In general, any information and data which you provide to POLOMARCONI.IT over the Website, or which is otherwise gathered via the Website in the context of the use of Polomarconi’s services – e.g., request for information under the section “contact us” of the Website (hereinafter, the „Services“) – will be used by POLOMARCONI.IT in compliance with the Regulation. This means, in particular, that any personal data processing carried out by POLOMARCONI.IT will respect the principles of lawfulness, fairness, transparency, purpose limitation, storage limitation, data minimisation, accuracy, integrity and confidentiality.
As you use the Website, POLOMARCONI.IT will collect and process information regarding you which will identify you in particular, by reference to an identifier such as a name, an identification number, location data, an on-line ID or to one or more factors specific to the physical, physiological, mental, economic, cultural or social, an identified or identifiable natural person (“Personal Data”).
Personal Data that can be processed by POLOMARCONI.IT through the Website are as follow:
a. CV and Special categories of Personal Data
If you will submit your CV spontaneously to the e-mail address email@example.com to apply for a job position at POLOMARCONI.IT you may provide to the Data Controller Personal Data which may also fall under the category of Personal Data referred to in Art. 9 of the Regulation – i.e. “[…] data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation”. POLOMARCONI.IT asks that you do not disclose any such types of Personal Data through your CV or any other means; if you nonetheless choose to do so, please mind that POLOMARCONI.IT, complying with the applicable law, requires your explicit consent to process this special category of Personal Data which can be provided, for example, by including in your CV the following: “I give my consent to POLOMARCONI.IT for the processing of my Personal Data under the special categories referred to in Art. 9 of EU Regulation 2016/679”
When receiving your CV, POLOMARCONI.IT may assess your professional social media accounts (e.g., LinkedIn) or professional websites, which are publicly available, in order to gain insight to your suitability for the position applied for.
b. Data, also of third parties, provided voluntarily by the data subject
When using some of the Website’s Services, for example if you send a specific request to POLOMARCONI.IT, POLOMARCONI.IT will process your Personal Data in order to respond to your request. Such processing is legally based on art. 6(1(b)) of GDPR (“processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”). Also, in some cases you may share Personal Data related to other persons with POLOMARCONI.IT. In those situations, you will be considered as a data controller regarding that Personal Data and must assume all inherent legal obligations and responsibilities. This means, among other things, that you must fully indemnify POLOMARCONI.IT against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, brought by the third parties whose information you provide through the Website.
At any case, when you provide or at any case process third parties’ Personal Data using the Website, you must make sure that you have these third parties’ consent or another appropriate legal basis under art. 6 of the Regulation which may allow for a lawful processing of such information before providing any information regarding them to POLOMARCONI.IT;
Definitions, characteristics, and application of standards
There are various types of cookies, depending on their characteristics and functions, which may be stored on your computer for different periods of time: “session cookies”, which are automatically deleted when you close your browser, and “persistent cookies”, which will remain on your device until their pre-set expiration period passes.
On the other hand, „profiling cookies“ – i.e., cookies used to create profiles on users and used to send advertising messages in line with the preferences revealed by users while browsing websites – require users’ prior consent. The Website does not use this type of cookies.
Types of cookies used by the Website
The Website uses third-party cookies, in particular only anonymised Google Analytics, whereby Google acts as a data processor according to the contractual obligations entered into between Google and POLOMARCONI.IT.
The use of this type of anonymised cookies implies the analysis of aggregated data already collected for statistical purposes. The anonymisation of cookies is performed by masking parts of the IP address and, according to the contractual obligations in force between the parties, by avoiding to combine the information collected through the provision of the service with other data available to Google.
You can block or delete cookies used on the Website via your browser options. Your cookie preferences will be reset if different browsers are used to access the Website. For more information on how to set the preferences for cookies via your browser, please refer to the following instructions:
POLOMARCONI.IT intends to use your Personal Data, collected through the Website, for the following purposes:
a. To complete the provision of the Service you have requested, for example: to respond to support or information requests sent via the section “contacts” of the Website;
b. To analyse CVs submitted and to get in contact with applicants who have submitted their application via the e-mail address firstname.lastname@example.org;
c. For compliance with laws which impose upon POLOMARCONI.IT the collection and/or further processing of certain kinds of Personal Data;
POLOMARCONI.IT legal basis to process your Personal Data, according to the purposes identified in Section 3 (a-b), is found in art. 6(1)(b) of the GDPR because the processing is necessary to provide the Services or to respond to your requests. It is not mandatory for you to give to POLOMARCONI.IT your Personal Data for these purposes; however, if you do not, POLOMARCONI.IT will not be able to provide any Services to you, to respond to your requests or to evaluate your CV. With specific refence to the analysis of your public professional social media accounts identified in the section 2(b), the legal basis to process such Personal Data is art. 6(1)(f) of the GDPR, namely the legitimate interest of POLOMARCONI.IT to scrutinise the suitability of candidates to fit the specific job position they have applied for.
The legal basis for processing your Personal Data identified in the Section 3(c) is necessary for POLOMARCONI.IT to comply with its legal obligations according to art. 6 (1)(c) of the GDPR. When you provide any Personal Data to POLOMARCONI.IT, POLOMARCONI.IT must process it in accordance with the laws applicable to it.
Your Personal Data, according to the purpose identified in section 3 above, may be shared, with:
a. Persons who typically act as data processors on behalf of POLOMARCONI.IT, namely: i) persons, companies or professional firms providing POLOMARCONI.IT with advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services; ii) entities engaged in order to provide the Services (e.g., hosting providers or e-mail platform providers); iii) persons authorised to perform technical maintenance (including maintenance of network equipment and electronic communications networks) (collectively “Recipients”);
b. Public entities, bodies or authorities to whom your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities;
c. Persons authorised by POLOMARCONI.IT to process Personal Data needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of POLOMARCONI.IT)
Some of your Personal Data may be transferred to Recipients located outside the European Economic Area. POLOMARCONI.IT implements appropriate safeguards to ensure the lawfulness and security of these Personal Data transfers, such as by relying on adequacy decisions from the European Commission, standard data protection clauses adopted by the European Commission, or other legal basis. More information on these transfers is available upon written request to POLOMARCONI.IT at the following address: email@example.com
Personal Data processed for the purposes identified in sections 2 (b) will be kept by POLOMARCONI.IT for one month and subsequently, it will be deleted. In any case, as these Personal Data are processed for the provision of the Services, POLOMARCONI.IT may continue to store this Personal Data for the period under which consent is still valid, according to Italian law, in order to guarantee its interest (art. 2946 c.c. e ss). With respect to the CV submitted through the e-mail address firstname.lastname@example.org of the section 2(a), they will be kept by POLOMARCONI.IT for as long as the vacancy for which the CV was submitted is still available or, in case of spontaneous applications, for up to 2 years. POLOMARCONI.IT may contact applicants before the expiration of this period, in order to request an extension of the retention period.
According to the articles 15 to 21 of the GDPR, you have the rights to request from POLOMARCONI.IT, at any time, to access your Personal Data, to correct, rectify and update them, to erase, or to object to the processing of them. Also, you have the right to request the restriction of the processing of your Personal Data in the cases mentioned by art. 18 of the GDPR and to obtain a copy of your Personal Data provided to POLOMARCONI.IT, in a structured, commonly used and machine-readable format in the cases, as well as the transmission of that Personal Data to another Data Controller, as provided by art. 20 of the GDPR.
You can always exercise your rights described above by sending a written request to POLOMARCONI.IT at the following address: email@example.com.
In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data (Personal Data Protection Authority), according to art. 77 of the GDPR, if you believe that the processing of your Personal Data carried out through the Website is unlawful.