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In accordance with the provisions of the Regulation, Wolf System shall process users’ personal data and information applying all principles of lawfulness, fairness, transparency, purpose and storage limitation, data minimisation, accuracy, integrity and confidentiality.
1. Data controller
The data controller of personal data processing activities through the Web Site is Wolf System, as hereinabove defined. For all information relating to the processing of users’ personal data on the part of Wolf System, including but not limited to the list of the data processors who process users’ personal data, users can write to the following e-mail address: email@example.com.
2. Type of personal data processed
As a result of navigating the Web Site, Wolf System shall process users’ personal data which may for example consist of an identifier such as a name, an identification number, an online identifier or one or more factors specific to the physical, physiological, mental, economic, cultural or social identity relating to an identified or identifiable data subject (hereinafter referred to as “Personal Data”). This is the list of Personal Data which shall be processed through the Web Site:
a. Web browsing data
The computer systems and software procedures used to run this website during normal operations acquire certain Personal Data whose transmission is implicit in the use of Internet communication protocols. This information is not collected with the aim of associating them with identified data subjects. However, due to its inherent nature, this information may identify users if elaborated and associated with data owned by third parties. This category of data comprises the IP addresses or the domain names of the computers connecting to the Web Site, the URI (Uniform Resource Identifier) notation addresses of the resources required, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the numeric code showing the status of the response from the server (successful, error, etc.) and other parameters relating to users’ operating system or IT environment. These data are processed with the sole aim of obtaining anonymous statistical information relating to the use of the Web Site, to check its proper operation, to detect any abnormal operation and/or abuse and they are erased immediately after they have been elaborated. It should be noted that the above-mentioned data could be also used to ascertain responsibility in case of computer crime which may harm the Web Site or any third party: apart from such a case, the data on the web contacts are not retained for more than a few days.
b. Special categories of Personal Data
It should be noted that through the section “Work with us” in the Web Site some Personal Data may be collected by e-mail and some of these Personal Data may belong to the special categories of Personal Data defined by art. 9 of the Regulation and namely “[…] data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as 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”. The Company invites users not to publish such data unless they are strictly required. Wolf System shall in no case be liable for and receive any claim for any special category of Personal Data which may be transferred without any specific and explicit consent to the processing of such data on the part of users themselves (without prejudice to users’ possibility to send their CV), since in such events Personal Data processing relates to Personal Data which are manifestly made public by the users themselves, in compliance with art. 9(1)(e) of the Regulation. However, as hereinabove stated, it should be noted that it is of fundamental importance that users expressly consent to the processing of special categories of Personal Data, should they decide to share such data.
c. Data voluntarily provided by data subjects
When using some services of the Web Site (e.g. the contact form, the order form, the event enrolment form), users shall be required to register through the following Personal Data (e.g. name, surname, e-mail address). These data are provided voluntarily and shall be processed in compliance with all the provisions on data protection. The refusal of such renders the users’ request impossible and the Company shall not be able to contact users, answers their questions, send information about products, submit offers or comply with the contract.
Users are required to provide correct data for the above-mentioned purposes. The above-mentioned data shall be retained for the time necessary to render the services required or for longer periods should it be required by any existing law or by any other legitimate purpose, e.g. should the Data Controller stand before a Court or should a legitimate reason exists for the Data Controller or for third parties.
Should the Personal Data of any third party be processed after being sent to Wolf System by any user, such user shall be deemed the autonomous data controller of these third-party Personal Data.
Definitions, characteristics and implementation of the provisions/em>
Cookies are small text files which web sites visited by users send and register on users’ computers or mobile devices and then are re-transmitted on subsequent visits. Thanks to cookies a web site remembers users’ actions and preferences (such as login data, selected languages, display settings, etc.) so that they will be available on users’ subsequent visits or when users navigate from one page to another. Therefore, cookies are used to perform IT authentications and session monitoring activities and to store information about the activities of the users who connect to a website and they may also contain a unique identifying number tracing users’ navigation through a web site for statistical or advertising purposes. When they navigate a web site, users may receive cookies from other web sites or web servers (the so-called “third-party cookies”). It should be noted that some operations would be impossible without cookies and under certain conditions cookies are necessary for web sites to operate from a technical point of view.
Cookies may be classified according to their functions and characteristics and they can remain in users’ computers for different time periods: the so-called “session cookies” are automatically erased when users close web browsers; the so-called “persistent cookies” are retained in users’ devices until they expire.
On the contrary, “profiling cookies” require users’ prior consent since they aim to create profiles about users and are used to send advertisements complying with specific preferences users have shown during their navigation on the web.
Types of cookies used by the Web Site and how to enable/disable cookies
The Web Site uses the following categories of cookies which can be disabled, except third-party cookies which users can enable/disable according to their specific methods available through specific links:
ATTENTION: should users disable technical and/or functional cookies, the Web Site and some services or functions of the Web Site itself may be unavailable or may not work properly. In such a case, users may be obliged to modify or to manually enter some information or preferences whenever they visit the Web Site.
Here are the links to the information about third-party cookies:
In details, here is the list of the cookies sent by Wolf System through the Web Site:
Cookies in the Web Site
Users may block or disable (in whole or in part) technical and functional cookies by selecting the relevant settings on browsers. However, it should be noted that the Web Site, its pages and its relevant services may not available to users who block or disable technical cookies (in whole or in part). It should be also noted that certain services or functions of the Web Site may not be available or properly work if users block or disable functional cookies (in whole or in part) and users may be obliged to modify or manually enter some information or preferences whenever they visit the Web Site.
Another dedicated cookie shall register any selection on the part of users relating to the cookies of the Web Site. However, the above-mentioned cookie may not function properly under some conditions: in such a case, users shall erase unwanted cookies and block them by setting browsers accordingly.
Preferences about cookies shall be redefined if users use different devices or browsers to connect to the Web Site.
How to view and modify cookies through Browsers
Users may authorise, block or erase cookies (in whole or in part) through some specific functions of Browsers. For further information about how to set cookies through Browsers, users may make reference to their relevant instructions:
3. Purpose of Personal Data processing
After users give their consent if required, their Personal Data shall be processed for the following purposes:
a. rendering the services required through the Web Site;
b. dealing with any assistance or information request;
c. analysing CVs and getting in touch with candidates who apply through the e-mail address available in the “Work with us” section;
d. complying with any possible law, accounting and tax obligation;
e. marketing: collected data may be processed, prior explicit and specific consent, to send marketing and promotional messages, as well as newsletters and market researches, using automated tools (sms and mms messages, e-mails, push notifications, fax messages) but not postal service or by telephone calls. The legal basis for processing Personal Data for the above-mentioned purposes resides in art. 6, paragraph 1, lit. a) of the Regulation. Processing for direct marketing purposes is voluntary and depends on users’ consent; therefore, users’ refusal to consent to such a purpose shall not affect the provision of services.
4. Legal basis and mandatory or voluntary processing
The legal basis for Personal Data processing for the purposes of section 3 (a-b-c) resides in art. 6, paragraph 1, lit. a) of the Regulation, since Personal Data processing is necessary to render the Services or to handle any request from users. The provision of Personal Data is voluntary for such purposes, but refusal may make Web Site services unavailable and may prevent the Company from handling requests or evaluating CVs. With specific reference to purpose 3(c) and its relevant analysis of professional social profiles made voluntarily available on the Internet, the legal basis resides in art. 6(1)(f) of the Regulation, thus in Wolf System’s legitimate interest to evaluate if candidates are enough qualified for vacant job positions.
Pursuant to art. 6(1)(c) of the Regulation, Personal Data processing is legitimate for the purpose of the above-mentioned section 3(d). After users provide their Personal Data, the processing is necessary for Wolf System to comply with a law provision which the Company is compelled to.
The legal basis for the purposes of section 3(e) resides in art. 6(1)(a) of the Regulation (users’ consent). For Personal Data processing for the same purposes which imply direct advertisement mailing or direct sales or market researches or commercial messages concerning products or services by Wolf System similar to the products and services purchased by users, the data controller is entitled to use users’ e-mail address and mail address without their consent in accordance with and to the extent allowed by art. 130, paragraph 4 of the Italian Civil Code and by the legislative measure dated 19th June 2008 of the Italian Data Protection Authority. The legal basis for Personal Data processing for the above-mentioned purpose resides in art. 6(1)(f) of the Regulation.
5. Recipients of Personal Data
Users’ Personal Data may be shared for the purposes of the above-mentioned section 3 with:
a. any third party acting as data collector, i.e.: i) natural persons, companies or consulting firms rendering consulting and supporting services to Wolf System relating to providing services, handling information and assistance enquiries as well as evaluating CVs; ii) third parties necessary for the Company to render its services (e.g. hosting providers); iii) or third parties appointed to render technical maintenance services (including maintenance services of network apparatus and electronic communication networks); (hereinafter jointly referred to as the “Recipients”);
b. any third party, organisation or authority whom Wolf System is compelled to transfer users’ Personal Data to on a mandatory base in compliance with law provisions or orders from relevant authorities;
c. any third party authorised by Wolf System to process users’ Personal Data for activities in connection with the provision of services and which shall commit to confidentiality or shall observe a lawful confidentiality obligation (e.g. Wolf System’s personnel).
6. Transfer of Personal Data
Users’ Personal Data shall not be shared with Recipients who may be located outside the European Economic Area.
7. Retention Period of Personal Data
Users’ Personal Data processed for the purposes of section 3(a-b-c) shall be retained for the time necessary to carry out the purposes for which they have been collected. However, since the Personal Data processing relates to the provision of services, the Company shall process Personal Data for the time allowed by Italian laws, thus protecting its own interests (art. 2946 et seq. of the Italian Civil Code). As to CVs sent by candidates as mentioned by section 3.b, Personal Data shall be retained as long as the job position which such CVs refer to is vacant, while spontaneous applications shall be retained up to 6 (six) months, without prejudice to the Company’s right to contact any candidate some time before such time elapses to require his/her content to extend the retention period.
Users’ Personal Data processed for the purposes of section 3.d shall be retained for the time fixed by the relevant law obligation or provision.
Users’ Personal Data processed for the purposes of section 3.e shall be retained until data subjects withdraw their consent or, should data subjects not withdraw their consent, for a fair period of time.
Data subjects can send an e-mail to firstname.lastname@example.org for further information about retention periods of Personal Data and about the criteria used to assess retention periods.
8. Rights of data subjects
In accordance with art. 15 et seq. of the Regulation, data subjects have the right at any time to access their Personal Data, check their accuracy, request additions or updates, or rectification thereof, request the cancellation thereof, object to their processing or obtain restriction of processing in compliance with art. 18 of the Regulation. In addition, data subjects shall have the right to receive the Personal Data concerning them in a structured, commonly used and machine-readable format in relation with the events stated by art. 20 of the Regulation.
When data processing is based on consent, data subjects have the right to withdraw that consent at any time.
Data subjects shall send any such request in writing to: email@example.com
However, data subjects shall always have the right to lodge a complaint with the relevant supervisory authority (the Privacy Protection Authority), in accordance with art. 77 or the Regulation if data subjects consider that the processing of their Personal Data infringes the existing legislation.