1. Data Controller
2. Personal Data processed
As you use the Website, we inform you that Pupa Milano may collect and process information related to you as an individual and which allows you to be identified (either directly, or together with additional information), or which is related to other individuals (“Personal Data”), such as your name, an identification number, an online ID or one or more characteristic elements of your physical, physiological, mental, economic, cultural or social identity.
a. Browsing Data
The Website’s operation, as is standard with any website on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation. While Pupa Milano does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information is also considered Personal Data. This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on. These data are used exclusively to compile anonymous, statistical information on the use of the Website, as well as to ensure its correct operation and identify any faults and/or abuse of the Website – the data is deleted immediately after processing, unless it must be used to identify responsible parties in the event of cybercrime committed which harms the Website or third parties, in which case information on web contacts may be kept as long as necessary.
b. Special categories of Personal Data
In the "Work with Us" section of the Website, you are allowed to submit Personal Data which may fall under the category of Personal Data referred to in Art. 9 of the Regulation – i.e. “[...] data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation”. While this should not prevent you from submitting your CV for a job application through the Website, Pupa Milano asks that you do not disclose any such types of Personal Data, unless you consider this to be strictly necessary. Indeed Pupa Milano remind you that if you disclose such special categories of Personal Data in absence of an explicit consent to process them, Pupa Milano may not in any case be held liable and cannot receive complaints in this regard because in such case the processing is permitted as it is based on the fact that you have publicly disclosed this information, according to Art. 9(1)(e) of the Regulation. In any case, Pupa Milano would stress the importance of providing your explicit consent to process this sort of Personal Data, if you decide, nonetheless, to share it. Please note that, for purposes of selection of an applicant to a certain position, Pupa Milano may decide to analyse the professional social media profiles which you make freely available on the Internet (e.g. LinkedIn).
c. Data provided voluntarily by the data subject
When using some of the Website’s Services you are allowed to submit Personal Data related to other persons. In any situation where you decide to share Personal Data related to other persons through the Website, you will be considered as an independent data controller regarding that Personal Data, and must assume all inherent legal obligations and responsibilities. This means that you must also must make sure that you have these third parties’ consent to their Personal Data being used in this manner before providing them to Pupa Milano or another appropriate legal basis which may allow for lawful processing of this information. To this end, you must fully indemnify Pupa Milano against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, initiated by the third parties whose information is processed via the Website by your initiative.
For more information please visit: https://www.pupa.fr/cookies.html
3. Purpose of the processing
Pupa Milano intends to use your Personal Data, collected through the Website, for the following purposes:
a. To provide Services you request, such as: i) granting access to reserved areas of the Website; ii) subscription to newsletters.
b. To respond to any of your requests for assistance or information;
c. To analyse CVs submitted through the Website, as well as to contact any candidates who submit their applications;
d. For compliance with laws which impose upon Pupa Milano the collection and/or further processing of certain kinds of Personal Data.
4. Legal basis and mandatory / discretionary nature of the processing
Pupa Milano’s legal bases to process your personal data, according to the purposes identified in Section 3, are as follows:
• Section 3(a), 3(b) and 3(c): processing for these purposes is necessary to provide the Services and, therefore, the applicable legal basis is the necessity of the processing for the performance of a contract with you, as well as to take steps at your request prior to entering into a contract with you – Art. 6(1)(b) of the Regulation. It is not mandatory for you to give Pupa Milano your Personal Data for these purposes; however, if you do not, Pupa Milano will not be able to provide any Services to you, nor will Pupa Milano be able to answer any requests or assess any CVs you may submit.
• Specifically regarding Section 3(c), in particular as to Pupa Milano’s analysis of professional social media profiles which you make freely available on the Internet, Pupa Milano relies on Art. 6(1)(f) of the Regulation – i.e., the necessity of the processing for the purposes of Pupa Milano’s legitimate interest in verifying whether there are any risks related to the candidate’s suitability for a given open position.
• Section 3(d): processing for this purpose is necessary for Pupa Milano to comply with its legal obligations and, therefore, the applicable legal basis is the necessity of the processing for compliance with the data controller’s legal obligations – Art. 6(1)(c) of the Regulation. When you provide any Personal Data to Pupa Milano, Pupa Milano must process it in accordance with the laws applicable to it, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations.
5. Recipients of Personal Data
Your Personal Data may be shared, for the purposes listed in Section 3, with different persons / entities (hereinafter and collectively, “Recipients”):
• Entities acting as data processors on Pupa Milano’s behalf, in particular:
• Persons, companies or professional firms providing Pupa Milano with advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services;
• Entities engaged in order to provide the Services (e.g., hosting providers or e-mail platform providers); and
• Persons authorised to perform technical maintenance (including maintenance of network equipment and electronic communications networks).
• Public entities, bodies or authorities to whom your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities;
• Persons authorised by Pupa Milano to process Personal Data needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of Pupa Milano.
6. Transfers of Personal Data
Some of your Personal Data are shared with Recipients who may be located outside the European Economic Area. The Company ensures that your Personal Data are processed by these Recipients in accordance with the Regulation. Under the Regulation, these transfers can be based on an adequacy decision or on the Standard Contractual Clauses approved by the European Commission. Further information is available at the Company at the following address.
7. Retention of Personal Data
Personal Data processed for the purposes set out in Section 3(a) and 3(b) will be kept by Pupa Milano for the period deemed strictly necessary to fulfil such purposes – in any case, as these Personal Data are processed for the provision of the Services, Pupa Milano will keep them for as long as the statute of limitations on liability related to the provision of the Services (as determined by the applicable law) lasts, so as to protect its interests.
Personal Data contained within CVs sent via the Website, as mentioned in Section 3(c), will be kept as long as the position for which the CV was sent remains open. As for spontaneous applications, this Personal Data may be kept for up to 1 (one) year. Pupa Milano may contact candidates before the mentioned periods end, in order to request an extension of this retention period.
Personal Data processed for the purposes set out in Section 3(d) will be kept by Pupa Milano for the period required by the specific legal obligation or by the applicable law. For more information on Pupa Milano’s Personal Data retention periods and the criteria adopted in determining these periods, please contact: privacyFR@pupa.it
8. Retention of Personal Data
Under Articles 15 and following of the Regulation, you, as a data subject, are entitled to request from Pupa Milano at any time, access to your Personal Data, the correction and erasure of your Personal Data, as well as to object to its processing. You are also entitled to request the restriction of the processing of your Personal Data in the cases set out in Article 18 of the Regulation, as well as to obtain the Personal Data you have provided to Pupa Milano in a structured, commonly used and machine-readable format, in the cases set out in Article 20 of the Regulation.
Requests should be made in writing to Pupa Milano at: privacyFR@pupa.it
In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data, if you believe that the processing of your Personal Data carried out through this Website violates applicable law.