Privacy Policy

ESSENTIAL INFORMATION ON PROCESSING OF PERSONAL DATA

Here we set out the main information regarding the processing of your personal data by the company Quadrivio Group Italy S.r.l., the data controller, by means of this website (hereinafter, the “Website”).

The company Quadrivio Group Italy S.r.l. (the “Company”) has its registered office at no. 9 Via Camperio, 20123 Milan (MI), Italy.

For any clarification, questions or needs connected with your privacy and your personal data, you may contact us at any time by writing to [email protected], by telephoning +39 02 89093758 or by sending a fax to +39 02 8900067.

Which data we use and why.

We process the personal data you provide us with when you communicate with us using the contact methods listed on our Website; this data comprises your personal and contact details present on your communication, as well as the information that you include or attach to any communication addressed to us.

Your personal data is processed for the following purposes:

a) to follow up on your specific request for information;

in this case, processing your data is for legitimate reasons since it is necessary to satisfying your specific request;

b) to assess any job application or proposal you have made and to carry out selection in light of a possible work relationship with you;

in this case, processing your data is for legitimate reasons since it is necessary to performing the pre-contractual procedures to meet your request.

c) to provide updates and information through our newsletter available from the Website;

in this case, processing your data is for legitimate reasons since it is necessary to carrying out your specific request for information or updates.

Who we share your data with.

Your data may be disclosed to:

- the Company's partners, shareholders, collaborators and employees specifically authorized to process this data;

- third parties based in Italy and belonging to the following categories: internet and telecommunications operators, technical support centres.

- law enforcement bodies and judiciary authorities, to comply with the law.

Under no circumstance will your data be disclosed to countries outside the European Union, except when specified in the Cookies Policy, which may be consulted on this Website.

How long we store your data.

We store your personal data for a limited period of time, which is established by the purposes it has been collected for; when this period expires, the data is deleted, or in any case irreversibly made anonymous.

More specifically, the data we collect when you send us an information request is deleted 3 months after we have satisfied your request. The data processed in relation to our newsletter is deleted 3 months after your request for cancellation, while the data processed when you send us a job application and/or your CV is deleted 12 months after receipt of your application/CV.

Your rights regarding personal data.

- You may at any time know which elements of your personal data is in our possession and how they are used; you may ask for this data to be updated, supplemented or corrected, and likewise request a copy of it.

- In those cases provided for by the regulations in force, you may ask for your data in our possession to be deleted or may restrict the processing operations involving your data.

- Should you wish to do so, you may ask to receive any of your personal data in our possession in a form legible by an electronic device; and, where technically possible, you may ask us to transfer this data directly to a third party that you specify.

To exercise the above-listed rights, you can contact us via the email address or telephone/fax numbers indicated above. We will then send you an email to confirm we have received your request and we will provide you with an answer as soon as possible.

Should you believe that your personal data has been processed unlawfully, you may lodge a complaint with the competent supervisory authority for enforcing regulations regarding personal data protection. In Italy, this complaint may be sent to the Italian Data Protection Authority (www.garanteprivacy.it).

This Privacy Policy was updated on [] 2021 and may undergo amendment or supplementation as time passes. Therefore, we suggest checking its contents from time to time.

For further information on the collection and processing of your personal data, please read our complete privacy policy, included here below.

For more detailed information on cookies or similar technologies, please consult our Cookies Policy.

FULL POLICY ON PROCESSING OF PERSONAL DATA

pursuant to Article 13 of EU Regulation 2016/679.

1. General information.

Who is the Data Controller?

2. Which personal data do we collect?

3. How do we use the collected personal data?

4. What are the legal grounds to our processing your data?

5. Who is this data disclosed to?

6. How long do we store this data?

7. Your rights and how to exercise them.

8. Security measures.

9. Complaints.

10. Changes to this Privacy Policy.

11. Legal references and useful links.

1. General information.

Who is the Data Controller?

The company Quadrivio Group Italy S.r.l. is the data controller (hereinafter, the “Controller”), this being the subject who decides how and why to process your personal data by means of this website (hereinafter, the “Website”).

This is the information you need in order to know who we are and how to contact us:

Quadrivio Group Italy S.r.l.

Address: no. 9 Via Camperio, 20123 Milan (MI), Italy

Telephone: +39 02 89093758

Email: [email protected]

Fax: +39 02 8900067

2. Which personal data do we collect?

The following are the categories of personal data that we process.

We collect the data you provide us with when you communicate with us using the contact addresses and numbers on our Website.

Besides your personal and contact details present on the communication we receive, we also process any information that you include or attach to a communication addressed to us, such as the data included on a CV.

For information on cookie usage on the Website, please consult the specific Cookies Policy.

3. How do we use the collected personal data?

We use your personal data only to the extent strictly necessary to the following purposes:

a) to follow up on your specific request for information.

We use the data you provide us with when you communicate with us (by letter, email, telephone or fax) through the contact addresses and numbers shown on the Website, in order to follow up on your specific request.

Depending on the type of request, provision of your personal data for this purpose may be a necessary requirement in order to complete any resulting contract with the Controller.

You are free to provide or withhold your personal data; however, should you withhold it, we will be unable to respond to your request, which means we will not be able to supply you with the requested information;

b) to assess any job application or proposal you have made and to carry out selection in light of a possible work relationship with you.

We use the data you provide us with when you, of your own initiative, apply for a position with us (by letter, email, telephone or fax); this is to assess your application and to carry out selection in light of a possible work relationship with you.

Provision of your personal data for this purpose is a necessary requirement for (possible) stipulation of a contract with the Controller.

You are free to provide or withhold your personal data; however, should you withhold it, we will be unable to evaluate your application, which means we will not be able to select you to begin a work relationship with us;

c) to provide updates and information through our newsletter available from the Website.

In this case, processing your data is for legitimate reasons since it is necessary to carrying out your specific request for information or updates.

Lastly, the laws regulating personal data protection oblige us in certain circumstances to use your contact data to provide you with specific information on how your data is processed (for instance, to inform you regarding security violations concerning your data and the measures we have adopted to deal with this).

In relation to all the above-mentioned activities, we will process your personal data primarily using electronic and computing devices; the devices we deploy ensure high standards of security and fully respect the pertinent regulations in force.

4. What are the legal grounds to our processing your data?

We process your personal data only if one of the conditions provided for by law is satisfied, this being:

- the processing is necessary in order to execute a contract that you are party to or to implement pre-contractual measures adopted upon your request.

These legal grounds are legitimate reason for the processing of your personal data in responding to your information request sent to our contact addresses and numbers on the Website. There is also legitimate reason if assessing a job application or proposal you may have made, if carrying out selection in light of a possible future work relationship with you, and in the case of a request to subscribe to our newsletter.

5. Who is this data disclosed to?

Your personal data may be disclosed to:

a) the Company's partners, stakeholders, collaborators and employees specifically authorized to process this data;

b) third parties based in Italy and whose services we use when conducting our business, and which belong to the following categories: internet and telecommunications operators, technical support centres.

Your personal data may also be disclosed, in compliance with the law, to law enforcement bodies, judicial authorities and administrative bodies in order to confirm or investigate possible crimes, to prevent and safeguard from threats to public security, to enable the Controller to confirm, exercise or defend its rights in the course of legal proceedings, as well as for other reasons connected with protecting the rights and freedoms of others.

Under no circumstance will your data be disclosed to countries outside the European Union, except when set out in the Cookies Policy, which may be consulted on this Website.

6. How long do we store your data?

We store your personal data for a limited period of time, which varies according to the type of activity dictating the data processing.

Once this period has expired, your data is permanently deleted or in any case irreversibly made anonymous.

Your personal data is stored respecting the following expiry dates and criteria:

a) the data we collect when you send us an information request is deleted 3 months after we have satisfied your request;

b) the data collected when you send us a job application and/or your CV is deleted 12 months after receipt of your application/CV.

c) the data collected when you subscribe to our newsletter is deleted 3 months after your request for cancellation.

Nonetheless, due to technical reasons, cessation of processing and the subsequent permanent deletion of data or it being irreversibly made anonymous will be completed within 30 days of the above-specified expiry dates.

7. Your rights and how to exercise them.

With regards to our processing your personal data, you may exercise the following rights:

a) Access, modify or supplement your data, and obtain a copy of it or part of it.

You have the right to access your personal data and to obtain specific information on the nature of the processing carried out by us.

You may ask for your personal data to be corrected, modified or supplemented with other information.

We will not accept requests to supplement your personal data with information that we do not require for the purposes of the above-described processing, in compliance with the provisions of the law on personal data protection.

Should you request it, we will provide you with a copy of your data in our possession.

b) Delete your data.

In the cases provided for by current legislation, you may ask for your personal data to be deleted.

Once your request has been received and considered, if it is deemed legitimate, we shall see to promptly ceasing processing of your personal data, with the exception of the data needed to continue processing in order to comply with any pertinent legal obligations.

c) Request temporary restrictions regarding the processing of your data.

You may ask for restrictions on the processing of your data; in this case, we will continue to store your personal data but we will not use it, with the exception of any specific request made by you or requirements to comply with the law.

You may restrict the processing of your data:

- when you dispute the accuracy of your personal data;

- when its processing is wrongful but you object to deletion of your data;

- when we no longer require your data but you need to exercise your rights during legal proceedings.

d) Request transfer of your data to parties other than us (the “right to data portability”).

In certain cases, you may ask to receive, in an electronic format commonly used and read by automated devices, the data we have collected and processed in relation to a contract entered into by you.

Should you wish so and if technically feasible, we will transfer your data directly to a third party specified by you and upon your request.

To exercise the above-listed rights, you can:

- email a request to [email protected];

- contact us by telephone/fax at the numbers specified in Paragraph 1 of this Privacy Policy.

We will then send you an email to confirm we have received your request and we will provide you with an answer as soon as possible, and in any case within 30 days of receiving your request.

To ensure that your personal data is not subject to violation or unlawful use by third parties, before meeting your request to exercise one or more of the above rights, we might need to ask you for further information to confirm your identity.

8. Security measures.

We protect your personal data with security measures of a specific technical and organizational type and that are designed to prevent your data from being used fraudulently or in any case unlawfully.

9. Complaints.

Should you believe that your personal data has been processed unlawfully, you may lodge a complaint with the competent supervisor authority for enforcing regulations regarding personal data protection.

In Italy, this complaint may be lodged with the Italian Data Protection Authority.

Further information on how to make a complaint is available on the website of the Italian Data Protection Authority, at the address www.garanteprivacy.it.

Complaints may also be lodged with other authorities besides the Italian one, if that supervisory authority belongs to the EU country where you normally work or live, or is where the claimed violation has taken place.

10. Changes to this Privacy Policy.

This Privacy Policy was updated on [] 2021.

This Privacy Policy may undergo amendment or supplementation as time passes; these may be necessary as a consequence of changes in the nature of the personal data processing described above, or as a result of new legislation regarding personal data protection. In the case of changes affecting the processing in progress, we undertake to inform all interested parties of these changes before they become applicable.

The updated version of this Privacy Policy will be published on this webpage, stating the date of its latest update. For this reason, we suggest you consult this page when you access the Website.

11. Legal references and useful links.

We process your personal data in full compliance with the relevant regulations set out in EU Regulation 2016/679 (General Data Protection Regulation or "GDPR") of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data, which superseded EC Directive 95/46/EC; we also fully comply with the relative Italian regulations governing the processing of personal data, and with the measures set out by the Italian supervisory body (this being the Italian Data Protection Authority) and by European Data Protection Board (EDPB).

More specifically, this Privacy Policy is formulated in compliance with Article 13 of EU Regulation 2016/679 and respecting the other above-mentioned sources.

Should you wish to consult the text of EU Regulation 2016/679 and the other provisions in force in this field in Italy, and likewise regarding measures by the Italian supervisory authority, please consult the website www.garanteprivacy.it.