Information provided pursuant to Articles 13-14 of the GDPR (General Data Protection Regulation) No. 2016/679 (hereinafter referred to as the “Regulation”)
1. DATA CONTROLLER AND DATA PROTECTION OFFICER
The data controller is Almec Srl, VAT Number IT04953110261, with registered office in Via del Lavoro 19, 31013 Codognè (TV) – Italy, who can be contacted at the following address: email@example.com for any information relating to the processing of personal data by Almec Srl.
2. TYPES OF DATA COLLECTED
The Data Controller informs you that, for the normal operation of the site, it will process data that by their nature can be defined as personal data. Personal data means any information relating to a natural person, identified or identifiable, even indirectly, by reference to any other information, including a personal identification number.
The personal data processed through the site are as follows:
a) Navigation Data
During the normal operation of the site, computer systems and software procedures acquire certain personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected in order to be associated with identified interested parties, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users connecting to the site, the URI (Uniform Resource Identifier) notation addresses of the resources requested, 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 (successful, error, etc.) and other parameters relating to the user’s operating system and IT environment.
b) Common personal data
In order to access certain services on the site, you may be required to provide common personal data. Such personal data may include, but are not limited to: first name, last name, e-mail address, telephone number, etc.
c) Special categories of personal data
When using the form in the contact section to send applications, you may be asked to provide personal data falling into the categories mentioned in art. 9 of the Regulation, the so-called special data: “[…] data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as […] genetic data, biometric data capable of uniquely identifying a natural person, data concerning a person’s health or sex life or sexual orientation”. These categories of data will be processed with the prior consent of the data subject.
We also inform you that, for the purpose of collecting applications, Almec Srl may analyse your social profiles of a professional nature, freely available on the Internet (e.g. LinkedIn).
3. FINALITÀ DEL TRATTAMENTO
The data you provide, including those of a personal and possibly particular nature, will be processed for the following purposes:
a. reply to any contact requests received by e-mail or by filling in the contact form on the Contact page;
b. publish comments referring to blog articles;
c. collecting applications, evaluating CVs and contacting candidates if necessary;
d. send newsletters or commercial and marketing communications;
e. carrying out administrative-accounting activities in general. For the purposes of the application of the provisions on the protection of personal data, processing carried out for administrative-accounting purposes are those connected with the performance of activities of an organisational, administrative, financial and accounting nature, regardless of the nature of the data processed. In particular, internal organisational activities, those functional to the fulfilment of contractual and pre-contractual obligations and information activities pursue these purposes.
4. METHODS OF PROCESSING
The processing will be carried out in paper and/or computerised form, but in any case with suitable measures to guarantee maximum security, by specially trained and appointed persons. The data collected for the purposes set out in section 3(a,b,c,f) will be kept for the time strictly necessary to fulfil these purposes. As regards the retention of data according to the purpose of collecting applications under section 3(d), the time identified is 36 months from the date of receipt of the application. On the other hand, in the case of data processing for commercial and marketing purposes referred to in section 3(e), the retention period has been set at 36 months. Further information on the data retention period and the criteria used to determine this period may be requested by writing to Almec Srl at the following address: firstname.lastname@example.org
5. LEGAL BASIS AND MANDATORY OR OPTIONAL NATURE OF PROCESSING
The legal basis for the processing of personal data for the purposes referred to in Section 3 (d,e) is Art. 6(1)(a) of the Regulation as the processing operations are subject to the acquisition of explicit consent. The legal basis for the processing of personal data for the purposes referred to in section 3 (a,b,c,f) is Art. 6(1)(b) of the Regulation insofar as the processing operations are necessary for the provision of the services or for the response to the data subject’s requests. The provision of personal data for these purposes is optional, but failure to provide them would make it impossible to activate the services provided by the site, respond to requests or evaluate applications. With specific reference to the purpose referred to in section 3(d) and to the related analysis of social profiles of a professional nature made freely available on the Internet referred to in section 2, the legal basis for the processing is Article 6(1)(f) of the Regulation, i.e. the legitimate interest of WABi lab Snc in verifying any risks concerning the candidate’s suitability for specific positions.
6. RECIPIENTS OF PERSONAL DATA
Your personal data may be shared, for the purposes set out in section 3, with:
a. parties acting as data processors, i.e.: parties with whom it is necessary to interact in order to provide the services (e.g. hosting providers, content managers), or parties delegated to perform technical maintenance activities;
b. entities, bodies or authorities to whom your personal data must be disclosed by virtue of legal provisions or orders of the authorities;
c. persons authorised by Almec Srl to process personal data necessary to carry out activities strictly related to the provision of services, who have committed themselves to confidentiality.
7. TRANSFERS OF PERSONAL DATA
In order to make it possible to fulfil the purposes set forth in section 3(e), the collected data may be transferred abroad, even outside the European Union, in the forms and ways provided for by the laws in force, guaranteeing in any case an adequate level of protection. In order to send commercial and marketing communications, Almec Srl makes use of www.brevo.com/, the Autonomous Data Controller, a proprietary mailing platform that, through statistical tracking systems, allows to detect the opening of a message, the clicks made on hypertext links contained within the email, from which IP address or which type of browser the email is opened, and other similar details. The collection of this data is functional to the use of the platform and is an integral part of the functionality of the message delivery system.
8. RIGHTS OF THE INTERESTED PARTIES
Specific rights are granted to the person concerned:
- the data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, even if they have not yet been recorded, and communication of such data in intelligible form;
- the interested party also has the right to obtain information on: the origin of the personal data; the purposes and methods of processing; the logic applied in the event of processing carried out with the aid of electronic instruments; the identification details of the data controller, data processors and the designated representative and their contact details; the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of it in their capacity as designated representative in the territory of the State, data processors or persons in charge of processing.
- The data subject is also entitled to obtain the legitimate interests pursued by the data controller or by third parties; the recipients or categories of recipients of the personal data, if any; the intention of the data controller to transfer the personal data to a third country or international organisation and the existence or absence of a Commission adequacy decision the data retention period or, if this is not possible, the criteria used to determine this period; the existence of an automated decision-making process; the right to lodge a complaint with the supervisory authority; the right to be informed if disclosure of the data constitutes a legal or contractual obligation or a necessary requirement for the conclusion of the contract.
- The data subject shall also have the right to obtain a) the updating, rectification or, where interested therein, the integration of the data; b) the cancellation, transformation into anonymous form or blocking of data processed in breach of the law, including data that need not be kept for the purposes for which the data were collected or subsequently processed c) certification to the effect that the operations as per letters a) and b) of this paragraph have been notified, as also related to their contents; the names of the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
- finally, the data subject shall have the right to object, in whole or in part: a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of collection; b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.
The data subject may exercise the aforementioned rights by contacting the Data Protection Officer at the following address: email@example.com.
Almec Srl, will provide an appropriate response without delay, and in any case within a period not exceeding 1 month. In the event of particular complexity, the deadline for the response, in accordance with the Regulation, may be 3 months.
9. RIGHTS TO COMPLAIN TO THE SUPERVISORY AUTHORITY
We would also like to inform you that pursuant to Articles 77 et seq. of EU Reg. 2016/679, if you believe your rights have been infringed upon, you may appeal to the Data Protection Authority as well as to the ordinary judicial authority.
Any translation of this document into a language other than Italian is provided for information purposes only. In case of discrepancies, the only legally valid and binding version is the Italian version of this document.
Via del Lavoro 19, 31013
Z.I. Cimavilla di Codognè (TV), Italy
VAT Number 04953110261
Economic and Administrative Index (REA) TV–413208
Share capital: 100,000.00 fully paid-up