Information on data protection in accordance with the GDPR, EU Reg. 679/2016 (L.D. 101/2018)

Pursuant to the combined provisions of European Regulation 2016/679 (General Data Protection Regulation, hereinafter “GDPR”) and Legislative Decree 196/2003 as amended (Legislative Decree 101/2018)

 

General Index

  1. INTRODUCTION:………………………………………………………………………………………………………………….. 1
  2. OBJECT, PURPOSE OF PROCESSING, LEGAL BASIS AND NATURE OF PROVISION,TYPES OF DATA PROCESSED AND DATA RETENTION PERIODS 2
  3. PROCESSING METHODS AND HOW DATA ARE COLLECTED…………………………………………………………….. 10
  4. ACCESS TO DATA BY PROCESSING EMPLOYEES…………………………………………………………………………… 10
  5. COMMUNICATION OF PERSONAL DATA……………………………………………………………………………………. 10

6.THIRD-PARTY WEBSITES……………………………………………………………………………………………………….. 12

  1. PERIOD OF RETENTION OF PERSONAL DATA (SO-CALLED DATA RETENTION)………………………………………. 12

8.COOKIE BANNER TEXT………………………………………………………………………………………………………….. 12

9.EXTRA EU/US TRANSFER……………………………………………………………………………………………………….. 12

10.RIGHTS OF THE DATA SUBJECT……………………………………………………………………………………………… 13

  1. OPPOSITION TO PROCESSING AND WITHDRAWAL OF CONSENT……………………………………………………. 13
  2. WAYS OF EXERCISING RIGHTS………………………………………………………………………………………………. 14
  3. AMENDMENTS TO THIS POLICY……………………………………………………………………………………………. 14
  4. MATERIALS…………………………………………………………………………………………………………………….. 14
  5. PROCEDURE FOR REVOCATION OF CONSENTS ON DATA PROCESSING…………………………………………….. 14
  6. DEFINITIONS AND LEGAL REFERENCES……………………………………………………………………………………. 15
  7. ACCEPTABLE USE POLICY FOR WEBSITE USERS…………………………………………………………………………. 16

18.LIST OF COOKIES USED BY THIS WEBSITE…………………………………………………………………………………. 17

 

1. INTRODUCTION:

The data controller is.

OPEN CREW S.R.L. headquartered in MILAN (MI) VIA RAFFAELLO SANZIO 16 CAP 20149 – P.IVA: 12961650962 – REA Number: MI – 2695267 – opencrewsrl@pec.it  –robin.rossi@opencrew.it  – www.opencrew.it

 

The company always considers of primary importance the protection of the personal data of its customers and users, to whom they ensure the processing of personal data in full compliance with the protections and rights recognized by the EU Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter also referred to only as the “Regulation“) and in general by the entire legislation on the protection of personal data.

In Art. 4 point 1) of the Regulation we find the definition of “personal data” as “any information relating to an identified or identifiable natural person; an identifiable person is considered to be any natural person who can be identified, directly or indirectly, by reference in particular to an identifier such as a name, an identification number, location data, an online identifier, or to one or more characteristic elements of his or her physical, physiological, genetic, mental, economic, cultural or social identity” (hereinafter referred to as “Personal Data“). And therefore, the data controller, in pursuit of its business purposes, may become aware of or request Personal Data from you, such as your first and last name, your e-mail address, your telephone and postal contact information, your Tax Identification Number or VAT number, your date of birth, and other identifying information about you.

The Regulations provide for the issuance, prior to the processing of Personal Data – by which term is to be understood, according to the relevant definition in Art. 4 under 2) of the Regulation, “any operation or set of operations, performed with or without the help of automated processes and applied to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, communication by transmission dissemination or any other form of making available, comparison or interconnection, restriction, deletion or destruction” (hereinafter the “Processing“) – adequate information to the person to whom such Personal Data belong about the purposes of the Processing, the manner in which the Processing will be conducted as well as in relation to as much other information as is required by law.

In this regard, the contents of this notice are intended to provide you, in a simple and intuitive manner, as much information as possible to supplement the information contained in the specific privacy notices rendered in accordance with Article 13 of the Regulations at the time of the provision and collection of your Personal Data.

This Information Notice, therefore, has been prepared, on the basis of the principle of transparency, precisely to provide all the elements required by Articles 13 and 14 of the Regulations, and, in deference to a principle of absolute ease of consultation, is divided into individual sections (hereinafter “Sections” and individually “Section”), each of which deals with a specific topic so as to make it quicker, easier and more intuitive for you to read (hereafter, the contents of this Internet page will be referred to jointly and briefly as “Information Notice“).

 

The purpose of this privacy policy (hereinafter “Privacy Policy“) is to describe the management methods – as to the processing of personal data of users/visitors in accordance with the Regulations (hereinafter only “Users“) – of the websites and Apps owned by the companies of the data controller, which are listed below:

 

www.opencrew.it

 

The data controller, in compliance with privacy regulations and according to the guidelines described in the Privacy Policy, intends to ensure the protection and security in the processing of personal data of each User of the Internet Sites, which include Cookies, usage data, e-mail addresses, first and last name, telephone number, and home/residence addresses.

In any case, even in the absence of a specific Privacy Policy pursuant to art. 13 of the Regulations, the Privacy Policy will be valid as a document capable of providing the proper indications referred to in articles 13 and 14 of the Regulations, for all Users of the Internet Sites who find themselves interacting with the Data Controller in order to take advantage of the services offered by the same Internet Sites.

 

 

2. OBJECT, PURPOSE OF PROCESSING, LEGAL BASIS AND NATURE OF PROVISION,TYPES OF DATA PROCESSED AND DATA RETENTION PERIODS

 

With regard to the data processed by this website with respect to users, the processing carried out by the owner is as follows:

  •  

 

ACTIVITIES

PURPOSE OF PROCESSING

LEGAL BASIS AND LAWFULNESS OF PROCESSING AND NATURE OF CONFERRAL

TYPE OF DATA PROCESSED

STORAGE TERMS

a

NAVIGATION

1) To enable the enjoyment and use of this website, as well as to carry out maintenance and technical support necessary for its proper functioning;

 The legal basis underlying the processing referred to in (a) of this point is provided for in Art. 6 par.1(f) GDPR, which states that “processing is necessary for the purposes of pursuing the legitimate interests of the data controller or a third party”.

The Processing of your Personal Data will be legally based on the contractual relationship that will be created between you and the Data Controller as a result of your interaction with the specific website of the Professional Practice;

-navigation data: this category of data includes IP addresses or domain names of the computers and terminals used by users, addresses in URI/URL (Uniform Resource Identifier/Locator) notation, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and computer environment. These data, necessary for the use of web services, are also processed for the purpose of:

-obtain statistical information on the use of services (most visited pages, number of visitors by time slot or daily, geographical areas of origin, etc.);

-check the proper functioning of the services offered.

-data communicated by the user: such as, for example, personal data given through the “contact” form or data given in the “Contact” section.

-cookies and other tracking systems: for details of the cookies used by the data controller’s website, please refer to the section on cookies in the data protection notice on the data controller’s website.

In particular, it is specified that the data processed by means of the website are:

Derived data

Information that our servers automatically collect when you access the Site, such as your IP address, browser type, operating system, access times, and the pages you viewed directly before and after accessing the Site.

Facebook Permissions

The Site can, by default, access basic Facebook account information, including name, email, gender, birthday, current city, and profile picture URL, as well as other public information.

Data from social networks

User information from social networking sites, Facebook, Google+, Linkedin, and other social networks,including name, social network username, location, gender, date of birth, e-mail address, profile photo, and public contact information, if the user links their account to such social networks.

Third-party data

the site currently makes no data submissions to third parties not affiliated with the owner

Data retention time depends on the retention time of individual cookies

b

RESPONSE BY THE OWNER TO USER REQUESTS

2) allow the Owner to respond to requests you make through this website

 The legal basis underlying the processing referred to in (a) of this point is provided for in Art. 6 par.1(f) GDPR, which states that “processing is necessary for the purposes of pursuing the legitimate interests of the data controller or a third party”.

The Processing of your Personal Data will be legally based on the contractual relationship that will be created between you and the Data Controller as a result of your interaction with the specific website of the Professional Practice;

-data communicated by the user: such as, for example, personal data given through the “contact” form or data given in the “Contact” section.

-cookies and other tracking systems: for details of the cookies used by the data controller’s website, please refer to the section on cookies in the data protection notice on the data controller’s website.

In particular, it is specified that the data processed by means of the website are:

Data from social networks

User information from social networking sites, Facebook, Google+, Linkedin, and other social networks,including name, social network username, location, gender, date of birth, e-mail address, profile photo, and public contact information, if the user links their account to such social networks.

 

Retention time depends on the time required to give response to the customer

  •  
  • With regard to the activities of the data controller
  • -with respect to users and customers, the data processing carried out by the owner is as follows:

 

ACTIVITIES

PURPOSE OF PROCESSING

LEGAL BASIS AND LAWFULNESS OF PROCESSING AND NATURE OF CONFERMENT

TYPE OF DATA PROCESSED

STORAGE TERMS

c

contract

The Data Controller, in order to enable the purchase of its products and/or services, as well as to follow up on your requests needs to collect some of your Personal Data, as requested within the subscription or purchase form

– Execution of pre-contractual measures taken at the request of the data subject and/or execution of a contract to which the data subject is a party (Art. 6(1)(b) GDPR).

The provision of data is optional in nature but in case of refusal to provide personal data it will not be possible for the Holder to provide the service

 

Identification and contact information:

 First name, last name, e-mail address, telephone number, Tax code, City, Country of residence, other data that may be provided by the customer.

 Data are kept for the duration of the contractual relationship and for 10 years after its conclusion

d

Legal obligations

 

Recording invoices, receiving payments;

 

– Fulfilling pre-contractual, contractual and tax obligations arising from the customer relationship;

– Fulfill obligations under the law, a regulation, EU legislation or an order of the Authority

 

 

-Legal obligation to which the owner is bound (Art. 6(1)(c) GDPR).

 

The provision of data is optional in nature but in case of refusal to provide personal data it will not be possible for the Holder to provide the service

 

 

Identification and contact information:

First name, last name, e-mail address, phone number, Social Security number, City, Country of residence

 Data are kept for the duration of the contractual relationship and for 10 years after its conclusion

e

Litigation defense

– Exercise the rights of the Owner, such as any right of defense in court.

–Legitimate interest of the data controller (Art. 6(1)(f) GDPR): right of defense fairly balanced with the same right of data subjects.

The provision of data is optional, but in case of refusal to provide personal data, it will not be possible for the Holder to provide the service

Identification and contact information:

First name, last name, e-mail address, telephone number, Tax code, City, Country of residence, and other data necessary for litigation

 Data are kept for the duration of the contractual relationship and for 10 years after its conclusion

f

Participation in events organized by the owner

the Data Controller, in order to allow you to participate in one of the events it organizes, needs to collect some of your Personal Data, as requested within the event registration form/form.

contractual purpose/legal obligations ex art. 6 letters b) and c) of the Regulations – the Processing of your Personal Data will be conducted by the Data Controller to register you for the event and ensure your participation and therefore will be legally based on the contractual relationship that will be created between you and the latter;

The provision of data is optional, but in case of refusal to provide personal data, it will not be possible for the Holder to provide the service

Identification and contact information:

 First name, last name, e-mail address, phone number, Social Security Number, City, Country of residence,

Data are kept for the time required to organize the event and for 24 put from the collection of data

g

Marketing

Activities of sending newsletters, commercial communications and marketing: the performance by the Data Controller of its own promotional and/or marketing activities towards you. This category includes all activities performed to promote products, services, sold and/or provided by the Data Controller; subject to your specific consent.

 -legitimate interest under Article 6 letter f) of the Regulations – The Processing of your Personal Data will be conducted by the Data Controller and will be legally based on its legitimate interest in promoting its products and services;

– consent of the data subject ex art. 6 letter a) of the Regulation – The Processing of your Personal Data will be conducted by the Data Controller and will be legally based on your free, express and unequivocal consent.

 

Identification and contact information:

 First name, last name, e-mail address, phone number, Social Security Number, City, Country of residence,

Data are kept for 24 months after data collection

 

-with respect to suppliers, the data processing carried out by the owner is as follows:

 

ACTIVITIES

PURPOSE OF PROCESSING

LEGAL BASIS AND LAWFULNESS OF PROCESSING AND NATURE OF CONFERMENT

TYPE OF DATA PROCESSED

STORAGE TERMS

j

contract

The Data Controller, in order to enable the purchase of its products and/or services, as well as to follow up on your requests needs to collect some of your Personal Data, as requested within the subscription or purchase form

– Execution of pre-contractual measures taken at the request of the data subject and/or execution of a contract to which the data subject is a party (Art. 6(1)(b) GDPR).

 

 

Identification and contact information:

 First name, last name, e-mail address, telephone number, Tax code, City, Country of residence, other data that may be provided by the customer.

Data are kept for the duration of the contractual relationship and for 10 years after its conclusion

k

Legal obligations

 

Recording invoices, receiving payments;

 

– Fulfilling pre-contractual, contractual and tax obligations arising from the customer relationship;

– Fulfill obligations under the law, a regulation, EU legislation or an order of the Authority

 

 

-Legal obligation to which the owner is bound (Art. 6(1)(c) GDPR).

 

The provision of data is optional, but in case of refusal to provide personal data, it will not be possible for the Holder to provide the service

 

 

Identification and contact information:

First name, last name, e-mail address, phone number, Social Security number, City, Country of residence

Data are kept for the duration of the contractual relationship and for 10 years after its conclusion

l

Litigation defense

– Exercise the rights of the Owner, such as any right of defense in court.

-Legitimate interest of the data controller (Art. 6(1)(f) GDPR): right of defense fairly balanced with the same right of data subjects

Identification and contact information:

First name, last name, e-mail address, telephone number, Tax code, City, Country of residence, and other data necessary for litigation

Data are kept for the duration of the contractual relationship and for 10 years after its conclusion

 

-with respect to employees and contractors, the data processing carried out by the owner is as follows:

m-The processing of personal data, including special data within the meaning and effect of Article 9 of the GDPR, including those of third parties, provided when entering into the contract of employment is carried out in accordance with the contract itself and/or the collective bargaining agreement for the sector, as well as in compliance with legal obligations.

 

The refusal to provide all or some of the requested data and/or the provision of partial and/or untrue data by the data subjects prevents the Data Controller from fulfilling its legal and contractual obligations, in particular the obligations of a welfare, social security nature, including in relation to the application for family allowances. In particular, the purposes are:

Ø    to fulfill obligations under the employment contract (e.g., to verify the exact performance, to commensurate the amount of pay, including overtime, or bonuses to be paid, to ascertain the existence of a legitimate cause for absence, to apply for family allowances, to quantify vacation and leave);

Ø    purposes stipulated in the sector’s collective bargaining agreement (e.g. to take advantage of union leave or expectations);

Ø    purposes stipulated by law: for communications and proxies to social security and welfare agencies, both public and private;

Ø    to fulfill accounting obligations (e.g., legally required entries and records) imposed on the employer;

Ø    Perform security auditing activities of the Owner’s IT systems to prevent unauthorized access or unauthorized communication and to protect the Owner’s corporate assets;

Ø    Fulfill obligations under the law, a regulation, EU legislation or an order of the Authority;

Ø    Exercise the rights of the Owner, such as any right of defense in court.

 

The legal basis that legitimizes the processing of data for the above purposes is the performance of a contract to which the data subject is a party (Art. 6 para. 1(b) GDPR), the fulfillment of legal obligations by the Data Controller (Art. 6 para. 1(c) GDPR) and the legitimate interest of the Data Controller (Art. 6 para. 1(f) GDPR) that is fairly balanced with the rights and freedoms of the data subjects.

The processing of special data revealing the health status of the data subject is necessary to fulfill the obligations and exercise the specific rights of the data owner or the data subject in the field of labor law and safety (Art. 9, no. 2 lett. b of the GDPR), as well as for occupational medicine purposes (Art. 9, no. 2 lett. h of the GDPR).

The provision of personal data is mandatory, as it is required for the fulfillment of legal and contractual obligations.

Failure to provide personal data will make it impossible for the Owner to establish and/or continue a working relationship or collaboration with the person concerned.

 

As for the purposes inherent in the preservation of corporate staff e-mail metadata they are:

Compliance with the consumer code in relation to customers, that is, to allow the fulfillment of customer requests in accordance with the regulations set forth in Legislative Decree No. 206 of September 6, 2005, as amended L.30/12/2023 No. 214;

·       security of IT systems and assets

·       Fulfillment of legal obligations and industry regulations;

·       defense at trial.

·       Verification of proper use of company resources and prevention of abuse or breach of contract

·       Ensure the proper functioning of electronic mail

 

The legal basis for data processing in this case is:

– the legitimate interest of the data controller: in accordance with European and national regulations, in order to ensure information security, and to carry out the assessment of the smooth running of business operations violations of company policy.

 

 

 

-with respect to applicants for job positions, the data processing carried out by the owner is as follows:

 

ACTIVITIES

PURPOSE OF PROCESSING

LEGAL BASIS AND LAWFULNESS OF PROCESSING AND NATURE OF CONFERMENT

TYPE OF DATA PROCESSED

STORAGE TERMS

n

Personnel selection

purposes related to the execution of pre-contractual negotiations:

Managing the process of selecting and evaluating candidates for inclusion in the corporate organization, including evaluating individuals to fill positions sought;

The Controller may process special data ex art. 9 GDPR such as but not limited to: health status, membership in protected categories, disability, or union membership, etc.

The legal basis legitimizing the processing of data for the purposes specified above is the execution of pre-contractual negotiations requested by the data subject is party (art. 6 no. 1 letter b) GDPR). In connection with the evaluation of the application, the Data Controller may also process special personal data under Article 9 GDPR, such as, but not limited to, those revealing health status or religious beliefs or trade union membership.

The legal basis legitimizing the processing in this case is the specific and informed free consent of the data subjects (Art. 6 No. 1 letter a) of the GDPR).  In case consent is not given, it will not be possible to evaluate the application.

Data subjects have the right to revoke their consent at any time, but processing carried out before revocation remains lawful. After revocation, the data controller will cease processing the data for which consent is required (Art. 7 No. 3 GDPR).

Curriculum vitae and the data contained therein:

 Contact information (such as, address, e-mail address, phone number, etc.);

Data on education, professional experience and previous activities;

Special categories of personal data (such as, for example, health status, union membership, etc.) only to the extent that such information is contained in the cv

Photo as it is on the cv

Processing is carried out in both manual and computerized ways and with the support of paper, computer (management software, accounting, etc.) or otherwise automated and telematic means.

In any case, the processing of data is carried out with the adoption of all appropriate measures to ensure the security and confidentiality of personal data, in particular in compliance with the security measures referred to in Article 32 of European Regulation No. 2016/679 and in accordance with the principles of lawfulness, necessity and proportionality.

Data processed are kept for 12 months after the last selection interview

 

 

Ø     

 

 

 

o

Legal obligation

Ø    Fulfilling obligations under the law, with reference to possible subsequent employment.

The legal basis legitimizing the processing of data for the purposes specified above is the fulfillment of legal obligations (Art. 6 No. 1 letter c) of the GDPR).

 Contact information (such as, address, e-mail address, phone number, etc.);

Data on education, professional experience and previous activities;

Data processed are kept for 12 months after the last selection interview

p

Litigation defense

Ø    Protection of the rights of the owner and exercise of the right of defense in case of litigation

The legal basis legitimizing the processing of data for the purposes specified above is the legitimate interest of the Data Controller (Art. 6 No. 1 letter f) of the GDPR), which in this case is fairly balanced with the rights and freedoms of the data subjects.

 Contact information (such as, address, e-mail address, phone number, etc.);

Data on education, professional experience, and previous activities; and data necessary for legal defense

Data processed are kept for 12 months after the last selection interview

 

 

3. PROCESSING METHODS AND HOW DATA ARE COLLECTED

The processing of your personal data is carried out by means of the following operations: collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, deletion and destruction of data.

The processing will be carried out either by manual and/or computerized and telematic means with logics of organization and processing strictly related to the purposes themselves and in any case in such a way as to ensure the security, integrity and confidentiality of the data themselves in compliance with the organizational, physical and logical measures provided for in Articles 24 and 25 and 32 of the GDPR.

The personal data subject to processing are collected directly by the Data Controller or by third parties expressly authorized by the Data Controller, or communicated by the Data Controller to such third parties for the pursuit of the purposes set forth in this policy.

The Data Controller carries out periodic checks so that no personal data are processed, collected, stored or retained that are not necessary in relation to the processing and related purposes as outlined in this policy.

 

4. ACCESS TO DATA BY PROCESSING EMPLOYEES

Your data may be made accessible for the exclusive purposes set forth in this notice:

-to employees and collaborators of the Controller, the auxiliaries and third persons employed companies and companies in supply and outsourcing relationship with the Controller in their capacity as authorized persons for processing and/or internal data controllers and/or system administrators;

-to third-party companies or other entities performing outsourced activities on behalf of the Controller, in their capacity as external data controllers.

 

5. COMMUNICATION OF PERSONAL DATA

Personal Data may be disclosed to specific parties considered to be recipients of such Personal Data, which should be understood to mean natural or legal persons, public authority, service or other body receiving communication of Personal Data, whether or not they are third parties.

With this in mind, in order to properly carry out all Processing activities necessary to pursue the purposes set forth in this Notice, the following Recipients may be in a position to process your Personal Data:

Third parties who perform part of the Processing activities and/or activities related and instrumental to the same on behalf of the Data Controller . These individuals have been appointed as data controllers, i.e., natural or legal persons, the public authority, service or other body that processes Personal Data on behalf of the Data Controller; individuals, employees and/or collaborators of the Data Controller, who have been entrusted with specific and/or more Processing activities on your Personal Data. Such individuals have been given specific instructions regarding the security and proper use of Personal Data and are defined as the “persons authorized to process Personal Data under the direct authority of the Data Controller or Data Processor.”

Where it is required by law or to prevent or suppress the commission of a crime, your Personal Data may be disclosed to public bodies or judicial authorities without, however, being defined as Recipients. In fact, the regulation states that public authorities that receive disclosure of Personal Data as part of a specific investigation conducted in accordance with Union or Member State law are not considered Recipients.

Without the need for express consent, the Data Controller may communicate your data for the above purposes to Supervisory Bodies, Judicial Authorities, insurance companies for the provision of insurance services, as well as to those subjects to whom the communication is compulsory by law for the fulfillment of the said purposes.

Specifically,data recipients may be:

  • -information and computer support companies;
  • -Companies, or professional firms offering professional and/or consulting services with respect to accounting, legal, tax, administrative, financial, and debt collection matters;
  • -Providers of IT infrastructure and solutions;
  • -Web service providers;
  • -Banks and payment service providers, acting as Processors, to whom your personal data may be disclosed for the purpose of processing your payments;
  • -consultants, to the extent necessary for the performance of their professional duties.

The communication concerns the categories of personal data whose transmission to the above-mentioned third parties is necessary for the performance of the activities and for the purposes referred to in this notice.

An up-to-date list of Data Processors and Authorized Persons is kept at the Data Controller’s office and is available upon request to be made by e-mail at

Some of these parties may process data in their capacity as autonomous data controllers.

Your data will not be disseminated.

Data communications may also relate to:

 

Law or exercise of rights

If the release of information is deemed necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share information as permitted or required by any applicable law, rule, or regulation. This includes sharing information with other entities for fraud protection and credit risk reduction.

 

Third-party service providers

The site shares information with third parties who perform services for the site or on our behalf, including data analysis, emailing, hosting services, customer service, and marketing support.

 

Cookies and web beacons

We may use cookies, web beacons, tracking pixels and other tracking technologies on the Site to help personalize the Site and improve your experience. When you access the Site, personal information is not collected through the use of tracking technologies. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action may affect the availability and functionality of the Site. Users cannot reject web beacons. However, they can be made ineffective by rejecting all cookies or by changing your web browser settings to notify you each time a cookie is offered, allowing you to accept or reject cookies on an individual basis. We may use cookies, web beacons, tracking pixels and other tracking technologies on the Site to help personalize the Site to improve your experience.

 

6.THIRD-PARTY WEBSITES

The site does not contain links to third-party websites and applications of interest, including external services, that are not affiliated with us.

 

7. PERIOD OF RETENTION OF PERSONAL DATA (SO-CALLED DATA RETENTION)

 

8.COOKIE BANNER TEXT

We value your privacy

We use cookies to improve your browsing experience, offer you personalized advertising or content, and analyze our traffic. By clicking “Accept All,” you consent to our use of cookies.

 

9.EXTRA EU/SEAS TRANSFER

In the management of the relationship with customers, there is no transfer of data to third countries nor to international organizations.

Should it become necessary to make transfers of personal data outside the territory of the European Union to countries not considered adequate by the European Commission, the Controller will ensure that appropriate or adequate safeguards are in place to protect personal data and that the transfer of such data complies with applicable data protection laws.

Any transfer of data subjects’ data to countries located outside the European Union will, in any case, take place in accordance with the appropriate and adequate safeguards for the purposes of the transfer itself, pursuant to the applicable legislation and in particular Articles 45 and 46 of the Regulations.

Accordingly, where required by applicable data protection laws, the Owner will ensure that service providers sign Standard Contractual Clauses approved by the European Commission.

  •  

10.RIGHTS OF THE DATA SUBJECT

In your capacity as a user you are entitled to the following rights:

-Right to access your data, obtain confirmation of the existence or otherwise of personal data concerning you, even if not yet registered, and their communication in intelligible form; -obtain indication of: (a) the origin of the personal data; (b) the purposes and methods of processing; (c) the logic applied in the case of processing carried out with the aid of electronic instruments; (d) the identification details of the data controller, data processors and the data controller’s representative and the persons authorized to process the data; and (e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of the data in their capacity as designated representative in the territory of the State, data processors or persons authorized to process the data; (Art. 15 GDPR).

-Right to update, rectify or, when interested, supplement data; (Art. 16 GDPR).

-Right to erasure, transformation into anonymous form or blocking of data processed in violation of the law, including data whose retention is not necessary in relation to the purposes for which the data were collected or subsequently processed ; (art. 17 GDPR).

-Right to request the restriction of use of data for the sole reasons of public interest and for the establishment or defense of a right, in cases where the data subject disputes the accuracy of the data and processing, in the case of exercising the right to object to processing under Article 21 GDPR, and in the other cases provided for in Article 18 GDPR; (Article 18 GDPR).

-Right to receive the personal data provided to the data controller in a structural format or on a commonly used, intelligible and accessible computer medium for any operating system (USB or duly encrypted ZIP file), and to move without constraints, the complexes of information and data concerning you from the present controller or another controller chosen by you in accordance with your purposes and in full compliance with the principles of transparency, lawfulness and proportionality of processing.  This right to data portability is without prejudice to other rights; (Art. 20 GDPR).

-Right to object, in whole or in part:

  1. a) on legitimate grounds to the processing of personal data concerning you, even if relevant to the purpose of collection; b) to the processing of personal data concerning you for any other purpose not relevant to the processing; (Art. 21 GDPR).

 

11. OPPOSITION TO PROCESSING AND WITHDRAWAL OF CONSENT

As provided for in the Regulations, if you have given your consent to the Processing of your Personal Data for one or more of the purposes for which you have been requested, you may, at any time, withdraw it in whole and/or in part without affecting the lawfulness of the Processing based on the consent given before the withdrawal.

The ways to revoke consent are very simple and intuitive, you just need to contact the Data Controller and/or the Co-Processor companies using the contact channels reported to you within this Policy.

In addition to the above and for the sake of simplicity, should you find yourself in the condition of receiving advertising e-mail messages from the Data Controller companies that are no longer of interest to you, simply click on the text “IF YOU NO LONGER WANT TO RECEIVE OUR NEWSLETTERS YOU CAN CAN CAN CANCEL BY CLICKING HERE.

placed at the bottom of the same to stop receiving any further communication or, if not present, using the additional contact channels made available by the Data Controller or the Co-Processor companies.

-Right to withdraw consent, where provided and at any time. Revocation of consent does not affect the lawfulness of the processing based on the consent given before revocation;

-Right to file a complaint with the supervisory authority.

-Right to withdraw consent: consent to data processing can be withdrawn at any time by the data subject.

▪         

12. WAYS OF EXERCISING RIGHTS

You may exercise your rights at any time by sending a request by email to the email address in Section 1. of this data protection notice,  writing to the Privacy Office of the data controller, or asking for the Privacy Office or the data controller.

You may also exercise your rights by contacting the Privacy Guarantor, with Headquarters in Piazza Venezia n. 11 – 00187 Rome, Telephone switchboard: (+39) 06.696771,Fax: (+39) 06.69677.3785. For general information you can send an e-mail to: protocollo@gpdp.it, protocollo@pec.gpdp.it

 

13. AMENDMENTS TO THIS POLICY

The Data Controller reserves the right to make changes to this Privacy Policy at any time by giving notice to users on this site. Therefore, please consult this page often, taking as reference the date of last modification indicated at the end of the document. In case of non-acceptance of the changes made to this Privacy Policy you may request the Data Controller to delete the personal data concerning you.

 

14. MATERIALS

All content on the Internet Sites (not uploaded by users) is part of the data controller’s own archive (including joint data controller companies), including images. Part of the photographic materials are taken from online archives. The user when registering and entering content, whether photographic or textual, for the purpose of publication on the Internet Sites, declares that he/she owns the rights (including for commercial purposes) to the uploaded images. The user therefore assumes full responsibility for the provenance and legality of the images uploaded to the Internet Sites.

 

15. PROCEDURE FOR REVOCATION OF CONSENTS ON DATA PROCESSING

Dear User, You may request the revocation of one or more of the privacy consents listed below by sending an email to the email address Section 1 of this Data Protection Notice and stating one or more of the options you wish to revoke.

– Revocation of Email Communications

– Revocation of third-party marketing communications by email

Once the request is received, it will generally be processed within 48 hours.

HOW TO DISABLE COOKIES OF ANY BROWSERS USED BY THE USER FOR BROWSING BY BROWSER CONFIGURATION?

Chrome

  1. Running the Chrome Browser
  2. Click on the menu on the browser toolbar next to the url entry window for browsing
  3. Select Settings
  4. Click Show Advanced Settings
  5. In the “Privacy” section, click “Content Settings” button.
  6. In the “Cookies” section, you can change the following cookie-related settings: – Allow local data to be saved locally – Change local data only until the browser is closed -Prevent sites from setting cookies – Block third-party cookies and data from sites – Manage exceptions for certain websites – Delete any or all cookies

For more information visit the dedicated page.

Mozilla Firefox

  1. Run the Mozilla Firefox Browser
  2. Click on the menu on the browser toolbar next to the url entry window for browsing
  3. Select Options
  4. Select the Privacy panel
  5. Click Show Advanced Settings
  6. In the “Privacy” section, click “Content Settings” button.
  7. In the “Tracking “section you can change the following settings related to cookies: – Require sites not to do any tracking – Notify sites of your willingness to be tracked – Notify no preference regarding tracking of personal data
  8. From the “History “section you can: – By enabling “Use custom settings” select to accept third-party cookies (always, from the most visited sites or never) and to keep them for a specified period (until they expire, when Firefox closes or to ask every time) – Remove individual stored cookies.

For more information visit the dedicated page.

Internet Explorer/Edge

  1. Run the Internet Explorer/Edge Browser.
  2. Click on the Tools button and choose Internet Options
  3. Click on the Privacy tab and in the Settings section change the slider to the
    of the desired action for cookies:

– Block all cookies

Allow all cookies

– Selection of sites from which to obtain cookies: move the slider to an intermediate position so as not to block or allow

all cookies,then press on Sites, in the Website Address box enter a website and then press on Block or Allow

For more information visit the dedicated page.

Safari 6

  1. Running the Safari Browser
  2. Click on Safari,select Preferences and press on Privacy
  3. In the Block Cookies section, specify how Safari should accept cookies from Internet sites.
  4. To view which sites have stored icookie click on Details

For more information visit the dedicated page.

Safari iOS(mobile devices)

  1. Running the Safari iOS Browser
  2. Tap on Settings and then Safari
  3. Tap on Block Cookies and choose from the options, “Never,” “Third Party and Advertisers,” or “Always”
  4. To clear all cookies stored by Safari, tap on Settings, then on Safari and finally on Clear Cookies and Data

For more information visit the dedicated page.

Opera

  1. Running the Opera Browser
  2. Click on Preferences then Advanced and finally Cookie
  3. Select one of the following options: -Accept all cookies – Accept cookies only from the site you are visiting: third-party cookies and that are sent from a domain other than the one you are visiting will be rejected – Never accept cookies: all cookies will never be saved

For more information visit the dedicated page.

 

16. DEFINITIONS AND LEGAL REFERENCES

  • Personal Data (or Data)

Personal data is any information that, directly or indirectly, including in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

  • Usage Data

This is the information collected automatically through this Application (including by third party applications integrated into this Application), including: the IP addresses or domain names of the computers used by the User who connects with this Application, the addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method used in forwarding the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc..) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (e.g. the length of time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the User’s operating system and computer environment.

  • User

The individual using this Application who, except where otherwise specified, coincides with the Data Subject.

  • Interested

The natural person to whom the Personal Data refers.

  • Data Processor (or Manager)

The natural person, legal entity, public administration and any other entity that processes personal data on behalf of the Controller, as set forth in this privacy policy.

  • Data Controller (or Owner)

The natural or legal person, public authority, service or other body which, individually or jointly with others, determines the purposes and means of the processing of personal data and the means adopted, including the security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.

  • This Application

The hardware or software tool by which Users’ Personal Data are collected and processed.

  • Service

The Service provided by this Application as defined in the relevant terms (if any) on this site/application.

  • European Union (or EU)

Unless otherwise specified, any reference to the European Union in this document shall be deemed to extend to all atSual member states of the European Union and the European Economic Area.

  • Cookie

Cookies are Tracking Tools that consist of small portions of data stored within the User’s browser.

  • Tracking Tool

Tracking Tool means any technology – e.g., cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting – that allows tracking Users, for example, by collecting or storing information on the User’s device.

 

  • Legal references

This privacy policy is prepared based on multiple legislative orders, including Articles 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy policy covers this Application only.

 

17. ACCEPTABLE USE POLICY FOR WEBSITE USERS

Prohibited use

You may not use the Services to post content or engage in activities that are illegal under applicable law, harmful to others, or that could expose us to liability, including but not limited to the following activities, each of which is prohibited by this AUP:

  • -Phishing or identity theft
  • -Distribution of computer viruses, worms, Trojan horses (TROJAN) or other malicious codes (MALWARE, RANSOMWARE, etc.).
  • -Distributing pornography or adult content or offering escort services.
  • -Promoting or facilitating violence or terrorist activities.
  • -Infringement of intellectual property or other property rights of others.

Application

Your services may be suspended or terminated with or without notice if you violate this policy. Any violation may result in immediate suspension or termination of your account.

Reporting violations

To report a violation of this policy, contact us as per Section 12 of this policy

We reserve the right to change this policy at any time, and you will be promptly updated of this. To make sure you are up-to-date on the latest changes, we recommend that you visit this page often.

 

18.DATA DELETION PROCEDURE

 

o        Request for Deletion of Personal Data

Users have the right to request the deletion of their personal data in accordance with Article 17 of the European Regulation 2016/679 (GDPR). To exercise this right, users can send a written request to the email address in Section 1 of this policy or use the form available on our website.

The request must contain the following information:

  • First and last name
  • Email address used for registration
  • A clear description of the cancellation request

We undertake to respond to all cancellation requests without undue delay and, in any case, within one month of receipt of the request. If we need additional information to verify your identity, we reserve the right to extend the response period by up to two months, informing you of the reason for the delay. Please note that there may be some circumstances in which we cannot proceed with data deletion, such as if the data is needed to fulfill legal obligations or for archival purposes. In such cases, we will inform you of the reasons why we cannot proceed with the request.

 

19.LIST OF COOKIES USED BY THIS WEBSITE

 

Below are the cookies used by this site:

 

 

 

 

 

o      First-party Cookies

1

Key

Domain

Vendor

Tags

Valid until

cookieyes-consent

www.opencrew.it

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Unsigned

2026-02-03 14:45:31

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o      Requests in EU

96

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Country

ISP

Home

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Italy

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Italy

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Italy

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Italy

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Italy

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Italy

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Italy

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Italy

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Italy

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Italy

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o      Requests out of EU

13

URL

Country

ISP

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