PRIVACY POLICY REGARDING THE PROTECTION OF PERSONAL DATA
Introduction. Martinelli Ginetto S.p.A. (also known as the “Company” or “MG”), collects and processes personal data regarding its clients (Clients), relative to activities necessary for the conclusion of a contract and during the fulfillment of the same contract held with the Company (the “Contract”), which concern (i) legal entities and/or (ii) sole proprietorships, as well as any employees, collaborators and company representatives who, on behalf of the subjects indicated in points (i) and (ii), operate in relation to the concluding and fulfillment of a Contract (the aforementioned subjects are collectively defined as “Data Subjects”).
Unless otherwise specified in this document, and where applicable, all the terms used here regarding the protection of personal data assume the meaning attributed in the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
Data responsibility. The Company Martinelli Ginetto S.p.A., with registered office in Via Agro del Castello, 38 – 24020 Casnigo (BG), tax code and VAT number 03403660164, is the data controller for the personal data of Data Subjects. The marketing office, which is responsible for compliance regarding matters of privacy for the Company, can be contacted as follows:
Tel.: +39 035.725011
E-mail: marketing@magitex.it
Type of data processed. During the fulfillment of the Contract, the Company collects and processes the personal data sent by the Client regarding the Data Subject, which refer to: name, surname, email address, telephone number and any other contact data.
Purposes of data processing. The Company processes the personal data regarding the Data Subjects, both manually and electronically:
a) to conclude and fulfill the Contract between the Company and the Client;
b) to protect and safeguard the rights of the Company; the Company may, for example, pass on the data concerning the Data Subjects whenever necessary (i) for the safeguarding and defending of its rights regarding, for example, privacy, security and property, as well as for the safeguarding and defending of the rights of its employees, collaborators and partners, (ii) to safeguard the Company from fraud or for purposes related to risk management;
c) in compliance with laws and applicable legal procedures, and to respond to requests from competent authorities.
Legal basis of the processing. The processing of personal data is necessary in order to conclude and fulfill the Contract and comply with applicable laws and regulations. Therefore, the refusal to provide personal data for the purposes above would not allow the Company to conclude and fulfill the Contract.
Duration of storage of data. The personal data are held for no longer than is strictly necessary for the conclusion and fulfillment of the Contract and, if required, for any necessary safeguarding of the rights of the Company and/or any necessary compliance with legal obligations (as indicated in the section “Purposes of data processing”).
In any case, the data are not stored for any longer than ten (10) years from the moment in which they were originally collected.
Access to personal data. The Company may communicate the personal data of Data Subjects to third party suppliers of services (including companies in the same group) which carry out activities useful to the Company for the fulfilling of the Contract and nominated as data controllers where required by applicable laws. These are, for example: suppliers of IT services (Cloud, etc.), experts, companies resulting from mergers, de-mergers, or other company transformations, as well as proper authorities, if permitted by applicable law.
Location of personal data. The data regarding Data Subjects are not transferred to other countries outside the European Economic Area.
Rights of Data Subjects. The Data Subject has, and/or may exercise at any time, free of charge, the following rights:
a) the right to be informed of the purposes and methods of data processing;
b) the right to access;
c) the right to obtain a copy of the personal data held, and information on the location in which they are stored;
d) the right to request the updating, correction or the integration of the personal data;
e) the right to request the cancellation of the personal data;
f) the right to restriction of processing only in the presence of one of the following conditions: (i) the data are not correct or updated; (ii) the illegitimacy of processing is proven; (iii) the data are necessary for the exercising or defending of rights in legal proceedings; or (iv) the Data Subject has opposed processing;
g) the right to either fully or partially oppose processing, even when carried out via automated decision-making processes, including profiling;
h) the right to freely withdraw consent for the processing of the data at any time;
i) the right to contact the data protection officer;
j) the right to lodge a complaint with the national authority responsible for data protection or to judicial authorities.
As from the date of 25 May 2018, the deadline for the full application of the GDPR, as well as the rights listed above, the Data Subject also has the right to data portability, or rather the right to receive an electronic copy of the personal data that regard them, for the transferring of the same to the Data Subject themselves or to another data controller. For the exercising of their rights, the Data Subject may contact the Company at the following email address: martinelliginettospa@pec.it.
Updating of this policy. The Company may modify or update this policy. Any modifications made to this policy will be communicated in advance.
JOB APPLICANT PRIVACY NOTICE (GDPR)
As part of any recruitment process Martinelli Ginetto S.p.A. (also known as the “Company” or “MG”) collects and processes personal data relating to job applicants. Martinelli Ginetto S.p.A. is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
What information does Martinelli Ginetto S.p.A. collect?
The organisation collects a range of information about you. This includes:
• your name, address and contact details, including email address and telephone number;
• details of your qualifications, skills, experience and employment history;
• information about your current level of remuneration, including benefit entitlements;
• whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process; and
• information about your entitlement to work in the EU.
Martinelli Ginetto S.p.A. may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.
Martinelli Ginetto S.p.A. may also collect personal data about you from third parties, such as references supplied by former employers and information from criminal records checks. Martinelli Ginetto S.p.A. will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so. Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).
Why does Martinelli Ginetto S.p.A. process personal data?
Martinelli Ginetto S.p.A. needs to process data to take steps at your request prior to entering into a contract with you. It may also need to process your data to enter into a contract with you.
In some cases, Martinelli Ginetto S.p.A. needs to process data to ensure that it is complying with its legal obligations.
Martinelli Ginetto S.p.A. has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the organisation to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide on whom to offer a job. Martinelli Ginetto S.p.A. may also need to process data from job applicants to respond to and defend against legal claims.
Martinelli Ginetto S.p.A. may process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor recruitment statistics. It may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. The organisation processes such information to carry out its obligations and exercise specific rights in relation to employment.
For some roles, Martinelli Ginetto S.p.A. is obliged to seek information about criminal convictions and offences. Where Martinelli Ginetto S.p.A. seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.
If your application is unsuccessful, Martinelli Ginetto S.p.A. may keep your personal data on file in case there are future employment opportunities for which you may be suited. Martinelli Ginetto S.p.A. will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.
CVs that are sent speculatively may also be kept on file for future recruitment exercises.
Who has access to data?
Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.
Martinelli Ginetto S.p.A. will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. Martinelli Ginetto S.p.A. will then share your data with former employers to obtain references for you and the Disclosure and Barring Service to obtain necessary criminal records checks.
The information which you give to us may be transferred to countries outside the European Union (“EU”). For example, some or our third-party providers may be located outside of the EU.
Where this is the case we will take steps to make sure the right security measures are taken so that your privacy rights continue to be protected as outlined in this policy.
By submitting your personal data, you’re agreeing to this transfer, storing or processing.
How does Martinelli Ginetto S.p.A. protect data?
Martinelli Ginetto S.p.A. takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.
For how long does Martinelli Ginetto S.p.A. keep data?
If your application for employment is unsuccessful, Martinelli Ginetto S.p.A. will hold your data on file for [6 months] after the end of the relevant recruitment process. If you agree to allow Martinelli Ginetto S.p.A. to keep your personal data on file, Martinelli Ginetto S.p.A. will hold your data on file for a further 12 months for consideration for future employment opportunities. At the end of that period [or once you withdraw your consent], your data is deleted or destroyed.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.
Your rights
As a data subject, you have a number of rights. You can:
• access and obtain a copy of your data on request;
• require Martinelli Ginetto S.p.A. to change incorrect or incomplete data;
• require Martinelli Ginetto S.p.A. to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
• object to the processing of your data where Martinelli Ginetto S.p.A. is relying on its legitimate interests as the legal ground for processing.
If you would like to exercise any of these rights, please contact marketing@magitex.it
If you believe that Martinelli Ginetto S.p.A. has not complied with your data protection rights, you can complain to the Information Commissioner.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to Martinelli Ginetto S.p.A. during the recruitment process. However, if you do not provide the information, the organisation may not be able to process your application properly or at all.
INFORMATION REGARDING COOKIES
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