Privacy Policy

PRIVACY INFORMATION STATEMENT

Pursuant to Art. 13 of Regulation (EU) No. 679/2016 on the protection of individuals with regard to the processing of personal data (hereinafter referred to as “GDPR”), we inform you that the processing of the personal data provided by you in concluding the aforementioned contract or in any case acquired by Movi during its negotiation, conclusion and performance (hereinafter referred to jointly as the “Data”) will be based on the principles of fairness, lawfulness and transparency and the protection of your confidentiality and your rights. In compliance with the GDPR, we provide you with the following information:

1. Data Controller
   The Data Controller is Movi S.p.A. (with registered office in Via Dione Cassio no. 15 – 20138 Milan, e-mail privacy@movigroup.com, PEC [certified e-mail] amministazione@pec.movigroup.com, fax 02/5061048) (hereinafter “Movi”, the “Controller” or “We/Us”). Movi is responsible to you for the lawful and fair processing of your Data.
2. Purpose and legal basis of the Data Processing
   The Data will be processed by us within the limits and in the manner provided for by the GDPR and, insofar as necessary, by (It.) Legislative Decree no. 196/2003 as amended and supplemented (hereinafter “Privacy Code”) exclusively to:
   i) perform the contract, to which you and/or the Company on whose behalf you act is a party, pursuant to Art. 6 letter b) of the GDPR; ii) comply with legal obligations arising from the performance of the contract, pursuant to Art. 6 letter c) of the GDPR;
   (iii) ascertain, exercise or defend a right of ours in a court of law, where this is rendered necessary by disputes relating to the contract or business relationship between Movi and you or the company on whose behalf you have dealings with Movi. In this case, the processing of the Data will be based on our legitimate interest, pursuant to Art. 6 letter f) of the GDPR, over which we consider that the interests or fundamental rights and freedoms of the data subjects to whom the Data relate do not prevail.
   For all the purposes described above, the processing of Data may also take place without the consent of the data subject.
3. Recipients of the Data – Transfer of the Data to Third Countries or international organisations
   The Data may be made accessible to third parties, appointed by us as Data Processors, who will process the Data on our behalf only to the extent strictly necessary for the pursuit of the purposes set out in point 2 above (including commercial agents, shipping companies, suppliers of IT services or maintenance of the database where the Data will be stored). The Data Processors may process the Data directly or through employees/collaborators appointed to carry out the activities that these external parties perform on behalf of the Data Controller. The updated list of Data Processors will be made available upon simple request to Movi to be sent by e-mail to the address indicated in point 6 below.
   The Data may also be disclosed by us to third parties, who will act as autonomous Data Controllers, such as Bodies, Public Offices or Public Administrations, where required by law or necessary to perform the contract. The Data will also be processed by all those designated by us as data processors, including our employees in charge of the sales department, as well as of the management of information systems, including system administrators.
   The Data will not be disseminated or transferred to third countries (i.e. outside the European Economic Area) or international organisations.
4. Processing methods – Data retention time
   The Data will be processed by both paper and computerised means.
   The Data will be retained for the period strictly necessary to pursue the purposes set out in point 2 above – i.e. for the entire duration of the contract – without prejudice to longer retention periods prescribed by law (e.g. for keeping tax and accounting documents) and/or necessary for the exercise or protection of our rights in court, in compliance with the statute of limitations provided for by the applicable law. Once the contract is terminated, the processing of the Data will consist exclusively in the retention thereof, except in cases where the Data must be examined or consulted as a consequence of or in anticipation of legal action or to comply with a legal obligation.
   Upon expiry of the aforementioned time limits, the Personal Data will be automatically erased or anonymised.
5. Compulsory or optional nature of the provision of Data – Consequences of a possible refusal
   The provision of Data for the purposes set out in point 2 is optional, but without them we will be unable to conclude the contract.
6. Rights of the data subject
   Pursuant to Articles 13, paragraph 2, letters b), c) and d), 15, 16, 17, 18, 19, 20 and 21 of the GDPR, we inform you that:
   a)You have the right to request access to the Data concerning you together with indications as to the purpose of the processing, the category of Data processed, the entities or categories of entities to whom the Data have been or will be disclosed (with an indication of whether such entities are located in third countries or are international organisations), when possible the period of retention of the Data or the criteria used to determine such period, the existence of your rights to rectification and/or erasure of the Personal Data, to restriction of processing and to object to the processing, your right to lodge a complaint with a supervisory authority, the origin of the Data, the existence and the logic applied in case of automated decision making. If you exercise this right, and unless otherwise stated by you, you will receive an electronic copy of your processed Data.
   
   
   b)You are also entitled to obtain

1. the rectification of your data if they are inaccurate or incomplete;
2. the erasure of your data if one of the conditions set out in Art. 17 of the GDPR is met (e.g. your Data are no longer necessary in relation to the purposes for which they were collected, you decide to withdraw your consent to the processing – where this is the legal basis – and there is no other legal basis for the processing, you object to the processing and no other legitimate interest of the Data Controller prevails, your Data are processed unlawfully);
3. the limitation of the processing of Data concerning you 1) for the time necessary for Movi to ascertain the accuracy of your Data (in case you have contested it), or 2) if the processing of your Data is unlawful and you request, instead of the erasure of your Data, the limitation of the relevant processing, or 3) when Movi no longer needs your Data but they are necessary for you to ascertain, exercise or defend a right in court, or, lastly, 4) for the time necessary to assess whether the Controller’s legitimate reasons prevail over yours, if you have opposed the processing of your Data in accordance with point c) below;
4. your Data in a structured, commonly used and machine-readable format, also for the purpose of transmitting them to another data controller, if the processing is based on consent or on a contract and is carried out by automated means (right to data portability). If it is in your interest, you may ask Movi to transmit your Data directly to the other data controller, if this is technically feasible.

c)You also have the right to object to the processing of your Data, if such processing is carried out pursuant to Art. 6.1 letter e) (i.e. to comply with a legal obligation to which the Controller is subject) or letter f) (i.e. to pursue a legitimate interest of the Controller) of the GDPR, unless there are compelling legitimate grounds for the Controller to process the data, pursuant to Art. 21 of the GDPR.

d) If you are dissatisfied with the processing of your Data by us, you may lodge a complaint with the Italian Data Protection Authority, following the procedures and indications published on the official website of that authority (www.garanteprivacy.it.).

e)Any rectification or erasure of your Data or limitation of processing carried out at your request – unless this proves impossible or involves a disproportionate effort – will be communicated by us to each of the recipients to whom your Personal Data may have been transmitted in accordance with this information statement.
The exercise of the above rights is not subject to any formal constraints and is free of charge. We may only ask you to verify your identity before taking further action on your request.

In order to exercise your rights, you may contact Movi by sending a communication to the Controller at the addresses indicated in point 1 above.

JOB APPLICANT PRIVACY POLICY (ART. 13 OF REG. 2016/679)

PURPOSE OF THE PROCESSING:

The personal, identifying data, the data included in the CV, as well as any sensitive data, collected from the data subject or from third parties whose services the Data Controller uses for selection procedures, are processed and used to fulfil the data subject’s request and, more specifically, to verify the prerequisites for recruitment and/or for starting a collaboration. The collection will concern only common data; therefore the applicant will not be required to indicate so-called particular data, as qualified by Art. 9 of Reg. 2016/679 or data on health status.

This is without prejudice to the hypothesis that the data in question must be known on account of the employment relationship being established, with particular reference to the possibility that the Data Subject may belong to protected categories and to any pre-employment medical examinations

MODE OF PROCESSING: The data are processed by computer, telematics and paper means.

NATURE OF PROVISION AND CONSENT:

The provision of the data is optional and it is up to the applicant to submit his or her curriculum vitae. With regard to the data subsequently and possibly requested by the Controller, failure to provide such data makes it impossible to proceed with the verification of the prerequisites for recruitment and/or for the start of the collaboration and, therefore, with the possible establishment of the relationship with the Controller.

Consent to processing is not required under Art. 24 of (It.) Legislative Decree no. 196/2003 as amended and supplemented (Art. 9 letter b of Reg. 2016/679), insofar as the processing relates to data contained in CVs voluntarily submitted by the Data Subjects for the purposes of the possible establishment of an employment/collaboration relationship. The same applies to any sensitive data transmitted in the same manner by the Data Subject, for which consent is excluded by Art. 26 of (It.) Legislative Decree no. 196/2003 as amended and supplemented, paragraph 3, letter B-bis).

A specific consent to data processing will be obtained at the time of the interview to the personnel who will be invited.

DISCLOSURE AND DISSEMINATION:

The data collected will not be divulged. The data may be disclosed to third parties identified and appointed pursuant to Art. 29 of Reg. 2016/679 if necessary for the stated purposes (e.g. selection and assessment companies);

RETENTION TIMES:

The data will be retained by the Controller until and no later than five years after their collection, unless the employment and/or collaboration relationship is established.

RIGHTS OF THE DATA SUBJECT: you may at any time exercise your rights vis-à-vis the data controller by contacting the Director of Human Resources, i.e. to request (for example) confirmation of the existence of your data, their origin, purpose, updating, deletion, or to exercise your right to object.

CONTROLLER AND PRIVACY NOTICES:

The Controller is Movi SpA Tax Code/VAT no.:11575580151 – Via Dione Cassio 15, 20138 Milan, privacy@movigroup.it

DATE ON WHICH THE INFORMATION STATEMENT WAS LAST UPDATED:2 May 2018