(Version 00, May 2018)
1. Data processing: what is it about and who is affected?
R-Everse SpA ("Company"), whose data is displayed on company websites at the following URLs https://www.r-everse.com and https://reallyzation.com/ ("Site(s)"), in accordance with (EU) Regulation 2016/679 pertaining to the protection of processing individuals’ personal data, the free movement of such data and which rescinds Directive 95/46 /CE ("GDPR"), as well as the Italian national legislation on personal data protection ("National Data Protection Law"), is committed to protecting personal data ("Data") belonging to Clients or potential Clients ("Clients") who use the Company, including on its Sites, in order to use the service to search for and select personnel provided by the Company ("Service").
2. Reference to contractual discipline
In order to provide its Services, the Company establishes various legal relationships with different individuals (Candidates, Scouts and Clients). Should you wish to find out more about the Service’s contractual obligations, please refer to the relative contractual Terms and Conditions published on the Sites or which are otherwise made available to contractors.
3. Authorized processing
Client Data is processed by Company personnel who are authorized and properly trained.
4. External managers/processing recipients
Client Data may be processed by external managers for reasons relating to agreements undertaken with the Company.
External managers be one of the following categories:
- CRM software suppliers and related assistance/maintenance
- accounting and tax advisors
- credit institutions
The Company can provide specific information about the managers should the interested party request it.
5. Processed personal data
The processed data is made up of common data, such as the names and surnames of Clients’ legal representatives or owners, company or corporate names, tax codes, VAT numbers, legal and tax addresses, any and all relevant contact information (including cell phone numbers), fax, PEC, emails and CAP. In addition, any general information needed carry out the contract, such as Client representatives’ email addresses assigned to the personnel selection office, bank account details and/or any data related to the payment debit system.
For the purposes of this Notice, as the GDPR and National Data Protection Laws only refer to data held by natural people, individuals are exclusively natural people who provide services for Clients regardless of their nature.
6. Why is your data processed?
1) Data processing is carried out in order to establish and execute contractual relationships with Clients, as well as to fulfill legal obligations.
2) Email addresses belonging to Clients and/or Client representatives are processed to perform requests from Candidates who upload their CVs onto the Sites, as well as to protect their legitimate interest so the Company can deliver the Service they have requested.
3) Unless the Company’s Clients disagree, the relative data is processed in order to send commercial communication about a Service which has already been provided in a previous commercial relationship ("Opt-out").
4) Client Data may also be processed for verification and control purposes related to obligations from Legislative Decree No. 231/01 about companies’ and bodies’ administrative responsibilities.
7. Legal basis of Data processing
Processing email addresses belonging to Clients or their representatives is done to pursue the Candidates’ legitimate interest so that the Service can be provided.
Data processing is necessary to execute pre-contractual measures and contractual obligations (choosing CVs from Candidates who meet Clients’ requirements and then sending the CVs to the Clients).
8. Data conservation time
Client Data is kept throughout the contractual relationship and is deleted ten years and six months after this relationship ends for defensive purposes, unless there is a legal dispute, in which case the data will be kept for the time needed to exercise the right of defense and handle the dispute.
Data processed for the purposes mentioned in points 2 and 3 of paragraph 6 (Why is your data processed?) is stored and processed until the Client has chosen to opt-out.
9. Transferring data abroad
Using CRM systems (or other systems for managing CVs) may involve transferring data to non-EU countries. Particularly at the moment, some of these CRMs are provided by companies based in the United States and related servers. In these cases, the Company has checked that the service provider has adhered to the Privacy Shield and as such, transferring Data is done in compliance with the provisions of articles 44 and adhering to the GDPR.
Clients may contact the Company or any external managers to exercise the rights set out in the National Data Protection Laws (where applicable) and the GDPR (articles 15 and onwards) specifically to access their personal data, request for it to be modified, updated, deleted, limited or transferred by getting in contact with the Company at the address indicated above.
11. Right to opposition
Along the same procedures described above, Clients may entirely or partly object to their personal data being processed where the relevant legal basis is constituted by the legitimate interests of the Company, pursuant to and for the purposes of the provisions of Article 21 of the GDPR.
Any Client who believes that Data processing is in violation of the GDPR may file a complaint in accordance with the provisions of Article 77 of the GDPR with a supervisory authority where the Candidate normally lives or works, or to a supervisory authority where the alleged data breach occurred.
13. Amendments and updates
The Company reserves the right to modify and/or update this Notice, including any subsequent additions and/or amendments to national and/or European Union regulations regarding personal data protection or due to possible further purposes of data processing. For this reason, this Notice is published with a progressive identification number and the month of publication, starting with the May 2018 version which displays the number "00". Subsequent versions of the notice will replace previous ones and will be valid, effective and applied from the date they are published on the Website.