Hi there, we are Lotras and this is our privacy policy. When we say “we” or “us” or “Whole Train Press” , it means Whole Train Press – Globcom Editorial Mark – VAT 03639410715 – Italia.
When we say “policy” or “privacy” or “Regulation” we mean this privacy policy which is aimed at explaining which personal data about you we collect, the reason why we collect them and how you can access, update and delete them. When we say “data” or “informazion” or “personal data” we refer to “personal information”.

What kind of data do we collect when you visit our website?
Our website is hosted by third party and finds itself in Italy. Our server collects automatically some information like your IP address during the web surfing, information and requested pages, your browser's version (that is to say the software you use to surf the web) and your operating system. Furthermore, date and hour of the different requests to our pages and the origin of your request (the page or the link by which you came to our website) are registered. Our service provider keeps these data for infrastructure-related security reasons, checking unauthorised accesses and preventing attacks and any other suspicious activities. Unless in the case of reported damage or potential problems, we will not use and give consent to the use of these data to our provider. We collect information also through “cookies” and “web analytics”, but we will talk about that in detail later.
Which personal data do we collect when you contact us?
When you provide us with information via the contact form of the website or when you send us an email, in accordance with this circular, you give your consent to the use of personal data. If you send us name, surname, telephone number and email address, these data are registered together with your message. If you attach or send your curriculum vitae, we will keep it by respecting this policy. If you contact us telephonically, we will save the information that you provide us with, but we will not register the call. If you contact through the postal service we will keep the information that you send us.
Which personal data do we collect when you interact with our website?
For each operation on our website (e.g. purchasing and access to a restricted area), you must sign up and send us some of your information. To sign up, suffice it to give your name, surname, email address (which will be your username or user-ID) and a password (that we cannot see). If you want to purchase, other data will be necessary such as address (street name, street number, postal code, city, province and nation) and, as for the invoicing, fiscal code (date and place of birth) and maybe VAT number are also needed. If you do not provide us with these information, you will not be able to purchase products and services from Lotras. If you want, you can give us also your telephone number, but it is not compulsory. To manage your payments, we use third-party services, such as bank or PayPal, which collect and use your data in order to make financial transactions. Go to your bank’s website for further details. To know the PayPal’s privacy policy, you can also go to their website by following this link: Privacy di PayPal. When you sign up to our newsletter, we are going to store only your email address and maybe the lists you want to receive information from.
How do we obtain information about you by third party?
Usually we do not receive information about you by third party, but sometimes we might access to your data through websites, publications or social medias when we do not have enough information to contact you or verify that data are correct. Altri dati che ti riguardano sono raccolti da terzi quando effettui pagamenti per acquistare i nostri prodotti o servizi. Also, Web analytics services and cookies are tracking technologies used by our third-party providers and provide us with information concerning your web surfing.
How and why do we use your information?
We will use your personal information to:
  • The functioning of the website, such as identifying you when you log in, making purchase transactions or resolving contestations
  • Keep you updated about modifications to our website and services or keep you informed about problems or security updates
  • Give you information that you requested, support you or, if you have given consent, send promotional information about our products and services that may interest you
  • Make technical analysis on the website in order to improve its efficiency and quality of services
  • Check activities on the website in order to identify potential fraudulent activities and make sure that all actions are in accordance with the terms of use of the website
  • Manage our legal and operational operativity
  • Provide with administrative services
  • Who we share your information with?
    Your information is not provided by third party unless to enjoy necessary services or supporting services to our activity. Among these services we have:
  • Telephone Company (IT)
  • E-mail services (IT)
  • Mailing list services (IT)
  • IT support (IT)
  • Web development (IT)
  • Hosting supply (IT)
  • Your information will be shared only if strictly necessary. We will be obliged to share them for legal reasons. This happens:
  • If we suspect a fraudulent use or crime and we will be obliged to contact the police
  • If we need to enforce our rights due to the violation of intellectual property right, missing payments or unfulfillment of contractual obligations.
  • To settle litigations with you and third party.
  • To comply with legal obligations.
  • Where and how do we store your information?
    Your personal information is memorised to safety on our servers or on those of our hosting service providers and occasionally in backups stored in safe places. The access to your personal data is restricted to authorised personnel only and only for the reasons mentioned above. We use authenticated access measure and, if possible, we encrypt your data. We use safe transition technologies with cryptography such as SSL (Secure Sockets Layer) in order to protect financial transactions. Paper documents containing your information is stored in restricted areas and is accessible to authorised personnel who can process them for supplying the service.
    How long do we store your information?
    We store your information just for the time we need to provide you with the services or to comply with regulations. In some cases, this period is specified clearly:
  • Per gli ordini di prodotti e servizi conserviamo le tue informazioni per 10 anni dopo il termine dell’anno finanziario.
  • For the mailing list you are registered to, we store your information as long as you keep your subscription or until when we decide to suspend the service.
  • For the emails and correspondence, we will keep your information for the period we need to answer you and for the following 6 months. After that, we will cancel your information.
  • If we cannot give a clear date, we store information until when it is necessary by considering the following criteria:
  • The purpose and use of the piece of information now and in the future
  • The possible obligations to store the registrations
  • The potential risks concerning the storage of personal data
  • The difficulty to keep the data updated
  • The legal basis to store your data (e.g., did you give us the consent?)
  • The nature of the relation and any other circumstance
  • Cookies and web analytics, what is that?
    Cookies are little text files used by the browser to memorise information about you for different purposes. We use them in order to improve your web surfing experience (e.g., to memorise your access password) or analyse the use. To get more information visit http://www.allaboutcookies.org/ and read our policy on cookies. On our website we use Google Analytics in order to obtain information about the traffic and web surfing from Google. Google gathers some of your data among which IP and cookies to provide its analysis service which are aggregated and anonymous because we decided to set our service in this way. Read Google privacy policy for partners for further details. You can also decide to deactivate Google Analytics by downloading the plugin for your browser.
    We do not process your sensitive data
    We process only your personal data by respecting the period and the way written before. Sensitive data concern health, religion, ethnicity, political opinions, subscription to trade unions, genetic and biometric data. We do not know and we do not collect these data intentionally and you do not have to send us your sensitive data. In the case you do it, intentionally or by mistake, we will give for sure your consent to process them just to be cancelled.
    How about minor’s right?
    If you are underage, you can surf our website, but under parental or tutor’s supervision who is responsible for the use of the website. If you are under 16 years old and you want to sign up, you need the express consent by your tutor or one of your parents.
    And now let's talk about your rights
    Taking into consideration the right limitations, here we have a list of your rights that you can enforce by sending an email to info@wholetrain.it:
    • You can request the access to your information and information concerning the processing of your data
    • You can ask for the correction or cancellation of your data
    • You can ask for the limitation in the use of your data
    • You can ask to receive the data that you provided us with in the modality generally used for the communication among the machines (e.g. a CSV file)
    • You can deny the consent to the process of the data for specific purpose
    • You can withdraw the consent to the use of your data in any moment also if you previously gave us the consent without impairing our previous authorization
    Information that you make public or give to others

    We cannot be held responsible if you provide information to third party, for example by sharing a link through a social network or contacting another user. Before sharing information, check their privacy policy about how they process data.

    Policy update
    Now and then we will update our policy to comply with law modifications or inform about the modifications to our way of processing. For this reason, come back to read this updated document. It is up to you.
    How can you get in touch with us?
    You can contact us by send an email to info@wholetrain.it or by postal service to the address Via Carlo Bartolomeo Piazza, 7 - 00161 Roma. If you are not satisfied with our answers and if you think that there might be problems for the data processing, you can contact The Italian Data Protection Authority.
    Thanks for your patience!
    We thank you for having followed us up to the end, because we believe that this is the best way to understand how your personal information is used and how to process it as best as you can.