Disclosure pursuant to Art. 13 of European Regulation No. 16/679

ACTL and Recruit Srl (hereinafter referred to as the Companies), in their capacity as Co-Processors of personal data, based at Via Duccio Di Boninsegna, 21 Milan, and Via Alvise Cadamosto 7, Milan, through the websites www.actl.it, www.sportellostage.it, www.recru.it and www.jobfarm.it,hanno as their objective is to protect the privacy of their users and are committed to ensuring that the processing of personal data is carried out in accordance with principles of fairness, lawfulness, transparency and in respect of the rights, fundamental freedoms and dignity of individuals, with particular reference to confidentiality and personal identity.

In providing our services, we necessarily come into possession of personal information and data: we intend, therefore, below, to illustrate an appropriate disclosure to individuals acting on behalf of and for suppliers, customers, partners and others involved in contractual or pre-contractual activities of the Companies, pursuant to Article 13 GDPR 679/16 – “European Data Protection Regulation”.

It should be noted from the outset that, at any time, a request may be made to change or delete the data entered by writing to the e-mail info@sportellostage.it and info@recru.it

1. What data we deal with:

The personal data processed are master and contact data, provided or received by the data subject in connection with:

• Enrollment in the job on cloud portal within the above sites;
• Phone or email;
• Direct contacts obtained as a result of attending events, etc;
• Direct contact as a result of sending inquiries via the e-mail address on the websites;
• Business inquiries;
• Requests through the above websites or through the websites of suppliers, customers, partners and others;
• Transmissions and transactions following the order to provide the service or good (supplied/purchased);
• Invitations to events related to business initiatives, fairs, events, etc;
• Acquisition of data from third parties as governed by Article 14 of GDPR 679/16

2. For what purposes:

Personal data of individuals acting on behalf of suppliers, customers, partners and others are processed for:

• To offer the services indicated in the sites and better specified in the contract that is entered into between the parties;
• Connecting internship demand and supply, job demand and supply;
• Delivering training services:
• Forward communications by various means of communication (telephone, text message, email, fax, paper mail, etc.);
• Formulate requests or process requests received;
• Exchanging information aimed at the execution of the contractual relationship, including pre- and post-contractual activities, including servicing;
• Giving execution at Public or Private Bodies to the fulfillments related or instrumental to the service if provided;
• To give effect to obligations laid down in laws, regulations or EU legislation, as well as to comply with measures issued by public authorities empowered to do so or by supervisory and control bodies to which the Companies are subject (e.g., to tax assessments, etc.);
• Use data for ancillary purposes such as “News Alerts” via email or text message;
• To carry out statistics and market researchin order to better understand the needs of users and to be able to optimize the service offered. In this case, the data will be used anonymously.

The data subject may refuse to provide the Companies with his or her personal data. However, the provision of personal data is necessary for the proper and efficient management of the contractual relationship with suppliers, customers, partners and others involved in the activities of the Companies. Therefore, any refusal to provide it may jeopardize all or part of the contractual relationship itself or the pre- and post-contractual activities.

3. Legal basis:

The data will be disclosed to employees/collaborators of the Companies who contact the data subject to enable the execution of the contract or pre-contractual or post-contractual measures taken at the request of the supplier, customer, partner, other parties or the Companies pursuant to Art. 6.1(b) of the GDPR, or to fulfill a legal obligation pursuant to Art. 6.1(c) of the GDPR, as well as to enable all related tax and accounting requirements. The data will also be disclosed to the operators of portals used by the Companies in order to promote research activities.

4. How we treat data:

The data of the interested parties will be processed in accordance with the principles of lawfulness correctness and transparency, using manual or automated tools, including through the inclusion in databases, lists and lists suitable for the storage, management and transmission of data,in the manner and to the extent necessary for the pursuit of the aforementioned purposes.

The Companies have provided adequate security measures in order to protect the data of individualsacting for and on behalf of suppliers, customers, partners and others, such as: firewalls,antivirus,high complexity passwords with periodic change.

The personal data being processed will be kept in such a way as to minimize, through the adoption of appropriate technical and organizational measures, as well as suitable and preventive security measures, the risks of destruction or loss, even accidental, of the data themselves, of unauthorized access or processing that is not permitted or does not conform to the purposes of the collection previously explained.

Data will be processed only by authorized persons within the Companies, in relation to the purpose of processing.

5. Because the nature of providing data is mandatory:

The provision of such data is mandatory in order to take advantage of the services offered by the Companies. In the event that consent to the processing of data is not provided, it will not be possible for the Companies to provide the activation of services.

The provision of the above data is also mandatory in order to receive newsletters (for which specific authorization is required) for updates on any new services (selection, training, guidance) provided by the Companies or for information on events and news regarding our activities: through the ACTL Sportello Stage, Recruit and Job Farmpostnewsletter, informative and/or promotional material may therefore be sent to the interested party, as well as invitations to training and informative events, such as conferences, presentations, refresher courses, seminars etc.

6. What are the categories of subjects To whom the data may be disclosed:

Personal data processed by the Companies, data related to internships or job positions may be disseminated through the Internet ( recruitingonlineportals) in order to promote the search for the required profiles.

They may, then, be communicated to the workers of the Companies and to some external subjects who collaborate with them, always in compliance with the purposes indicated in point 2. In particular, these are employees/collaborators who, on the basis of the roles and work duties performed, have been legitimized to process personal data, trained to do so within the limits of their competencies and in accordance with the instructions given to them by the Data Controller. They may, moreover, be communicated, to the extent strictly necessary, to the subjects who for the purpose of issuing our orders or requests for information and estimates or formulation of offers, our services, must supply/deliver goods and/or perform/receive on our behalf or on behalf of the person concerned performances or services. The data may be accessed (for purposes of assistance on software applications, computer networks and for connectivity) by our appointed technicians or external consultants or appointees of companies that provide such services; subjects who exercise control activities on the work of the Companies (by way of example: Auditors, Supervisory Board, personnel of certification bodies, etc.).

Finally, they may be communicated to the subjects entitled to access them by virtue of provisions of the law, regulations, and EU rules.The updated list of data processors, where required, is available at the offices of the Companies indicated above.

The Companies, through the sites www.actl.it, www.sportellostage.it, www.recru.it and www.jobfarm.it, may disclose to third parties personal data collected only for purposes strictly related to the services provided.

The data provided may therefore be disclosed to:

• Professionals, companies or professional firms that, on behalf of the Companies, perform consulting, assistance, accounting and tax management activities
• Third-party companies to fulfill contractual obligations
• Banking institutions for handling payments arising from the execution of the contract
• Other online recruiting portals with which the Companies have active partnerships in order to promote the search for required positions
• Companies engaged in transmission, enveloping, transportation, sorting and delivery of communications and correspondence for third parties.

7. Transfer of data abroad:

Although at the moment all entities that process data on behalf of the Companies as external data controllers are established within the European Union, in the future it may also be necessary to give such data to entities that may be established outside the European Union, in countries that do not guarantee personal data an adequate level of protection under the European Data Protection Regulation RE. EU 679/2016. The Companies will transfer, if any, the data outside the European Union only after taking the precautions established by the European Regulation and after obtaining from the indicated subjects the necessary guarantees and with the consent of the data subjects.

8. How long we keep data:

The Companies will retain and process personal data for as long as necessary to fulfill the stated purposes. Thereafter, personal data will be retained, and not further processed, as documented in the Processing Log. The retention period may vary significantly depending on: the purposes, the type of data processed, and legal obligations.
In the event that the data is processed as part of an institutionally funded project, the retention period may be subject to the requirements of the institution’s notice.
When it is no longer necessary to retain personal data it will be deleted or de-indexed or securely destroyed in accordance with our privacy policy.

9. What rights can be exercised:

Pursuant to Articles, 15 to 22, of the European Data Protection Regulation RE. EU 679/2016, the Data Subject is entitled to and may exercise the following rights:

RIGHTS

(a) To request confirmation of the existence or otherwise of his or her personal data concerning him or her, even if not yet recorded, and its communication in intelligible form
(b) Obtain information about the purposes of the processing, the categories of personal data, the recipients or categories of recipients to whom the personal data have been or will be disclosed, and, when possible, the retention period;
(c) Obtain rectification and erasure of data;
(d) Obtain restriction of processing;
(e) Obtain portability of data, i.e., receive them from a data controller in a structured, commonly used, machine-readable format and transmit them to another data controller without hindrance;
(f) Object to processing at any time and also in the case of processing for direct marketing purposes;
(g) Object to automated decision-making relating to fixed individuals, including profiling.
h) To request from the data controller access to and rectification or erasure of personal data or restriction of processing concerning him or her or to object to its processing, as well as the right to data portability;
i) To withdraw consent at any time without affecting the lawfulness of the processing based on the consent given prior to withdrawal.

The same, where exercisable by you may be enforced by writing to: info@sportellostage.it/ info@recru.it specifying the subject of the request, the right that the interested party intends to exercise and attaching a photocopy of an identity document attesting to the legitimacy of the request.

10. Proposition of complaint:

The data subject has the right to lodge a complaint with the supervisory authority of the state of residence. More information on the right to lodge a complaint can be found on the following webpage: www.garanteprivacy.it

11. Data Protection Officer:

Believing that the protection of personal data of data subjects is of paramount importance, the companies have appointed a data protection officer (DPO) who can be contacted by writing to the email address dpo@actl.it/ dpo@recru.it for any issues concerning the protection of personal data.

Disclosure pursuant to Art. 13 of European Regulation No. 16/679

The Companies ACTL and Recruit Srl (hereinafter the Companies), as the Co-Processors of the processing of personal data, based at Via Duccio Di Boninsegna, 21 Milan, and Via Alvise Cadamosto 7, Milan, through the websites www.actl.it, www.sportellostage.it, www.recru.ite www.jobfarm.it,hanno as the objective of protecting the privacy of their users and are committed to ensuring that the processing of personal data is carried out in accordance with principles of correctness, lawfulness, transparency and in respect of the rights, fundamental freedoms and dignity of individuals, with particular reference to confidentiality and personal identity.

In providing our services, we necessarily come into possession of personal information and data: therefore, we intend, below, to illustrate an appropriate information in accordance with Article 13 GDPR 679/16 – “European Data Protection Regulation”.

It should be noted, as of now, that, at any time, it may be requested to change or delete the data entered by writing to the e-mail info@sportellostage.iteinfo@recru.it

1. What data we deal with:

The personal data processed are master and contact data fornitio received by the data subject on the occasion of:

• Enrollment in the job on cloud portal within the above sites;
• Phone or email;
• Direct contacts obtained as a result of attending events, etc;
• Direct contact as a result of sending inquiries via the e-mail address on the websites;
• Business inquiries;
• Requests through the above websites or through the website of suppliers, customers, partners, other parties;
• Transmissions and transactions following the order to provide the service or good (supplied/purchased);
• Invitations to events related to business initiatives, fairs, events, etc.

2. For what purposes:

The Companies, through the sites www.actl.it, www.sportellostage.it, www.recru.ite www.jobfarm.itraccolgonoinformation and personal data when registering for the sites and when subsequently changing them (such as first name, last name, e-mail address, telephone number, residence/domicile address, Tax Code and professional qualification), for the following purposes:

• Collection and dissemination of resumes for matching supply and demand for internships/jobs;
• Information and registration for training courses;
• Sending information materials and about the services provided by ACTL and Recruit;
• Subscription to specific services (including but not limited to newsletters).

The provision of personal data is necessary in order to take advantage of the services provided by the Companies (collection and dissemination of resumes to match supply and demand for internships and jobs, training, sending newsletters and information material). Registration for services presupposes in any case the acknowledgement and acceptance of the terms of use and privacy policy of the Companies.

The interested party may refuse to provide the Companies with his/her personal data. Any refusal to confer, and consequently failure to register, will result in the inability to provide services.

3. Legal basis:

The data will be disclosed to the employees/collaborators of the Companies, the supplier, the client, the partner, other parties who will have to contact the data subjects in order to allow, in accordance with Art. 6.1(b), (c) of the GDPR:

– Service delivery;

• The execution of the contract to which each party is a party;
• The execution of pre-contractual or post-contractual measures taken at the request of the supplier, customer, partner, other parties or Companies pursuant to Art. 6.1(b) of the GDPR;
• The fulfillment of a legal obligation under Article 6.1(c) of the GDPR)

– All related tax and accounting requirements, as well as managing portals in order to promote research activities.

4. How we treat data:

The data of the interested parties will be processed in accordance with the principles of lawfulness correctness and transparency, using manual or automated tools, including through the inclusion in databases, lists and lists suitable for the storage, management and transmission of data,in the manner and to the extent necessary for the pursuit of the aforementioned purposes.

Processing will be carried out in the following ways:

• Operations of recording, organization, storage, processing, modification, use, dissemination and deletion of data;
• Communications and data releases.

The Companies have provided adequate security measures in order to protect the data of individualsacting for and on behalf of suppliers, customers, partners and others, such as: firewalls,antivirus,high complexity passwords with periodic change.

The personal data being processed will be kept in such a way as to minimize, through the adoption of appropriate technical and organizational measures, as well as suitable and preventive security measures, the risks of destruction or loss, even accidental, of the data themselves, of unauthorized access or processing that is not permitted or does not conform to the purposes of the collection previously explained.

Data will be processed only by authorized persons within the Companies, in relation to the purpose of processing.

5. Because the nature of providing data is mandatory:

The provision of such data is mandatory in order to take advantage of the services offered by the Companies provided in point 2.

Finally, the Companies may use the personal data collected (subject to specific authorization) for statistical purposes or to conduct market research in order to better understand the needs of users and to be able to optimize the service offered. It should be noted that said market research and studies will be carried out using anonymous data.

6. What are the categories of subjects To whom the data may be disclosed:

The data may be disclosed to companies, institutions, institutes and organizations that use the services offered by the Companies both in Italy and abroad for the purpose of selection and promotion of internships and jobs.

They may, then, be communicated to the workers of the Companies and to some external subjects who collaborate with them, always in compliance with the purposes indicated in point 2. In particular, these are employees/collaborators who, on the basis of the roles and work duties performed, have been legitimized to process personal data, trained to do so within the limits of their competencies and in accordance with the instructions given to them by the Data Controller.

The data may be accessed (for purposes of assistance on software applications, computer network and connectivity) by technicians, external consultants or appointees of external companies that provide such services; subjects who perform control activities on the work of the Companies (by way of example: Auditors, Supervisory Board, staff of certifying bodies, etc. ).Finally, data may be communicated to the subjects entitled to access them by virtue of provisions of the law, regulations, EU regulations.The updated list of data processors, where required, is available at the offices of the Companies indicated above.

The Companies, through the sites www.sportellostage.it and www.recru.it, may disclose personal data collected to third parties only for purposes strictly related to the services provided.

The data provided may therefore be disclosed to:

• Professionals, companies or professional firms that, on behalf of the Companies, perform consulting, assistance, accounting and tax management activities
• Third-party companies to fulfill contractual obligations
• Banking institutions for handling payments arising from the execution of the contract.
• Other online recruiting portals with which the Companies have active partnerships in order to promote the search for required positions
• Companies engaged in transmission, enveloping, transportation, sorting and delivery of communications and correspondence for third parties

7. Transfer of data abroad:

Although at present all entities that process data on behalf of the Companies as external data controllers are established within the European Union, in the future it may also be necessary to give such data to entities that may be established outside the European Union, in countries that do not guarantee personal data an adequate level of protection under the European Data Protection Regulation RE. EU 679/2016. The Companies will, if necessary, transfer data outside the European Union only after taking the precautions established by the European Regulation and after obtaining the necessary guarantees from the indicated parties and with the consent of the data subjects.

8. How long we keep data:

The Companies retain and process personal data for as long as necessary to fulfill the stated purposes. Thereafter, personal data will be stored, and not further processed, as documented in the Processing Record. The retention period can vary significantly depending on: the purposes, the type of data processed, and legal obligations. In the event that the data are processed as part of a funded project, retention times may be subject to the requirements of the funding body’s announcement.

When it is no longer necessary to retain personal information it will be deleted or de-indexed or securely destroyed in accordance with our privacy policy.

9. What rights can be exercised:

Pursuant to Articles 15 to 22 of the Regulations, the Data Subject is entitled to and may exercise the following rights:

RIGHTS

(a) To request confirmation of the existence or otherwise of his or her personal data concerning him or her, even if not yet recorded, and its communication in intelligible form
(b) Obtain information about the purposes of the processing, the categories of personal data, the recipients or categories of recipients to whom the personal data have been or will be disclosed, and, when possible, the retention period;
(c) Obtain rectification and erasure of data;
(d) Obtain restriction of processing;
(e) Obtain portability of data, i.e., receive them from a data controller in a structured, commonly used, machine-readable format and transmit them to another data controller without hindrance;
(f) Object to processing at any time and also in the case of processing for direct marketing purposes;
(g) Object to automated decision-making relating to fixed individuals, including profiling.
h) To request from the data controller access to and rectification or erasure of personal data or restriction of processing concerning him or her or to object to its processing, as well as the right to data portability;
i) To withdraw consent at any time without affecting the lawfulness of the processing based on the consent given prior to withdrawal.

The same, where exercisable by you may be enforced by writing to: info@sportellostage.it/ info@recru.it specifying the subject of the request, the right that the interested party intends to exercise and attaching a photocopy of an identity document attesting to the legitimacy of the request.

10. Proposition of complaint:

The data subject has the right to lodge a complaint with the supervisory authority of the state of residence. More information on the right to file a complaint can be found at the following webpage: www.garanteprivacy.it

11. Data Protection Officer:

Believing that the protection of personal data of data subjects is of paramount importance, the Companies have appointed a data protection officer (DPO) who can be contacted by writing to the email address dpo@actl.ite dpo@recru.itperany issues concerning the protection of personal data.