Information on the processing of personal data pursuant to Articles 13-14 of EU Regulation 2016/679

Interested Parties: Whistleblower.

Lagor Srl, as Data Controller of your personal data, pursuant to and for the purposes of EU Regulation 2016/679 (hereinafter 'GDPR'), hereby informs you that the aforementioned regulation provides for the protection of data subjects with respect to the processing of personal data and that such processing will be based on principles of fairness, lawfulness, transparency and protection of your privacy and your rights.

Your personal data will be processed in accordance with the legislative provisions of the above-mentioned regulation and the confidentiality obligations set forth therein.

Furthermore, the Data Controller may become aware of special categories of personal data, specifically: Common data and any special data processed in the context of managing whistleblowing reports. The processing of personal data for these special categories is carried out in compliance with Article 9 of the GDPR.

Purpose and legal basis of the processing: In particular, your data will be processed for the following purposes related to the implementation of legislative or contractual obligations:

  • Compliance activities pursuant to Legislative Decree 24/2023;
  • Receiving, analyzing, and managing reports, as well as ascertaining the facts underlying the report and adopting the resulting measures, in compliance with the provisions of Legislative Decree. March 10, 2023, n. 24.

Your personal data may also, with your consent, be used for the following purposes:

  • disclosure of his identity to persons other than those competent to receive or follow up on reports (paragraph 2 of art. 12 Legislative Decree 24/2023) or within the scope of the proceedings, where the dispute is based, in whole or in part, on the report and knowledge of his identity is essential for the defense of the accused (paragraph 5 of art. 12 Legislative Decree 24/2023).

Providing your data for the aforementioned purposes is optional, and your refusal to allow processing will not compromise the continuation of the relationship or the appropriateness of the processing itself.

Treatment methods. Your personal data may be processed in the following ways:

  • by means of electronic calculators using software systems managed by third parties;
  • Oral treatment;
  • processing by electronic means;
  • temporary processing in anonymous/anonymized form if chosen by the reporter.

All data processing is carried out in compliance with the procedures set out in Articles 6 and 32 of the GDPR and through the adoption of the appropriate security measures required.

Your data will be processed only by personnel expressly authorized by the Data Controller and, in particular, by the following categories of authorized personnel:

Lagor Srl

Via Urbano Rattazzi, 43
15121 Alessandria (AL)
Tel: 0141403711
P.IVA 00254520067
PEC: info.lagor@pec.it

  • Report Manager, i.e. the person(s) responsible for receiving and managing reports, appointed in accordance with art. 4 co.2 del D.Lgs. 24/2023;
  • OdV - Supervisory Body;
  • Internal investigation bodies;
  • RPCT - Responsible for Corruption Prevention and Transparency.

Communication: Your data may be communicated to external parties for the proper management of the relationship and in particular to the following categories of Recipients, including all duly appointed Data Processors:

  • Judicial Authority;
  • Communication to legally required bodies relating to whistleblowing regulations pursuant to Legislative Decree 24/2023;
  • Investigative bodies;
  • Wallbreakers digital whistleblowing management platform as Data Controller pursuant to Article 28 of the GDPR.

Dissemination: Your personal data will not be disseminated in any way.

Your personal data may also be transferred, limited to the purposes indicated above, to the following countries:

  • EU countries;
  • safe states outside the EU.

Retention Period. We inform you that, in compliance with the principles of lawfulness, purpose limitation and data minimization, pursuant to art. 5 of the GDPR, the retention period of your personal data is:

  • established for a period of time not exceeding the achievement of the purposes for which they are collected and processed and in compliance with the mandatory time limits prescribed by law.

Owner: the Data Controller, pursuant to the Law, is Lagor Srl (Via Urbano Rattazzi, 43, 15121 Alessandria (AL), VAT number 00254520067, contactable at the following addresses: e-mail privacy@lagor.it, telephone 0141403711) in the person of Ryoji Shiraki.

You have the right to obtain from the data controller the erasure (right to be forgotten), restriction, updating, rectification, portability, and objection to the processing of your personal data, as well as, in general, the right to exercise all the rights provided for in Articles 15, 16, 17, 18, 19, 20, 21, and 22 of the GDPR.

Reg.toUE 2016/679:Artt. 15, 16, 17, 18, 19, 20, 21, 22 - Rights of the interested party

1. The interested party has the right to obtain confirmation of the existence or otherwise of personal data concerning him or her, even if not yet recorded, communication of such data in an intelligible form, and the right to lodge a complaint with the Supervisory Authority.

2. The interested party has the right to obtain information on:

  • of the origin of personal data;
  • of the purposes and methods of processing;
  • of the logic applied in case of processing carried out with the aid of electronic instruments;
  • of the identifying details of the owner, the managers and the designated representative pursuant to Article 5, paragraph 2;
  • of the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of them in their capacity as designated representative in the territory of the State, managers or persons in charge.

3. The interested party has the right to obtain:

  • a. the updating, rectification or, when relevant, integration of the data;
  • b. the deletion, transformation into anonymous form or blocking of data processed in violation of the law, including data whose retention is not necessary in relation to the purposes for which the data were collected or subsequently processed;
  • c. the certification that the operations referred to in the letters a) and b) have been brought to the attention, including with regard to their content, of those to whom the data have been communicated or disseminated, except in the case in which such fulfillment proves impossible or involves the use of means manifestly disproportionate to the right protected;
  • d. data portability.

4. The interested party has the right to object, in whole or in part:

  • for legitimate reasons, to the processing of personal data concerning him, even if pertinent to the purpose of the collection;
  • to the processing of personal data concerning him/her for the purpose of sending advertising or direct sales materials or for carrying out market research or commercial communications.

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