The Companies ACTL and Recruit Srl (hereinafter the Companies), in their capacity as Joint Data Controllers, with registered offices at Via Duccio Di Boninsegna, 21 Milan, Italy, and Via Alvise Cadamosto 7, Milan, Italy, through the sites www.actl.it, www.sportellostage.it, www.recru.it e www.jobfarm.it, have as their objective the protection of the privacy of their users and are committed to ensuring that the processing of personal data is carried out in accordance with principles of fairness, lawfulness, transparency and with respect for the rights, fundamental freedoms and dignity of persons, with particular reference to confidentiality and personal identity.

In providing our services, we necessarily come into possession of personal information and data: we intend, therefore, below, to outline an appropriate disclosure in accordance with Art. 13 GDPR 679/16 – “European Data Protection Regulation.”

It should be noted from the outset that, at any time, a request may be made for the modification or deletion of the data entered by writing to the e-mail info@sportellostage.it and info@recru.it and more generally the exercise of the rights provided by the GDPR 679/16 to which, if possible will be implemented, as further detailed in Section 9.

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1. What data we process The personal data processed vary depending on the service requested by the data subject. These data are: biographical data, data in the CV and video presentation (if any), results of training activities, and other data that the person concerned makes available (possibly also special data). Therefore, interested parties are asked to make available (e.g., in the CV) only the data of interest for the evaluation of the application. Contact information is provided or received by the data subject in connection with:

• Enrollment in the Job Farm Go portal within the sites mentioned above;
• Application, application for selection for job/internship offers (which may also include a video of the candidate(s));
• Application, enrollment, possible selection to courses including funded courses;
• Requests from the interested party.
• Direct contacts obtained as a result of attending events, etc;
• Direct contact as a result of sending inquiries via the e-mail address on the websites;
• Response, by the data subject, to advertisements posted on job board portals used by the Holders;
• Response to inquiries received through phone calls or emails;
• Business inquiries;
• Requests through the above websites or through the website of suppliers, customers, partners, other parties;
• Transmissions and transactions following the order to provide the service or good (supplied/purchased);
• Invitations to events related to business initiatives, fairs, events, etc.

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2. For what purposes: The Companies, through the sites www.actl.it, www.sportellostage.it, www.recru.it and www.jobfarm.itcollect information and personal data when registering on the sites and when subsequently changing them (such as, in relation to the purpose of processing, first name, last name, e-mail address, telephone number, address of residence/domicile, Tax Code, professional qualification, other data inferable from the CV), for the following purposes:

• 1.Collection and dissemination of resumes and possible video presentation of the candidate, for matching the demand and supply of internship/job;
• 2.Information, possible selection and enrollment in training courses;
• 3.Carry out statistics and market research in order to better understand users’ needs and to be able to optimize the service provided. In that case, the data will be used anonymously.
• 4.Sending information materials on the topic of employment and training and the services provided by ACTL and Recruit and subscription to specific services (by way of example but not limited to newsletters)
• 5. Management of any litigation and protection of the rights of ACTL and/or Recruit;

registration for the services presupposes in each case the acknowledgement and acceptance of the terms of use and privacy policy of the Companies.
The data subject may refuse to give the Companies his or her personal data for purposes 1, 2, 3 and 5. Any refusal to provide, and consequently failure to register, will result in the inability, in whole or in part, to provide services.
Failure to consent for purpose 4 does not preclude the provision of the service.

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3. Legal basis and target subjects: The data will be disclosed, as further detailed in Section 6, to the employees/collaborators of the Companies, their suppliers to the customer, the internship host companies and those offering job/internship opportunities, the partner, other parties who will have to contact the data subjects to enable, in accordance with Art. 6.1, lett. b), (c) (processing for the purpose of the performance of a contract or pre-contractual measures or to comply with a legal obligation) of the GDPR:

• Service delivery;
• The execution of the contract to which each party is a party;
• The execution of pre-contractual or post-contractual measures taken at the request of the supplier, customer, partner, other parties or the Companies pursuant to Art. 6.1(b) of the GDPR;
• The fulfillment of a legal obligation under Art. 6.1(c) of the GDPR)
• All related tax and accounting requirements, as well as managers of portals in order to promote the services provided

For purpose 4, the legal basis is consent under Art. 7.

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4. How we treat data: The data of the interested parties will be processed in accordance with the principles of lawfulness correctness and transparency, using manual or automated tools, including through the inclusion in databases, lists and lists suitable for the storage, management and transmission of data, in the manner and to the extent necessary for the pursuit of the aforementioned purposes.
   Processing will be carried out in the following ways:

• Operations of recording, organization, storage, processing, modification, use, dissemination and deletion of data;
• Communications and data releases.
• Dissemination of data is limited to those necessary to deliver the service aimed at matching supply and demand for internships/jobs

The Companies have provided adequate security measures in order to protect the data of individuals acting on behalf of suppliers, customers, partners and others, such as: firewalls, antivirus, high complexity passwords with periodic change.
The personal data being processed will be kept in such a way as to minimize, through the adoption of appropriate technical and organizational measures, as well as suitable and preventive security measures, the risks of destruction or loss, even accidental, of the data themselves, of unauthorized access or processing that is not permitted or does not conform to the purposes of the collection previously explained.

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5. Why the nature of the provision of data is mandatory: For purposes 1 and 2, the provision of such data is mandatory in order to take advantage of the services offered by the Companies provided in point 2.
Finally, the Companies may use the personal data collected (subject to specific authorization) for statistical purposes or to conduct market research, anonymously, in order to better understand the needs of users and to be able to optimize the service offered (purpose 3). It should be noted that said market research and studies will be conducted using anonymous data.

For purpose 4, data are processed with prior consent; while for purpose 5, the legal basis is the legitimate interest of the Holders and for compliance with legislation.

Regarding the request for the video presentation of the person concerned, referred to in purpose 1, it is not to be considered binding, but an opportunity offered to the job/internship applicant, in order to better present his or her application. The video is not released, but will only be communicated to companies interested in evaluating the candidate’s profile; no other use is intended. The candidate must follow the guidelines that will be provided to him/her during the post-application contact phase; the Holders reserve the right to withhold the video at their sole discretion.

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6. What are the categories of individuals to whom the data may be disclosed: For purpose 1 the data may be disclosed to companies, institutions, institutes and organizations that use the services offered by the Companies both on the Italian territory and abroad for the purpose of selection and promotion of internships and jobs, in the case of enrollment in training activities or selection the data may be disclosed to partners, financing institutions.
   For all purposes they may, then, be communicated to the workers of the Companies and to some external parties that collaborate with them, always in compliance with the indicated purposes mentioned in point 2. Specifically, these are employees/collaborators who, on the basis of their roles and work duties, have been legitimized to process personal data, trained to do so within the limits of their competencies and in accordance with the instructions given to them by the Controller.

The data could be accessed (for purposes of assistance on software applications, computer network and connectivity) by technicians, external consultants or appointees of external companies that provide such services; individuals who carry out control activities on the work of the Companies (by way of example: Auditors, Supervisory Board, personnel of certification bodies, etc.). Finally, they may be communicated to the subjects entitled to access them by virtue of provisions of the law, regulations, and EU regulations. The updated list of data processors, where required, is available at the offices of the above-mentioned Companies.
The Companies, through the sites www.sportellostage.it, www.recru.it, www.jobfarm.it and go.jobfarm.it may disclose personal data collected to third parties only for purposes strictly related to the services provided.
The data provided may therefore be disclosed to:

• Professionals, companies or professional firms that, on behalf of the Companies, carry out consulting, assistance, accounting and tax management activities
• Third-party companies to fulfill contractual obligations
• Banking institutions for handling payments arising from the execution of the contract.
• Other online recruiting portals with which the Companies have active partnerships in order to promote the search for required positions
• Companies engaged in transmission, enveloping, transportation, sorting and delivery of communications and correspondence for third parties.

Limited to the video presentation, which may have been prepared by the data subject, the data will be managed with the help of the www.box.com platform ; any changes in the platform used will be communicated through the change in this policy.

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7. Transfer of data abroad: Although at present all entities that process data on behalf of the Companies as external data controllers are established within the European Union or declare compliance with the GDPR, in the future it may also be necessary to give such data to entities that may be established outside the European Union, in countries that do not guarantee personal data an adequate level of protection under the European Data Protection Regulation RE. EU 679/2016. The Companies will, if necessary, transfer data outside the European Union only after taking the precautions established by the European Regulation and after obtaining the necessary guarantees from the indicated parties and with the consent of the data subjects.

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8. How long we keep data:

The Companies retain and process personal data for as long as necessary to fulfill the stated purposes. Thereafter, personal data will be stored, and not further processed, as documented in the Processing Record. The retention period can vary significantly depending on: the purposes, the type of data processed, and legal obligations. In the event that the data are processed as part of a funded project, retention times may be subject to the requirements of the funding body’s announcement.
When it is no longer necessary to retain personal information it will be deleted or de-indexed or securely destroyed in accordance with our privacy policy.

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9. What Rights Can Be Exercised: Pursuant to Articles 15 through 22 of the Regulations, the Data Subject is entitled to and may, when applicable, exercise the following rights:

The same, where exercisable by you may be enforced by writing to info@sportellostage.it, info@recru.itspecificando, the subject of the request, the right that the interested party intends to exercise and attaching a photocopy of an identity document attesting to the legitimacy of the request.

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10. Co-ownership agreement: The data subject has the right to access the essential contents of the co-ownership agreement between the parties, subject to verification of the legitimacy of the request.
11. Proposition of complaint: The data subject has the right to file a complaint with the supervisory authority of the state of residence. More information on the right to file a complaint can be found at the following webpage: www.garanteprivacy.it
12. Data Protection Officer:Believing that the protection of personal data of data subjects is of paramount importance, the Companies have appointed a Data Protection Officer (DPO) who can be contacted by writing to the email address dpo@actl.ite dpo@recru.it for any issues concerning the protection of personal data.

Update to March 2022