Telema S.r.l., Registered Office Via Gaetano Strigelli 15 20135, Milan, Italy, in the person of its legal representative Mr. Zuffo Riccardo Giorgio, as Data Controller protects your personal data, provided by you while browsing and using this website, ensuring their confidentiality and guaranteeing compliance with the regulations in force as well as the necessary level of protection, from any event that may put them at risk of being violated.
As required by art. 13 of the General Data Protection Regulation of the European Union (GDPR), Telema S.r.l. informs you that your personal data, collected through this website, are subject to processing by means of computer and/or telematic tools, for the purposes indicated below in this statement.
1.OBJECT OF PROCESSING
With regard to the data processed by Telema S.r.l.’s business activity.
The Data Controller processes:
- personal, identifying data (e.g. name, surname, company name, address, telephone number, e-mail, bank and payment references) hereinafter, “personal data”.
- the “particular data” communicated by you on the occasion of the conclusion of contracts for the Controller’s services and in your capacity as recipient of such data with reference to all communications made and received in dealings with the entities and subjects involved in the Controller’s and Processor’s own professional activity.
With regard to the data processed by the Telema S.r.l. website:
The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. Consequently, the following personal data, by way of example, may be processed:
- browsing data: this category of data includes IP addresses or domain names of the computers and terminals used by users, URI/URL (Uniform Resource Identifier/Locator) notation addresses, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and IT environment. These data, necessary for the use of web services, are also processed in order to obtain statistical information on the use of the services (most visited pages, number of visitors per time slot or per day, geographical areas of origin, etc.).
- checking the proper functioning of the services offered.
- data communicated by the user: such as, for example, personal data provided by you through the “contact us” form or data provided in the “create an account” section. The optional sending of such requests through the completion and submission of forms on this site involves the acquisition of your personal data.
Information that our servers automatically collect when you access the Site, such as your IP address, browser type, operating system, access times and pages viewed directly before and after accessing the Site.
Data from social networks
User information may be collected from social networking sites, such as Linkedin, including name, social networking user name, location, gender, date of birth, email address, profile photo and public contact information, if the user links their account to such social networks.
Mobile device data
Device information, such as mobile device ID, model and manufacturer, and device location information, may be collected if you access the Site from a mobile device.
2. PROCESSING PURPOSES
2.1 With regard to the processing purposes of Telema S.r.l.’s commercial activity
Your personal data are processed:
pursuant to Art 6 EU Regulation No.679/2016 (and subsequent legislative adaptation provisions
Legislative Decree 101/2018) (GDPR). lett. b), e) GDPR), for the following Service Purposes:
A) to conclude contracts for the Controller’s services:
- for the activity of personnel search and selection carried out exclusively on assignment conferred by the employer, consisting of searching, selecting and evaluating candidates on the basis of the professional profile and in the manner agreed with the principals, approaching the means and supports necessary and suitable for the purpose;
- for the performance, pursuant to Legislative Decree No. 469 of 23/12/1997 and subsequent supplements and amendments, of all complementary, connected and instrumental activities, with the exclusion of those not permitted by law
- for management and organisation consultancy activities,
- for business consulting activities,
- for training activities,
- for corporate training activities,
- for carrying out salary surveys,
- for the management of databases of potential candidates and any other related activity,
- for the performance of commercial, industrial, financial, movable and real estate transactions deemed necessary by the administrative body,
- for the direct or indirect acquisition of shareholdings in companies with a purpose similar or related to its own, which shall not be exercised vis-à-vis the public or natural persons concerned,
- for the entry of data in computer databases;
- for the issuance of transport documents, invoices and credit notes;
- for issuing quotations and offers to active and/or potential customers;
- for issuing requests for offers to active and/or potential suppliers;
- for ordinary and simplified bookkeeping and VAT;
- for administrative data management;
- for the management of collections and payments;
B) to fulfil the obligations provided for by law, regulation, Community legislation or an order of the Authority;
C) to exercise the Controller’s rights, such as the right of defence in court
D) Subject to your consent, to carry out information and commercial promotion of Telema S.r.l.’s services; the legal basis of the processing is consent
E) subject to your specific, written, unequivocal and unconditional consent, to carry out a form of automated processing of personal data consisting of the use of such data for the performance of studies, analysis, and processing of the same for the sole purpose of searching for, selecting and evaluating candidates on the basis of their professional profile and in the manner agreed upon with the clients themselves; the legal basis of the processing is consent;
2.2 With regard to the processing purposes of the TelemaS.r.l. website
Pursuant to Article 6 EU Regulation No.679/2016 (and subsequent legislative adaptation provisions Legislative Decree 101/2018) (GDPR). lett. b), e) GDPR), for the following Service Purposes:
Your personal data will be processed for the following purposes:
a) to enable the enjoyment and use of this website, as well as to perform the maintenance and technical assistance necessary for its proper functioning;
b) to allow the Data Controller to respond to requests made by you through this website.
The legal basis underlying the processing referred to in (a) of this point is:
– Art. 6 par.1 lett. f) GDPR: “processing is necessary for the pursuit of the legitimate interest of the data controller or a third party”.
3. METHODS OF PROCESSING
The processing of your personal data is carried out by means of the following operations: collection, recording, organisation, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data.
The processing will be carried out using manual and/or computerised and telematic tools with organisational and processing logics strictly related to the purposes themselves and in any case in such a way as to guarantee the security, integrity and confidentiality of the data themselves in compliance with the organisational, physical and logical measures provided for by Articles 24, 25 and 32 of the GDPR. The processing of personal data carried out for the sole purpose referred to in point E paragraph 2 (purpose of processing) of this information notice will be carried out in automated form and also on an online platform and consists of the use of such personal data to assess certain personal aspects relating to your person for the carrying out of studies, analysis, and processing of the same for the sole purpose of seeking, selecting and assessing candidates on the basis of their professional profile and in the manner agreed upon with the principals themselves; the legal basis of the processing is consent;
The personal data subject to processing are collected directly by the Data Controller or by third parties expressly authorised by the latter, or communicated by the Data Controller to such third parties for the pursuit of the purposes referred to in point 2.
Personal data shall be processed mainly with the aid of IT tools by persons inside and outside the Data Controller’s organisation who are duly authorised and instructed for this purpose in accordance with the methods and with the means suitable to guarantee the security and confidentiality of such data, in compliance with the provisions of the GDPR.
The Data Controller periodically carries out checks to ensure that no personal data are processed, collected, filed or stored that are not necessary in relation to the processing operations and related purposes as indicated in point no. 2 of this information notice.
4. NATURE OF THE PROVISION OF DATA AND CONSEQUENCES OF REFUSAL TO ANSWER
We inform you that, taking into account the purposes of the processing referred to in points A), B) AND C) as illustrated in point 2.1 above, the provision of the data necessary for the purposes is free, but failure to provide the data, or the provision of partial or incorrect data, may make it impossible to carry out the activity and pre-contractual and contractual fulfilments as provided for in the contract of sale and/or supply of products. Where the person providing the data is under 13 years of age, such processing is lawful only if, and to the extent that, such consent is given or authorised by the holder of parental responsibility for whom the identification data and copies of identification documents are acquired.
5. ACCESS TO DATA BY DATA PROCESSORS
Your data may be made accessible for the exclusive purposes set out in art. 2.A) and 2.B) of this information notice
- to employees and collaborators of the Data Controller, its auxiliaries and third party employees companies and companies in outsourcing relationship with the Data Controller in their capacity as persons authorised to process and/or internal data processors and/or system administrators;
- to third-party companies or other entities (by way of example, credit institutions, consultants, insurance companies for the provision of insurance services, etc.) that perform outsourcing activities on behalf of the Controller, in their capacity as external data processors.
6. COMMUNICATION OF DATA
Without the need for your express consent (pursuant to Article 24 letters a), b) and d) of the Privacy Code and Article 6 letters b) and c) of EU Regulation No. 679/2016 (and subsequent provisions of Legislative Decree 101/2018) (GDPR), the Data Controller may disclose your data for the purposes set out in Article 2.
In particular, the recipients of the data may be
- information and computer support companies
- companies or professional firms offering professional and/or consultancy services in relation to accounting, legal, tax, administrative, financial and credit recovery matters
- providers of IT infrastructure and solutions
- web service providers;
- banks and payment service providers, acting as Processors, to whom your personal data may be disclosed for the purpose of processing your payments consultants, to the extent necessary for the performance of their professional duties.
The communication concerns the categories of personal data whose transmission to the above-mentioned third parties is necessary for the performance of the activities and for the purposes referred to in this policy.
The updated list of Data Processors and persons authorised to process data is kept at the Data Controller’s head office and is available upon request by e-mail to firstname.lastname@example.org.
Some of these subjects may process the data in their capacity as autonomous data controllers.
Your data will not be disclosed.
The communication of data may also relate to:
law or exercise of rights
If we believe the release of user information is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, or safety of others, we may share information as permitted or required by any applicable law, rule, or regulation. This includes sharing information with other entities for fraud protection and credit risk reduction.
Third party service providers
We may share information with third parties who perform services for us or on our behalf, including payment processing, data analysis, emailing, hosting services, customer service and marketing support.
Please note that the third parties involved are those related to the “Google Font”, “Adobe font”, “Font Awsome” and the “Job on Air” platform plug-ins for whose data protection policies please refer to the following links respectively:
Only with your explicit and unambiguous consent, and an opportunity to withdraw consent, may we share information with third parties for marketing purposes, as permitted by law.
Third Party Advertisers
We may use third-party advertising companies to serve ads when you visit the Site. These companies may use information about your visits to the Site and other websites that is contained in web cookies in order to provide advertisements about goods and services of interest to you.
Social media contacts
If you connect to the Site through a social network, contacts on the social network will see your name, profile photo and business description, On the Telama S.r.l. Site there is a linkedin link.
7. DATA STORAGE AND TRANSFER
Personal data are stored on servers located in Milan, within the European Union and in full compliance with the provisions and requirements necessary for the security and proper location of data storage units (Data centres). It should be noted that data storage is carried out through the “Invoices in the Cloud” software service.
The aforementioned location and storage methods of the data centres may only be disclosed to the data subject whose data is being processed and to the supervisory authorities for reasons of national security, public safety, defence in court, for the prevention, detection and prosecution of crimes, for the protection of the interests and freedoms of others, for the execution of civil actions and for relevant objectives of public and economic interest. It is considered that the Data Controller shall process personal data for the time necessary to fulfil the above-mentioned purposes and in any case for no longer than 5 years from the termination of the relationship for the Purposes of the Billing Service and Corporate Accounting and no longer than 10 years for the Purposes relating to the exercise of rights;
8. EXTRA EU/SEAS TRANSFER
The Data Controller does not carry out any transfer of your personal data abroad (all countries not belonging to the European Economic Area being intended as foreign countries).
9. RIGHTS OF THE DATA SUBJECT
In your capacity as user, you are entitled to the following rights:
- You have the right to access your data, to obtain confirmation as to whether or not personal data concerning you exists, even if not yet recorded, and communication of such data in intelligible form; -You have the right to be informed (a) the origin of the personal data; (b) the purposes and methods of the processing; (c) the logic applied in the event of processing carried out with the aid of electronic instruments; (d) the identification details of the Data Controller, the data processors and the representative of the Data Controller and the persons authorised to process the data; and (e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of it in their capacity as designated representative in the territory of the State, data processors or authorised persons for the processing; (Art. 15 GDPR).
- Right to update, rectification or, when interested, integration of data; (art. 16 GDPR).
- Right to erasure, anonymisation or blocking of data processed in breach of the law, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed; (art. 17 GDPR).
- Right to request the restriction of the use of data solely for reasons of public interest and for the establishment or defence of a right, in cases where the data subject contests the accuracy of the data and the processing, in the case of exercising the right to object to the processing referred to in Art. 21 GDPR and in the other cases provided for in Art.18 GDPR ; (Art.18 GDPR).
- Right to receive the personal data provided to the Data Controller in a structural format or on a commonly used, intelligible and accessible computer support for any operating system (USB or duly encrypted ZIP file), and to move, without constraints, the information and data concerning you from this controller to another controller chosen by you in accordance with your purposes and in full compliance with the principles of transparency, lawfulness and proportionality of the processing.
This right to data portability is without prejudice to other rights; (Art. 20 GDPR).
Right to object, in whole or in part:
(a) on legitimate grounds, to the processing of personal data concerning you, even if relevant to the purpose of collection; (b) to the processing of personal data concerning you for any other purpose not relevant to the processing; (Art. 21 GDPR).
Right to withdraw consent, where applicable and at any time. Withdrawal of consent does not affect the lawfulness of the processing based on the consent given before the withdrawal;
Right to lodge a complaint with the supervisory authority.
Further rights of the data subject:
- Right to object to and restrict processing carried out by means of profiling for the exclusive purposes referred to in point E), paragraph 2 of this notice pursuant to Article 22 GDPR.
It is mentioned that you, in your capacity as a data subject, have the right not to be subjected to a decision based solely on profiling (purposes referred to in point E), paragraph 2 of this information notice), which significantly affects your person unless such processing is based on your explicit, unequivocal and unconditional consent, exercised in writing and separate from other specific requests for consent.
Furthermore, in the event of the provision of explicit, unambiguous and unconditional consent, exercised in writing to the aforementioned profiling processing (purposes referred to in point E), paragraph 2 of this policy), the data controller shall implement appropriate measures to protect the rights, freedoms and legitimate interests of the data subject, at least the right to obtain human intervention by the data controller, to express your opinion and to contest the decision, including in the event that the data controller should eventually become aware of data referred to in Article 9 GDPR (special data)
- Limitations to the obligations of data controllers and data processors under Art. 23 GDPR
The obligations of the Data Controller and the Data Processor to make this disclosure pursuant to Art. 12 GDPR, not to submit to an automated procedure pursuant to Art. 22 GDPR, and to make the disclosures pursuant to Art. 34 GDPR may be waived only upon your consent or for the need to disclose to the Supervisory Authorities for reasons of national security, public safety, defence in court, for the prevention, detection and prosecution of criminal offences, for the protection of the interests and freedoms of others, for the independence of the judiciary, for the execution of civil actions and for relevant objectives of public and economic interest.
- Right to withdraw consent: consent to data processing may be withdrawn at any time by the person concerned.
10. HOW TO EXERCISE YOUR RIGHTS
You may exercise your rights at any time by sending a request by email to email@example.com. You may also exercise your rights by contacting the Garante della Privacy, with offices in Piazza Venezia n. 11 – 00187 Rome, Telephone: (+39) 06.696771,Fax: (+39) 06.69677.3785. For general information, please send an e-mail to: firstname.lastname@example.org, email@example.com.
11. AMENDMENTS TO THIS INFORMATION NOTICE
ACCEPTABLE USE POLICY FOR WEBSITE USERS AND WEBSITE ACCOUNT HOLDERS OWNED BY:
Telema s.r.l. – Sole Shareholder – Via Oltrocchi 11 20137 Milan – Telephone +39 02599212.1 – Fax +39 0259902329, Registered Office: Via Strigelli 15 20135 Milan – Tax Code and VAT No. 08590700152.
Please read this acceptable use policy (“policy”, “AUP”) carefully before using the [website] website (“website”, “service”) operated by [name] (“we”, “us”, “our” www.telemainternational.com”).
The services provided by us may only be used for lawful purposes. You agree to comply with all applicable laws, rules and regulations in connection with your use of the services. Any material or conduct that, in our opinion, violates this policy in any way may result in suspension or termination of the services or removal of your account with or without notice.
You may not use the Services to post content or engage in activities that are illegal under applicable law, harmful to others, or that could expose us to liability, including but not limited to the following activities, each of which is prohibited by this AUP:
- Phishing or identity theft
- Distribution of computer viruses, worms, Trojan horses (TROJAN) or other malicious code (MALWARE, RANSOMWARE, etc).
- Distributing pornography or adult content or offering escort services.
- Promoting or facilitating violence or terrorist activities
- Infringement of intellectual property or other property rights of others.
Your services may be suspended or terminated with or without notice if you violate this policy. Any violation may result in immediate suspension or termination of your account.
To report a violation of this policy, please contact us.
We reserve the right to change this policy at any time, and you will be promptly updated of this. To ensure that you are up to date with the latest changes, we recommend that you visit this page often.