
reserves the right to ask for a fee for such requests.
We ask you to send your request in writing:
·
Lyreco Italia srl, via Papa Giovanni Paolo II
snc, 20040 Cambiago (MI)
The request
must be complete with:
1
Phone number
2
Description of the specific
documents to which access is sought, including their specific dates, where
possible
Please provide as much detail as possible.
All formal access requests will be addressed to
the Privacy Contact, for the purposes of subsequent review and to determine if
Lyreco will have to provide the requested information. The Privacy Contact can
be contacted at the following address: IT.privacy@lyreco.com.
If you believe there is an error in your Personal
Data, you have the right to request that the information be corrected. We may
ask you to provide appropriate documentation to highlight any errors. We will
correct the incorrect data within one month and will notify you as soon as the
modification requested by you is completed. The GDPR recognizes the right to
request the rectification of your Personal Data held by Lyreco if you believe
there is an error or omission. It is your right to attach a statement
indicating any corrections requested by you, but not made by Lyreco - which
will inform each natural or legal person to whom the Personal Data has been
transmitted within one year of your request for correction, informing them of
the correction.
It is your right to ask Lyreco to move, copy or
transfer Personal Data concerning you from one IT environment to another, in a safe and secure
way, without hindrance. This right applies to your Personal Data held by
Lyreco, where the processing has been automated and used in consideration of
Lyreco's provision of Services, pursuant to the contract entered
into with the Customer, or if the processing is based on your consent.
to Lyreco.
You can access the Lyreco online web portal and
download the information provided in the “Export” section of the portal.
Lyreco does not
store Personal Data without a predefined and documented purpose. We comply with
the laws that require us to delete Personal Data if there is no longer a reason
for its collection and storage. We believe this meets the requirements of the
privacy principle of the "right to be forgotten".
In the event that Personal Data is held by Lyreco are based on
entering into a contract, and it is your desire to be removed from our systems
before the expiration of the retention period indicated in the section
"How long do we keep your Personal Data?", you are invited to contact
our Privacy Contacts at following address: IT.privacy@lyreco.com.
If you have transmitted your Personal Data to us
by registering, you can deactivate your account at any time. For security
reasons, we have provided a cooling-off period of seven days after your account
deletion request; however, accessing your account during that period will
result in its reactivation. After deactivation and the cooling-off period
expires, the account will be irrevocably suspended, ensuring that no one can
use its ID yet.
It is your right to object to our processing of
your Personal Data if we are no longer authorized to use it. In this case,
Lyreco will refrain from further processing the Personal Data unless it
demonstrates the existence of compelling legitimate reasons to proceed with the
processing that override your interests, rights and
freedoms or for the ascertainment, exercise or defense of a right in court.
You have the right
to withdraw any consent given to Lyreco. In any case, the withdrawal of consent
does not affect the lawfulness of the processing based on consent before its
withdrawal.
To exercise your rights, express a concern, raise a question, propose a complaint or obtain further information on the processing of your Personal Data by Lyreco, you can send an email to the following address: IT.privacy@lyreco.com by sending a document that proves your identity.
Lyreco undertakes to respond to the request
within a period of between one month and three months, depending on the
complexity of the request and / or the number of requests received by the
company.
In the event of a dispute, it is possible to
lodge a complaint with the local regulatory authority responsible for data
privacy - Guarantor for the protection of personal data - Piazza Venezia n. 11
- 00187 ROME - Fax: (+39) 06.69677.3785 - Telephone: (+39) 06.696771 - E-mail:
garante@gpdp.it - Certified mail: Protocol@pec.gpdp.it
.
Lyreco may occasionally update or modify this
Privacy Policy.
If so, it will notify you by posting a notice on the
home page of its website or, if required by law, by sending you a notice
directly. Lyreco invites you to periodically review this Privacy Policy to be
always informed on how Lyreco helps protect the Personal Data collected.
Continued use of the Lyreco Services constitutes acceptance by you of this
Privacy Policy and its subsequent updates.
Definitions
Cookies are short fragments of text (letters and
/ or numbers) that allow the web server to store information on the browser to
be reused during the same visit to the site (session cookies) or later, even
after days (persistent cookies) ). Cookies are stored,
according to user preferences, by the single browser on the specific device
used (computer, tablet, smartphone).
Cookies are useful because they allow a website
to recognize the user's device. They have different purposes such as, for
example, to allow you to navigate between pages efficiently, to remember your
favorite sites and, in general, to improve the browsing experience. They also
help to ensure that the advertising content displayed online is more targeted
to the user and his interests. Based on the function and purpose of use,
cookies can be classified into technical cookies, profiling cookies, third-party
cookies. The Lyreco webshop exclusively uses
technical cookies and third-party cookies.
Technical
cookies
Technical cookies are those used for the sole
purpose of carrying out the transmission of a communication over an electronic
communications network, or to the extent strictly necessary for the provider of
an information society service explicitly requested by the subscriber or user
to provide such service. They are not used for other purposes and are normally
installed directly by the owner or manager of the website. They can be divided
into navigation or session cookies, which guarantee the normal navigation and
use of the website; analytics cookies, similar to
technical cookies when used directly by the site manager to collect
information, in aggregate form, on the number of users and how they visit the
site; functionality cookies, which allow the user to browse according to a
series of selected criteria in order to improve the service provided.
The prior consent of users is not required for
the installation of these cookies.
These cookies can be disabled and / or deleted
through the browser settings. All modern browsers allow you to change your
cookie settings. These settings can usually be found in the "options"
or "preferences" menu of the user's browser. To understand these
settings, the following links may be helpful. Or you can use the
"Help" option in your browser for more information.
·
Cookie settings in Internet Explorer : https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies#ie=ie-10
·
Cookie settings in Firefox : https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer?redirectlocale=en-US&redirectslug=Cookies
·
Cookie settings in Chrome : https://support.google.com/chrome/answer/95647?hl=en&ref_topic=14666
·
Cookie settings in Safari and iOS : https://support.apple.com/it-it/guide/safari/sfri11471/mac
·
Cookie settings in
Opera: https://help.opera.com/en/how-to-clear-browser-cache-history-cookies/
If the use of cookies is blocked, the service
offered to the user through the website will be limited, thus influencing the
experience of using the site itself.
Profiling
cookies
Profiling cookies are cookies used to track the
user 's navigation on the network and create profiles on his tastes, habits,
choices, etc. With these cookies, advertising messages can be transmitted to
the user's terminal in line with the preferences already expressed by the same
user while browsing online.
Lyreco does not use profiling cookies within its webshop.
Third party
cookies
During navigation, the user may also receive
cookies from different sites or web servers on his terminal (so-called
"third-party" cookies): this happens because the site may contain
elements such as, for example, images, maps, sounds, specific links to web
pages of other domains that reside on servers other than the one on which the
requested page is located. In other words, these cookies are set directly by
website managers or servers other than the Lyreco website. Through these
cookies, third parties may obtain information relating to the fact that you
have visited the Lyreco webshop.
If the user decides not to grant authorization
for the use of third-party cookies, only the functions of the webshop that do not require these cookies can be used.
Below, for each third-party cookie on the site,
we report the name, purpose, name of the third party that stores the
information and the related link to the third party's website.
Scope |
Third party that stores user
information |
Link to the site where you can view the
privacy information provided by the third party and opt - out |
Web analysis
and feedback collection |
Hotjar Ltd |
|
Web marketing
campaign |
Sleeknote ApS |
https://sleeknote.com/privacy-policy |
Web marketing
campaign |
GetWebCraft Limited |
https://getsitecontrol.com/privacy/ |
Web marketing campaign |
Bing Ads - Microsoft |
|
Web marketing campaign |
Google |
|
Social Media Campaigns |
Meta
Platforms Ireland Limited |
|
Social Media Campaigns |
LinkedIn
Ireland Unlimited Company |
|
Gamification Campaigns |
LeadFamly ApS |
Google
Analytics
The Lyreco website also includes certain
components transmitted by Google Analytics, a web traffic analysis service
provided by Google, Inc. ("Google"). Also in
this case these are third-party cookies collected and managed anonymously to
monitor and improve the performance of the host site (performance cookies).
Google Analytics uses cookies to anonymously collect and analyze information on
website usage behavior (including the user's IP address). This information is
collected by Google Analytics, which processes it in order to
draw up reports on the activities on the websites themselves. This site uses
the Google analysis tool to monitor or collect personally identifiable
information. Google does not associate the IP address with any other data held
by Google nor does it try to link an IP address with
the identity of a user. Google may also communicate this information to third
parties where this is required by law or where such third parties process the
aforementioned information on behalf of Google. For more information, please
refer to the link below: https://www.google.it/policies/privacy/partners/
User may disable in a selective way the action of
Google Analytics by installing opt -out component provided by Google on his
browser. To disable the, please refer to the link below: https://tools.google.com/dlpage/gaoptout
Cookies can be saved on the terminal device based
on the consent expressed in the web browser settings, but we use them for
statistical purposes, development of services and marketing purposes (display
of advertisements on websites), based on the legal basis of the legitimate
interest (Article 6 paragraph 1 letter f of the GDPR).
Lyreco uses Google Analytics. Further information
on the terms of use of Google Analytics by Lyreco is available at: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage?hl=it
Lyreco uses Google Analytics. For more
information on Lyreco's use of Google Analytics, see: http://www.google.com/analytics/learn/privacy
To guarantee visitors to its website more choices
on the collection of data by Google Analytics, Google has developed the browser add-on for the deactivation of Google Analytics . This add-on communicates with Google Analytics
JavaScript (ga.js) to indicate that information about website visits should not
be sent to Google Analytics. However, the deactivation of Google Analytics does
not prevent the information from being sent to the site itself or to other web
analytics services.
* * *
Annex 1 - Detailed table on personal data
and related processing purposes
Categories of Personal Data |
Typology |
Purpose of the processing |
Legal basis |
|
|
Customers; Potential clients; Providers; Other contractors |
Name and surname; name of the company; VAT number and tax code; Telephone number; Email address; Signature; Number of employees; Activity data; Data relating to the management and execution of orders; Data relating to the management of Customers / Suppliers and any complaints; Identification data and authorizations |
Definition of contractual relationships and execution of the contract; Creation and management of utilities within the webshop; Solving technical problems; Management of reports or other types of information directly linked
to our services; Order management and execution; Management of payments and any credit recovery practices. |
art. 6 par. 1 let. b of the GDPR - the processing is necessary for the execution of a contract of which
the interested party is a party or for the execution of pre-contractual
measures adopted at the request of the same |
|
|
Keeping of data and accounting for tax purposes; Issue and storage of invoices; Communication of information to public bodies or authorities |
art. 6
par. 1 let . c of the GDPR - the processing is
necessary to fulfill a legal obligation to which the owner of the treatment |
|
|||
Monitoring of relations with customers / suppliers; Carry out
customer satisfaction surveys ; Prepare sales statistics; Carry out soft spam marketing campaigns and information about our
products and services; Data retention to be able to defend ourselves in court. |
art. 6
par. 1 let . f of the GDPR - the processing is
necessary for the pursuit of the legitimate interest of the owner of the treatment
or of third parties, provided that the interests or rights and freedoms do
not prevail fundamental
data of the interested party that require the protection of personal data |
|
|||
Employees, Consultants, Agents, Prosecutors, any person acting in the name or on behalf of the Customer, Supplier or other contractor, in particular any person
authorized to enter into contracts and send or receive orders |
Name and surname; name of the company; Working position; Telephone number; Email address; Signature; Identification data and authorizations |
Issue and storage of invoices; Communication of information to public bodies or authorities |
art. 6
par. 1 let . c of the GDPR - the processing is
necessary to fulfill a legal obligation to which the owner of the treatment |
|
|
Definition of contractual relationships and execution of the
contract with a Customer, Supplier or other contractor in the name and on
behalf of which you are acting; Creation and management of utilities within the webshop ; Solving technical problems; Management of reports or other types of information directly linked
to our services; Order management and execution; Carry out customer satisfaction surveys ; Prepare sales statistics; Carry out soft spam marketing campaigns and information about our
products and services; Management of payments and any credit recovery practices. |
art. 6
par. 1 let . f of the GDPR - the processing is
necessary for the pursuit of the legitimate interest of the owner of the processing
or of third parties, provided that the interests or fundamental rights and
freedoms of the data subject requesting the protection of personal data do
not prevail |
|
|||
webshop users , other Lyreco websites and social media profiles |
IP address of the computer; Web addresses (URLs); The internet address you came from before browsing our websites ; The type of web browser you use Other information transmitted through the http protocol; Data resulting from cookie files; Name and surname; Image; The name of the social profile; Social media identifier; Other data provided in connection with the use of our social media
profiles |
Processing of statistics for our websites ; Service development; Promotion of our products and services (display of advertisements
and promos on our websites); Monitoring the user experience on our websites; Organization, execution and definition of
competitions. |
art. 6
par. 1 let . f of the GDPR - the processing is
necessary for the pursuit of the legitimate interest of the data controller
or third parties, provided that the interests or fundamental rights and
freedoms of the data subject that require the protection of personal data do
not prevail |
||
Organization and management of these social media profiles; Communicate and reply to your messages; Maintain relationships with users and promote our brand on the
Internet. |
art. 6
par. 1 let . f of the GDPR - the processing is
necessary for the pursuit of the legitimate interest of the data controller
or third parties, provided that the interests or fundamental rights and
freedoms of the data subject that require the protection of personal data do
not prevail art. 6 par. 1 let. b of the GDPR - the processing is necessary for the execution of a contract of which
the interested party is a party or for the execution of pre-contractual
measures adopted at the request of the same |
|
|||
People who contact Lyreco (for purposes not described in other
sections); |
The type of personal data processed will depend on the case for
which you contact us. In particular, we can process
your contact details and the data resulting from the subject of the
communication. |
The purpose of the processing of your personal data will depend on
why you contact us. In particular, your Personal
Data may be processed in order to: - accept and take charge of your provision, request, complaint or
request, as well as the execution of the order or the presentation of the offer; - guarantee IT security and information security; - carrying out disputes, as well as proceedings before public
authorities and other proceedings, including for the purpose of investigation
and defense against complaints |
art. 6
par. 1 let . f of the GDPR - the processing is
necessary for the pursuit of the legitimate interest of the data controller
or third parties, provided that the interests or fundamental rights and
freedoms of the data subject that require the protection of personal data do
not prevail |
|
|
People who visit our headquarters, branches
and other locations where Lyreco operates (for purposes not described in
other sections) |
Name and surname; Name of the company; Data identifiers |
Ensure the safety of offices and people |
art. 6
par. 1 let . f of the GDPR - the processing is
necessary for the pursuit of the legitimate interest of the data controller
or third parties, provided that the interests or fundamental rights and
freedoms of the data subject that require the protection of personal data do
not prevail |
|
Privacy Policy - updated on 05 August
2022