Michele Collini (hereinafter the ” Owner”) provides below the information regarding the processing of personal data it collects from the online platform named “Michele Collini” (website michelecollini.com, hereinafter the “Platform”). This notice refers to the fundamental principles of the current legislation on privacy/personal data protection, in particular with reference to the EU Regulation 2016/679 (General Data Protection Regulation, hereinafter “GDPR”), Art. 13 of Legislative Decree 30 June 2003 n. 196 “Code on the Protection of Personal Data” and Legislative Decree 10 August 2018, n. 101, issued for the adaptation of national legislation to the provisions of EU Regulation 2016/679. Michele Collini, with registered office in Milan, Via Vitruvio, 3, is the owner and manager of the data collected.
The information and data provided by the user as part of registration with the Platform will be processed in accordance with European and Italian regulations. (The full text of the regulations can be found on the Guarantor’s website at www.garanteprivacy.it). Michele Collini reserves the right to modify the aforementioned policy by publishing the updated version within the Platform. If substantial changes are made to the Owner’s use of the data, the Owner will notify the user by email, push notifications and other alternative or similar means.
For an adequate understanding of this information, it is recalled that as stated by the Guarantor, constitutes “personal data” that information that identifies or makes identifiable, directly or indirectly, a natural person and that can provide information about his characteristics, habits, lifestyle, personal relationships, health status, economic situation, etc. In the context of this document, “sensitive data” are defined as those personal data belonging to special categories as indicated in Article 9 of the GDPR. In particular, they include: personal data capable of revealing racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership in parties, trade unions, associations or organizations of a religious, philosophical, political or trade union nature, as well as personal data capable of revealing health status and sex life.
1. INFORMATION COLLECTION AND PROCESSING
Michele Collini may collect and store, through the Platform, information about users in connection with their use of the website and mobile app, including information transmitted to the Platform or transmitted to other users through the Platform. This information is used for the purpose of enabling the Data Controller to ensure the proper functioning of the service provided by the Platform such as fulfilling user requests, conducting research and analysis, personalizing the user experience, marketing the service, providing customer support, sending informational and promotional messages to the user, backing up computer systems, preparing a disaster recovery plan, improving the security of the service, and fulfilling legal obligations. All information is transmitted to the server infrastructure used by the Owner to host the Platform software and retained long enough to be processed, even if it is not retained. Personal data collected will never be transferred to third parties.
1.1 Public Content.
Except for some personal information and messages (communications sent via the “Contact Us” form and private chat conversations), all content that the user enters within the Platform is intended for sharing within the Platform and therefore may be viewed by another user the moment the Platform finds a “match” (correspondence between the Candidate’s resume and the job posting). It is therefore emphasized that in the absence of a “match” the Candidate will not have access to the Company’s (or Agency’s) data and vice versa.
1.2 Third Party Data.
Before entering personal data of third parties, such as those of co-workers, family members, or friends, you must be sure that these individuals have been adequately informed and have consented to its processing in the manner described in this document.
1.3 Information Requests.
The optional, explicit and voluntary sending of electronic mail to the addresses indicated on the site and on the app entails the subsequent acquisition of the user’s email address, which is necessary to respond to requests, as well as any other personal data included in the missive.
1.4 User Actions.
The Owner stores information related to the use of the service, such as pages viewed, date and time of visit, and activities followed.
1.5 Technical Data.
Through use of the Platform, the Owner may automatically collect certain technical data (IP address, browser type, information about the device being used, approximate geographic location data) and other data collected using browser cookies or similar technologies.
1.6 Anonymous Data.
The purposes of the processing also concern the collection, storage and processing of data to perform statistical analysis in anonymous and/or aggregate form, without the possibility of identifying the user, aimed at verifying the quality of the services offered.
1.7 Private Chat Messages.
The Owner collects and processes the contents of chat conversations between users during the normal provision of the service. If a message cannot be delivered immediately (for example, if the recipient is not connected to the Internet at that time), the information will be stored for up to 30 days in an attempt to deliver the message. If after 30 days the message has still not been delivered, it will be deleted automatically. Once delivered to the recipient, messages will be deleted from the Platform servers within 30 days.
2. ADDITIONAL PROCESSING PURPOSES
With the expressed, free and optional consent of the user, personal data may also be processed by the Controller for the following purposes:
2.1 send informative and promotional communications referring to the news and offers covered by the service itself. These messages can be delivered through the contacts provided during registration (Email or SMS) and by sending push notifications.
2.2 Offer the user a personalized service and in line with their interests. User profiling is done on the basis of how users use the Platform, the interest shown in the different services promoted, and exposure to advertising communication.
2.3 to send advertising material and commercial communications, i.e. so that the Owner can contact you to propose the purchase of products and/or services offered by third party companies.
Consent to the processing of personal data for these purposes is free and optional, and in case of lack of consent, the possibility to subscribe to the Platform will not be affected in any way. Even in the case of consent, the user may revoke it at any time by making a request to the Data Controller and/or the DPO in the manner indicated in paragraph 6 below. With regard to any promotional emails, the user may easily object to further mailings by clicking on the appropriate link for revocation of consent, which is present in each communication. To limit or disable the receipt of push notifications, the user can use the settings of his/her device or browser. The Owner informs that, following the exercise of the right to object to the sending of promotional communications, it is possible that, for technical and operational reasons (e.g., formation of contact lists already completed shortly before the Owner’s receipt of the request for objection) the user will continue to receive some additional promotional messages. Should the user continue to receive promotional messages after 24 hours have elapsed since the exercise of the right to object, please report the problem to the Controller, using the contacts indicated in paragraph 6 below.
3. METHODS OF PROCESSING
The user’s personal data are processed with automated tools for the time strictly necessary to achieve the purposes for which they were collected, respecting the privacy of users and current regulations. We also remind you that data related to telematic traffic, excluding in any case the contents of communications, will be kept for a period not exceeding 6 years from the date of communication, in accordance with Article 24 of Law No. 167/2017, which transposed EU Directive 2017/541 on anti-terrorism. Deletion of the account by the user removes the association with the system access key and deletes all personal data contained in the profile. Specific security measures are observed to prevent data loss, unlawful or incorrect use, and unauthorized access, in compliance with the security measures set forth in the GDPR (Art. 32).
4. SCOPE OF COMMUNICATION AND DISSEMINATION OF DATA
Employees and/or collaborators of Michele Collini in charge of managing the Platform may become aware of users’ personal data. These individuals, who are formally appointed by Michele Collini as “data processors”, will process the User’s data exclusively for the purposes indicated in this statement and in compliance with the provisions of the Privacy Code. Third parties who may process personal data on behalf of Michele Collini as “external data processors”, such as, by way of example, providers of IT and logistical services functional to the operation of the Platform, outsourcing or cloud computing service providers, professionals, consultants and companies in charge of sending promotional communications, may also become aware of Users’ personal data. Users have the right to obtain a list of any data processors appointed by the Data Controller, by making a request in the manner indicated in paragraph 6 below. Under no circumstances does the Data Controller transfer the personal data collected to third parties.
5. PLACE OF DATA PROCESSING
Processing related to the Platform may take place at the Data Controller’s premises or at the premises of the entities indicated in paragraph 4 above. Personal data collected by the Platform will be processed within the territory of the European Union. Should it become necessary to use non-EU parties for technical and/or operational issues, or should it become necessary to transfer the collected data (in whole or in part) to computer systems and cloud services located outside the European Union, the processing will be regulated in such a way as to ensure the same level of protection as provided by the applicable privacy legislation. Therefore, the Data Controller will proceed with the transfer of data only in the presence of one of the conditions of legitimacy set forth in Chapter V of the GDPR, such as the consent of the data subject, the adoption of Standard Clauses approved by the European Commission, the selection of entities adhering to international programs for the free movement of data, (e.g., EU-USA Privacy Shield) or operating in countries considered safe by the European Commission.
6. RIGHTS OF INTERESTED PARTIES
Users may contact the Data Controller to enforce the rights recognized by the GDPR. In particular, he/she may: (i) obtain confirmation of the existence or otherwise of his personal data and have them communicated in an intelligible form; (ii) obtain a copy of the personal data collected by the Data Controller; (iii) know the origin of the data, the purposes of the processing and its methods, as well as the storage period and the logic applied to the processing carried out by electronic means; (iv) request the updating, rectification or – if he is interested – the integration of the data concerning him; (v) obtain the deletion, transformation into anonymous form or blocking of any data processed in violation of the law, as well as oppose the processing; (vi) oppose or limit any processing aimed at the use of the service, the sending of advertising material, direct sales, the performance of market research, profiling and commercial communication. The user must make the request by sending a registered letter with acknowledgement of receipt to Michele Collini, Via Vitruvio 3 cap 20124 Milano (Mi) or by sending an email to “email@example.com”.
Michele Collini may also use:
- functional cookies that allow the site itself to remember choices made by the user in order to optimize its functionality. For example, functional cookies allow the site to remember a user’s specific settings;
- analytical cookies that allow the site to collect data about a user’s use of the site, including what elements are clicked on while browsing, in order to improve the performance and design of the site. Information from these cookies may be shared with our analytics tool providers. However, they are only used for purposes related to the website.
For profiling activities, personal data collected via cookies are processed for a maximum period of 12 months from the time consent to processing is given. The Owner reminds you that it cannot guarantee the correct functioning of the service and the effectiveness of the indications contained in this policy for browser and/or app versions that are no longer supported. For best results, we recommend downloading the latest version of your browser and/or app.