EU Regulation 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, the so called General Data Protection Regulation (hereinafter “GDPR”) and legislative decree no. 196/2003 and subsequent amendments and integrations (hereinafter the “Privacy Code” and collectively with the GDPR, the “Privacy Legislation”) introduced laws for the protection of natural persons with respect to personal data processing.
The Firm is the data controller, having its registered office in Rome, Via Venti Settembre 1. For any issues pertaining to the protection of personal data, please contact the data controller at the following email address: firstname.lastname@example.org.
Categories of personal data collected and processed
- Navigation Data
When the Site is visited or consulted, the Firm does not generally collect users’ personal data, except for the 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 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.
- Data provided voluntarily by the user
The personal data provided by users voluntarily when interacting with the “Recruitment” feature of the Site in order to send their CV are collected and processed by the Firm. In the latter case, pursuant to art. 111-bis of the Privacy Code, the user’s specific consent to the processing of the data provided in said section is not required for the purposes set forth in art. 6, para. 1, lett. b) of the GDPR.
Purposes of data processing
The Firm shall process users’ data for the following purposes:
- operational management of Site navigation;
- management of Site security;
- statistical analysis;
- search and selection of associates or personnel.
Legal basis for the processing of data
The processing carried out by the Firm for the above-mentioned purposes may be legally based on one of the following:
- as far as navigation data are concerned, processing is necessary to pursue a legitimate interest of the Firm. Specifically, the legitimate interest in the proper functioning of its Site and in the production of statists regarding user Site navigation;
- as far as the data voluntarily provided by users is concerned, processing is necessary for the performance of the pre-contractual measures adopted upon the data subject’s request.
The personal data will be processed on paper and through automated means, only with procedures that are strictly necessary to achieve the above described purposes. The processing is carried out through the operations set out in art. 4 n. 2) of the GDPR, with or without automated means, and more specifically: collection, recording, organisation, structuring, updating, storage, adaptation or alteration, retrieval and analysis, comparison, consultation, use, disclosure by transmission, alignment or combination, restriction, erasure or destruction.
All personal data will be processed in accordance with current legislation on the protection of personal data, in particular the principles of lawfulness, fairness, transparency, minimisation, accuracy, integrity and confidentiality and by using appropriate organisational and technical measures ensuring the security of data and the protection of the processing from unauthorized and unlawful processing, loss, destruction and accidental damage.
Scope of data provision
Except for navigation data (which are automatically collected by the system), the provision of personal data by users 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.
Storage of personal data
The personal data processed for the above-mentioned purposes will be stored both on hard-copy and digital files for as long as it is strictly necessary.
Recipients or categories of recipients of personal data
The personal data will be processed exclusively by individuals authorised to perform such processing, such as professionals and employees of the Firm, to the extent strictly necessary in order to pursue the above-mentioned purposes; generally, the data can be communicated for the purposes set forth above to all individuals/entities in relation to which said communication is necessary for the achievement of the above-mentioned purposes.
Profiling and data dissemination
The personal data processed by the Firm are not subject to dissemination or to any decision-making process executed wholly by automated means, including profiling.
Data subject’s rights
Pursuant to Chapter III of the GDPR, data subjects are entitled to exercise, among other things, the following rights:
- request access to their personal data and to information concerning the same; rectification of inaccurate data or integration of incomplete data; erasure of personal data (in the event that one of the conditions set out in art. 17, paragraph 1 of the GDPR is met and in compliance with the exceptions set out in paragraph 3 of the same article); restriction of processing (if one of the conditions set out in art. 18, paragraph 1 of the GDPR is met);
- request and obtain – where the processing is based on a contract and carried out by automated means – his/her personal data in a structured and machine-readable format, also in order to transmit those data to another data controller (so called “right to data portability”);
- object at any time to the processing of personal data on grounds relating to his/her specific situation;
- withdraw of his/her consent at any time, limited to the cases in which the processing is based on the data subject’s consent to one or more specific purposes and concerns “ordinary” data (e.g., date and place of birth or his/her residence), or specific categories of data (e.g., data revealing racial origin, political opinions, religious beliefs, data concerning health or a person’s sex life) – it being understood that such withdrawal shall not affect the lawfulness of processing based on consent before its withdrawal.
Furthermore, pursuant to art. 77 of the GDPR, data subjects are entitled to lodge a complaint with the competent supervisory authority (Autorità Garante per la protezione dei dati personali – www.garanteprivacy.it).
Amendments to this document
- 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: http://windows.microsoft.com/it-it/windows7/how-to-manage-cookies-in-internet-explorer-9