Privacy Policy of www.smeup.com

This Application collects some Personal Data from its Users.


This document contains a section dedicated to Users in the United States and their privacy rights.

This document contains a section dedicated to Users in Switzerland and their privacy rights.

This document contains a section dedicated to Brazilian Users and their privacy rights.


This document can be printed for reference by using the print command in the settings of any browser.

Owner and Data Controller

SMEUP S.p.A.
Società socio unico – soggetta al controllo e al coordinamento di SME HOLDING S.p.A.
Sede Legale: Via Albano Zanella, 23 – 25030 Erbusco (BS) – Capitale sociale: € 500.000,00 i.v. – C.F./Reg.Imp. e P.IVA: 04409600980 – Rea: BS-612571


Il Titolare del trattamento, SMEUP S.p.A., è la società controllante di un Gruppo Societario e in quanto tale eroga servizi alle società del Gruppo.
Un elenco completo e aggiornato delle società controllate è consultabile all’indirizzo https://www.smeup.com/holding/aziende

Owner contact email: gdpr@smeup.com

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: first name; email address; website; Tracker; Usage Data; Data communicated while using the service; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; last name; VAT Number; company name; ZIP/Postal code; various types of Data; city; field of activity; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Content commenting, Platform services and hosting, Analytics, Remarketing and behavioural targeting, Interaction with live chat platforms, Interaction with external social networks and platforms, Displaying content from external platforms, SPAM protection, Tag Management, Contacting the User, Information collection, Human resources, Advertising and Managing support and contact requests.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

  • Advertising

    This type of service allows User Data to be utilised for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, possibly based on User interests.
    This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
    Some of the services listed below may use Trackers for identifying Users, behavioural retargeting i.e. displaying ads tailored to the User’s interests and behaviour, or to measure ads performance. For more information, please check the privacy policies of the relevant services.
    Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

    Google Ads conversion tracking (Google Ireland Limited)

    Google Ads conversion tracking is an analytics service provided by Google Ireland Limited that connects data from the Google Ads advertising network with actions performed on this Application.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: Ireland – Privacy Policy.

    Category of Personal Information collected according to CCPA: internet information.

    This processing constitutes:

    • a Sale in California

    Meta ads conversion tracking (Meta pixel) (Meta Platforms Ireland Limited)

    Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms Ireland Limited that connects data from the Meta Audience Network with actions performed on this Application. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: Ireland – Privacy Policy – Opt out.

    Category of Personal Information collected according to CCPA: internet information.

    This processing constitutes:

    • a Sale in California

    Meta Audience Network (Meta Platforms Ireland Limited)

    Meta Audience Network is an advertising service provided by Meta Platforms Ireland Limited In order to understand Facebook's use of Data, consult Facebook's data policy.

    This Application may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Meta Audience Network service. One of the ways Audience Network shows ads is by using the User's ad preferences. The User can control this in the Facebook ad settings.

    Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.

    Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

    Place of processing: Ireland – Privacy Policy – Opt Out.

    Category of Personal Information collected according to CCPA: identifiers; internet information.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California

    LinkedIn Ads (LinkedIn Ireland Unlimited Company)

    LinkedIn Ads is an advertising service provided by LinkedIn Ireland Unlimited Company.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: Ireland – Privacy Policy – Opt out.

    Category of Personal Information collected according to CCPA: internet information.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California

    Meta Lookalike Audience (Meta Platforms Ireland Limited)

    Meta Lookalike Audience is an advertising and behavioural targeting service provided by Meta Platforms Ireland Limited that uses Data collected through Meta's Custom Audience in order to display ads to Users with similar behaviour to Users who are already in a Custom Audience list on the basis of their past use of this Application or engagement with relevant content across Meta's apps and services.
    On the basis of these Data, personalised ads will be shown to Users suggested by Meta Lookalike Audience.

    Users can opt out of Meta's use of Trackers for ads personalisation by visiting this opt-out page.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: Ireland – Privacy Policy – Opt out.

    Category of Personal Information collected according to CCPA: internet information.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California
  • Analytics

    The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.

    Google Analytics (Universal Analytics) (Google LLC)

    Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilises the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
    Google may use the Data collected to contextualise and personalise the ads of its own advertising network.

    In order to understand Google's use of Data, consult Google's partner policy.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

    Category of Personal Information collected according to CCPA: internet information.

    This processing constitutes:

    • a Sale in the United States

    Google Analytics 4 (Google Ireland Limited)

    Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
    Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
    In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.

    In order to understand Google's use of Data, consult Google's partner policy.

    Personal Data processed: Trackers.

    Place of processing: Ireland – Privacy Policy – Opt Out.

    Category of Personal Information collected according to CCPA: internet information.

    This processing constitutes:

    • a Sale in California

    Google Analytics (Universal Analytics) with anonymised IP (Google Ireland Limited)

    Google Analytics (Universal Analytics) is a web analysis service provided by Google Ireland Limited (“Google”). Google utilises the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
    Google may use the Data collected to contextualise and personalise the ads of its own advertising network.
    This integration of Google Analytics anonymises your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.

    In order to understand Google's use of Data, consult Google's partner policy.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: Ireland – Privacy Policy – Opt Out.

    Category of Personal Information collected according to CCPA: internet information.

    This processing constitutes:

    • a Sale in California

    Meta Events Manager (Meta Platforms Ireland Limited)

    Meta Events Manager is an analytics service provided by Meta Platforms Ireland Limited. By integrating the Meta pixel, Meta Events Manager can give the Owner insights into the traffic and interactions on this Application.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: Ireland – Privacy Policy.

    Category of Personal Information collected according to CCPA: internet information.

    This processing constitutes:

    • a Sale in California
  • Contacting the User

    INFORMATION ON THE PROCESSING OF PERSONAL DATA EX ART. 13 (EU) REG. 2016/679 (GDPR) - “CONTACT FORMS”

    DATA CONTROLLER
    SME UP Spa Via Albano Zanella, 23 - 25030 Erbusco (Bs) - Italy - Tax Code and VAT number 04844000960, in the person of its pro-tempore legal representative Mr. Piero Gagliardo

    The Data Controller, SME UP SPA, is the parent company of a Corporate Group; as such, it provides services to companies of the Corporate Group.
    For a complete and updated list of the subsidiaries, please visit www.smeup.com

    PURPOSES OF PROCESSING 1 - RESPONSE TO REQUESTS FOR INFORMATION
    The data you provided when filling out the contact form shall be processed by the Company to respond to your requests for information about the Company and/or its products/services.

    LEGAL BASIS OF PROCESSING
    Execution of a contract of which the party concerned is a party.

    DATA RETENTION TIME PRIOD
    Data shall be stored for 30 (thirty) days to respond to individual requests for information.
    Upon expiry of the above period, data will be erased and destroyed or made anonymous in accordance with the technical procedures for cancellation and backup.

    PURPOSES OF PROCESSING 2 – MARKETING PURPOSES
    Subject to your consent, the data you provided when filling out the contact form may be processed for marketing purposes: by way of example, sending - through automated contact methods (such as sms, mms and e-mail), and non-automated tools (such as operator telephone calls and paper mail) - of advertising material and communications relating to services/products provided by the Company or reporting of business events, as well as carrying out market research and statistical analysis.

    LEGAL BASIS OF PROCESSING
    Consent (optional and can be withdrawn at any time)

    DATA RETENTION TIME PERIOD
    Data shall be stored for 24 (twenty-four) months. Upon expiry of the above period, data will be erased and destroyed or made anonymous in line with the technical procedures for cancellation and backup.

    COMPULSORY PROVISION OF DATA
    The provision of data marked with an asterisk (*) and referred to in the data collection form is mandatory in order to provide you with the information required; in the event of a failure to provide the data, the Company will therefore not be able to process your request. Data not marked with an asterisk are optional.

    DATA RECIPIENTS
    Your data may be submitted to subjects acting in their quality as Data Controllers (such, by way of example, supervisory and control authorities, as well as any public entity entitled to request data) or processed, on behalf of the Company, by subjects appointed as Processors, who are provided with adequate operating instructions.
    These subjects essentially fall into the category of companies that provide management and/or maintenance service of the Company's website and the newsletter sending system.

    In addition, by virtue of the relationships between and among the companies of the Corporate Group, data may be processed by the parent company, SME UP SPA, as well as by other companies under its control, on account of the services provided between the companies themselves. An updated list of subsidiaries is available on our website at www.smeup.com

    SUBJECTS AUTHORIZED TO PROCESS DATA
    Data may be processed by employees of the company’s departments who are appointed to pursue the abovementioned purposes, and have been expressly authorised to process them, having received adequate operating instructions.

    RIGHTS OF THE DATA SUBJECT - LODGING OF COMPLAINTS WITH THE SUPERVISORY
    AUTHORITY
    By mailing the Registered Office at: SME UP SpA Via Albano Zanella, 23 - 25030 Erbusco (BS) – Italy or by contacting the Data Controller via e-mail at: Gruppo Sme.UP GDPR (gdpr@smeup.com ), data subjects may ask the controller for access to the data concerning them, their erasure, the rectification of inaccurate data, the integration of incomplete data, the restriction of processing in the cases provided for in art. 18 of the GDPR, as well as to object to the processing of data, for reasons connected with their specific situation, on legitimate grounds on the part of the data controller.

    Furthermore, in the event of processing based on consent or on a contract, and performed with automated tools, data subjects have the right to receive the data in a structured, commonly used machine-readable and interoperable format, and, if technically possible, arrange to have them submitted to other data controllers without hindrance.

    Data subjects have the right to lodge a complaint with a supervisory authority in the Member State of their habitual residence, place of work or place of the alleged infringement.

    Data subjects have the right to revoke the consent at any time for marketing purposes, as well as to object to the processing of data for the same purposes. The possibility remains, for the data subjects concerned who prefer to be contacted for the aforementioned purposes exclusively through traditional methods, to express their objection only on receipt of communications obtained through automated methods.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California

    INFORMATION ON THE PROCESSING OF PERSONAL DATA EX ART. 13 (EU) REG. 2016/679 (GDPR) - “NEWSLETTER”

    DATA CONTROLLER
    SME UP Spa Via Albano Zanella, 23 - 25030 Erbusco (Bs) - Italy - Tax Code and VAT number 04844000960, in the person of its pro-tempore legal representative, Mr. Piero Gagliardo.

    The Data Controller, SME UP SPA, is the parent company of a Corporate Group; as such, it provides services to companies of the Corporate Group.
    For a complete and updated list of the subsidiaries, please visit www.smeup.com

    PURPOSES OF PROCESSING
    Sending, via e-mail, communications of an informative nature ("Newsletter") to those who explicitly request them.

    LEGAL BASIS OF PROCESSING
    Execution of a contract of which the party concerned is a party.

    DATA RETENTION TIME PERIOD
    The data collected shall be stored until you ask to unsubscribe from the newsletter service. Upon expiry of the above period, data will be erased and destroyed or made anonymous, in line with the technical procedures for cancellation and backup.

    DATA PROVISIONING
    Pursuant to art. 13, co. 2, lett. e) of the GDPR, we inform you that the provision of the e-mail address for the aforementioned purpose is mandatory; therefore any refusal to provide it will make it impossible to send you the Newsletter.

    UNSUBSCRIPTION FROM THE SERVICE
    In order to no longer receive the newsletter, you may click on the “Unsubscribe” link at the bottom of each newsletter.

    DATA RECIPIENTS
    Data may be submitted to subjects acting in their quality as Data Controllers (such as, by way of example, supervisory and control authorities, as well as any public entity entitled to request data) or processed, on behalf of the Company, by subjects appointed as Processors, who are provided with adequate operating instructions (such as, by way of example, companies entitled to carry out management and/or maintenance service of the Company's website).

    In addition, by virtue of the relationships between and among the companies of the Corporate Group, data may be processed by the parent company, SME UP SPA, as well as by other companies under its control, on account of the services provided between the companies themselves. An updated list of subsidiaries is available on our website at www.smeup.com

    SUBJECTS AUTHORIZED TO PROCESS DATA
    Data may be processed by employees of the company’s departments who are appointed to pursue the abovementioned purposes, and have been expressly authorised to process them, having received adequate operating instructions.

    RIGHTS OF THE DATA SUBJECT - LODGING OF COMPLAINTS WITH THE SUPERVISORY
    AUTHORITY
    By mailing the Registered Office at: SME UP SpA Via Albano Zanella, 23 - 25030 Erbusco (BS) – Italy or by contacting the Data Controller via e-mail at: Gruppo Sme.UP GDPR (gdpr@smeup.com ), data subjects may ask the controller for access to the data concerning them, their erasure, the rectification of inaccurate data, the integration of incomplete data, the restriction of processing in the cases provided for in art. 18 of the GDPR.
    Furthermore, in the event of processing based on consent or on a contract, and performed with automated tools, data subjects have the right to receive the data in a structured, commonly used machine-readable and interoperable format, and, if technically possible, arrange to have them submitted to other data controllers without hindrance.

    Data subjects have the right to lodge a complaint with a supervisory authority in the Member State of their habitual residence, place of work or place of the alleged infringement.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California

    Contact form (this Application)

    By filling in the contact form with their Data, the User authorises this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

    Personal Data processed: city; company name; email address; field of activity; first name; last name; Trackers; various types of Data; VAT Number; website; ZIP/Postal code.

    Category of Personal Information collected according to CCPA: identifiers; commercial information; internet information.

    This processing constitutes:

  • Content commenting

    Content commenting services allow Users to make and publish their comments on the contents of this Application.
    Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
    If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.

    Comment system managed directly (this Application)

    This Application has its own internal content comment system.

    Personal Data processed: email address; first name; website.

    Category of Personal Information collected according to CCPA: identifiers; internet information.

    This processing constitutes:

    • a Sale in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
    • Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
  • Displaying content from external platforms

    This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
    This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

    Google Fonts (Google LLC)

    Google Fonts is a typeface visualisation service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Application to incorporate content of this kind on its pages.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

    Category of Personal Information collected according to CCPA: internet information.

    This processing constitutes:

    • a Sale in California

    Google Maps widget (Google LLC)

    Google Maps is a maps visualisation service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Application to incorporate content of this kind on its pages.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

    Category of Personal Information collected according to CCPA: internet information.

    This processing constitutes:

    • a Sale in California

    Font Awesome (Fonticons, Inc. )

    Font Awesome is a typeface visualisation service provided by Fonticons, Inc. that allows this Application to incorporate content of this kind on its pages.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: United States – Privacy Policy.

    Category of Personal Information collected according to CCPA: internet information.

    This processing constitutes:

    • a Sale in California

    YouTube video widget (Google Ireland Limited)

    YouTube is a video content visualisation service provided by Google Ireland Limited that allows this Application to incorporate content of this kind on its pages.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: Ireland – Privacy Policy.

    Category of Personal Information collected according to CCPA: internet information.

    This processing constitutes:

    • a Sale in California

    Video Vimeo (Vimeo, LLC)

    Vimeo is a video content visualisation service provided by Vimeo, LLC that allows this Application to incorporate content of this kind on its pages.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: United States – Privacy Policy.

    Category of Personal Information collected according to CCPA: internet information.

    This processing constitutes:

    • a Sale in California
  • Human resources

    INFORMATIVA RELATIVA AL TRATTAMENTO DEI DATI PERSONALI DEI CANDIDATI AI SENSI DEL REGOLAMENTO (UE) 2016/679 (“GDPR”)

    TITOLARE DEL TRATTAMENTO: SME UP S.p.A.
    Via Albano Zanella n. 23
    Erbusco (BS),
    indirizzo e-mail: gdpr@smeup.com
    (“Società” o “Titolare”)

    PREMESSA
    Il Titolare del trattamento, SME UP SPA, è la società controllante di un Gruppo Societario e in quanto tale eroga servizi di recruiting e selezione del personale alle società del Gruppo.
    Un elenco completo e aggiornato delle società controllate è consultabile all’indirizzo www.smeup.com

    DEFINIZIONE DI “DATI”
    Per “Dati” si intendono, a titolo esemplificativo e non esaustivo, nome, cognome, luogo e data di nascita, residenza, indirizzo di posta elettronica e contatti telefonici, titolo di studio, esperienze lavorative ed eventuali ulteriori Dati da Lei inseriti nel curriculum vitae e/o eventualmente inseriti nel questionario che Le sarà sottoposto in fase di colloquio (dati cd. “comuni”), nonché quelli idonei a rivelare, a titolo esemplificativo, lo stato di salute (come l’appartenenza a categorie protette) che riterrà opportuno inviare alla Società, categorie particolari di dati personali trattati (dati cd. “sensibili”).
    In tale ultimo caso, sarà cura della Società trattare anche questa specifica tipologia di dati in conformità alla Normativa Privacy.

    FINALITÀ DEL TRATTAMENTO 1 - Candidatura a posizione lavorativa specifica
    Finalità connesse o strumentali allo svolgimento dell’attività di ricerca e selezione in relazione alla posizione lavorativa specifica per la quale l’interessato inoltra la propria candidatura.

    BASE GIURIDICA DEL TRATTAMENTO
    Esecuzione di misure precontrattuali adottate su Sua richiesta.

    PERIODO DI CONSERVAZIONE DEI DATI
    Tutta la durata dell’attività di selezione, salva l’ulteriore eventuale conservazione da Lei autorizzata (vedi di seguito).

    FINALITÀ DEL TRATTAMENTO 2 - Verifica dei dati ricevuti
    Verificare che i dati forniti corrispondano al vero avvalendosi di informazioni pubbliche (ivi inclusi profili di social network professionali, banche dati, registri web o archivi multimediali accessibili al pubblico). Il trattamento, in conformità con quanto indicato dal Gruppo di lavoro art. 29 nell’«Opinion on data processing at work», è limitato alle sole informazioni connesse all’attitudine professionale al lavoro, necessario al solo fine di valutare gli specifici rischi legati al tipo di attività che dovrà essere svolta dai candidati, effettuato nella misura meno intrusiva possibile, adottando ogni necessaria misura per garantire un corretto bilanciamento tra il legittimo interesse del datore di lavoro a controllare e i diritti e le libertà fondamentali di questi ultimi.

    BASE GIURIDICA DEL TRATTAMENTO
    Legittimo interesse

    PERIODO DI CONSERVAZIONE DEI DATI
    Tutta la durata dell’attività di selezione, salva l’ulteriore eventuale conservazione da Lei autorizzata (vedi di seguito).

    FINALITÀ DEL TRATTAMENTO 3 - Gestione centralizzata delle candidature
    Comunicare i dati ad altre società del gruppo societario cui appartiene la Titolare per finalità di ricerca e selezione del personale, come da premessa.

    BASE GIURIDICA DEL TRATTAMENTO
    Legittimo interesse

    PERIODO DI CONSERVAZIONE DEI DATI
    Tutta la durata dell’attività di selezione, salva l’ulteriore eventuale conservazione da Lei autorizzata (vedi di seguito).

    FINALITÀ DEL TRATTAMENTO 4 - Candidatura spontanea
    Conservare per 3 anni i dati per eventuali future selezioni, nel caso in cui la selezione per cui Lei si è candidato abbia esito negativo, previa Sua richiesta, da esprimersi con manifestazione di volontà in calce alla presente Informativa
    Qualora Lei decidesse di non usufruire di tale ulteriore servizio e quindi di non autorizzare la conservazione dei suoi dati per future selezioni e il conseguente trattamento, ciò non precluderà che il Suo profilo sia preso in considerazione per la selezione in corso, ma impedirà solo che la Sua candidatura sia presa in considerazione per eventuali future selezioni

    BASE GIURIDICA DEL TRATTAMENTO
    Consenso

    PERIODO DI CONSERVAZIONE DEI DATI
    3 anni dalla cessazione della selezione.

    FINALITÀ DEL TRATTAMENTO 5 - Obblighi normativi
    Adempiere agli obblighi ed esercitare i diritti della Società o dell’interessato previsti dalla normativa applicabile in materia di diritto del lavoro e della sicurezza sociale e protezione sociale, o da contratti collettivi, nonché a disposizioni impartite da autorità a ciò legittimate e da organi di vigilanza e controllo.

    BASE GIURIDICA DEL TRATTAMENTO
    Necessità di assolvere obblighi legali cui è soggetta la Società nel rispetto, per quanto riguarda i dati “sensibili”, di quanto previsto nell’art. 9.2, lett. b).

    PERIODO DI CONSERVAZIONE DEI DATI
    Per tutta la durata del rapporto di lavoro e, dopo la sua cessazione, per il periodo prescrizionale ordinario.
    Decorsi i termini di conservazione sopra indicati, i Dati saranno distrutti o resi anonimi, compatibilmente con le procedure tecniche di cancellazione e backup.

    CONFERIMENTO DEI DATI
    Obbligatorio per l’attività di ricerca e selezione del personale. Il rifiuto di fornire i dati non consente di svolgere tale attività e non consentirà che la Sua candidatura sia presa in considerazione

    DESTINATARI DEI DATI
    I dati potranno essere comunicati a soggetti operanti in qualità di titolari autonomi legittimati a richiederli, oppure trattati, per conto della Società, da soggetti designati come responsabili del trattamento, a cui sono impartite adeguate istruzioni operative. Tali soggetti sono essenzialmente costituiti da:
    a) società, ivi incluse società appartenenti allo stesso gruppo societario, di cui il Titolare si avvale ai fini della, selezione, recruiting e valutazione dei candidati;
    b) società che si occupano di ricerca e selezione del personale.

    SOGGETTI AUTORIZZATI AL TRATTAMENTO
    I dati potranno essere trattati dai dipendenti delle funzioni aziendali deputate al perseguimento delle finalità sopra indicate, che sono stati espressamente autorizzati al trattamento e che hanno ricevuto adeguate istruzioni operative.

    TRASFERIMENTO DEI DATI PERSONALI IN PAESI NON APPARTENENTI ALL’UNIONE EUROPEA
    Per ragioni legate all’utilizzo di servizi cloud, i dati potranno essere trasferiti all'estero in paesi extra-europei, ed in particolare verso:
    a) Paesi extra UE “il cui livello di protezione dei dati è stato ritenuto adeguato dalla Commissione Europea ai sensi dell’art. 45 del GDPR”
    OPPURE
    b) Paesi Extra UE diversi da quelli di cui al punto che precede previa adozione delle garanzie di cui all’art. 46, 2, lett. c) e d)”
    Una copia delle garanzie può essere ottenuta indirizzando specifica richiesta al Titolare secondo le modalità previste al paragrafo “Diritti dell’interessato – Reclamo all’autorità di controllo”.

    DIRITTI DELL'INTERESSATO - RECLAMO ALL’AUTORITÀ DI CONTROLLO
    Contattando il Titolare via e-mail all’indirizzo gdpr@smeup.com , gli interessati possono chiedere l’accesso ai dati che li riguardano, la loro rettifica, l’integrazione o la loro cancellazione, nonché, la limitazione del trattamento nei casi previsti dall’art. 18 GDPR nonché l’opposizione al trattamento nelle ipotesi di legittimo interesse del Titolare.
    Gli interessati, inoltre, nel caso in cui il trattamento sia basato sul consenso o sul contratto e sia effettuato con strumenti automatizzati hanno il diritto di ricevere in un formato strutturato, di uso comune e leggibile da dispositivo automatico i dati, nonché, se tecnicamente fattibile, di trasmetterli ad altro titolare senza impedimenti.
    Gli interessati hanno il diritto di revocare il consenso prestato in qualsiasi momento, nonché di opporsi al trattamento effettuato per perseguire il legittimo interesse del Titolare.
    Gli interessati hanno il diritto di proporre reclamo all'Autorità di controllo competente.

    DICHIARAZIONE DI CONSENSO DELL’INTERESSATO
    Presa visione dell'Informativa Privacy sopra riportata, consapevole che il mio consenso è puramente facoltativo, oltre che revocabile in qualsiasi momento, autorizzo la conservazione dei miei dati per 36 mesi affinché il mio CV possa essere preso in considerazione per eventuali future selezioni di SME UP S.p.A. e delle società del Gruppo il cui elenco completo e aggiornato è consultabile all’indirizzo www.smeup.com, consapevole che, nel caso di mancata autorizzazione, i miei dati saranno trattati esclusivamente per la selezione in corso e successivamente cancellati e che la presente autorizzazione può essere revocata in qualsiasi momento.

    This processing constitutes:

    • a Sharing in California
  • Information collection

    Lead Champion

    Questo sito utilizza servizi di terze parti che richiedono l’utilizzo di cookies: Lead Champion è un servizio di lead generation fornito da IntelligenceFocus Inc.
    Luogo del trattamento: Italia – Privacy Policy – Opt Out
    URL per le Privacy Policy: http://www.leadchampion.com/privacy/
    URL di Opt Out: http://www.leadchampion.com/optout

    This processing constitutes:

    • a Sale in California
    • a Sharing in California
  • Interaction with external social networks and platforms

    This type of service allows interaction with social networks or other external platforms directly from the pages of this Application.
    The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network.
    This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
    It is recommended to log out from the respective services in order to make sure that the processed data on this Application isn’t being connected back to the User’s profile.

    Facebook Like button and social widgets (Meta Platforms, Inc.)

    The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Meta Platforms, Inc.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: United States – Privacy Policy.

    Category of Personal Information collected according to CCPA: internet information.

    This processing constitutes:

    • a Sale in the United States

    Twitter Tweet button and social widgets (X Corp.)

    The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: United States – Privacy Policy.

    Category of Personal Information collected according to CCPA: internet information.

    This processing constitutes:

    • a Sale in California

    LinkedIn button and social widgets (LinkedIn Corporation)

    The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: United States – Privacy Policy.

    Category of Personal Information collected according to CCPA: internet information.

    This processing constitutes:

    • a Sale in California
  • Interaction with live chat platforms

    This type of service allows Users to interact with third-party live chat platforms directly from the pages of this Application, in order to contact and be contacted by this Application‘s support service.
    If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

    Facebook Messenger Customer Chat (Meta Platforms, Inc.)

    The Facebook Messenger Customer Chat is a service for interacting with the Facebook Messenger live chat platform provided by Meta Platforms, Inc.

    Personal Data processed: Data communicated while using the service; Tracker; Usage Data.

    Place of processing: United States – Privacy Policy.

    Category of Personal Information collected according to CCPA: internet information.

    This processing constitutes:

    • a Sale in California

    My LiveChat Widget (CuteSoft Components Inc.)

    The My LiveChat Widget is a service for interacting with the My LiveChat live chat platform provided by CuteSoft Components Inc.

    Personal Data processed: Data communicated while using the service; Tracker; Usage Data.

    Place of processing: Canada – Privacy Policy.

    Category of Personal Information collected according to CCPA: internet information.

    This processing constitutes:

    • a Sale in California
  • Managing support and contact requests

    This type of service allows this Application to manage support and contact requests received via email or by other means, such as the contact form.
    The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).

    LiveChat - Ovy

    Questo sito utilizza il prodotto Ovy, servizio di automatizzazione delle conversazioni offerto da Neuraltech Srl.
    Privacy Policy disponibile al link: https://userbot.ai/it/privacy-policy/

  • Platform services and hosting

    These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
    Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

    WordPress.com (Automattic Inc.)

    WordPress.com is a platform provided by Automattic Inc. that allows the Owner to build, run and host this Application.

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: United States – Privacy Policy.

    Category of Personal Information collected according to CCPA: internet information.

    This processing constitutes:

    • a Sale in California
  • Remarketing and behavioural targeting

    This type of service allows this Application and its partners to inform, optimise and serve advertising based on past use of this Application by the User.
    This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioural targeting activity.
    Some services offer a remarketing option based on email address lists.
    Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

    Google Ads Remarketing (Google LLC)

    Google Ads Remarketing is a remarketing and behavioural targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of this Application with the Google Ads advertising network and the DoubleClick Cookie.

    In order to understand Google's use of Data, consult Google's partner policy.

    Users can opt out of Google's use of Trackers for ads personalisation by visiting Google's Ads Settings.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

    Category of Personal Information collected according to CCPA: internet information.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California

    Facebook Remarketing (Meta Platforms, Inc.)

    Facebook Remarketing is a remarketing and behavioural targeting service provided by Meta Platforms, Inc. that connects the activity of this Application with the Facebook advertising network.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: United States – Privacy Policy – Opt Out.

    Category of Personal Information collected according to CCPA: internet information.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California

    Meta Custom Audience (Meta Platforms Ireland Limited)

    Meta Custom Audience is a remarketing and behavioural targeting service provided by Meta Platforms Ireland Limited that connects the activity of this Application with the Meta Audience Network.

    Users can opt out of Meta's use of Trackers for ads personalisation by visiting this opt-out page.

    Personal Data processed: email address; Trackers.

    Place of processing: Ireland – Privacy Policy – Opt out.

    Category of Personal Information collected according to CCPA: identifiers; internet information.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California
  • SPAM protection

    This type of service analyses the traffic of this Application, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognised as SPAM.

    Google reCAPTCHA (Google LLC)

    Google reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
    The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

    In order to understand Google's use of Data, consult Google's partner policy.

    Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Tracker; Usage Data.

    Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

    Category of Personal Information collected according to CCPA: internet information; inferred information.

    This processing constitutes:

  • Tag Management

    This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralised fashion.
    This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

    Google Tag Manager (Google LLC)

    Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

    Category of Personal Information collected according to CCPA: internet information.

    This processing constitutes:

    • a Sale in California

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Cookie Policy

This Application uses Trackers. To learn more, Users may consult the Cookie Policy.

Further Information for Users

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes.
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Further information about retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The rights of Users based on the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following, to the extent permitted by law:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or enquire with the Owner using the information provided in the contact section.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.

Further information for Users in Switzerland

This section applies to Users in Switzerland, and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.

Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the personal data, if any, the retention period and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.

The rights of Users according to the Swiss Federal Act on Data Protection

Users may exercise certain rights regarding their Data within the limits of law, including the following:

  • right of access to Personal Data;
  • right to object to the processing of their Personal Data (which also allows Users to demand that processing of Personal Data be restricted, Personal Data be deleted or destroyed, specific disclosures of Personal Data to third parties be prohibited);
  • right to receive their Personal Data and have it transferred to another controller (data portability);
  • right to ask for incorrect Personal Data to be corrected.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible, providing Users with the information required by law.

Further information for Users in Brazil

This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in the LGPD.

The grounds on which we process your personal information

We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:

  • your consent to the relevant processing activities;
  • compliance with a legal or regulatory obligation that lies with us;
  • the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
  • studies conducted by research entities, preferably carried out on anonymised personal information;
  • the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
  • the exercising of our rights in judicial, administrative or arbitration procedures;
  • protection or physical safety of yourself or a third party;
  • the protection of health – in procedures carried out by health entities or professionals;
  • our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
  • credit protection.

To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.

Categories of personal information processed

To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.

Why we process your personal information

To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

Your Brazilian privacy rights, how to file a request and our response to your requests

Your Brazilian privacy rights

You have the right to:

  • obtain confirmation of the existence of processing activities on your personal information;
  • access to your personal information;
  • have incomplete, inaccurate or outdated personal information rectified;
  • obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
  • obtain information on the possibility to provide or deny your consent and the consequences thereof;
  • obtain information about the third parties with whom we share your personal information;
  • obtain, upon your express request, the portability of your personal information (except for anonymised information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
  • obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
  • revoke your consent at any time;
  • lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
  • oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
  • request clear and adequate information regarding the criteria and procedures used for an automated decision; and
  • request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.

You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.

How to file your request

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.

How and when we will respond to your request

We will strive to promptly respond to your requests.
In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.

In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.
You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.
In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.

Transfer of personal information outside of Brazil permitted by the law

We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:

  • when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
  • when the transfer is necessary to protect your life or physical security or those of a third party;
  • when the transfer is authorised by the ANPD;
  • when the transfer results from a commitment undertaken in an international cooperation agreement;
  • when the transfer is necessary for the execution of a public policy or legal attribution of public service;
  • when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.

Further information for Users in the United States

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana.

For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term Personal Information (and Sensitive Personal Information).

Notice at collection

The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.

While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.

  • Identifiers

    Personal Information collected or disclosed: first name, email address, website, last name, company name, ZIP/Postal code, various types of Data, city, field of activity, Trackers, Usage Data, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example)

    Sensitive Personal Information collected or disclosed ℹ️: VAT Number

    Purposes:

    • Content commenting
    • Contacting the User
    • Advertising
    • Remarketing and behavioural targeting

    Retention period: for the time necessary to fulfill the purpose

    Sold or Shared ℹ️: Yes

    Targeted Advertising: ℹ️: Yes

    Third-parties: Meta Platforms Ireland Limited

    Service providers or contractors: this Application

  • Internet or other electronic network activity information

    Personal Information collected or disclosed: first name, email address, website, various types of Data as specified in the privacy policy of the service, Tracker, Usage Data, Data communicated while using the service, answers to questions, clicks, keypress events, motion sensor events, mouse movements, scroll position, touch events, Trackers, last name, company name, ZIP/Postal code, various types of Data, city, field of activity, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example)

    Sensitive Personal Information collected or disclosed ℹ️: VAT Number

    Purposes:

    • Content commenting
    • Platform services and hosting
    • Analytics
    • Remarketing and behavioural targeting
    • Interaction with live chat platforms
    • Interaction with external social networks and platforms
    • Displaying content from external platforms
    • SPAM protection
    • Tag Management
    • Contacting the User
    • Advertising

    Retention period: for the time necessary to fulfill the purpose

    Sold or Shared ℹ️: Yes

    Targeted Advertising: ℹ️: Yes

    Third-parties: Automattic Inc., Google LLC, Meta Platforms, Inc., X Corp., LinkedIn Corporation, Fonticons, Inc. , Google Ireland Limited, CuteSoft Components Inc., Vimeo, LLC, Meta Platforms Ireland Limited, LinkedIn Ireland Unlimited Company

    Service providers or contractors: this Application

  • Inferences drawn from other personal information

    Personal Information collected or disclosed: Usage Data, Tracker, answers to questions, clicks, keypress events, motion sensor events, mouse movements, scroll position, touch events

    Purposes:

    • SPAM protection

    Retention period: for the time necessary to fulfill the purpose

    Sold or Shared ℹ️: Yes

    Targeted Advertising: ℹ️: Yes

    Third-parties: Google LLC

  • Commercial information

    Personal Information collected or disclosed: first name, last name, company name, email address, ZIP/Postal code, various types of Data, city, field of activity, website, Trackers

    Sensitive Personal Information collected or disclosed ℹ️: VAT Number

    Purposes:

    • Contacting the User

    Retention period: for the time necessary to fulfill the purpose

    Sold or Shared ℹ️: Yes

    Targeted Advertising: ℹ️: Yes

    Service providers or contractors: this Application

ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.

To know more about your rights in particular to opt out of certain processing activities and to limit the use of your sensitive personal information (“Limit the Use of My Sensitive Personal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy.

For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.

We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.

What are the sources of the Personal Information we collect?

We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use this Application.

For example, you directly provide your Personal Information when you submit requests via any forms on this Application. You also provide Personal Information indirectly when you navigate this Application, as Personal Information about you is automatically observed and collected.

Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.

Your privacy rights under US state laws

You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:

  • the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
  • the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
  • the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
  • the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
  • the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
  • the right to non-discrimination.

Additional rights for Users residing in California

In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have:

  • The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
  • The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.

Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana

In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana you have

  • The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
  • The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. In Maryland, your Sensitive Personal Information will be collected or processed only if strictly necessary to provide or maintain a specific product or service requested by you.

In Minnesota and Maryland Users also have the right to obtain a list of the specific third parties to which the controller has disclosed the consumer's personal data

* Note that in some states like Minnesota you have the following specific rights connected to profiling:

  • The right to question the results of the profiling;
  • The right to be informed of the reason that the profiling resulted in the decision; if feasible
  • The right to be informed of what actions the consumer might have taken to secure a different decision and the actions that the consumer might take to secure a different decision in the future;
  • The right to review personal data used in the profiling;
  • If inaccurate, the right to have the data corrected and the profiling decision reevaluated based on the corrected data;

Additional rights for users residing in Utah and Iowa

In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have:

  • The right to opt out of the processing of your Personal Information for Targeted Advertising;
  • The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

How to exercise your privacy rights under US state laws

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

If you are an adult, you can make a request on behalf of a child under your parental authority.

How to exercise your rights to opt out

In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Application.

If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.

Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).

We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data) / Personal Information (or Information)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Sensitive Personal Information

Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.

Usage Data

Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilised by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Application as described in the relative terms (if available) and on this site/application.

Sale

Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.

Sharing

Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioural advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioural advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.

Targeted advertising

Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.


Legal information

This privacy statement has been prepared based on provisions of multiple legislations.

This privacy policy relates solely to this Application, if not stated otherwise within this document.

Latest update: 17 July 2025

This document has been created with the iubenda Privacy and Cookie Policy Generator. See also the Terms and Conditions Generator. iubenda hosts this content and only collects the Personal Data strictly necessary for it to be provided.

Show the simplified Privacy Policy