This is a courtesy translation of the Italian version of this document. In case of ambiguity or disagreement between the two versions, the Italian document will be considered valid

Inticom Spa, with registered office in Via Carlo Noè, 22, 21013 Gallarate (VA), Tax Code and VAT no. 02649140122, as data controller (hereinafter "Controller"), informs you, pursuant to EU Regulation 679/2016 ("GDPR") and legislation, including national legislation, concerning the protection of personal data currently in force ("Privacy Law"), that your data will be processed in the following manner and for the following purposes:

1. Nature of data processed
The Controller processes non-sensitive, personal and identity data (specifically, first name, surname, email, phone number, IP address, etc. - hereinafter “Data” or “Personal Data”), provided by you upon registering on the "Careers" section of the website (hereinafter "Site”).

2. Purpose and legal grounds for the processing
Your Data is processed, without your prior consent, for the following purposes:
  1. To implement the contract or fulfil pre-contractual requirements: specifically,
    • to respond to your contact request;
    • to enable you to register on the Site;
    • to enable you to submit your application online through the Site and to process it further;
    • to manage and maintain the Site;
  2. to pursue the Controller's legitimate business activities: specifically:
    • to analyze cookies - as indicated in the Cookie Policy – arising from your use of the Site;
    • to prevent or uncover fraud or abuse potentially harmful to the Site;
    • to fulfil the obligations foreseen by law, regulation, community standards or other official requirements;
    • to exercise the Controller's rights, such as the right to legal defense.
3. Processing modes
The processing of your Data will be undertaken - electronically - through the collection, recording, updating, organization, conservation, consultation, elaboration, modification, selection, extraction, comparison, use, interlinking, blocking, cancellation and destruction of Data.

4. Data Retention
The Controller will process the data for the time necessary to meet your requests and fulfil the purposes set out above and, in any case, for no more than 24 months from the time of collection

5. Access to Data
Your Data may be accessed for the above purposes by:
  • the Controller's employees and/or collaborators, in their capacity as persons responsible for processing and/or internal data processing managers and/or system administrators; 
  • third-party companies or other parties (for example, website providers, suppliers, hardware and software technicians, professional firms, etc.) who perform outsourced activities on behalf of the Controller, in their capacity as external processors. 
6. Data sharing
Your Data may be disclosed, even without your consent, for the purposes mentioned above to oversight authorities, the police or judiciary who will process it, at their own, express request, as autonomous data Controllers for institutional purposes and/or as required by law during investigations and oversight activities. Your Data may also be disclosed to third parties (for example, partners, independent contractors, agents, etc.), as autonomous data Controllers, in connection with activities relating to the purposes mentioned above.

7. Data transmission
Your Data will not be disclosed nor transferred to countries outside the EU. Personal data will be stored and managed on servers located within the European Union. It is understood that the Controller shall, wherever necessary, retain the right to change the location of the servers in the European Union and/or non-EU countries. In this event, to ensure an adequate level of protection of Personal Data, the transfer of data to non-EU countries will be undertaken in accordance with the standards approved by the European Commission, i.e. the Controller shall adopt the Standard Contractual Clauses drawn up by the European Commission.

8. Data submission
Data submission is a prerequisite for the processing of Your Data by the Controller for the purpose’s outlined in article 2. Should you decide to withhold your Data, we will be unable to process your request.

9. Rights of interested parties
As an interested party, the Controller informs you that you have the right to:
  • obtain confirmation of the existence or otherwise of your Personal Data, even if not yet registered, and to have such data made available to you in an intelligible form;
  • receive and, where applicable, copy information about: a) the origin and category of the Personal Data; b) the parameters applied in the event of processing using electronic tools; c) processing purposes and procedures; d) identity details of the data Controller and managers; e) subjects or categories of subjects to whom the Personal Data may be communicated or who may view it, particularly in relation to recipients in third countries or international organizations; e) whenever possible, the data retention period or the criteria used to determine that period; f) the existence of an automated decision process and, in this event the parameters applied, the significance and the consequences for the person concerned; g) the existence of adequate safeguards in the event of transfer of the Data to a non-EU country or to an international organization;
  • obtain, without undue delay, the updating and correction of inaccurate Data or, if you so wish, the integration of missing Data;
  • obtain the cancellation, transformation into anonymous form or blocking of Data that: a) was processed unlawfully; b) is no longer required for the purposes for which it was collected or subsequently processed; c) in case of withdrawal of consent on which processing is based and if there is no other legal basis, d) in the event you objected to the processing and there is no legitimate justification for its continuance; e) if required in order to comply with a legal obligation; f) in the event of Data relating to minors. The Controller may refuse to delete only in the following cases: a) the exercise of the right to freedom of expression and information; b) compliance with a legal obligation, performance of a task carried out in the public interest or in the exercise of public powers; c) public health reasons; d) archiving in the public interest or for historical or scientific research or for statistical purposes; e) exercise of a legal claim; 
  • have limits applied to the processing in the event of: a) dispute concerning the accuracy of the Personal Data; b) illegal processing by the Controller to prevent deletion; c) exercise of a legal claim; d) where the Controller's legitimate claims may take precedence over those of the person concerned;
  • receive, in the event of automated processing, freely and in a structured format, commonly used and readable Personal Data relating to you to pass on to another Controller or – if technically feasible – to obtain direct transmission from the Controller to another Controller;
  • object, in whole or in part: a) for legitimate reasons, to the processing of your Personal Data, even if pertinent for the purposes of collection; b) to the processing of your Personal Data for purposes of sending advertising materials or direct selling or for carrying out market research or commercial communications, through automated calling systems not involving an operator via e-mail and/or through traditional marketing channels by phone and/or mail.
  • submit a complaint to the data protection Authority.
In the above cases, wherever necessary, the Controller will advise any third parties with whom your personal data has been shared of any exercise of rights by you, except in specific instances (i.e. when this proves impossible or involves an effort clearly disproportionate to the protected right).

10. Exercise of Rights
You may exercise these rights at any time by: 
  • sending a registered letter with delivery confirmation to the Controller's address; 
  • sending an email to
  • phoning .
11. Data processing Controller and External Data Processor
The data processing Controller is: 
  • Inticom Spa
The External Data Processor of the platform "Careers" is ALTAMIRA S.R.L., with registered office in Via G. Marradi 1, 20123 Milan.

The list of internal and outsourced External Data Processors is available at the registered office of the Controller in Via Carlo Noè, 22, 21013 Gallarate (VA).

Milan, 25/05/2018


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