PRIVACY INFORMATION PROCESSING OF PERSONAL DATA
This page describes how to manage the site in relation to the processing of personal data of users who consult it. This is an information that is also provided pursuant to art. 13 of EU Regulation 2016/679 applicable from 25 May 2018 – General Regulation for the protection of personal data (hereinafter referred to as GDPR) to those who interact with the web services of the company THE INNOVATION FACTORY S.r.l. accessible electronically starting from the address:
https://www.theinnovationfactory.it/
The information is provided only for the site https://www.theinnovationfactory.it/ and not for other websites that may be consulted by the user via links and complies with Recommendation n. 2/2001 concerning the minimum requirements for online data collection in the European Union, adopted May 17, 2001 by the Article 29 Working Group.
1. HOLDER OF THE TREATMENT
According to the art. 4 point 7 of the GDPR 2016/679, The data controller is the company The Innovation Factory S.r.l. with headquarters in Via del Serafico, 200 – 00142 Rome – Tel .: 0039 06 6534735 – Mail: privacy@theinnovationfactory.it
2. PLACE OF DATA PROCESSING
The processing operations connected to the web services of this site take place at the headquarters of the data controller.
Using third-party cookies, processing may also take place outside the European community by Google and third-party cookie companies. In this regard, please refer to the relevan Cookie Policy.
The personal data provided by users who request dispatch of informative material are used for the sole purpose of performing the service or provision requested while some data acquisition forms provide for the possibility of communicating the personal data of the interested party to service providers to comply with to the contract and provide the services requested.
All data acquired through our website will be stored for a period of time not exceeding that necessary for the purposes for which they were collected and processed or, in accordance with the provisions of the guarantor for privacy in previous general measures, for a period not exceeding 12 months from the last action / request / activity / visit made. Upon expiration of the aforementioned storage period, the personal data will be automatically deleted, or made permanently and non-reversibly anonymous. The Personal Data you provide through the Site will be processed by THE INNOVATION FACTORY S.r.l. for the following purposes:
- Respond to specific request of the person concerned through the “Contacts” section. Consent Not required. The legal basis is based on Article 6 par. 1 letter b) or the processing is necessary for the execution of a contract of which the interested party is a party or the execution of pre-contractual measures adopted at the request of the same;
- Register voluntarily to the company’s newsletter. Required Consent. The legal basis is based on Article 6 par. 1 letter a) or processing is possible with the explicit consent of the interested party;
- To evaluate possible job applications by acquiring the curricula in the “Work with Us” section and in the online application form in the “Graduates” section. Requires explicit consent. The legal basis is based on Article 111 bis of Legislative Decree 196/2003;
- To manage requests for technical assistance through the online chat service by selecting the “Send Message” button. Consent Not required. The legal basis is based on Article 6 par. 1 letter b) or the processing is necessary for the execution of a contract of which the interested party is a party or the execution of pre-contractual measures adopted at the request of the same;
- profiling purposes through third-party cookies; Necessary consent as per Cookie Policy
- research and statistical analysis on aggregated anonymous data, aimed at measuring the functioning of the Site, measuring traffic and assessing usability and interest to make it more functional and performing; Consent not necessary as the processing of personal data is not configured
- purposes related to the fulfillment of laws and regulations; Consent Not Required The legal basis is based on Article 6 par. 1 letter c) of the GDPR 2016/679;
- purposes necessary to ascertain, exercise or defend a right in a court of law or whenever the judicial authorities exercise their jurisdictional functions. Consent Not Required The legal basis is based on Article 6 par. 1 letter f) of the GDPR 2016/679 or the processing is necessary for the pursuit of a legitimate interest of the owner;
- purposes related to the fulfillment of laws and regulations; Consent Not Required. The legal basis is based on Article 6 par. 1 letter f) of the GDPR 2016/679 or the processing is necessary to fulfill a legal obligation to which the data controller is subject.
3. TYPES OF DATA PROCESSED
Navigation data
The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified interested parties, but by their 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) addresses of the 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 numeric code indicating the status of the response given by the server (success, error, etc.) and other parameters relating to the operating system and the user’s IT environment.
This data is used only to obtain anonymous statistical information on the use of the site and to check its correct functioning and is deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site: except for this eventuality, the data on web contacts do not persist for more than 30 (thirty) days.
Data provided voluntarily by the user
The optional, explicit and voluntary sending of electronic mail to the addresses indicated on this site 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. Specific summary information will be progressively reported or displayed on the site pages set up for particular services on request.
4. METHOD OF TREATMENT
Personal data is processed by automated tools for the time necessary to achieve the purposes for which it was collected. Specific security measures are observed to prevent the loss of data, illicit or incorrect use and unauthorized access.
5. PURPOSE, LEGAL BASIS AND NATURE OF THE PROVISION
All data acquired through our website will be stored for a period of time not exceeding that necessary for the purposes for which they were collected and processed or, in accordance with the provisions of the guarantor for privacy in previous general measures, for a period not exceeding 12 months from the last action / request / activity / visit made. Upon expiration of the aforementioned storage period, the personal data will be automatically deleted, or made permanently and non-reversibly anonymous.
- The Personal Data you provide through the Site will be processed by THE INNOVATION FACTORY S.r.l. for the following purposes:
Respond to specific request of the person concerned through the “Contacts” section. Consent Not required. The legal basis is based on Article 6 par. 1 letter b) or the processing is necessary for the execution of a contract of which the interested party is a party or the execution of pre-contractual measures adopted at the request of the same; - Register voluntarily to the company’s newsletter. Required Consent. The legal basis is based on Article 6 par. 1 letter a) or processing is possible with the explicit consent of the interested party;
- To evaluate possible job applications by acquiring the curricula in the “Work with Us” section and in the online application form in the “Graduates-Graduates” section. Requires explicit consent. The legal basis is based on Article 111 bis of Legislative Decree 196/2003;
- To manage requests for technical assistance through the online chat service by selecting the “Send Message” button. Consent Not required. The legal basis is based on Article 6 par. 1 letter b) or the processing is necessary for the execution of a contract of which the interested party is a party or the execution of pre-contractual measures adopted at the request of the same;
- profiling purposes through third-party cookies; Necessary consent as per Cookie Policy;
- research and statistical analysis on aggregated anonymous data, aimed at measuring the functioning of the Site, measuring traffic and assessing usability and interest to make it more functional and performing; Consent not necessary as the processing of personal data is not configured;
- purposes related to the fulfillment of laws and regulations; Consent Not Required The legal basis is based on Article 6 par. 1 letter c) of the GDPR 2016/679;
- purposes necessary to ascertain, exercise or defend a right in a court of law or whenever the judicial authorities exercise their jurisdictional functions. Consent Not Required The legal basis is based on Article 6 par. 1 letter f) of the GDPR 2016/679 or the processing is necessary for the pursuit of a legitimate interest of the owner;
- purposes related to the fulfillment of laws and regulations; Consent Not Required. The legal basis is based on Article 6 par. 1 letter f) of the GDPR 2016/679 or the processing is necessary to fulfill a legal obligation to which the data controller is subject.
6. CURRICULA MANAGEMENT
The company THE INNOVATION FACTORY S.r.l. reserves the right to evaluate the CVs received via the online applications on the website in accordance with this privacy policy.
The storage time of the curricula considered “interesting” is 24 months and the same will be treated in compliance with the security measures of the EU Regulation 2016/679.
At the end of the 24 months the curricula will be destroyed or the person concerned can be contacted to request authorization to receive an updated curriculum.
The curricula will not be communicated to third parties.
However, we kindly invite the candidates to respect the following rules in the transmission of the curricula in electronic format:
by filling in your resume the European format;
- sending the curriculum in pdf format;
- avoiding to insert in your curriculum particular data as per article 9 of EU Regulation 2016/679 (concerning, in particular, the state of health, religious, philosophical or political convictions) not relevant in relation to the job offer;
- providing consent to the processing of particular categories of personal data relevant to the establishment of an employment relationship (for example belonging to protected categories Law 68/99).
The Company will provide appropriate information pursuant to art. 13 of EU Regulation 2016/679, during any interviews with candidates.
The purpose of the processing related to the management of the curricula will involve activities strictly related to the evaluation, recruitment or selection of personnel, with objectives of collaboration, temporary or permanent employment, of internships, or to allow the chosen candidate to prepare his / her own thesis degree at our headquarters.
7. TRANSFERS OF PERSONAL DATA TO THIRD COUNTRIES OR INTERNATIONAL ORGANIZATIONS
Some of the Personal Data of the interested party are transferred to Recipients located outside the European Community. THE INNOVATION FACTORY S.r.l. ensures that the electronic and paper-based processing of your Personal Data by the Recipients takes place in compliance with the Applicable Law which has a legal scope of application outside the EU.
In other cases, the transfers are based alternatively on an adequacy decision or on the Standard Model Clauses approved by the European Commission as well as in compliance with the Privacy Shield principles in case of transfers to the USA.
8. AREAS OF COMMUNICATION OF PERSONAL DATA
The personal data acquired through the website in question may be disclosed to:
- authorized persons for the treatment of the company THE INNOVATION FACTORY S.r.l .;
- to Public Bodies or Offices according to legal and / or contractual obligations;
- third-party companies that host the website;
- the company Zendesk International Ltd with headquarters in 1 Grand Parade Dublin 6 D06 R9X8 Ireland for the management of the online chat platform (privacy policy available at the url: https://www.zendesk.it/company/customers-partners/eu -data-protection/)
At the data controller it is possible to request the updated list of external managers appointed pursuant to art. 28 of the GDPR 2016/679.
9. DATA STORAGE
THE INNOVATION FACTORY S.r.l. will process the Personal Data of the user for the time strictly necessary to achieve the purposes indicated in this statement and up to the time allowed by the Italian law for the protection of its interests (Art. 2947 (1) (3) c.c.).
The user will remain registered in the newsletter of the company until he exercises the right of cancellation exercisable simply with a simple click directly from the received email.
10. AUTOMATED TREATMENTS
THE INNOVATION FACTORY S.r.l. does not send profiled emails but uses profiling cookies. For the details of the profiling cookies used and their interaction with the social tools, consult the Cookie Policy of the site.
11. RIGHTS OF THE INTERESTED PARTIES
The user can freely exercise the rights referred to in articles 15 and subsequent of the GDPR 2016/679 or:
- withdraw consent at any time. The User can revoke the consent to the processing of his Personal Data previously expressed;
- object to the processing of your data. You may object to the processing of your data when it takes place on a legal basis other than consent;
- access your Data. You have the right to obtain information on the Data processed by the Owner, on certain aspects of the processing and to receive a copy of the Data processed;
- verify and ask for rectification. The User can verify the correctness of his / her Data and request its updating or correction;
- get the treatment limitation. When certain conditions are met, the User can request the limitation of the processing of his / her Data. In this case, the Data Controller will not process the Data for any other purpose than their storage;
- obtain the cancellation or removal of your Personal Data. When certain conditions are met, the User can request the deletion of their Data by the Owner;
- receive your data or have it transferred to another owner. The User has the right to receive his / her Data in structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain its transfer without obstacles to another holder. This provision is applicable when the Data is processed by automated tools and the processing is based on the consent of the User, on a contract of which the User is a party or on contractual measures connected to it;
- to make a complaint. The User can make a complaint to the competent personal data protection supervisory authority or act in court.
12. HOW TO EXERCISE OUR RIGHTS
For the exercise of the aforementioned rights, the interested party may contact the data controller by writing to the email address: privacy@theinnovationfactory.it
13. UPDATE AND REVISION
This privacy and cookie policy has been updated on 01-02-2019 to Revision 1 and may be subject to future revisions