This Privacy and Cookie Policy aims to describe the purposes and methods used by Openjobmetis S.p.A., with registered office located at Via Generale Gustavo Fara 35, Milan, Italy, in its role as Controller (“Company” or “Controller”), for the collection and processing of personal data relating to users (“User/Users”) who interact with the websites http://www.openjobmetis.it and https://openjobmetis.dyndevicelcms.com (“Website”) and with the different services offered by it.
The information contained in this Privacy and Cookie Policy is provided in accordance with EU Regulation No. 679 of 27 April 2016 (“Regulation”), with Italian Legislative Decree 196/2003 (“Privacy Code”), as well as the Regulations issued by the Italian Data Protection Authority (“Data Protection Authority”), and the Guidelines of European authorities.
Information regarding data processing is provided only for the Website and for the processing carried out by the Company, and does not extend to processing carried out by third parties via other websites that can be consulted by the User through links. The Company does not assume any liability with regard to this additional processing; the User must refer to the individual Privacy and Cookie Policies of the third-party websites.
1. Controller
The Company is the Controller, as indicated in the introductory paragraphs.
2. Purposes and legal basis for processing
Through its Website, the Company may process the User's data for the following purposes:
a. Database registration and sending of applications for temporary employment positions. The Company offers Users the possibility to send an application for temporary employment with Openjobmetis clients through the “Candidates – Respond to advert/Register” section of the Website. For this purpose, the Company will acquire and use the information provided by the User who has applied for a specific position, solely for the purposes of selection and management of temporary employment applications, in order to respond to the User's request and carry out any pre-contractual measures required for their hiring for the temporary position. In the case of speculative and generic applications by the User, on the other hand, the personal data provided may be used by Openjobmetis to contact the User in relation to positions and selections - including in the future - in line with his or her professional profile. In any case, Users are requested not to add any “special” and/or sensitive information to their CVs (e.g. regarding state of health, political opinions, sexual orientation, etc.), unless strictly necessary according to the law for the purpose of the selection and assessment of CVs (e.g. belonging to protected categories). The Company may also ask the User to give his or her express and voluntary consent for the purpose of communicating his or her CV to companies belonging to the same Corporate Group as Openjobmetis and, in particular, to the subsidiary Seltis S.r.l., in their role as independent controllers, to be contacted for their respective selection and recruitment activities, regarding future selections.
b. Collection of applications for internal positions. The Company offers the User the possibility to submit an application for employment at Openjobmetis through the “Candidates – join the team – job opportunities” section of the Website. For this purpose, the Company will acquire and use the information provided by the User who has sent an application for a specific position, solely for the purposes of selection and management of internal applications, in order to respond to the User's request and carry out any pre-contractual measures required for their hiring for the position. In the case of speculative and generic applications by the User, on the other hand, the personal data provided may be used by Openjobmetis to contact the User in relation to positions and selections - including in the future - in line with his or her professional profile. In any case, Users are requested not to add any “special” and/or sensitive information to their CVs (e.g. regarding state of health, political opinions, sexual orientation, etc.), unless strictly necessary according to the law for the purpose of the selection and assessment of CVs (e.g. belonging to protected categories). The Company may also ask the User to give his or her express and voluntary consent for the purpose of communicating his or her CV to companies belonging to the same Corporate Group as Openjobmetis and, in particular, to the subsidiary Seltis S.r.l., in their role as independent controllers, to be contacted for their respective selection and recruitment activities, regarding future selections.
c. Quality Service and Support. Through the “Contacts – quality service” and “Contacts – HELP-FAQ” sections of the Website, the Controller offers the User the possibility to send communications and/or complaints to the Company in relation to the services it offers and to ask the Company for support in relation to the services offered on the Website. In this respect, the personal data provided by the User will be processed by the Company for the purposes of taking charge of, correctly managing and responding to the User's communication/request. The legal basis for the processing is the performance of the service explicitly requested by the User, and any refusal to provide personal data will result in the Company being unable to manage and reply to the communication or request.
d. Request candidate profile. Whenever the User is a business, the Controller offers the User the option to ask the Company, as part of the temporary employment services offered, for a candidate in line with the position offered and the User's specific requirements, through the “Companies – request profile” section of the Website, entering the identification data and contact details of the User company, as well as the relative contact person. The legal basis for the processing is the implementation of the temporary employment contract (and/or the pre-contractual measures aimed at establishing the contract) explicitly requested by the User/company; any refusal to provide the data will result in the Company being unable to manage and perform the temporary employment service.
e. Megaphone. Through the “Companies - megaphone” section of the Website, the Controller offers the User the possibility to enter its details (in particular, identification data and contact details, e.g. e-mail address and/or telephone number via which the User asks to be contacted) in order to be contacted directly by the most suitable Company consultant to provide the User with the requested information and meet the User's needs. The legal basis for the processing is the performance of the service explicitly requested by the User and any pre-contractual measures aimed at establishing the contractual relationship with the Company, whenever the User is not a client of the Company; any refusal to provide personal data will result in the Company being unable to manage and reply to the request.
f. Pursuit of legitimate interests by the Company and/or third parties. The User's data may also be used to exercise the rights and legitimate interests of the Company and/or third parties (including other companies of the Openjobmetis Group), for example, the right of defence in court, claims and dispute management, debt collection, and the prevention of fraud and/or illegal activities. In these cases, although the provision of personal data by the User is not mandatory, it is necessary since these data are strictly connected and instrumental to the pursuit of these legitimate interests, which do not prevail over the fundamental rights and freedoms of the User; any refusal to provide these data could result in the Company being unable to provide the requested services (e.g. to request information from the Company, request a candidate profile, etc.).
g. Fulfilment of legal obligations and/or applicable obligations. The Company may also use personal data provided by the User or otherwise acquired over the course of the User's interaction with the Website for purposes connected to compliance with legal obligations, regulations, Italian and/or EU legislation as well as deriving from provisions issued by authorities authorised to do so by law, which are the legal basis for the processing, without the need to obtain prior consent from the User.
h. Performance of aggregate statistical analysis on an anonymous basis. In order to improve performance and the services offered by the Company through the Website. In this case, no consent will be requested from the User since the processing will be carried out solely on anonymous data.
i. Sending of newsletters and communications on Company activities and services. The Controller offers the User, subject to the User's express consent, the option to receive commercial communications and general information and updates on the Company's results and activities through automated channels (e.g. fax and e-mail) through the “Investors - newsletter” section of the Website. The legal basis for the processing in this case is the optional consent of the User, who can freely choose whether to receive these communications; if this consent is not given by the User, this will not in any way prevent the use of the Company's services and Website. The User can object to the sending of these communications and withdraw consent, including partially for the individual channels of communication, by using the contact details specified in section 6 of this Privacy Policy, as well as clicking on the special unsubscribe link in the e-mails sent.
3. Categories of data subject to processing
The Company receives and collects, through the Website, information regarding Users that visit the pages of the Website and use the web services available on it. In particular, the Company acquires and processes the following information.
3.1 Data collected through browsing and cookies
When the User visits the Website, the latter collects certain data, including the pages viewed, links or buttons clicked by the User, the date and time of access, the User's IP address, the browser and the operating system used (so-called “browsing data”). Browsing data could, by their very nature, enable the User to be identified, including through processing and associations with data held by third parties. However, the Company uses these data only for the purpose of obtaining statistical and anonymous information on the use of the Website for purposes strictly connected to the functioning of the site. Browsing data could also be used to determine responsibility in the case of any IT offences that cause damage to the Website.
Secondly, in relation to the collection of User data through cookies and similar technologies, please visit section 7 of this Policy.
3.2 Data provided voluntarily by the User
The Company limits the collection of information provided voluntarily by the User to that required to pursue the purposes detailed in the previous section 2 and the explicitly requested services. Furthermore, the Company may collect and process additional personal data where these are provided voluntarily by the User as part of the services offered on the Website, for example, in the case where the User contacts the Company to report any poor service or malfunctions, to ask for assistance, to exercise his or her rights regarding the processing of personal data, etc. These data will be processed by the Company solely for the purposes strictly related to the User's request. If these data are not provided, it may not be possible to obtain the requested service.
4. Communication of data to third parties
The data supplied by the User as well as those collected by the Website as part of the related services (e.g. IP address) will not be disclosed, but may be communicated, for the purposes outlined in this Privacy and Cookie Policy, to the categories of subjects specified below:
• Openjobmetis Group companies for administrative purposes, for the pursuit of the legitimate interests of the Company and/or third parties and for the supply of the services explicitly requested by the User;
• subject to the express consent of the User, Openjobmetis Group companies and, in particular, the subsidiary Seltis S.r.l., for the performance of selection and recruitment activities;
• in the case of a business User (company), candidates for the job position being offered by the User and/or temporary workers of the Company, who the User intends to use for work activities;
• companies, partners, consultants or freelance professionals which the Company uses to perform the tasks of a technical or organisational nature (including, for example, suppliers of IT services), or with which the Company works for the purposes of the supply and functioning of its services, or for any communication activities;
• people, companies, or professional practices that provide support and consultancy to the Company, with particular, but not exclusive, reference to accounting, administrative, legal, fiscal and financial issues;
• subjects for which the right to access the data is recognised by legal provisions or orders of authorities.
Subjects belonging to the categories listed above will use the data in the role of independent controllers according to the law, or processors duly appointed by the Company.
These subjects can be located in Italy and/or EU countries.
The list of subjects to which the data are or can be communicated can be requested from the Company through the “Contacts” section on the Website.
5. Data retention
User data will be retained for the time necessary for the pursuit of the purposes for which they were collected, and for the performance of activities connected and instrumental to these, as specified in the previous section 2. After this, they will be retained in compliance with the standard time periods identified by the Italian Civil Code or by specific legal provisions, for administrative purposes and/or to assert or defend a right in court or a legitimate interest. The data will be deleted once the purposes for which they were collected no longer apply.
Secondly, the personal data collected for the purposes of assessing applications for internal positions within the Openjobmetis team will be retained for 24 months from receipt.
Finally, the data collected for the purposes of sending newsletters will be retained until the User unsubscribes/objects.
At the end of these periods, the data will be retained in anonymous form for analytical and statistical purposes.
6. Rights
The User can exercise the rights set out by the Regulation in those cases expressly provided for by the law and where applicable. In particular, Users have the right to:
ask for confirmation that there is ongoing processing of their personal data and, in this case, ask the Controller for access to information relating to the processing (e.g. purpose, categories of processed data, recipients or categories of recipients of the data, retention period, etc.);
ask for amendment of any inaccurate or incomplete data;
ask for the deletion of the data;
ask for restriction of processing;
receive the personal data concerning them in a structured and machine-readable format, and transmit those data to another controller, or ask for the direct transmission from one controller to another, if technically feasible (so-called “data portability”);
withdraw their consent at any time, without prejudice to the lawfulness of the processing carried out before the withdrawal based on consent.
Users also have the right to completely or partially oppose the processing of their personal data for legitimate reasons, as well as the right to oppose at any time the processing of data for marketing purposes (including partially for individual channels).
These rights can be exercised directly by writing to the following e-mail address: privacy@openjob.it.
Finally, whenever it is considered that the processing of the personal data provided breaches personal data protection legislation, Users have the right to submit a complaint to the Italian Data Protection Authority (www.garanteprivacy.it).
7. Data collection via cookies
A cookie is a short string of text, which visited websites send to the User's browser. They are stored when the User visits a website and then resent on the next visit.
Cookies are used by the Company for the functioning of its Website or to improve performance, but also to provide information on the Website or on the User's browsing.
The Website uses cookies both for technical purposes and for other reasons: while technical cookies are used in a way strictly necessary for the technical functioning of the Website as well as to provide the service specifically requested by the User (e.g. language settings, etc.), as better described below, cookies for other purposes (e.g. analytics cookies) are used to perform an analysis of the User's behaviour on the Website, as indicated below.
7.1 Technical cookies
Technical cookies are essential to allow the User to move around the Website and to use its functions, to register the User's choices (e.g. language, country of origin, etc.), to distribute requests on multiple servers, to save the User's choice to give consent for specific options (e.g. accepting the use of certain cookies beyond the information banner). These cookies last 24 days and do not require the User's consent. Specifically, the Company has installed session cookies on the Website, used to identify Users and to ensure the security of the User's data.
7.2 Company performance and analytics cookies
These cookies can last for the session or longer, and their use is limited to Website performance and improvement. These cookies enable Website visitors to be recognised, measured and tracked, enabling the improvement and fine-tuning of the Website; for example, establishing whether the User manages to easily find the desired information, or identifying which aspects of the Website are of the most interest. These cookies are used by the Company to carry out anonymous statistical analysis on the way users browse the Website, on the number of pages visited or the number of clicks carried out on a page during browsing. The privacy regulations regarding these cookies are similar to technical cookies in that they do not require the User's consent.
7.3 Third-party performance and analytics cookies
The Company may also use third-party analytics and performance cookies on the Website, and in particular Google cookies (so-called “Google Analytics”) for the same purposes as outlined above, in order to carry out analysis on the ways Users browse the Website, on the number of pages visited or the number of clicks made on the page during browsing. The Company processes the results of this analysis only if the third party uses cookies in connection with the browser installed on the computer or on other devices used by the User to browse the Website.
The IP address obtained by Google Analytics will not be associated with any other type of data held by Google and, to protect your privacy, Openjobmetis has adopted the appropriate tools to reduce the identification power of analytics cookies, anonymising your IP address before any storage or processing takes place. Due to the adoption of these tools, therefore, the use of these cookies can occur even in the absence of your express consent.
You can disable or block Google cookies by selecting the related settings on your browser. However, this may mean that you will not be able to use all the functions of the Website. You can download and install the Google Analytics opt-out browser Add-on, available via the following link: http://tools.google.com/dlpage/gaoptout.
7.4 Social plugins and social widgets/buttons
The Company uses cookies on the Website that are employed by operators other than the Controller, in particular Facebook, LinkedIn, YouTube and Twitter, to track social media subscribers (and non-subscribers) for the purposes of market analysis and product development. Since the Company does not manage these cookies, you are advised to consult the website of the individual third-party operator before clicking on the link on this Website, to understand the practices and control systems adopted by the operator.
There are also social buttons/widgets on the Website, i.e. specific "buttons" depicting the icons of social networking sites (i.e. Facebook, Twitter, YouTube and LinkedIn). These “buttons” allow Users browsing the Website to reach and interact directly with these social networks with one "click". By clicking on the social buttons/widgets, the social networking site acquires the data concerning the related visit. Outside these cases where the User voluntarily wants to share his or her browsing data with the predefined social networking sites, the Company does not share any browsing information or data on the User acquired through its websites with the social networking sites accessible through social buttons/widgets.
7.5 Disabling of cookies through the browser
As well as being able to choose whether to accept or reject all or some of the cookies used by the Website for additional purposes through the mechanisms described in this Privacy and Cookie Policy, in the future, the User can also delete the cookies posted by the Website from his or her browser, including through the browser settings.
Most browsers are set up to accept cookies. However, the User can set up his or her browser to limit the number of cookies accepted or to block all cookies, changing the browser settings as follows:
Microsoft Internet Explorer
Click on the 'Tools' icon in the top right-hand corner and select 'Internet Options'. In the pop-up window, select 'Privacy'. Here, the User can modify the cookie settings.
Google Chrome
Click on the “spanner” icon in the top right-hand corner and select 'Settings'. At this point, select 'Show advanced settings' and change the 'Privacy' settings.
Mozilla Firefox
From the dropdown menu in the top left-hand corner, select 'Options'. In the pop-up window, select 'Privacy'. Here, the User can adjust the cookie settings.
Safari
From the dropdown settings menu in the top right-hand corner select 'Preferences'. Select 'Security' and then adjust the cookie settings.
It should be noted, however, that by disabling the use of all cookies on the Website (including technical cookies) some functionalities will be compromised.
7.6 Further information concerning cookies
The website www.allaboutcookies.org contains instructions on how to manage cookies on the most widely used browsers; alternatively, it is possible to consult the documentation attached to the software used on your device.
8. Changes to the Privacy and Cookie Policy
The Company reserves the right to make changes to this Privacy and Cookie Policy at any time, giving notice through publication on the Website. We invite Users to check these updates on the Website.
When the changes are particularly significant and/or significantly affect User rights, the Company may inform the User in a different manner (for example, by e-mail).
9. Data Protection Officer
The Data Protection Officer (“DPO”) of Openjobmetis can be contacted by e-mailing privacyofficer@openjob.it or by telephoning +39 0331211501 (switchboard).
Privacy Policy updated on 20 March 2019.
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