Privacy Policy

The purpose of this document is to inform the natural person (hereinafter the
“Data Subject”) about the processing of his/her personal data
(hereinafter the “Personal Data”) collected by the data controller,
ByteWex Srl, with registered office in Viale Timavo 85, 42121 Reggio Emilia (RE), Italy,
Tax Code/VAT No. 02896470354, e-mail address
privacy@bytewex.com
(hereinafter the “Data Controller”), via the website and the application
LaborLumen and the related domains and subdomains:
laborlumen.com, people.laborlumen.com, hub.laborlumen.com, passport.laborlumen.com,
coaching.laborlumen.com, training.laborlumen.com, recruiting.laborlumen.com
(hereinafter the “Application”).

Changes and updates will be effective as soon as they are published on the Application.
In case of non-acceptance of the changes made to this Privacy Policy, the Data Subject
shall stop using the Application and may request that the Data Controller delete his/her Personal Data.

1. Categories of Personal Data processed

The Data Controller processes the following types of Personal Data voluntarily provided by the Data Subject:

  • Contact Data: first name, last name, address, e-mail address,
    phone number, pictures, authentication credentials, any further information sent by the Data Subject, etc.
  • Fiscal and payment Data: tax code, VAT number, credit card data,
    bank account details, etc.
  • Data on the employment relationship: data entered in the curriculum vitae,
    data on spouse or children, social security data, etc.

The Data Controller processes the following types of Personal Data collected automatically:

  • Technical Data: Personal Data produced by devices, applications, tools and protocols,
    such as, for example, information about the device used, IP addresses, browser type, type of Internet provider (ISP).
    Such Personal Data may leave traces which, combined with unique identifiers and other information received by the servers,
    can be used to create profiles of individuals.
  • Usage Data: such as, for example, pages visited, number of clicks,
    actions taken, duration of sessions, etc.
  • Data relating to the exact location of the Data Subject: for example,
    geolocation data that precisely identifies the location of the Data Subject, which may be collected via the satellite network
    (e.g. GPS) and other means, with the consent of the Data Subject. The Data Subject may withdraw consent at any time.

If the Data Subject decides not to provide Personal Data for which there is a legal or contractual obligation,
or if such data is a necessary requirement for the conclusion of the contract with the Data Controller,
it will be impossible for the Data Controller to establish or continue any relationship with the Data Subject.

The Data Subject who communicates Personal Data of third parties to the Data Controller is directly and exclusively liable
for their origin, collection, processing, communication or disclosure.

2. Cookies and similar technologies

The Application uses cookies, web beacons, unique identifiers and other similar technologies to collect the Data Subject’s
Personal Data regarding visited pages, links and other actions performed during the use of the Application.
This data is stored and then used the next time the Data Subject browses the Application.

The full Cookie Policy can be viewed at the following address:
Cookie Policy – LaborLumen HCM.

3. Legal basis and purpose of data processing

The processing of Personal Data is necessary:

  1. For the performance of the contract with the Data Subject, and especially:

    1. fulfillment of any obligation arising from the pre-contractual or contractual relationship with the Data Subject;
    2. registration and authentication of the Data Subject, in order to allow the Data Subject to register in the Application, access it and be identified in it, also via external platforms;
    3. support and contact with the Data Subject, in order to answer the Data Subject’s requests;
    4. management of payments, including by credit card, bank transfer or other methods.
  2. For compliance with legal obligations, and especially:

    1. the fulfillment of any obligation provided for by the applicable laws, regulations and rules, in particular in tax and fiscal matters.
  3. For the legitimate interest of the Data Controller, for:

    1. marketing by e-mail of the Data Controller’s products and/or services, to directly promote products or services similar to those already purchased by the Data Subject, using the e-mail address provided in the context of a previous sale;
    2. management, optimization and monitoring of the technical infrastructure, in order to identify and solve technical issues, improve the performance of the Application, and manage and organize information in a computer system (e.g. server, database, etc.);
    3. security and anti-fraud purposes, in order to guarantee the security of the Data Controller’s assets, infrastructures and networks;
    4. anonymous statistical analysis based on aggregated and anonymous data, in order to analyze the behavior of Data Subjects, improve the products and/or services provided by the Data Controller, and better meet the expectations of the Data Subject.
  4. On the basis of the Data Subject’s consent, for:

    1. retargeting and remarketing, in order to reach Data Subjects who have already visited or shown interest in the products and/or services offered by the Application with customized advertisements using their Personal Data. The Data Subject may opt out by visiting the Network Advertising Initiative page;
    2. marketing of the Data Controller’s products and/or services, in order to send information or commercial and/or promotional materials, perform direct sales activities, or conduct market research through automated and traditional methods;
    3. detection of the exact location of the Data Subject, in order to detect the presence of the Data Subject, control logins, times and presence in a specific place, etc.

The Data Subject’s Personal Data may also be used by the Data Controller to protect its rights in judicial proceedings before the competent courts.

4. Data processing methods and recipients of Personal Data

The processing of Personal Data is performed by means of paper-based and computer tools, with methods of organization and logic strictly related to the specified purposes, and through the adoption of appropriate security measures.

Personal Data are processed exclusively by:

  • persons authorized by the Data Controller to process Personal Data who have committed themselves to confidentiality or are subject to an appropriate legal obligation of confidentiality;
  • subjects acting independently as separate data controllers, or subjects designated as data processors by the Data Controller in order to carry out all processing activities necessary to pursue the purposes set out in this policy (for example, business partners, consultants, IT companies, service providers, hosting providers);
  • subjects or bodies to whom Personal Data must be communicated by law or by order of the authorities.

The subjects listed above are required to use appropriate measures and safeguards to protect Personal Data and may only access the data necessary to perform their duties.

Personal Data will not be indiscriminately shared in any way.

5. Place of processing

Personal Data will not be transferred outside the territory of the European Economic Area (EEA).

6. Personal Data storage period

Personal Data will be stored for the period of time required to fulfill the purposes for which it was collected. In particular:

  • For purposes related to the execution of the contract between the Data Controller and the Data Subject,
    Personal Data will be stored for the entire duration of the contractual relationship and, after termination,
    for the ordinary limitation period of 10 years. In the event of legal disputes, Personal Data will be stored for the entire duration of such disputes,
    until the time limit for appeals has expired.
  • For purposes related to the legitimate interests of the Data Controller,
    Personal Data will be stored until such legitimate interest has been fulfilled.
  • For compliance with legal obligations, by order of an authority and for legal protection,
    Personal Data shall be stored according to the relevant timeframes provided for by such obligations and regulations,
    and in any case until the expiry of the applicable limitation period.
  • For purposes based on the consent of the Data Subject,
    Personal Data will be stored until consent is revoked.

At the end of the storage period, all Personal Data will be deleted or stored in a form that does not allow the identification of the Data Subject.

7. Rights of the Data Subject

Data Subjects may exercise specific rights regarding the Personal Data processed by the Data Controller.
In particular, the Data Subject has the right to:

  • be informed about the processing of his/her Personal Data;
  • withdraw consent at any time;
  • restrict the processing of his/her Personal Data;
  • object to the processing of his/her Personal Data;
  • access his/her Personal Data;
  • verify and request the rectification of his/her Personal Data;
  • obtain the erasure of his/her Personal Data;
  • transfer his/her Personal Data to another data controller;
  • file a complaint with the competent Personal Data protection supervisory authority and/or take legal action.

In order to exercise these rights, Data Subjects may send a request to:
privacy@bytewex.com.
Requests will be handled by the Data Controller and processed as soon as possible, in any case within 30 days.

Last update: 02/04/2026