(pursuant to Art. 13 of the General Data Protection Regulation (EU) 2016/679 (GDPR) and Art. 13 of Italy’s Data Protection Act (Legislative Decree 196 of June 30, 2003)
Processing of personal data means any operation or set of operations which is performed with or without the aid of automated processes on personal data or sets of personal data, even if not recorded in a database, such as collection, recording, organization, structuring, storage, processing, selection, blocking, adaptation or modification, extraction, consultation, use, transmission, disclosure or other provision of access, alignment or combination, restriction, erasure or destruction.
S.A. STUDIO SANTAGOSTINO s.r.l.,confirms to all interested parties that it will process the data freely transmitted, both sensitive and non, for the sole purpose of the management of career consultancy, training, selection and evaluation of personnel activities which it carries out. S.A. STUDIO SANTAGOSTINO s.r.l. undertakes to process the data as supplied and to safeguard it with the utmost confidentiality, with care and diligence, in accordance with the provisions of the personal data protection Regulation (679/2016)
2. Kinds of data processed
We process the personal and identification data (e.g. name, tax ID, company name, address, telephone number, e-mail address, bank and payment details—in short, "Personal Data" or "Data") that you enter when you visit the website www.sastudiosantagostino.com (for example by clicking on "information request" or "register your resume") and/or when you contract our services.
We process your data for the following purposes:
A) Provision of service (Art. 6b GDPR and Art. 24[a, b, c] of the Data Protection Act), in particular for:
- responding to requests for our services;
- concluding contracts for our services;
- fulfilling the precontractual, contractual and tax obligations that arise when we do business with you;
- complying with laws, regulations, EU or other legislation (e.g. for the prevention of money laundering);
- exercising our rights as Data Controller (e.g. the right of defense in legal proceedings).
B) (Only if you have given us specific, separate consent) for promotional purposes (Arts. 23 and 130 of the Data Protection Act and Art. 7 GDPR), meaning you may:
- receive e-mail, regular mail and/or text messages, telephone calls, newsletters or direct marketing materials about our products and services and/or opinion surveys about our quality of service;
- receive marketing e-mail, regular mail, text messages and/or telephone calls from third parties (e.g. business partners).
If you are already our client, we may send you marketing materials on products and services similar to those you have already used, unless you no longer wish to receive them (Art. 130 of the Data Protection Act).
4. How your data is processed
Your data may be processed in the ways specified in Art. 4 of the Data Protection Act and Art. 4.2 GDPR, that is, through its collection, recording, organization, storage, consultation, processing, modification, selection, retrieval, alignment, use, combination, blockage, disclosure, erasure or destruction. This occurs on paper as well as through electronic/automated procedures.
We will process your data for the time necessary to fulfill the above purposes and in any case for no longer than 10 years from termination of the relationship for provision-of-service purposes, while for promotional purposes your data will be kept in compliance with the principle of proportionality and in any case until such purposes have been pursued, or until you revoke consent.
5. Who can access your data
Your personal data may be made accessible, for the purposes stated in Arts. 2A) and 2B), to:
- our employees and consultants in Italy and abroad, in their capacity as processing personnel, internal data processors and/or system administrators;
- third-party companies or other parties (banks, accounting firms, consultants, insurers for the provision of insurance coverage, other companies in the Santagostino Group, etc.) that act as outsourcers for our company, in their capacity as external data processors.
6. To whom we disclose your data
Without your express consent (Art. 24[a, b, d] of the Data Protection Act and Art. 6[b, c] GDPR), we may disclose your data for the purposes of Art. 2A) to supervisory bodies (such as IVASS), legal authorities, insurers for the provision of insurance coverage, and any other parties to whom disclosure is mandated by law or compulsory for the stated purposes. These parties will process your data in their capacity as independent data controllers. They will not disclose it to others.
7. How your data may be transferred
Your data is stored on servers located in the European Union: at our offices at Via dei Gracchi 26 in Milan and at Via F.lli Rosselli 5 in Laveno Mombello (VA). If necessary, we may move the servers elsewhere, including outside the European Union. Should this occur, we assure you that your data will be transferred in accordance with the law, under standard contracts required by the European Commission.
8. What if you decline to provide your data?
Your data for the purposes of Art. 2A) is required. If you decline to provide it, we will be unable to furnish our services. For the purposes of Art. 2B), providing your data is optional. You can decide not to provide any data or ask that data you have already provided no longer be processed; in this case, you will be unable to receive newsletters or direct marketing materials about our products and services.
9. Your data rights
Pursuant to Art. 7 of the Data Protection Act and Arts. 15-21 GDPR, you have the right to:
- receive confirmation as to whether we are processing any of your personal data;
- obtain the following information from us: a) how we obtained your data; b) how and for what purposes it is processed; c) the logic involved if your data is processed using electronic means; d) information identifying the data controller, data processors and designated representative pursuant to Art. 5(2) of the Data Protection Act and Art. 3(1) GDPR; e) the persons or categories of persons to whom your data may be disclosed or who may learn of it in their capacity as designated representative in Italy, data processors or processing personnel; f) (if possible) how long we will store your data;
- demand that we: a) update, correct, or supplement your data; b) delete, anonymize, or block your data if unlawfully processed, or if kept unnecessarily given the purposes of collection or subsequent processing; c) certify that we have notified anyone to whom we have disclosed your data of the changes you have requested per letters a) and b), unless this is impossible or requires disproportionate effort;
- deny consent, in whole or in part, to: a) the processing of your data, if you have reason to do so, even if it was collected for the stated purposes; b) the processing of your data for the purposes of sending direct marketing materials or conducting market research, using automated call systems, e-mail, telemarketing or traditional mail. Note that denied consent as per point b), for direct marketing using automated systems, also extends to traditional means of communication and that you may also exercise this right only in part. Therefore, you may decide to receive communications by traditional means only, by automated means only, or neither.
Where applicable, you also have the rights specified in Arts. 16-21 GDPR (rectification, erasure, restriction of processing, data portability, right to object), as well as the right to make complaints to the Data Privacy Regulator.
10. How to exercise your rights
You may exercise your rights at any time by sending an e-mail to: firstname.lastname@example.org
11. Data controller, data processor and processing agents
S.A. Studio Santagostino s.r.l. (Tax ID and VAT no. 02560320158)
- registered office: Via delle Stelline 1, Milan, Italy
- operating premises: Via dei Gracchi 26, Milan, Italy; Via Fratelli Rosselli 5, Laveno Mombello (VA), Italy
An up-to-date list of data processors and processing personnel is kept at our registered office.