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Certifications, ethics and compliance

ISO 9001:2015 Certification

Since 1997, Lagitre S.r.l. has been certified to the UNI EN ISO 9001:2015 standard, ensuring the highest quality in every aspect of its work.

Organizational Model D.Lgs. 231/2001 231/2001

Committed to responsibility and transparency, the company has adopted the organizational, management and control model under Legislative Decree 231/2001, promoting ethics and compliance while preventing unlawful conduct.

Code of Ethics

As a member of Confindustria Dispositivi Medici, and with daily involvement in public procurement, Lagitre S.r.l. fully adheres to the association’s Code of Ethics, operating with transparency, fairness and integrity to build clear and responsible relationships with all stakeholders.

See also

Our History
Vision & Mission
Team & Network
Contattaci

whistleblowing

Submit a report

Note Information on the implementation of the Whistleblowing platform of LAGITRE SRL

In accordance with the Legislative Decree No. 24 of 10 March 2023, “Implementation of Directive (EU) 2019/1937 of the European Parliament and of the Council, of 23 October 2019 which introduces the obligation for all the companies or entities which have employed used, in the last calendar year, with more than 50 employees to set up an internal a33> internal reporting platform, commonly referred to as, known as Whistleblowing.

LAGITRE SRL Via Venezia Giulia, 10 20157 Milan (MI) VAT No. and Tax Code 04804230151
tel. 02 38001360 email lagitre@lagitre.com

provides a reporting platform configured to comply with current legislation in accordance with the guidelines issued by Confindustria. This platform is made available to those authorised to use it and who are therefore able to submit a report:

  • employees, self-employed workers, contractors, volunteers and trainees, including those who are unpaid, who carry out their work at LAGITRE SRL;
  • employees or contractors who carry out their work at organisations that supply goods or services or carry out works on behalf of third parties; freelancers and consultants who provide their services to LAGITRE SRL; and shareholders and individuals at LAGITRE SRL holding positions of administration, management, control, supervision or representation. These individuals report information regarding violations of which they have become aware within their working environment.

Reports can also be made:

  • where the legal relationship has not yet commenced, if the information regarding the breaches was obtained during the selection process or at other pre-contractual stages;
  • during the probationary period;
  • after the termination of the legal relationship, if the information regarding the breaches was obtained during the course of that relationship.

The whistleblowing platform provided is intended to:

  1. Identify irregularities and unethical behaviour at an early stage
  2. Preventing and mitigating risks
  3. Promoting transparency and integrity
  4. Building trust among employees
  5. Improving risk management and regulatory compliance
  6. Promoting innovation and accountability

What to report

Breaches relating to acts (of any nature, including mere omissions) committed by persons associated with LAGITRE SRL, which may concern:

  • breaches of the procedures implementing the Anti-Corruption Policy, the Code of Ethics and/or internal company regulations; and/or, in any event, breaches likely to cause harm or damage, even if only to the image or reputation, to LAGITRE SRL;
  • administrative, accounting, civil or criminal offences;
  • unlawful conduct as defined in Legislative Decree No. 231 of 8 June 2001;
  • offences falling within the scope of European Union legislation and the national provisions implementing it;
  • acts or omissions that harm the financial interests of the European Union;
  • acts or omissions relating to the internal market (for example: infringements of competition law and state aid rules);
  • acts or conduct that undermine the object or purpose of the provisions set out in European Union legislation.

In order to assist the Whistleblower in identifying matters that may be reported, the following is a list of relevant breaches and/or conduct, provided by way of example only and is neither exhaustive nor binding:

  • breach of the Code of Ethics, policies and procedures adopted by the Company;
  • the giving of a sum of money or the offering of other benefits to a public official or a person entrusted with a public service in return for the performance of their duties (e.g. expediting a procedure) or for the commission of an act contrary to their official duties (e.g. failing to issue a notice of violation for tax irregularities);
  • conduct intended to obstruct the activities of the public administration (e.g. failure to submit documentation, provision of false or misleading information);
  • the promise or offering of money, goods, services or any other benefit with the aim of bribing suppliers or customers;
  • the acceptance of money, goods, services or other benefits from suppliers or other parties in exchange for favours or unethical conduct;
  • illegal agreements with suppliers, consultants, customers or competitors (e.g. issuing fictitious invoices, price-fixing agreements, etc.);
  • forgery, tampering, destruction or concealment of documents;
  • irregularities in accounting, administrative or tax compliance, or in the preparation of the Company’s financial statements;
  • falsification of expense claims (e.g. inflated reimbursements or claims for non-existent travel);
  • theft of cash, valuables, supplies or other property belonging to the Company or to customers;
  • unauthorised disclosure of confidential information;
  • computer fraud;
  • behaviour aimed at hindering equality between women and men in terms of their rights, treatment, responsibilities, opportunities, and economic and social outcomes;
  • offences falling within the scope of European Union or national legislation, or of national legislation implementing European Union legislation in the fields of public procurement; services, products and financial markets; the prevention of money laundering and terrorist financing; product safety and conformity; environmental protection;
  • as otherwise provided for by law.

Reports must relate to facts of which the Whistleblower is aware, and the Whistleblower must have reasonable grounds to believe that the information reported is true at the time of reporting. Reports must be made promptly after the facts come to light, so as to make verification practically possible. The following do not constitute whistleblowing reports: complaints, claims or requests linked to the Whistleblower’s personal interests that relate exclusively to their individual employment relationship, or to their relationship with their superiors; communications or complaints relating to commercial activities or services to the public.

What to report

You must log in to the AntaresWB platform via the link https://lagitre.antareswb.it, available on the LAGITRE SRL website. Click on the “Submit a report” button. You will then be required to enter your personal details and provide a copy of your identity document. You will then need to provide a description of the breach you wish to report, the date or period to which it relates, where the breach occurred, how you are involved in the report, whether you have reported the facts to other organisations or individuals, and any other relevant details. Reports cannot be submitted anonymously. The platform offers a guided process in which certain fields, marked with a red asterisk, are mandatory. Each report will be assigned a code. This code will allow the reporter to retrieve the reports they have submitted and check the responses received. Please note that this code is unique and cannot be duplicated. If lost, you will need to resubmit the report, stating in the description that it is a duplicate made necessary by the loss of the original code.

Milan (MI), 15 December 2025

Information for Whistleblowers pursuant to LAGITRE SRL’s data protection policy

1. Processing of personal data

  1. Pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 on the protection of personal data (“GDPR”), We hereby inform you that, following your non-anonymous report, LAGITRE SRL (the “Company” or the “Data Controller”), in its capacity as data controller, will process your personal data collected via the AntaresWB platform (the “Platform”) for the purpose of managing reports.
  2. Through the Platform, you may report (i) conduct that may constitute one of the predicate offences set out in Legislative Decree 231/2001, where applicable, as well as breaches of the relevant organisational model; (ii) other unlawful conduct or conduct that is otherwise contrary to company policies.

2. Purpose of this policy

This notice explains the nature of your personal data being processed, the purposes and methods of processing, any recipients of such data, and the rights to which you are entitled.

3. Purposes and lawfulness of processing

Your personal data will be used for the purpose of collecting and managing reports (so-called whistleblowing) relating to conduct that may constitute one of the predicate offences set out in Legislative Decree 231/2001, where applicable, as well as breaches of the relevant organisational model or other unlawful conduct or conduct that is otherwise contrary to company policies; for the subsequent conduct of the internal investigation and for the imposition of disciplinary or contractual measures against the person responsible for the unlawful acts or irregularities, including the possible reporting of such offences to the judicial authorities. The Company processes personal data in compliance with regulatory obligations and, in particular – should you be an employee of the Company – in compliance with Law 179/2017 protecting those who report offences or irregularities of which they become aware in the course of their employment. In particular, personal data is used for the following specific and legitimate purposes:

  1. the collection of reports concerning potential offences or irregularities committed by company representatives;
  2. the conduct of an internal investigation to verify the validity of the report, including contacting you via the Platform in order to gather further information;
  3. should the report prove to be well-founded, the imposition of disciplinary sanctions or the invocation of contractual remedies against the company representatives responsible for the offence or irregularity;
  4. the conduct of legal proceedings against the company representatives involved; in this case, your personal data will be used to enable the Company to exercise its right of defence;
  5. where the reported conduct constitutes a criminal offence, reporting the offences to the judicial authorities;
  6. checks and audits in relation to the obligations arising from Legislative Decree 231/2001, where applicable, concerning the administrative liability of companies and organisations, as well as to comply with obligations regarding transparency and disclosure; for all the aforementioned purposes, personal data is used in order to comply with legal obligations;
  7. for the purpose of safeguarding the Company’s security in general; in such cases, the use of your personal data is justified by the Company’s legitimate interest in the efficient and proper management of its business activities.

In addition, your personal data will be processed for the purpose of carrying out all activities that are instrumental, ancillary or otherwise necessary to the achievement of the aforementioned purposes.

4. Nature of the contribution

The processing of your personal data is necessary for the purposes set out in paragraph 3 above. The provision of your personal data is mandatory for the performance of the activities referred to in paragraph 3 above; any refusal to provide such data will make it impossible to follow up on your report.

5. Legal basis for processing

With regard to the processing of personal data carried out by the Company:

  1. where the facts reported relate to conduct that may constitute one of the predicate offences set out in Legislative Decree 231/2001, where applicable, or to breaches of the relevant organisational model, your consent is not required as the processing of your report is necessary to comply with a specific legal obligation;
  2. in tutti gli altri casi il suo consenso non è necessario in quanto il trattamento è necessario per perseguire il legittimo interesse della Società alla repressione di eventuali illeciti o irregolarità commesse dai propri esponenti e verificare la legalità dei processi aziendali.

6. Dati personali oggetto di trattamento

1. Categories of data processed

Your general personal data, such as identifying details (name, address or other personal identification details), will be processed. Special categories of personal data, such as information on racial and/or ethnic origin, religious and/or ideological beliefs, trade union membership or sexual orientation, will not be processed. Given the presence of free-text fields on the Platform, you may voluntarily provide such special categories of personal data. With regard to the personal data of the individuals subject to reporting, it will not be necessary to provide them with any information, given that the processing is carried out either (i) for the purpose of asserting or defending a right of the Company in court or (ii) for the purpose of pursuing the public interest in the prosecution of criminal conduct.

2. Any processing of data beyond the categories specified

The Company may, however, need to request and process personal data in addition to those falling within the categories set out above, for the same purposes as those set out in paragraph 3 above, provided that the provision of such additional data is:

  1. required by laws, regulations or decisions of public authorities; and/or
  2. necessary and essential for the management and conduct of the investigation following your report or for the exercise of the right of defence in court.

7. Data retention periods

Your personal data will be retained for as long as is necessary to carry out the investigation. Should the investigation confirm the validity of the report, your data will be retained until appropriate measures have been taken against the person responsible for the reported offences or irregularities. Once these activities have been completed, your personal data will be deleted or anonymised.

8. How we use your data

  • 8.1 Data processing is carried out via the IT platform or other automated means by internal or external personnel who have been specifically appointed for this purpose and are bound by a duty of confidentiality.
  • 8.2 Data is protected by security measures designed to prevent unauthorised access, loss or destruction, in accordance with the provisions of the applicable legislation on the protection of personal data.
  • 8.3 Once you have submitted a report, you will receive the login details for an internal email account on the Platform, which allows you to communicate securely.
  • 8.4 The Platform, managed by the provider acting as data processor, is equipped with appropriate technical measures to ensure data protection and confidentiality. The data provided by whistleblowers will be stored in a database managed by the Platform provider, which is specially secured and equipped with appropriate security measures. All data stored within this database is encrypted using state-of-the-art technology.
  • 8.5 Personal data held on the Platform will be processed exclusively within countries belonging to the European Union.

9. Data flow

  • 9.1 Your data is used by Company staff who have been assigned a specific role and given appropriate operational instructions. Your personal data is made available only to those within the Company’s organisational structure who require it by virtue of their role or position within the hierarchy.
  • 9.2 Your personal data will be processed, in its capacity as an independent data controller, by the Platform provider, Antares sas di Corradi V. & C., with registered office at Via Bruno Buozzi, 7/a, Desio (MB), Italy, in accordance with instructions provided by the Data Controller.
  • 9.3 Your personal data may also be processed by public bodies or entities under their control a8> public bodies or entities under the control of which the Company transmits its own data, in both cases for the sole purposes of which in the previous paragraph 3 letters c), d) and e). These recipients will act, in their capacity as data controllers acting independently and are included in the following categories:
  1. law enforcement agencies;
  2. judicial authorities;
  3. private investigation agencies; legal advisers, engaged to protect the Company’s rights against those responsible for offences or irregularities;
  4. companies within the same group to which the Data Controller belongs, where the offences or irregularities relate to an employee of such companies. ff For further information on the recipients and categories of recipients to whom your data is disclosed, please write to lagitre@lagitre.com

10. Data controller

The Data Controller is LAGITRE SRL, Via Venezia Giulia 10, 20157 Milan (MI), VAT No. and Tax Code 04804230151, tel. 02 38001360, email lagitre@lagitre.com

11. Data Protection Officer

The Company is not required to appoint a Data Protection Officer (also known as a “DPO”).

12. Exercising your rights

Where the conditions are met and within the limits set out in the applicable legislation, you may exercise the following rights in relation to the processing of your personal data: (i) the right of access to personal data and information regarding its processing; (ii) the right to rectification where personal data is inaccurate or incomplete; (iii) the right to have your personal data erased; (iv) the right to object to the processing of your personal data; (v) the right to restrict the processing of your personal data; (vi) the right to have your personal data transferred to other companies or organisations and/or to receive your personal data in a structured, commonly used and machine-readable format. The above rights may be exercised by contacting lagitre@lagitre.com. Should you identify any irregularities in the processing of your personal data, you may lodge a complaint with the Data Protection Authority, in accordance with the procedures set out on the Authority’s website (www.garanteprivacy.it).

whistleblowing

Submit a report

Note Information on the implementation of the Whistleblowing platform of LAGITRE SRL

In accordance with the Legislative Decree No. 24 of 10 March 2023, “Implementation of Directive (EU) 2019/1937 of the European Parliament and of the Council, of 23 October 2019 which introduces the obligation for all the companies or entities which have employed used, in the last calendar year, with more than 50 employees to set up an internal a33> internal reporting platform, commonly referred to as, known as Whistleblowing.

LAGITRE SRL Via Venezia Giulia, 10 20157 Milan (MI) VAT No. and Tax Code 04804230151
tel. 02 38001360 email lagitre@lagitre.com

provides a reporting platform configured to comply with current legislation in accordance with the guidelines issued by Confindustria. This platform is made available to those authorised to use it and who are therefore able to submit a report:

  • employees, self-employed workers, contractors, volunteers and trainees, including those who are unpaid, who carry out their work at LAGITRE SRL;
  • employees or contractors who carry out their work at organisations that supply goods or services or carry out works on behalf of third parties; freelancers and consultants who provide their services to LAGITRE SRL; and shareholders and individuals at LAGITRE SRL holding positions of administration, management, control, supervision or representation. These individuals report information regarding violations of which they have become aware within their working environment.

Reports can also be made:

  • where the legal relationship has not yet commenced, if the information regarding the breaches was obtained during the selection process or at other pre-contractual stages;
  • during the probationary period;
  • after the termination of the legal relationship, if the information regarding the breaches was obtained during the course of that relationship.

The whistleblowing platform provided is intended to:

  1. Identify irregularities and unethical behaviour at an early stage
  2. Preventing and mitigating risks
  3. Promoting transparency and integrity
  4. Building trust among employees
  5. Improving risk management and regulatory compliance
  6. Promoting innovation and accountability

What to report

Breaches relating to acts (of any nature, including mere omissions) committed by persons associated with LAGITRE SRL, which may concern:

  • breaches of the procedures implementing the Anti-Corruption Policy, the Code of Ethics and/or internal company regulations; and/or, in any event, breaches likely to cause harm or damage, even if only to the image or reputation, to LAGITRE SRL;
  • administrative, accounting, civil or criminal offences;
  • unlawful conduct as defined in Legislative Decree No. 231 of 8 June 2001;
  • offences falling within the scope of European Union legislation and the national provisions implementing it;
  • acts or omissions that harm the financial interests of the European Union;
  • acts or omissions relating to the internal market (for example: infringements of competition law and state aid rules);
  • acts or conduct that undermine the object or purpose of the provisions set out in European Union legislation.

In order to assist the Whistleblower in identifying matters that may be reported, the following is a list of relevant breaches and/or conduct, provided by way of example only and is neither exhaustive nor binding:

  • breach of the Code of Ethics, policies and procedures adopted by the Company;
  • the giving of a sum of money or the offering of other benefits to a public official or a person entrusted with a public service in return for the performance of their duties (e.g. expediting a procedure) or for the commission of an act contrary to their official duties (e.g. failing to issue a notice of violation for tax irregularities);
  • conduct intended to obstruct the activities of the public administration (e.g. failure to submit documentation, provision of false or misleading information);
  • the promise or offering of money, goods, services or any other benefit with the aim of bribing suppliers or customers;
  • the acceptance of money, goods, services or other benefits from suppliers or other parties in exchange for favours or unethical conduct;
  • illegal agreements with suppliers, consultants, customers or competitors (e.g. issuing fictitious invoices, price-fixing agreements, etc.);
  • forgery, tampering, destruction or concealment of documents;
  • irregularities in accounting, administrative or tax compliance, or in the preparation of the Company’s financial statements;
  • falsification of expense claims (e.g. inflated reimbursements or claims for non-existent travel);
  • theft of cash, valuables, supplies or other property belonging to the Company or to customers;
  • unauthorised disclosure of confidential information;
  • computer fraud;
  • behaviour aimed at hindering equality between women and men in terms of their rights, treatment, responsibilities, opportunities, and economic and social outcomes;
  • offences falling within the scope of European Union or national legislation, or of national legislation implementing European Union legislation in the fields of public procurement; services, products and financial markets; the prevention of money laundering and terrorist financing; product safety and conformity; environmental protection;
  • as otherwise provided for by law.

Reports must relate to facts of which the Whistleblower is aware, and the Whistleblower must have reasonable grounds to believe that the information reported is true at the time of reporting. Reports must be made promptly after the facts come to light, so as to make verification practically possible. The following do not constitute whistleblowing reports: complaints, claims or requests linked to the Whistleblower’s personal interests that relate exclusively to their individual employment relationship, or to their relationship with their superiors; communications or complaints relating to commercial activities or services to the public.

What to report

You must log in to the AntaresWB platform via the link https://lagitre.antareswb.it, available on the LAGITRE SRL website. Click on the “Submit a report” button. You will then be required to enter your personal details and provide a copy of your identity document. You will then need to provide a description of the breach you wish to report, the date or period to which it relates, where the breach occurred, how you are involved in the report, whether you have reported the facts to other organisations or individuals, and any other relevant details. Reports cannot be submitted anonymously. The platform offers a guided process in which certain fields, marked with a red asterisk, are mandatory. Each report will be assigned a code. This code will allow the reporter to retrieve the reports they have submitted and check the responses received. Please note that this code is unique and cannot be duplicated. If lost, you will need to resubmit the report, stating in the description that it is a duplicate made necessary by the loss of the original code.

Milan (MI), 15 December 2025

Information for Whistleblowers pursuant to LAGITRE SRL’s data protection policy

1. Processing of personal data

  1. Pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 on the protection of personal data (“GDPR”), We hereby inform you that, following your non-anonymous report, LAGITRE SRL (the “Company” or the “Data Controller”), in its capacity as data controller, will process your personal data collected via the AntaresWB platform (the “Platform”) for the purpose of managing reports.
  2. Through the Platform, you may report (i) conduct that may constitute one of the predicate offences set out in Legislative Decree 231/2001, where applicable, as well as breaches of the relevant organisational model; (ii) other unlawful conduct or conduct that is otherwise contrary to company policies.

2. Purpose of this policy

This notice explains the nature of your personal data being processed, the purposes and methods of processing, any recipients of such data, and the rights to which you are entitled.

3. Purposes and lawfulness of processing

Your personal data will be used for the purpose of collecting and managing reports (so-called whistleblowing) relating to conduct that may constitute one of the predicate offences set out in Legislative Decree 231/2001, where applicable, as well as breaches of the relevant organisational model or other unlawful conduct or conduct that is otherwise contrary to company policies; for the subsequent conduct of the internal investigation and for the imposition of disciplinary or contractual measures against the person responsible for the unlawful acts or irregularities, including the possible reporting of such offences to the judicial authorities. The Company processes personal data in compliance with regulatory obligations and, in particular – should you be an employee of the Company – in compliance with Law 179/2017 protecting those who report offences or irregularities of which they become aware in the course of their employment. In particular, personal data is used for the following specific and legitimate purposes:

  1. the collection of reports concerning potential offences or irregularities committed by company representatives;
  2. the conduct of an internal investigation to verify the validity of the report, including contacting you via the Platform in order to gather further information;
  3. should the report prove to be well-founded, the imposition of disciplinary sanctions or the invocation of contractual remedies against the company representatives responsible for the offence or irregularity;
  4. the conduct of legal proceedings against the company representatives involved; in this case, your personal data will be used to enable the Company to exercise its right of defence;
  5. where the reported conduct constitutes a criminal offence, reporting the offences to the judicial authorities;
  6. checks and audits in relation to the obligations arising from Legislative Decree 231/2001, where applicable, concerning the administrative liability of companies and organisations, as well as to comply with obligations regarding transparency and disclosure; for all the aforementioned purposes, personal data is used in order to comply with legal obligations;
  7. for the purpose of safeguarding the Company’s security in general; in such cases, the use of your personal data is justified by the Company’s legitimate interest in the efficient and proper management of its business activities.

In addition, your personal data will be processed for the purpose of carrying out all activities that are instrumental, ancillary or otherwise necessary to the achievement of the aforementioned purposes.

4. Nature of the contribution

The processing of your personal data is necessary for the purposes set out in paragraph 3 above. The provision of your personal data is mandatory for the performance of the activities referred to in paragraph 3 above; any refusal to provide such data will make it impossible to follow up on your report.

5. Legal basis for processing

With regard to the processing of personal data carried out by the Company:

  1. where the facts reported relate to conduct that may constitute one of the predicate offences set out in Legislative Decree 231/2001, where applicable, or to breaches of the relevant organisational model, your consent is not required as the processing of your report is necessary to comply with a specific legal obligation;
  2. in tutti gli altri casi il suo consenso non è necessario in quanto il trattamento è necessario per perseguire il legittimo interesse della Società alla repressione di eventuali illeciti o irregolarità commesse dai propri esponenti e verificare la legalità dei processi aziendali.

6. Dati personali oggetto di trattamento

1. Categories of data processed

Your general personal data, such as identifying details (name, address or other personal identification details), will be processed. Special categories of personal data, such as information on racial and/or ethnic origin, religious and/or ideological beliefs, trade union membership or sexual orientation, will not be processed. Given the presence of free-text fields on the Platform, you may voluntarily provide such special categories of personal data. With regard to the personal data of the individuals subject to reporting, it will not be necessary to provide them with any information, given that the processing is carried out either (i) for the purpose of asserting or defending a right of the Company in court or (ii) for the purpose of pursuing the public interest in the prosecution of criminal conduct.

2. Any processing of data beyond the categories specified

The Company may, however, need to request and process personal data in addition to those falling within the categories set out above, for the same purposes as those set out in paragraph 3 above, provided that the provision of such additional data is:

  1. required by laws, regulations or decisions of public authorities; and/or
  2. necessary and essential for the management and conduct of the investigation following your report or for the exercise of the right of defence in court.

7. Data retention periods

Your personal data will be retained for as long as is necessary to carry out the investigation. Should the investigation confirm the validity of the report, your data will be retained until appropriate measures have been taken against the person responsible for the reported offences or irregularities. Once these activities have been completed, your personal data will be deleted or anonymised.

8. How we use your data

  • 8.1 Data processing is carried out via the IT platform or other automated means by internal or external personnel who have been specifically appointed for this purpose and are bound by a duty of confidentiality.
  • 8.2 Data is protected by security measures designed to prevent unauthorised access, loss or destruction, in accordance with the provisions of the applicable legislation on the protection of personal data.
  • 8.3 Once you have submitted a report, you will receive the login details for an internal email account on the Platform, which allows you to communicate securely.
  • 8.4 The Platform, managed by the provider acting as data processor, is equipped with appropriate technical measures to ensure data protection and confidentiality. The data provided by whistleblowers will be stored in a database managed by the Platform provider, which is specially secured and equipped with appropriate security measures. All data stored within this database is encrypted using state-of-the-art technology.
  • 8.5 Personal data held on the Platform will be processed exclusively within countries belonging to the European Union.

9. Data flow

  • 9.1 Your data is used by Company staff who have been assigned a specific role and given appropriate operational instructions. Your personal data is made available only to those within the Company’s organisational structure who require it by virtue of their role or position within the hierarchy.
  • 9.2 Your personal data will be processed, in its capacity as an independent data controller, by the Platform provider, Antares sas di Corradi V. & C., with registered office at Via Bruno Buozzi, 7/a, Desio (MB), Italy, in accordance with instructions provided by the Data Controller.
  • 9.3 Your personal data may also be processed by public bodies or entities under their control a8> public bodies or entities under the control of which the Company transmits its own data, in both cases for the sole purposes of which in the previous paragraph 3 letters c), d) and e). These recipients will act, in their capacity as data controllers acting independently and are included in the following categories:
  1. law enforcement agencies;
  2. judicial authorities;
  3. private investigation agencies; legal advisers, engaged to protect the Company’s rights against those responsible for offences or irregularities;
  4. companies within the same group to which the Data Controller belongs, where the offences or irregularities relate to an employee of such companies. ff For further information on the recipients and categories of recipients to whom your data is disclosed, please write to lagitre@lagitre.com

10. Data controller

The Data Controller is LAGITRE SRL, Via Venezia Giulia 10, 20157 Milan (MI), VAT No. and Tax Code 04804230151, tel. 02 38001360, email lagitre@lagitre.com

11. Data Protection Officer

The Company is not required to appoint a Data Protection Officer (also known as a “DPO”).

12. Exercising your rights

Where the conditions are met and within the limits set out in the applicable legislation, you may exercise the following rights in relation to the processing of your personal data: (i) the right of access to personal data and information regarding its processing; (ii) the right to rectification where personal data is inaccurate or incomplete; (iii) the right to have your personal data erased; (iv) the right to object to the processing of your personal data; (v) the right to restrict the processing of your personal data; (vi) the right to have your personal data transferred to other companies or organisations and/or to receive your personal data in a structured, commonly used and machine-readable format. The above rights may be exercised by contacting lagitre@lagitre.com. Should you identify any irregularities in the processing of your personal data, you may lodge a complaint with the Data Protection Authority, in accordance with the procedures set out on the Authority’s website (www.garanteprivacy.it).