Privacy policy for person discharging managerial responsibilities

In addition to what is already specified in the Policy Privacy, in accordance with art. 13 and 14 of the Regulation, Openjobmetis S.p.A. in its capacity as Controller (hereafter the “Company” o the “Controller”),, hereby informs you that your personal data will be subject to processing in compliance with the above mentioned regulations and confidentiality obligations, according to the principles of fairness, lawfulness and transparency, on which the activities of the Company are modelled.

 

In this regard, the Controller will process personal data by adopting all the measures required to ensure the adequate security and confidentiality of the data, including in order to block unauthorised access or use of personal data and the tools through which the processing is carried out.

  1. Purposes and legal basis for processing

Your data will be processed for: a) the purpose of managing the relationship established with the Company, b) the fulfilment of the obligations of the Company itself, including - and especially - the effects of the status of issuer listed on the MTA of the Italian Stock Exchange and compliance with the Corporate Governance Code for Listed Companies, and c) the purpose of producing the documentation required in relation to activities and/or procedures of interest to the Company, including, for example, accreditations, tenders (ref. Article 2-octies of the Privacy Code) and the like.

The legal basis for such processing is the carrying-out of obligations deriving from laws, regulations, Italian and/or EU legislation, as well as obligations deriving from provisions issued by authorities empowered to do so by the law.

  1. Categories of data subject to processing

The Company will process, for the purposes referred to in paragraph 2 above, your personal and/or legal data as defined in Articles 4 and 10 of the Regulation (hereinafter, collectively, the “Data”).

  1. Data origin

The Company will acquire the Data directly from the data subject who person discharging managerial responsibilities of the Company; the Company may also acquire from the same subject the Data of the persons referring to him/her latu sensu - as communicated by him/her by virtue of the obligations and provisions referred to in paragraph 1) above.

  1. Communication of data to third parties

The Data provided will not be disclosed, but may be communicated, for the purposes and with the methods outlined in this Privacy policy, to the categories of subjects specified below:

  • customers to whom activities and/or procedures of interest to the Company refer (for example, accreditations, tenders, and the like);

  • companies, partners, consultants or freelance professionals used by the Company to carry out technical or organisational tasks (such as, for example, suppliers of IT services), or with whom the Company works for the purposes of the provision and operation of its services, or for any communication activities;

  • persons, companies or professional firms that provide support and consultancy to the Company, with a particular but not exclusive reference to accounting, administrative, legal, tax and financial matters;

  • subjects whose right to access the Data is recognised by legal provisions or by orders of the authorities.

Subjects belonging to the above categories will use the data as independent data controllers in accordance with the law or as data processors duly appointed by the Company.

These subjects may be established in Italy and/or EU countries.

  1. Personal data retention

Your 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. 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 the fulfilment of all obligations connected to or deriving from the conclusion of the contract, 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.

  1. Rights

You can exercise the rights set out by the Regulation in those cases expressly provided for by the law and where applicable. In particular, You have the right to:

  • ask for confirmation that there is ongoing processing of Your 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 You 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 Your consent at any time, without prejudice to the lawfulness of the processing carried out before the withdrawal based on consent.

 

You also have the right to completely or partially oppose the processing of Your 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, You have the right to submit a complaint to the Italian Data Protection Authority (www.garanteprivacy.it).

  1. Controllers

The Controller is Openjobmetis S.p.A. with registered office located at Via Assietta 19, Milan, Italy.

  1. 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).

 

This section of the Privacy Policy has been adopted on 20 March 2019