Cleafy Privacy Policy
PRIVACY NOTICE TO THE APPLICANTS
_pursuant to Art. 13 of EU Regulation no. 679/2016 and Legislative Decree no. 196/2003 _
Pursuant to art. 13 of EU Regulation no. 679/2016 (“Regulation”) and Legislative Decree no. 196/2003 (“Privacy Code”), Cleafy S.p.A., with registered office in (20158) Milan (MI), Via Simone Schiaffino 11/19, Tax Code and VAT 02340370226, tel. +39 0249517001, pec address cleafy@legalmail.it, e-mail address privacy@cleafy.com, DPO dpo@cleafy.com (“Data Controller” or “Company”), informs you that the personal data you provide in connection with your application or otherwise collected during the interview with our Company may be processed as follows.
1. Purposes and legal basis of the processing
The Company processes your personal data for:
i. the handling and the evaluation of your application.
The legal basis of the processing is the evaluation of your application for the purposes of selection and possible establishment of an employment / professional relationship between you and the Company;
ii. purposes connected with the fulfilment of legal obligations, national and European regulations as well as of the provisions issued by authorities entitled by law.
The legal basis of the processing is the fulfilment of obligations provided by law and the applicable regulations.
Regarding the above purposes, the Data Controller will process your “personal” data (e.g., name, surname, telephone number, e-mail address, etc.) as well as, in specific cases and only within the limits provided for by the law, also your "particular categories of personal data", i.e., belonging to protected categories. The processing of the latter categories of personal data is necessary for the purposes of selecting and evaluating your profile and is justified by legal obligations which the Company must fulfil.
In view of the above, the Company will collect and process the personal data and information provided by you for your application, including the data contained in your CV, for the exclusive purposes of evaluating and managing such application. In any case, please do not include in your CV and/or communicate to the Company during the interview data of a "particular" nature (e.g., relating to health, political opinions, sexual life, etc.), unless strictly necessary under the law for the purposes of selecting and evaluating the CV. The Company will refrain from processing any additional personal data provided by you that is not relevant and necessary for the purpose of selecting and evaluating your profile.
2. The nature of provision of personal data and consequences of the failure to provide it
For the execution of the purposes listed in paragraph 1 above, the processing of your personal data is necessary and the failure to provide such data will make it impossible to evaluate your application.
3. Communication of personal data
Your personal data may be communicated, for the purposes referred to in paragraph 1 above, to a service provider based in the US that offers Cleafy an HR portal for better and quicker management of the applications received. The Data Controller guarantees that the transfer of applicants personal data outside EEA will be carried out under the “EU-US Data Privacy Framework” program or, alternatively, to have adopted the measures provided for by the Regulation to legitimise the transfer of personal data abroad, including the so-called "Standard Contractual Clauses" approved by the European Commission, and to have verified through a Transfer Impact Assessment (TIA) that the legislation applicable in the importing state allows personal data to receive a level of protection equivalent to that guaranteed to them within the European Union.
4. Data retention
The data you provide will be stored for the time necessary to achieve the purposes for which they were collected (i.e., for the entire duration of the recruitment process) and for the performance of activities related and instrumental to the same process, as indicated in paragraph 1 above.
In case of not hiring, the data collected for the purposes of recruitment will be stored by the Company for a further 24 months. The Company, in this period, reserves the right to contact you again if your professional profile could be considered adequate with respect to other vacant job positions. After this period, the Company will send you an e-mail asking for your express consent to your CV remaining stored in our databases; if you do not respond or do not consent, it will be permanently deleted.
5. Privacy rights
We inform you that you may exercise, in the cases expressly provided for by the Regulation, the rights referred to in articles 15 et seq. of the Regulation and ask the Data Controller to:
i. confirm that the data are being processed and to access to the information relating to the processing of your personal data;
ii. rectify the inaccurate or incomplete personal data;
iii. delete the personal data;
iv. limit the processing of your personal data;
v. provide you with your personal data in a structured, commonly used and machine-readable format or to transmit your personal data to another data controller, if it’s possible (so-called “data portability right”).
You also have the right to object, in whole or in part, for legitimate reasons, to the processing of your personal data. To exercise the aforementioned rights, you may send a request to the e-mail address privacy@cleafy.com.
Finally, if you believe that the processing of your personal data infringes the legislation on the protection of personal data, you have the right to lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).
Cleafy S.p.A. VAT: 02340370226 email: info@cleafy.com
pec: cleafy@legalmail.it
cleafy.com
Headquarters Via Simone Schiaffino n. 11 20158 Milano, ITALY
Tel: +39 02 49517 001
Fax: +39 02 70059905