PRIVACY INFORMATION SHEET FOR CANDIDATES

INFORMATION SHEET
pursuant to Article 13 of (EU) Regulation No. 2016/679 (“GDPR”)

1. DESIGNATED DATA CONTROLLER
SPINELLI S.r.l., with registered offices situated at No. 171. Via Angelo Scarsellini, Genoa (GE), in the person of the appointed corporate legal representative, Income Tax Ref. No. and VAT Reg. No. 02716640103, listed in the Register of Companies of Genoa (hereinafter referred to as “The Data Controller” or “Spinelli”)

2. DEFINITION OF PERSONAL DATA AND INFORMATION AS REGARDS DATA PROCESSING ACTIVITIES
In terms of the GDPR, the term “Personal information” is deemed to mean: “any information regarding an identifiable or non-identifiable individual. An individual is deemed to be directly or indirectly “identifiable” based on specific personal details such as his/her name, ID number, location data, online ID or one or more unique physical, physiological, genetic, psychic, economic, cultural or social features” (“Details”).
Furthermore, the GDPR also defines specific categories of personal details, namely “personal details that reveal an individual’s ethnic or racial origin, political affiliations, philosophical or religious beliefs or union membership, as well as the processing of genetic information, biometric information aimed at uniquely identifying an individual and information regarding an individual’s health status, sex life or sexual orientation” (“Unique details”).
As part of the selection process, the Data Controller will process the Personal Data contained in your curriculum vitae, specifically your:
– name and surname;
– date and place of birth;
– home address;
– contact details such as contact telephone number and e-mail address;
– qualifications and work experience.
During the course of the candidate evaluation process, the Data controller has no particular interest in acquiring your Personal Information. For this reason, the Data Controller requests that you do not provide any such information except where it may be strictly necessary to do so due to the nature of the position for which you are applying.
The provision of your Personal Information is entirely voluntary, however, should you refuse to provide any necessary Personal Details, the Data Controller will be unable to duly consider your application.
The legal foundation for processing your Personal Information lies in the execution of the contract and, more specifically, in the engagement and sign-on process.

3. PURPOSES OF THE DATA PROCESSING
Your Personal Information will be processed by the Data Controller for the purposes of assessing your suitability for any vacant posts available within the company itself or within other Group companies.

4. DISCLOSURE OF PERSONAL DETAILS TO OTHER PARTIES WITHIN THE EU
The Data Controller may disclose your Personal Information to other parties whose services are utilised for personnel selection purposes.
More specifically, in order to achieve the ends described in paragraph 3 above and as an integral part of the data processing activities, your Personal Information may be disclosed to external companies that provide the Data Controller with IT and Administration services or, where applicable, to agencies that provide personnel assessment and selection services or external consultants, who shall duly process your Personal Information directly as de-facto Data Controllers in their own right.
Furthermore, the Data Controller may also disclose your Personal Information to any parties to whom it is legally obliged to do so, as well as to Public Administration bodies and to other Group Companies.
Personal Information will never be disclosed indiscriminately to any unauthorised parties.

5. DATA RETENTION PERIOD
The Data Controller will retain your Personal Information for a maximum of 6 months from the date of receipt of your curriculum vitae, after which the aforesaid information will be totally deleted.

6. YOUR RIGHTS AS THE INDIVIDUAL CONCERNED
For the entire duration of the period in which the Data Controller retains possession of the aforesaid Personal Information, as the individual concerned, you shall be entitled to exercise the following rights at any time:
– Right of access – You are entitled to request confirmation as to whether or not any of your Personal Information has indeed been processed, and to obtain any further details you require regarding such processing;
– Right of correction – You are entitled to demand that any of your Personal Information in our possession be corrected in the event that said information is incomplete or incorrect;
– Right of cancellation – In certain cases, you will be entitled to demand that any of your Personal Information contained in our records be permanently deleted ;
– Right to restrict the use of your personal information – Under certain circumstances, you will be entitled to restrict the use of your Personal Information;
– Right of transfer – You are entitled to request that any of your Personal Information in our possession be transferred to some other Data Controller;
– Right of objection – You are entitled, at any time and for specific reasons relating to special circumstances, to object to the processing of your Personal Information for legitimate interests or for the execution of public powers, including profiling purposes, except where the Data Controller has legitimate grounds for proceeding with the processing, grounds that take precedence over your rights and liberties as the interested party or for the purposes of ascertaining, exercising or defending some legal right in court;
– Right of revocation – You are entitled to revoke your approval for your Personal Information to be processed at any time, without prejudice to the legitimacy of the processing based on the authorisation granted prior to the revocation;
– Right to lodge a complaint with the Oversight Authority – Should the Data Controller refuse to comply with your access requests, reasons shall be provided for such refusal. Where applicable, you will be entitled to lodge a complaint as described in paragraph 7 below.
Such requests may be submitted to the Data Controller exclusively at the following e-mail address: careers@gruppospinelli.com.

7. COMPLAINTS
Should you wish to lodge a complaint regarding the manner in which the Data Controller has processed your Personal Information or the way in which a complaint submitted by you has been dealt with, you are entitled to submit an application directly to the Oversight Authority.

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Spinelli Srl, Via Scarsellini 171, 16149 Genova
F.C. and VAT 02716640103



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