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Privacy Information Report for selection of the applicants provided by art. 13 of the European Regulation no. 679/2016

The European Regulation 2016/679 of 27 April 2016 “on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC” adopted the “General Data Protection Regulation” (the “GDPR”) which requires, for the protection of data subjects, to provide the information regarding their personal data processing.

According to the EU Regulation 2016/679 dated April 27, 2016 pertaining the “the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC” it has been approved the “General Data Protection Regulation” (here in after also “GDPR”) which imposes, for the protection of such persons, to provide them information on the processing of their personal data.

This law supports the Legislative Decree no. 196/2003 dated June 30, 2003 “Code of protection of personal data” (hereinafter also the “Privacy Code”) aimed at ensuring that the processing of personal data complies the fundamental rights and freedoms, as well as the dignity of the relevant person, with particular reference to privacy, personal identity and the right to protect its personal data, in compliance with the principles of simplification, harmonization and effectiveness.

Therefore, according the law, Studio SabelliPartners provides here below the information related to the processing of your personal data, based on the principles of correctness, lawfulness and proportionality, as well as transparency, clarity, awareness and protection of your privacy and your rights, also pursuant to and for the purposes of art. 5 of the GDPR.

1. Object and source of the processing data

1.1 According to the principles of transparency and protection and any other principle provided by the GDPR, as well as pursuant to art. 7, par. 2, lit. a), Legislative Decree 196/2003, we inform you that your personal data in our possession are solely and exclusively those that you provide by sending your curriculum vitae.

1.2 It may occur that by sending your curriculum vitae or later thereafter Studio SabelliPartners will collect particular personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and genetic data, biometric data aimed to uniquely identify a person, as well as data concerning health or person’s sex life or sexual orientation.

For the processing of those data the law requires the release of a specific consent.

2. Purpose of data processing

According to art. 7, par. 2, lit. b), and art. 13, par. 1, lit. a) of the Legislative Decree 196/2003, and articles 13, par. 1, lit. c) and 15, par. 1, lit. a) of the GDPR, we inform you that your personal data will be processed for the following purposes:

a) evaluation of the consistency of your profile with to the open positions at Studio SabelliPartners and, in general, for the management of selection procedures for consultants and professionals;

b) contact you to the contact details provided in order to schedule interviews that may be deemed necessary.

3. Recipients: subjects to whom data may be disclosed

3.1 According to art. 7, par. 2, lit. e), and art. 13, par. 1, lit. d) of the Legislative Decree 196/2003, and articles 13, par. 1, lit. e) and 15, par. 1, lit. c) of the GDPR, we inform you that your personal data will be available only to subjects who, belonging to the organization of Studio SabelliPartners, may need access to those data for the performance of their tasks or role (employee, consultants). Those subjects, which will be as few as possible, according to principle of data minimization, will be instructed in order to avoid any leakage, destruction, unauthorized access or forbidden processing of the data.

3.2 Your personal data will be also accessible and disclosed, according to the applicable law, to any subject and/or third-party (e.g. professional firms, professionals, consultants, insurance companies for rendering insurance services) which carry out services on behalf of Studio SabelliPartners.

3.3. Your personal data will be also accessible by public authorities, pursuant to any applicable law.

4. Scope of dissemination

According to art. 13, par. 1, lit. a) of the Legislative Decree no. 196/2003 and art. 13, par. 1, lit. f), and 15, par. 1, lit. c) of the GDPR, we inform you that your personal data could be disclosed to the subjects indicate in the previous point 3 within the State or within any State member of the European Union.

5. Period during which the personal data will be stored

According to art. 13, par. 2, lit. a) and art. 15, par. 1, lit. d) of the GDPR, we inform you that the personal data you provide to us will be stored by Studio SabelliPartners for a period of 24 months from the relevant disclosure and they can be used for contacts and future interviews.

6. Rights of the data subject

According to art. 13, par. 1, lit. e) of the Legislative Decree no. 196/2003, and articles 13, par. 2 and 15 of the GDPR, we inform you that is your right to:

a) obtain from Studio SabelliPartners confirmation of the existence or not of your personal data, even if not registered yet, and their duly disclosure;

b) obtain indication of the logic behind a data processing based on electronic means;

c) obtain indication of subjects and categories of subjects to which the personal data may be disclosed or that may became aware of it as designated representative in the State, of representatives or of appointed person;

d) obtain the updating, the rectification, the integration of the personal data or the limitation in data processing by the Studio SabelliPartners;

e) obtain the deletion, the conversion in anonymous form or the block of the data processed in violation of the law, including those for which storage is not required based on the aims for which the data have been collected or subsequently processed and therefore to oppose the data processing carried in violation of the law;

f) obtain the confirmation that the activities described in lit. d) and e), even with reference to the relevant content, have been disclosed to the subject to whom the relevant data had been disclosed or communicated, except for the case in which such confirmation will be not possible or involve a use of means manifestly disproportionate to the protected right

g) oppose, in whole or in part, for rightful reasons, the processing of the personal data disclosed;

h) file a complaint with a supervisory authority, pursuant to article 77 of the GDPR;

i) obtain a copy of the processed personal data, with the warning that for any further copies requested by the data subject, Studio SabelliPartners may charge a reasonable fee based on the administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form

7. Methods of the data processing

According to art. 7, par. 2, lit. b), and art. 13, par. 1, lit. a) of the Legislative Decree no. 196/2003, and articles 13, par. 2, lit. f) and 15, par. 1, lit. h) of the GDPR, we inform you that, relating to the purposes indicated at point 2) above, the personal data processing may be performed by electronic, computerized or telematics or any other automatic means, with logics strictly related to the same purposes, and in any case in compliance with procedures able to guarantee the prudence, security and confidentiality of such data according to the applicable law and, in particular, by online and/or offline communication means, database storage, without prejudice to the personality rights of the data subject.

8. Nature of the data providing

8.1 According to articles 13, par. 1, lit. b) and c) of the Legislative Decree no. 196/2003 we inform you that the collection and processing of the personal data that you provided is absolutely optional, but in case you not provide such data Studio SabelliPartners will not be able to evaluate your profile and, contact you, if any.

8.2 The Privacy Code and the GDPR provide that explicit consent of the data subjects in relation to one or more specific purpose when the data processing may reveal 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 person, data concerning health or data concerning a person’s sex life or sexual orientation shall be prohibited. The processing of any particular categories of data will be carried out in compliance with the provisions set forth by art. 9, par. 2 lit. a) of the GDPR.

8.3 The processing of your data by Studio SabelliPartners is legitimate with the consent to data processing given for the purposes identified by the previous point 2.

9. Controller of the data processing

According to art. 13, par. 1, lit. f) of the Legislative Decree no. 196/2003 and art. 13, par. 1, lit. a), GDPR, we inform you that controller of data processing is Studio SabelliPartners, with registered in Rome – 00185 – office at Via Parigi, 11, VAT number 05059011006.

10. Final clauses

We inform you that at any time you may exercise your rights identified by this information report sending a letter to Studio SabelliPartners at the office placed in Rome (RM), Via Parigi n. 11, by P.E.C. to sabellibenazzo@legalmail.it, or by registered letter or e-mail to roma@sabellipartners.it.