Privacy Notice for Users of the Vocations Platform regarding the processing of personal data pursuant to Articles 13 and 14 of European Regulation No. 16/679, as amended and supplemented.

DATA CONTROLLER

VOCATIONS is the Data Controller of personal data, with registered office at Via Milano 37/C, Gorgonzola (MI) 20064, VAT No. 13607470963, certified email (PEC) [email protected], legal representative Alessandro Galli.

VOCATIONS owns the platform known as "Vocations", available at www.vocations.io, on which job advertisements collected online and originally published by third parties are published in real time. Job searches can be targeted using specific filters, and users can also stay updated on a day-by-day basis regarding open positions through dedicated alerts.

DATA SUBJECT TO PROCESSING

Personal data subject to processing means any information concerning You and attributable to You in Your capacity as a User of the Platform.

The data that the company intends to process are:

• personal identification data: personal image, first name, last name, company name, telephone number, email address, tax code;
• economic and financial data.

PURPOSES, LEGAL BASIS FOR PROCESSING AND RETENTION PERIOD

The processing of Your personal data is intended to manage the contractual relationship established when You accept the terms and conditions of the Platform.

In particular, Your data will be processed for the following purposes:

The personal data of the data subject are retained for the entire duration of the contractual relationship and, following deletion of the account, for a total period of 2 years, unless retention is necessary for the protection of rights before a Judicial Authority. In such case, the data will be retained for 10 years from the conclusion of the judicial/out-of-court proceedings.

PERMITTED USE OF CONTACT DATA OBTAINED THROUGH THE PLATFORM AND PROHIBITION ON COMMERCIAL COMMUNICATIONS TO CONTACT DATA

Users are expressly prohibited from using Vocations services, or any contact data obtained through Vocations (including, by way of example and without limitation, the email addresses of company contacts), to send emails or any other electronic communications of a commercial, marketing, promotional, advertising or sales-related nature to contacts who have not previously given their consent to receive such communications.

Contact data made available through the Platform may be used exclusively for recruitment, personnel selection and professional talent sourcing purposes. Through the Platform, it will be possible to send professional communications and automated emails, including any attachments and third-party documents, specifically for the purpose of speeding up contact with and identification of professional profiles requested by the interested third party. However, the User expressly releases Vocations from any liability in relation to the content of such emails, considering that Vocations itself will in no way be able to process any data contained therein and/or view documents attached to automated emails. Therefore, should the User decide to use this functionality, the User must ensure in advance that the explicit consent of the data subject to the transfer to third parties has been obtained. The provisions set out in the Terms and Conditions are hereby incorporated in full.

If the User or Customer intends to send a commercial or marketing communication to a contact obtained through the Services, they must first obtain the valid, freely given, specific, informed and unambiguous consent of that contact and be able to demonstrate such consent upon request. It is acknowledged that the business-to-business nature of the Services does not exempt the User or Customer from this obligation: pursuant to Article 130 of Legislative Decree 196/2003, prior consent is also required for commercial communications addressed to professional or business contacts, and the so-called "soft spam" exemption cannot be relied upon with respect to contacts acquired through the Services.

The User must at all times: (i) provide a clear and functioning mechanism enabling recipients to object to further communications or unsubscribe from them; (ii) act without delay on any request to object, unsubscribe or withdraw consent; (iii) refrain from concealing, falsifying or misrepresenting the identity of the sender or the subject matter of the communication; and (iv) comply with all applicable laws and regulations concerning electronic communications and direct marketing, including Regulation (EU) 2016/679 (GDPR), Directive 2002/58/EC (ePrivacy) and Article 130 of Legislative Decree 196/2003 (Personal Data Protection Code), as amended, as well as any equivalent legislation applicable in the recipient's jurisdiction.

The recipient of a communication may object to further communications at any time. Following such objection, the contact will be added to VOCATIONS' global suppression system and the related data may no longer be viewed or unlocked through the Platform, even if subsequently returned by a different provider.

Any breach of the provisions of this section constitutes a material breach of the Terms and Conditions of use of the Service and entitles VOCATIONS to suspend or deactivate, with immediate effect, the User's or Customer's account and access to the Services, without any right to a refund. VOCATIONS acts solely as a data source and assumes no liability for unsolicited communications sent by the User or Customer in violation of this section.

NATURE OF THE PROVISION OF PERSONAL DATA

The provision of data, with regard to the aforementioned purposes, is necessary for data for which a legal obligation is provided and for data necessary for the performance of the contract in question; any refusal to process your data will make it impossible to perform the contract itself and/or to fulfill the legal obligations to which the Data Controller is subject.

PROCESSING METHODS

Within the scope of the purposes indicated, your data will be processed using paper-based media as well as computer/electronic tools in compliance with the regulatory provisions on personal data processing, adopting adequate security measures.

The processing of your Data will be managed by authorized personnel specifically trained and instructed to ensure its adequate security and confidentiality, as well as to avoid risks of loss and/or destruction and access by unauthorized parties. The Company has implemented adequate security measures to protect your personal and business/commercial data.

COMMUNICATION AND TRANSFER OF DATA

Your personal data, considering the type of contract in place, may be communicated to subjects legitimated to access them by virtue of legal provisions, regulations, EU regulations, as well as to credit institutions and law firms for the purpose of legal advice. Your Data may also be communicated to subjects specifically appointed as external data processors, such as the accountant, IT and management service providers, cloud providers. If your data are transferred outside the European Union, they will be processed in accordance with Art. 46 EU Reg. 16/679.

DISSEMINATION

The personal data provided by you will not be subject to dissemination without prior authorization.

RIGHTS OF DATA SUBJECTS

You, as a data subject, may exercise at any time the rights expressly recognized to you by the European Regulation, in particular:

• The right of access to personal data (Art. 15 Reg. 16/679) in order to obtain from the data controller confirmation as to whether or not personal data concerning you are being processed and, if so, to obtain access to the personal data and the following information: the purposes of the processing; the categories of personal data in question; the recipients or categories of recipients to whom the personal data have been or will be disclosed; where possible, the envisaged retention period of the personal data; the existence of the data subject's right to request rectification or erasure of personal data; the right to lodge a complaint with a supervisory authority; the existence of automated decision-making; the existence of adequate safeguards relating to the transfer of data abroad.
• The right to rectification (Art. 16 Reg. 16/679) and integration of inaccurate or incomplete personal data concerning you.
• The right to erasure (Art. 17 Reg. 16/679) of personal data concerning you where: they are no longer necessary in relation to the purposes for which they were collected; they were collected in relation to the offer of information society services; you withdraw consent and where there is no other legal ground for the processing.
• The right to restriction of processing of personal data (Art. 18 Reg. 16/679) where one of the following applies: you contest the accuracy of the personal data; the processing is unlawful; you object to the processing.
• The right to data portability (Art. 20 Reg. 16/679), i.e., to transmit such data to another data controller where the processing is based on consent or on a contract.
• Right to object (Art. 21 Reg. 16/679) at any time, on grounds relating to your particular situation, to the processing of your data concerning you.
• Withdraw consent
• The right to lodge a complaint with a supervisory authority.

Should you wish to exercise the rights listed above, the email address of the Data Controller, VOCATIONS S.R.L., to which you may apply, as well as the address for ordinary mail, is indicated below: [email protected]