1. TYPES OF PROCESSED DATA
1.1 Navigation data
Visiting and consulting the Site does not generally involve collection and processing of user’s Personal Data. The Personal Data processing of users who visit and consult the Site is limited to the so-called navigation data which transmission is necessary for the functioning of computer systems and of programs essentials for the operation of the Site but which, by their very nature and in conjunction with other data, may permit the identification of users. This category includes, for example, the IP addresses (Internet Protocol) or the domain names of the computer used to visit the Site, as well as other parameters concerning the operating system used by the user to connect to the Site. The collection of Navigation data occurs automatically and inevitably and can only be used to obtain statistical information on the use of the Site and to verify its proper functioning. If expressly requested, such data may be used by the Public Authority to ascertain liability in the event of computer offenses committed against the Site and/or third parties, in accordance with the procedures in force at the competent Authorities. Except for this possibility, navigation data described above are only temporarily kept in compliance with the applicable regulations.
1.2 Data voluntarily provided by individual users
In addition, HiDew collects and processes Personal Data voluntarily provided by individual users that consist of those data collected through the sending of e-mail, the interaction with the Site’s features, the request for services offered by the Site, the sending of their own Curriculum Vitae, the compilation of other specific format for access to reserved sections of the Site. Personal Data that HiDew collects and processes include name, gender, place and date of birth, nationality, contact information such as addresses, phone numbers, e-mails and other information contained within the Curriculum.
2. MEANS AND PURPOSES FOR PROCESSING PERSONAL DATA
The Data will be processed both manually and with the help of electronic instruments to respond and manage requests for information and/or materials of the user, questions, communications or feedback from users; to provide services rendered on the Website, including registration and updates through price sensitive press releases, presentation, interim reports, annual reports, and to manage the initiatives organized through the Site; to carry out recruitment and staff selection activities.
In addition to the purposes connected to Site’s operations, HiDew may use the personal data collected for the purposes of, or in connection with the following services:
Newsletter Management and Mailing List;
Customer Support and Product Service;
Interaction with social network and external platforms;
Marketing and commercial purposes;
Legal grounds used for processing personal information
HiDew will process User’s Personal Data only if at least one of the following conditions exist:
In any case, user can always ask HiDew to clarify the legal grounds used for processing its personal information.
Personal Data will be stored for a period of time not exceeding what is necessary to achieve the purposes for which they have been collected and, in any case, not longer than 10 years.
Personal Data stored for recruiting will be stored for a period no longer than 18 months.
At the end of the retention period Personal Data will be deleted. Therefore, at the end of this term the right to access, delete, rectification and the right to data portability can no longer be exercised.
3. NATURE OF PERSONAL DATA GRANTING
The Personal Data granting for the purposes mentioned in point 2 above, is necessary to allow HiDew to respond to requests for information, to provide the services requested through the Site, including registration; in the event of non-submission of Personal Data for the purposes referred to in point 2, HiDew will not be able to answer to requests for information or to provide the services requested through the Site.
4. PERSONAL DATA DISCLOSURE
Personal Data are accessible to the Data Processor indicated below, to the other persons who will act as external Controllers appointed by HiDew and, in their quality as Persons in charge of the Processing, to the staff of HiDew involved in the provision of services and features from time to time offered by HiDew according to criteria of need. Personal data are also accessible, for the purposes listed in point 2 (“Means and Purposes For Processing Personal Data”) to HiDew’s parent company HiRef S.p.a.
Personal Data may be disclosed to agencies, authorities, public institutions and legitimate recipients in compliance with laws and regulations; they may be made accessible to self-employed professionals and collaborators, also organized in associated form, third parties suppliers of professional and technical service for the for processing purposes referred to in paragraph 2 that assist HiDew in legal, tax, social security, accounting and/or organization’s field, who will act as Data Processors or Persons in charge of the Processing, as the case may be, without prejudice to the adoption of Personal Data security and protection measures pursuant to current legislation.
Personal Data may also be disclosed to third parties in the event of extraordinary transactions (e.g. mergers, acquisitions, transfer of business, etc.) by HiDew. Only the information necessary to perform their respective functions will be provided to such those persons. Such third parties will commit to use the information received only for purposes for processing specified above, to keep them confidential and secure and to comply with the protection of Personal Data required by law and any instructions given by HiDew.
Personal Data may also be transferred abroad to persons established in countries that are not members of the European Union (to those companies part of HiDew’s sale and trade network which are based outside the European Union) that could not guarantee an adequate level of protection pursuant to the Privacy Law. In such cases, HiDew transfers Personal Data to such third countries after the adoption of the measures laid down in Art. 44 and subsequent of the GDPR in order to legitimate the transfer and ensure adequate protection to transferred Personal Data.
Personal Data will not be subject to dissemination.
5. AUTOMATIC DATA COLLECTION MECHANISMS - COOKIES
6. USER’S RIGHT
User may exercise at any time the rights to which he/she is entitled to pursuant to Articles 15 – 22 of the GDPR including, for example, the right to obtain confirmation of the existence or not of Personal Data relating to him/her, verifying its content, source and accuracy, requesting its integration, updating, rectification, deletion, transformation into an anonymous form, portability. The user may object in whole or in part, or ask for the restriction of the processing of data for legitimate reasons.
For any question or request about the processing of Personal Data and for exercise the rights granted by the GDPR, the user may contact Hidew at the following address: firstname.lastname@example.org.
8. DATA CONTROLLER AND DATA PROCESSOR
The Data Controller is Hidew, based in Via dell'Artigianato, 5 – 35026 Conselve (PD).
The Data Processor is Mr. Davide Grinzato, based at the headquarters of the Controller and available at the following e-mail address (email@example.com) and phone number (+39 049.950 2511).