In compliance with the Regulation, any Personal Data processing carried out by ITALIA LONGE will respect the principles of lawfulness, fairness, transparency, purpose and storage limitation, data minimization, accuracy, integrity and confidentiality.
- Who is the Data controller of your Personal Information?
- What do we mean with Personal Data and which Personal Data we collect?
- Which is the purpose of Data Processing?
- Which is the legal basis of processing your Personal Data?
- How do we process your Data?
- Who are the recipients of Personal Data?
- Where do we transfer your Personal Data?
- How long do we store your Personal Data?
- Which are your rights?
1. Who is the Data controller of your Personal Information?
The Data Controller regarding all Personal Data processing operations carried out through the Website is ITALIA LOUNGE S.r.l., in the person of its pro tempore legal representative, as above indicated. For any information regarding the processing of Personal Data by ITALIA LOUNGE please contact: firstname.lastname@example.org.
2. What do we mean with Personal Data and which Personal Data we collect?
With “Personal Data” we mean any information directly or indirectly identifying an individual, in this case You, the user of the services provided by ITALIA LOUNGE.
We collect and handle your Personal Data necessary to provide the required services, as:
- Browsing data;
- Biographical and identifying data (name, surname);
- Contact data (mobile/landline telephone number, email address);
- Curriculum vitae (CV).
While using the section “Contact Us” under the option “Type of request – Work with us”, the transfer of your personal data which falls into the special categories of personal data pursuant to art. 9 of the Regulation, may occur, textually “[…] personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data intended to uniquely identify a natural person, data relating to a person’s health, sex life or sexual orientation”. We invite you to refrain from publishing such data unless strictly necessary. In fact, we remind you that, in the event of submission of special categories of personal data but in the absence of a specific demonstration of consent to process such data (a possibility that obviously allows users to send a curriculum vitae), ITALIA LOUNGE cannot be held responsible for any reason whatsoever, nor can receive any complaints of any kind, since, in this case, the processing of the Data will be possible as having object Data which are manifestly made public by the owner, in compliance with art. 9(1)(e) of the Regulation. We, therefore, specify the importance, as already indicated above – for you to express explicit consent to the processing of the special categories of personal data, if and when you decide to share such information.
We inform you that, in order to help us assess your compatibility with the position for which you have applied, ITALIA LOUNGE may evaluate your professional profiles on social networks (e.g., Linkedin), if publicly accessible.
3. Which is the purpose of Data Processing?
We collect and process your Personal Data which are strictly necessary to follow up your requests or services stipulated. In particular:
- Answer requests of assistance, information or give quotations required through the section “Contact Us”;
- Analyse Curriculum Vitae (CVs) and re-contact the candidates who submitted their job application through the section “Contact Us” under the option “Type of request – Work with us”;
- Fulfil any obligations stipulated by applicable laws (e.g. financial and fiscal obligations).
We are committed to grant that the Personal Data collected and processed are appropriate respect to the purposes described, and that do not determine an invasion of your privacy.
4. Which is the legal basis of processing your Personal Data?
The legal basis for processing personal data for the purposes set out in section 4(a-b) is art. 6(1)(b) of the Regulation, as processing is necessary for the provision of services and to respond to requests made by the interested party. The provision of personal data for these purposes is optional, but failure to provide it would make it impossible to activate the services provided by the Website, reply to requests or evaluate CVs.
With reference to the purposes referred to in section 4(b) and the related analysis of the professional social profiles freely available on the Internet as per section 3, the legal basis of the processing is art. 6(1)(f) of the Regulation, namely, ITALIA LOUNGE’s legitimate interest to verify any risks regarding the suitability of the candidate to occupy the specific vacant position.
The legal basis for processing personal data for the purposes referred to in section 4(c) is art. 6(1)(c) of the Regulation. Once personal data are conferred, processing is necessary to comply with a legal obligation to which ITALIA LOUNGE is subject.
5. How do we process your Data?
Your Personal Data may be processed using manual processes, electronical systems or automated systems, implementing a principle of strict necessity and guaranteeing your Personal Data (with particular regard when using the means of distance communication).
6. Who are the recipients of Personal Data?
Your Personal Data may be shared, for the purposed listed in Section 4, with the following persons / entities:
- Entities acting as data processor for ITALIA LOUNGE and only upon instruction of ITALIA LOUNGE, e.g.: i) Persons, Companies or Firm providing assistance and expertise to ITALIA LOUNGE in accounting, administrative, legal, tax and financial matters and debt recovery, connected to the provision of services; ii) entities with which it is necessary to interact for the provision of services (e.g. hosting providers and bank institutions); iii) entities delegated to technical maintenance (including maintenance of the network equipment and electronic communications networks);
- Public entities, bodies or authorities to whom your Personal Data must be disclosed, under the applicable law or following binding orders from those entities, bodies or authorities;
- Persons authorized by ITALIA LOUNGE to process Personal Data needed to carry out activities related to the provision of services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of ITALIA LOUNGE).
7. Where do we transfer your Personal Data?
Generally, we do not share your Data with Recipients who may be located outside the European Union. If this occurs, we ensure that your Personal Data is processed in accordance with the Regulation, included clauses specifically given for the sharing of your personal data to third countries. These transfers can be based, among other mechanisms, on an adequacy decision or on agreements including standard data protection clauses approved by the European Commission.
8. How long do we store your Personal Data?
Your Personal Data shall be stored for time strictly necessary to achieve above mentioned purposes.
In detail, we indicate below the more relevant periods of retention of Personal Data with reference to the different purposes:
- With reference to purposes of recruiting of employee or staff, your Personal Data will be store for a period up to 24 months from the receipt of your CV;
- For the amount of time envisaged by the specific obligation or applicable legal standard.
9. Which are your rights?
• Right of access: you have the right to obtain confirmation as to the existence of your Personal Data being processed, access and obtain copy of such data;
• Right of rectification: you have right to rectify your Personal Data where it may be inaccurate or incomplete;
• Right to erasure: in some circumstances, you can obtain erasure of your Personal Data in our archives, where non-relevant for the continuation of the contractual relationship or unnecessary by legal requirements.
• Right to limitation of processing: upon the occurrence of certain conditions, you have the right to request the limitation of processing where non-relevant for the continuation of the contractual relationship or unnecessary by legal requirements.
• Right to portability: you have the right to obtain the transfer of your Data to a different data Controller.
• Right to oppose processing: you have the right to oppose processing, in any moment for reasons connected to your situation, to the Personal Data, based on the condition of lawfulness of the legitimate interest or the execution of a task of public interest or the exercise of official authority, included profiling.
• Right of revocation: you have the right to withdraw the consent of processing your Personal Data in any moment, without precluding the lawfulness of the processing based on the consent before the revocation.
Requests should be sent in writing to ITALIA LOUNGE to the following address: email@example.com.
The exercise of your rights is free pursuant to art. 12 of the Regulation.
In any case, you are always entitled to lodge a complaint with the competent supervisory authority (Italian Data Protection Authority), pursuant to art. 77 of the Regulation, if you consider the processing of your data to be in violation of the existing legislation.