According to the rules of the Regulations, the treatments carried out by DIVA will be based on the principles of lawfulness, correctness, transparency, purpose limitation and retention, data minimization, accuracy, integrity and confidentiality.
- Data controller /strong>
- Personal data processed
- Data from navigation
- Special categories of personal data
- Data provided voluntarily by concerned
- Purpose of processing
- Legal basis and mandatory nature o optional treatment
- Recipients of personal data
- Transfers of personal data
- Retention of personal data
- Rights of the data subject
1. Data controller
The holder of the processing carried out through the Website is Di.Va. Service s.r.l. as defined above, reachable at the e-mail address: email@example.com.
The Owner has appointed the person responsible for the protection of personal data (hereinafter, "DPO") reachable at the address firstname.lastname@example.org.
2. Personal data subject to processing
Following the navigation of the Website, we inform you that DIVA will process your personal data which may consist of an identifier such as a identification number, an online identifier or one or more characteristic elements of yours physical, physiological, psychological, economic, cultural or social identity to make the subject interested party identified or identifiable (hereinafter only “Personal Data”).
The Personal Data processed through the Website are the following:
- common data (name, surname, e-mail)
- data particulars (particular data freely entered by the interested party in communications via e-mail.)
I. Navigation data
The IT systems and software procedures used to operate the Site acquire, during their normal operation, some Personal Data whose transmission it is implicit in the use of Internet communication protocols. This is information that they are not collected to be associated with identified, but by their very nature could, through processing and associations with data held by third parties, allow to identify users. This category of data includes IP addresses or domain names of the computers used by users who connect to the Site, the addresses in URI notation (Uniform Resource Identifier) of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response given by the server (good order, error, etc.) ed other parameters relating to the operating system and the user's IT environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of Site and to check its correct functioning, to identify anomalies and / or abuse, and they come deleted immediately after processing. Data could be used for assessment of responsibility in case of hypothetical computer crimes against the site or third parties except for this eventuality, data on web contacts do not currently persist for more than seven days.
II. Special categories of personal data
In the use of email to communicate with DIVA, it could a provision of your Personal Data falls under the category of special categories of Personal Data referred to in art. 9 of the Regulations, verbatim "the data [...] suitable to disclose racial or ethnic origin, political opinions, religious or philosophical beliefs, or union membership, as well as processing genetic data, biometric data to identify in unambiguous way of a natural person, data relating to health or sex life or to sexual orientation of the person. We invite you to communicate this information only when necessary. Indeed, we remind you that in the face of the transmission of special categories of Personal Data, but in the absence of specific manifestation of consent pursuant to art. 9 (2) (a) of the Regulations to process such data, DIVA can not be held responsible in any way, nor can it receive disputes of any kind, since in this case the treatment will be allowed as it has to object data made manifestly public by the interested party, in accordance with Article 9 (1) (e) of the Regulation. However, we specify the importance, as indicated above, of demonstrating the explicit consent to the processing of the special categories of Personal Data, where it decides to share this information.
We also inform you that, for the purposes of the selection, DIVA could analyze the professional social profiles you have freely made available on Internet (eg LinkedIn).
III. Data provided voluntarily by the interested
In the use of certain Site Services Personal data may be processed by third parties sent by you to DIVA. With respect to these hypotheses, you stand as an independent data controller, assuming all the data legal obligations and responsibilities. In this sense, confers on the point the widest indemnity with respect to any objection, claim, request for compensation for damage from treatment, etc. that it should reach DIVA from third parties whose Personal Data have been processed through your use of the functions of the Site in violation of the rules on the protection of personal data applicable. In any case, if it provides or otherwise processes Personal Data from third parties in the use of the Site, guarantees from now - assuming all connected responsibility - that such particular treatment hypothesis is based on a suitable legal basis pursuant to art. 6 of the Regulation that legitimizes the processing of the information in question.
Definitions, characteristics and application of the normative
There are various types of cookies, depending on their characteristics and functions, and these can remain in the user's computer or mobile device for different periods of time: c.d. cookie session, which is automatically deleted when the browser is closed; c.d. cookie persistent, which remain on the user's equipment until a predetermined deadline.
Among the cookies technicians, who do not require an express consent for their use, the Guarantor for protection of Italian personal data (cfr. see Determination of the modalities of the em modality if the use of the cookies of May 8, 2014, hereinafter only “Ruling“) also includes:
- “analytics cookies” where used directly by the site operator to collect information, in aggregate form, on the number of users and how they visit the site;
- browsing or session cookies that guarantee the normal navigation and use of the website (allowing, for example, to make a purchase or authenticate to access areas confidential);
- functional cookies, which allow the user to navigate in function of a set of selected criteria (for example, language, products selected for purchase) in order to improve the service rendered to the same.
For “profiling cookies”, those aimed at creating profiles related to the user and used to send messages advertising in line with the preferences expressed by the same in the context of navigation in network, a prior consent from the user is required.
Types of cookies used by the Site
The Website uses the following types of cookies, except that for third-party cookies for which the user must refer directly to the relative methods for selecting and de-selecting the respective cookies, indicated by means of links :
- Cookies analytics, which allow the site manager to understand how this is used by users. With these cookies are not collected information on the identity of the user, or any personal data. The information is treated in aggregate and anonymous form.
https://www.divaservice.com/ uses third-party cookies, that is site or web server cookies other than that of the Owner used for the purposes of these third parties, including cookies analytical and profiling. It is specified that these third parties, listed below with the related hypertext links to privacy policies, act as independent owners the processing of data collected through the cookies sent by them therefore, the user must refer to their policies for processing personal data, information and any forms of collection of consent (selection and de-selection of the respective cookies).
Google: https://www.google.it/intl/it/policies/technologies/types/ Google Analytics: https://tools.google.com/dlpage/gaoptout?hl=en-GB
In detail, cookies sent directly through the Website are shown below:
|Type of cookie and owner||Technical name of cookies||Functioning and purposes||Time of persistence|
|Allow the analysis on the use of the site by users in order to improve the contents and services offered. In the area of activity information related to navigation is collected, for example the pages visited by user, the time since the last visit to the site; session information such as duration of the visit and the time spent on the page; information on the source of origin of the visits.||2 years|
How to view and modify cookies through your navigation program (c.d. browser)
The user can select, authorize, block or delete (in whole or in part) cookies through the specific functions of your browser (browser): however, in the event that all or some of the cookies are disabled, it is possible that the Site is not available or that certain services or certain functions of the Site are not available or norn function properly and / or the user may be forced to change or to manually enter some information or preferences each time you visit the website.
3. Purpose of the treatment
The treatment we intend to carry out, upon your specific consent where necessary, has the following purposes:
- Respond to requests for assistance or information;
- analyze CVs and re-contact the candidates who submitted their candidacy;
- absolve any legal, accounting and tax obligations.
4. Legal basis and mandatory nature or optional treatment
The legal basis for the processing of Personal Data for the purposes of in section 3 (a-b-c-e) is art. 6 (1) (b) of the Regulations as the treatments are necessary for the provision of the Services or for the response of requests by the interested party. The conferment of Personal Data for these purposes is optional but any failure conferment would imply the impossibility to activate the Services provided by the Site or find requests or evaluate CVs. With specific reference to the purpose 3.c) and to the connected one analysis of professional social profiles freely available on the Internet of in section 2.b, the legal basis of the treatment is art. 6 (1) (f) of the Regulations, ie the the holder's legitimate interest in verifying any risks to the suitability of the candidate a cover the specific open position.
The purpose of section 3.d) represents a legitimate processing of Personal Data pursuant to art. 6 (1) (c) of the Rules. One time when the Personal Data is given, the processing is necessary to fulfill a legal obligation to which the Owner is subject
5. Recipients of personal data
Your Personal Data may be shared, for the purposes of referred to in Section 3, with:
- entities typically acting as managers of the treatment pursuant to art. 28 of the Regulations that is:
- eople, companies or professional firms that provide assistance and advice to DIVA in accounting, administrative, legal, tax, financial and debt collection with respect to the provision of the Services;
- subjects with whom it is necessary to interact for the provision of the Services (for example hosting provider), or subjects delegated to carry out technical maintenance activities (including the maintenance of network equipment and electronic communications networks); (collectively “Recipients”); the list of data processors who process data can be requested to the Data Controller by writing to the following address: email@example.com;
- subjects, bodies or authorities, independent data controllers, to whom it is mandatory to communicate your personal data in force legal provisions or orders from authorities;
- ersons authorized by DIVA for processing of Personal Data pursuant to art. 29 of the Regulations necessary to carry out closely related activities to the provision of the Services, whether they are committed to confidentiality or have an adequate one legal obligation of confidentiality.
6. Transferring personal data
Some of your personal data are shared with recipients could be found outside the European Economic Area. The holder ensures that the processing of your Personal Data by these Recipients takes place in compliance with the Regulation Indeed, transfers can be based on an adequacy decision, on the Standard Contractual Clauses approved by the European Commission or on another suitable basis legal. Further information is available from the Data Controller at the following addresses: firstname.lastname@example.org.
7. Data Retention
Personal Data processed for the purposes mentioned in section 3 (a-b-d-e) will be kept for the time strictly necessary to reach those same purposes in compliance with the principles of minimization and limitation of the conservation ex artt. 5.1.e) of the Rules. In any case, the Data Controller will process the Personal Data for the time necessary for contractual and legal obligations. Regarding the transmitted CVs, Personal Data will be retained as long as the position for which the CV was sent is available or, in the case of a spontaneous application, up to a year and subject to the possibility for the owner to contact the candidate shortly before the deadline indicated to request a extension of this retention period.
More information on the period of data retention and the criteria used to determine this period may be requests by writing to the Data Controller at the following address: email@example.com.
8. Rights of the interested parties
Pursuant to articles 15 and following of the Rules, he has the right to request at any time, access to your Personal Data, the correction or the cancellation of the same, the limitation of processing in the cases provided for by art. 18 of the Rules, get in a structured format, commonly used and readable by device automatic data concerning you, in the cases provided for by art. 20 of the Rules. In each moment, can begin ex art. 7 of the Regulations the consent given; propose a complaint to the competent supervisory authority (Personal Data Protection Authority) pursuant to art. 77 of the Regulations, if it considers that the processing of your data is contrary to current legislation. You can make a request for opposition to the processing of your data ex Article 21 of the GDPR in which to give evidence of the reasons justifying the opposition the Owner reserves the right to evaluate the request, which would not be accepted in case of existence of legitimate legitimate reasons to proceed with the processing that prevail over your interests, rights and freedom.
Requests must be sent in writing to the Data Controller at the following address: firstname.lastname@example.org.