1) TYPES OF PERSONAL DATA COLLECTED AND PROCESSED
- A) Navigation data
When the Site is visited or consulted, the Firm does not generally collect the user’s personal data, except for so-called navigation data. As a matter of fact, the technological platform through which the Site is made available to users automatically records some of their navigation data – which are implicitly transmitted while using web communications protocols – such as, for example, the name of the internet provider, the site of origin, which pages have been viewed, date e duration of the visit etc.. Such information may be used in anonymous and aggregate form for statistical purposes and to verify the proper functioning of the Site.
- B) Data provided voluntarily by the user
2) PURPOSES OF DATA PROCESSING
The Firm shall process the user’s data for the following purposes:
- operational management of Site navigation;
- management of Site security;
- statistical analysis;
- search and selection of associates and personnel.
3) PROCESSING MODES
Processing takes place through the procedures or series of procedures set forth in art. 4, para. 1, letter a) of the Privacy Code (collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, deletion and destruction of data).
The procedures can be followed with or without the support of electronic or, in any case, automated systems. The processing is carried out by the data controller and/or the data processors and/or the persons in charge of data processing.
In pursuance of the Privacy Code, specific safety measures are observed in order to prevent data loss, unlawful or improper use and unauthorized access.
4) SCOPE OF DATA PROVISION
Except for navigation data (which are automatically collected by the system), the provision of personal data by the user with regard to the “Recruitment” feature of the Site is optional. The provision of personal data is necessary in order to use such feature of the Site. Failure to provide the data shall make it impossible to access said feature of the Site.
5) ENTITIES INVOLVED IN THE PROCESSING
The Firm, with office in Rome, Via Venti Settembre no. 1, is the data controller (“Data Controller”).
The personal data may be conveyed to and processed by the data processors or the persons in charge of data processing, in compliance with the provisions of articles 29 and 30 of the Privacy Code, and they may be communicated for the purposes under point 2 to associates and employees of the Firm and, in general, to all those entities to whom such communication is necessary for the proper fulfilment of the purposes set forth under point 2.
An updated list of the data processors or the persons in charge of data processing can be obtained from the Data Controller identified below by sending a request to the following e-mail address email@example.com.
The user’s personal data shall not be distributed.
6) AMENDMENTS TO THIS DOCUMENT
7) USER RIGHTS
The users of the Site may exercise the rights under article 7 of the Privacy Code, the unabridged version of which can be read hereinafter. Such rights may be exercised without any formality, by simply sending a request to the Data Controller as identified above, at the following e-mail address firstname.lastname@example.org.
Art. 7 of Legislative Decree 196/2003. Rights of the data subject
- The data subject has the right to obtain confirmation as to whether or not personal data concerning him exist, even if they have not been recorded yet, and communication of such data in an understandable form.
- The data subject has the right to be informed of:
- the source of the personal data;
- the purposes and methods of the processing;
- the reasons behind the processing in case the latter is done with the support of electronic systems;
- the personal details of the data controller, of the data processors and of the designated representative pursuant to article 5, para. 2;
- the entities or categories of entities to whom such personal data may be communicated or who may become aware of them in their capacity as designated representatives in the territory of the State, as data processors or as persons in charge of data processing.
- The data subject has the right to obtain:
- the update, the amendment and, if interested therein, the integration of the data;
- the deletion, the transformation in anonymous form or the blocking of data processed in violation of the law, including data whose storage is not necessary in relation to the purposes for which they were collected or subsequently processed;
- the certification to the effect that the procedures under letters a) and b) have been conveyed, also with regard to their content, to those to whom the data has been communicated or spread, except where such obligation proves to be impossible or requires efforts that are manifestly disproportionate compared with the right to be protected.
- The data subject has the right to object, in whole or in part:
- for legitimate reasons, to the processing of personal data concerning him, even if they are pertinent to the purpose of such collection;
- to the processing of personal data concerning him, carried out to send advertising materials or for direct sale purposes or to carry out market or commercial communication research.
- A) What are cookies?
Cookies are small files stored on the computer and sent directly by visited websites or – where required – also by third parties (so-called “third parties”). Cookies are stored on the browser’s file directory. During the user’s subsequent visit to the website, the browser reads the cookie and retransmits the information to the same site or to the third party that originally created the cookie.
- B) Cookies used by the Site
The Site only uses so-called “technical cookies”. It does not use profiling cookies, nor does it send cookies to third parties.
“Technical” cookies are those used for the sole purpose of «carrying out the transmission of a communication on an electronic communications network, or insofar as this is strictly necessary to the provider of an information society service that has been explicitly requested by the customer or user to provide said service» (art. 122, para. 1, of the Privacy Code). They are usually installed directly by the owner or manager of the website and can be divided in:
- navigation or session cookies necessary to ensure the regular navigation and use of the website;
- analytics cookies used by website managers to collect aggregate information on the number of users and on how websites are visited;
- functionality cookies, which allow the user to navigate on the basis of a number of selected criteria (e.g., language, products selected for purchase) for the purpose of improving the website navigation experience.
The use of the above types of cookies does not require the user’s prior consent.
- C) Browser settings
The user can decide whether or not to accept cookies by accessing the browser settings.
The total or partial disabling of technical cookies may affect the proper functioning of the Site.
Most browsers automatically accept cookies and allow for most cookies to be controlled through the browser settings, even though the user is not required to accept them. Cookies can be disabled also by changing browser settings, by following the procedure to adjust such settings.
Please find below the links to the settings section of the most common browsers:
Internet Explorer: //windows.microsoft.com/it-it/windows7/how-to-manage-cookies-in-internet-explorer-9