A. Legal Notice

B. Terms of Use

C. Privacy and Cookie Policy

A. LEGAL NOTICE

The websites “https://www.smartlex.eu” and “https://dashboard.smartlex.eu” are provided by: SmartLex S.r.l.
VAT number: 02190520508
Registered office: Via Lenin 132G San Giuliano Terme, 56017 (PI), Italy.
E-mail: info@smartlex.eu
Certified Email (PEC): protocollo@pec.smartlex.eu
Phone: +39 050 9350158

B. TERMS OF USE

Last update: March 2, 2026

These terms of use govern access to and use of the websites www.smartlex.eu and dashboard.smartlex.eu, owned by SmartLex s.r.l.

The User declares that they have read, understood and fully accepted these Terms of Use before using the websites www.smartlex.eu and dashboard.smartlex.eu.

a. Definitions

• “Account”: the profile created by the User to access the Services offered by SmartLex s.r.l.;
• “Generated Document”: the output produced by the SmartLex Privacy Service based on the information entered by the User;
• “Pre-filled Templates”: personal data processing templates already filled in (available in the SmartLex Privacy Service) with certain suggested information based on the information provided by the User;
• “Services”: the provision of technological and innovative tools for compliance with Privacy regulations (such as, for example, SmartLex Privacy);
• “Websites”: https://www.smartlex.eu and https://dashboard.smartlex.eu;
• “SmartLex Privacy”: one of the Services of SmartLex s.r.l. which, through the generation of the Record of Processing Activities and the related documents connected to it, enables organizations to comply with privacy obligations imposed by the GDPR (such as, for example, the mandatory drafting of the Record of Processing Activities, etc.);
• “User”: any natural or legal person who uses the Websites for professional or personal purposes.

• SmartLex Privacy Service
  SmartLex Privacy is an innovative technological tool which, through the generation of the Record of Processing Activities and the related documents connected to it, helps organizations comply with personal data protection obligations imposed by the GDPR (such as, for example, the mandatory drafting of the Record of Processing Activities, etc.).
  This is not professional legal advice from a law firm.
  Therefore:
  
  • there is no relationship comparable to that of attorney-client: the use of SmartLex Privacy does not constitute a professional legal advisory relationship subject to the corresponding legal obligations. Documents are generated automatically based on the information entered by the User according to automation logic;
  • data accuracy: the User is solely responsible for the truthfulness of the information entered. SmartLex does not verify the compliance of the automatically generated documents with the User’s actual activities nor, even less so, the correctness of the information entered;
  • exclusion of warranty: although the templates of the generated documents are constantly updated from a regulatory standpoint, their drafting depends on the information entered and on the choices made by the User, who always remains responsible for the final drafting.

• SmartLex Privacy Service
  
  • initial configuration with information entry: the User must enter information relating to their organization for the protection of Personal Data through a guided process;
  • creation of the Record of Processing Activities and entry of processing activities: after entering information about the organization, the User may create one or more Records of Processing Activities by entering all personal data processing activities carried out within their organization;
  • generation of Documents: once all processing activities have been entered, the User may download in PDF format the Record of Processing Activities and the other documents related to their organization and/or to the entered processing activities;
  • updating of documents: SmartLex undertakes to update the texts that generate the documents in the event of legislative changes;
  • review of generated documents: once downloaded, the User must verify the correctness and consistency of the content of the generated documents with the reality of their organization.

• Property of SmartLex s.r.l.
  The Websites (and all their elements such as trademarks, design, texts, hyperlinks, logos, images, videos, sounds, software, screen layouts, databases, code, etc.), the Services, the content of the pre-filled templates and that of the generated documents are the exclusive property of SmartLex s.r.l. and are protected by national and international intellectual property laws. Users, unless expressly authorized in writing by SmartLex s.r.l., may not reproduce, represent, republish, redistribute, adapt, translate and/or modify in whole or in part, or transfer to other media, any information owned by SmartLex s.r.l.
  
  Failure by the User to comply with the provisions of paragraph d. constitutes a violation punishable under applicable civil and criminal laws.
  

• The Services are offered through subscription plans or one-time purchases, as described on the relevant Service page. Unless otherwise indicated, subscriptions renew automatically.
  The User may disable renewal at any time by contacting SmartLex at the following email address: info@smartlex.eu.
  

• The User undertakes not to:
  
  • resell the templates of the generated documents to third parties;
  • use reverse-engineering techniques on software owned by SmartLex s.r.l.;
  • reproduce, represent, republish, redistribute, adapt, translate and/or modify in whole or in part, or transfer to other media, any information owned by SmartLex s.r.l., unless expressly authorized in writing;
  • use the SmartLex Privacy Service to generate documents for illegal activities.

• SmartLex s.r.l. reserves the right to modify these Terms of Use, in whole or in part, at any time, to reflect regulatory changes or technical developments of the Services. In the event of substantial changes, SmartLex will notify users by email of the modification/update of these Terms of Use. It is therefore the User’s responsibility to regularly review the latest version of these Terms of Use.
  In case of disagreement with changes to the Terms of Use, as notified with appropriate notice in accordance with applicable EU laws, the User must cease using the Websites owned by SmartLex s.r.l.
  By continuing to use the Websites after the notice date, Users agree to be bound by the updated Terms of Use.
  
  • Exercise of the Right of Withdrawal
    Users, if EU or UK consumers, may exercise the right of withdrawal within 14 days from the date of acquisition of the service. To exercise the right of withdrawal, it is necessary to contact SmartLex at the following email address: info@smartlex.eu.

• In the event of total or partial breach or failure by a User to comply with any of the obligations or provisions of these Terms of Use, if a User performs any of the prohibited actions provided for herein, or for any other reason, SmartLex s.r.l. may modify, suspend, limit or remove access to one or all Services, including deactivation of the User’s Account, without notice and without the User having the right to claim compensation, and without prejudice to any compensation that SmartLex s.r.l. may otherwise seek in court.
  
  SmartLex s.r.l. also reserves the right to claim compensation for any damages suffered.
  

• Account activation and the provision of Personal Data and organizational information occur upon purchase of one of the Services on the Websites. Withdrawal from all services does not imply a request for Account deletion. Account deletion must be explicitly requested (via email to: info@smartlex.eu) and entails the complete deletion of data from the database, without prejudice to legal or contractual retention obligations.
  

• Governing law
  These Terms of Use and the relationships between SmartLex s.r.l. and Users are governed by and interpreted in accordance with Italian law. If the User acts as a consumer in the United Kingdom or the European Union, this does not prevent the application of mandatory rights granted under the applicable law of their country of residence.
  
• Dispute resolution – jurisdiction
  Jurisdiction for non-consumers: for any dispute arising from or relating to these Terms of Use, if the User does not act as a consumer, any dispute shall be subject to the exclusive jurisdiction of the Court of Pisa.
  Jurisdiction for consumers: for any dispute arising from or relating to these Terms of Use, if the User acts as a consumer, territorial jurisdiction shall mandatorily lie with the court of the place of their residence or domicile, if located within the territory of the Italian State or the European Union.
  

C. PRIVACY AND COOKIE POLICY

Last update: March 2, 2026

Privacy Notice on the Processing of Personal Data for the websites www.smartlex.eu and dashboard.smartlex.eu

Dear Users,

The protection of your Personal Data is important to SmartLex s.r.l. (hereinafter, “SmartLex”). On this page we will explain how SmartLex manages your Personal Data (as Users) and how it uses cookies on the websites www.smartlex.eu and dashboard.smartlex.eu.
We want to be clear and transparent about how we protect your information when you browse our platforms and how we track your browsing to offer you a secure and tailored experience.

The following notice therefore relates exclusively to any Processing of Users’ Personal Data carried out by SmartLex during and in connection with browsing the websites.

• a. Data Controller
  The Data Controller of your Personal Data is SmartLex S.r.l., Via Lenin 132G, 56017 San Giuliano Terme (PI), email address: info@smartlex.eu.
• b. Purposes of Processing of Personal Data
  Users’ Personal Data are collected and used to:
  
  • register and manage the Account, including enabling access to the websites;
  • process payments for the Services;
  • allow browsing on the websites, improving the browsing experience;
  • respond to any requests and communications from Users;
  • monitor and improve the quality of the service and the websites.
  Please note that statistical data on access to and use of the websites are also collected, including through third-party cookies.
  
• c. Categories of data processed
  Data collected by SmartLex may include the following:
  
  • Identification data of the User (such as first name, last name, phone number, postal addresses and email addresses);
  • Username and Password and other Account-related details;
  • Billing information and other payment information (such as the name of the payment card holder and the billing address);
  • Browsing data: the IT systems and software procedures used to operate these websites acquire, during their normal operation, certain Personal Data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified data subjects, but which, by its very nature, could, through processing and association with data held by third parties, allow Users to be identified. This category includes IP addresses or domain names of the computers used by Users who connect to the websites, URI (Uniform Resource Identifier) addresses of requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (e.g., successful outcome, error, etc.) and other parameters relating to the User’s operating system and IT environment. The data may be used to ascertain liability in the event of alleged cybercrimes to the detriment of the websites.
  • Data voluntarily provided by Users: the optional, explicit and voluntary sending of data through web forms or by email to the addresses indicated on these websites entails the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other Personal Data included in the message. Such data will be used only for these purposes, unless a different legal basis applies.
• d. Optional nature of providing data
  Except as specified for browsing data and cookies, the User is free to provide their Personal Data to request the sending of informational material or other communications or to proceed with the purchase of products.
  
• e. Methods of Processing of Personal Data, security and deletion of information
  Users’ Personal Data are processed through automated tools (e.g., using electronic procedures and media) for the time strictly necessary to achieve the purposes for which the data were collected and, in any case, in compliance with applicable laws. SmartLex adopts specific security measures to prevent data loss, unlawful or incorrect use and unauthorized access (for example, robust encryption mechanisms, access controls, automatic backup mechanisms, redundancy, etc.).
  
  SmartLex will retain Users’ Personal Data (provided upon creation of the Account) until a request for Account deletion, without prejudice to SmartLex s.r.l.’s retention and use of Personal Data to establish, exercise or defend its rights.
  
• f. Sharing data with third parties
  Except for the cases indicated in this notice, no data collected during Users’ browsing of the websites is disclosed to third parties or disseminated.
  The website may allow the use of “third-party” cookies, governed by this notice and the Cookie Policy, in compliance with applicable law.
  
• g. Transfer of Personal Data to countries outside the European Union
  Personal Data collected by SmartLex are processed and stored within the territory of the European Union. However, certain Personal Data may be transferred to recipients located outside the European Economic Area. The websites smartlex.eu and dashboard.smartlex.eu use Google Analytics and Contentsquare services.
  
  • Google Analytics: this is a service that uses cookies and similar technologies to collect information on how Users use the website. The data collected may include IP addresses, browsing data, device and browser information, and are processed in aggregated form for statistical and analytical purposes. The legal basis for processing is the data subject’s consent, given via the cookie banner. Data may be transferred to third countries, in particular to the United States of America, on the basis of Standard Contractual Clauses and the EU–US Data Privacy Framework. The collected data are retained for a maximum period of 14 months. The user may withdraw consent at any time via cookie settings.
  • Contentsquare: this is a service that helps understand how Users interact with pages through session recordings, heatmaps and feedback tools. Contentsquare may collect information related to browsing behavior, interactions with the interface and technical data of the device. Data are collected in pseudonymized form and Contentsquare applies masking mechanisms to avoid collecting Personal Data entered into input fields. The legal basis for processing is the data subject’s consent, given via the cookie banner. Data may be transferred to third countries, in particular to the United States of America, on the basis of Standard Contractual Clauses adopted by the European Commission. The user may withdraw consent at any time via cookie settings.
• h. Data Subjects’ Rights
  Pursuant to Articles 15–22 of the GDPR, Data Subjects have the right to:
  
  • Request access to their Personal Data: the User has the right to request and obtain from the Data Controller confirmation as to whether or not Personal Data concerning them are being processed and, where that is the case, access to such data. Access may be requested in order to obtain the following information:
    
    • The purposes of Processing;
    • The categories of Personal Data collected;
    • The recipients or categories of recipients to whom the data have been or will be disclosed, in particular recipients in third countries or international organizations;
    • The retention period of Personal Data or, if that is not possible, the criteria used to determine that period;
    • The right to request from the Controller rectification or erasure of Personal Data or restriction of processing or to object to processing;
    • The existence of an automated decision-making process.
  • Request rectification of Personal Data: the Data Subject has the right to obtain rectification of inaccurate Personal Data concerning them, as well as to have incomplete Personal Data completed;
  • ‍Request erasure of Personal Data: for the reasons set out in Article 17 GDPR, the Data Subject has the right to request from the Data Controller the erasure of data without undue delay, and the Controller has the obligation to erase, without delay, the Data Subject’s Personal Data, provided that there is no legal obligation to retain the data ex lege;
  • ‍Request restriction of data processing: for one of the reasons set out in Article 18 GDPR, the Data Subject has the right to request restriction of processing of Personal Data concerning them;
  • ‍Request data portability: the Data Subject has the right to receive, in a structured, commonly used and machine-readable format, the Personal Data concerning them which they have provided to a Controller and has the right to transmit those data to another Controller where the processing is based on consent or on a contract and is carried out by automated means;
  • ‍Request objection to Processing: the Data Subject has the right to object to the processing of Personal Data concerning them at any time, on grounds relating to their particular situation;
  • ‍Withdrawal of consent: the Data Subject has the right to withdraw consent to the processing of their Personal Data at any time, as easily as it was given.
  The data subject also has the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei Dati Personali) (see www.garanteprivacy.it).
  Requests to exercise the above rights may be submitted: to the email address: info@smartlex.eu
  
• i. Links to other Websites
  This privacy notice refers exclusively to the websites www.smartlex.eu and dashboard.smartlex.eu. For any links to third-party websites, it is specified that SmartLex does not exercise any form of control over them. SmartLex will therefore not be liable in any way for the processing of Personal Data carried out by such third parties.
  
  Cookie Notice for the websites smartlex.eu and dashboard.smartlex.eu
  
  • a. Cookie Processing
    • What cookies are and what their functions are
      Cookies are small text files that the websites visited by the User send to their device (computer, smartphone or tablet), where they are stored to be retransmitted to the same websites upon the next visit.
      We can think of them as a “technical memory” of the browser that allows the website to:
      
      • recognize the User, avoiding, for example, that the user has to enter username and password on each new page;
      • remember the User’s choices, such as the preferred language or products added to the cart;
      • understand how the User browses, collecting statistical data (often anonymous) to improve the website’s operation.
      Cookies may perform different functions:
      
      • technical cookies are essential for the proper functioning of the website (for example, they allow remembering the User during their browsing on the website);
      • analytical cookies collect aggregated information regarding the parts of the website most frequently visited by Users and often monitor promotional messages delivered by the website itself, in order to improve content and facilitate consultation;
      • profiling cookies are used to study the User’s interests and create related profiles based on browsing experience, not only on the single website, but generally across the web, and are used to send advertising messages in line with the preferences expressed by the User while browsing online.
    • Cookies used on the websites www.smartlex.eu and dashboard.smartlex.eu
      The cookies installed by the websites www.smartlex.eu and dashboard.smartlex.eu are:
      
      • Technical cookies: they ensure normal browsing and use of the website (allowing, for example, to make a purchase or authenticate to access restricted areas).
        SmartLex uses two types of technical cookies:
        
        • Technical authentication cookies (session cookies)
          These cookies are necessary for managing the user session and enabling access to restricted areas. In particular:
          - they are generated at login;
          - they allow the system to recognize the User during authenticated browsing;
          - they are valid only for the access session or for the duration of the relevant token;
          - they are automatically deleted at logout or upon expiration.
          They are essential to ensure Account security and the proper functioning of restricted features.
          
        • Technical functionality cookies
          SmartLex uses technical functionality cookies aimed at improving the use of the website and storing certain technical choices made by the User. These cookies may have a variable duration and are used, for example, to:
          - store acknowledgement of the cookie banner (technical cookie consent);
          - show or hide certain interface elements;
          - properly manage navigation components and platform features.
          
      • Analytical (statistical) cookies: they are used by the website operator to collect information, in aggregated form, on the number of Users and how they visit the website in order to improve the service.
      • Profiling cookies: SmartLex does not use profiling cookies, as it has no interest in tracking or profiling the User for advertising purposes nor in collecting information suitable for identifying them individually. SmartLex s.r.l. uses Google Analytics 4 (GA4) which has IP anonymization enabled automatically and does not collect Personal Data.
  • b. Cookie management
    
    SmartLex allows Users to easily adjust and customize previously set cookie preferences by clicking the “Manage cookie preferences” button, always available in the lower section of the website and the dashboard.
    Consent to technical cookies (both session and functionality) is always active and cannot be disabled, as these cookies are necessary for the proper operation of the website, authentication, security and the provision of SmartLex services.
    The User’s consent is requested (and can be changed) exclusively for the use of analytical cookies, used solely to analyze, in aggregated form, website usage and to improve functionality, performance and user experience. Refusal of such cookies does not affect access to SmartLex services.
    Below are links for cookie management in the main browsers:
    
    • Google Chrome: https://support.google.com/chrome/answer/95647.
    • Mozilla Firefox: https://support.mozilla.org/kb/enable-and-disable-cookies-website-preferences.
    • Apple Safari (macOS): https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac.
    • Apple Safari (iPhone/iPad): https://support.apple.com/en-us/HT201265.
    • Microsoft Edge: https://support.microsoft.com/windows/manage-cookies-in-microsoft-edge-view-allow-block-delete-and-use-168dab11-0753-043d-7c16-ede5947fc64d.

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