Notice pursuant of EU Regulation 2016/679
Processing the data of users who visit the truecompany.it Website and register for the True Company newsletter
This notice is provided in compliance with Art. 13 Regulation 2016/679 (GDPR)
All companies listed below belonging to the True Company Network, with registered office at Via Carlo Poma 50,
True s.r.l.; Sterling Cooper s.r.l.; Chili PR s.r.l., are data controllers
Email address of the Data Controller: firstname.lastname@example.org
Types of Data Collected
The personal data processed are collected as they are supplied directly by the data subject or automatically.
The data supplied directly by the data subject are personal data given directly by the data subject to the Data Controller by any means. In particular, the following personal details are collected and processed: first name, last name, email address.
The data collected automatically are browsing data. Although such data are not collected to be associated with your identity, they may indirectly allow for identifying you when processed and associated with data collected by the Data Controller.
After sending the newsletter, the platform used can detect if and when a message is opened and if and when the recipient clicks on the newsletter.
You assume responsibility for the personal data of third parties obtained, published or shared through this Website, and you guarantee that you have the right to disclose them, and release the Data Controller of any responsibility towards third parties.
Data processing methods
The Data Controller takes appropriate security measures to prevent unauthorised access, disclosure, alteration or destruction of the Personal Data. Processing is carried out by using IT and/or screen-based instruments with organisational procedures and logics strictly related to the indicated purposes. Apart from the Data Controller, in some cases some people involved in the organisation of this Website (administrative, commercial, marketing and legal personnel, system administrators) may have access to the data, as well as external subjects (such as third-party technical service providers, courier services, hosting providers, IT companies, communications agencies) appointed by the Data Controller as Processors, if necessary. You may ask the Data Controller for an updated list of Processors.
Legal basis for processing
The Data Controller processes your Personal Data when any of the following conditions are met:
- You give your consent to processing for one or more specific purposes;
- processing is necessary for execution of a contract with you and/or for taking pre-contractual measures;
- processing is necessary for compliance with a legal obligation to which the Data Controller is subject;
- processing is necessary for the performance of a task carried out in the interest of the public or in the exercise of official authority vested in the Controller;
- processing is necessary for pursuing the lawful interest of the Data Controller or third parties.
However, you are free to ask the Data Controller to clarify the real legal basis of each processing and to let you know whether processing is based on the law, foreseen by a contract or necessary for concluding a contract.
Your Data are processed at the operations offices of the Controller and anywhere else the parties involved in processing are located. For more information contact the Controller.
Your data are processed and stored for the time required for the purposes for which they were collected. Therefore:
- Personal Data collected for purposes connected to execution of a contract between the Data Controller and you shall be kept until execution of the contract has been completed.
- Personal Data collected for purposes tied to the lawful interest of the Data Controller shall be kept until that interest is satisfied. You can obtain additional information on the lawful interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.
When processing is based on your consent, the Data Controller can keep your Personal Data longer until consent is withdrawn. In addition, the Data Controller might be obligated to keep your Personal Data for a longer period of time for fulfilment of a legal obligation or by order of the authorities.
At the end of the storage period your Personal Data shall be deleted. Upon expiry of this time limit the right to access your Data, their erasure, rectification and the right to portability of the Data can no longer be exercised.
Purpose of Processing Collected Data
Your data are collected to enable the Controller to supply its services and for the following purposes: Statistical; to contact you; for interaction with social networks and external platforms; to enable comments about contents; for commercial affiliation; to handle payments; to manage addresses; to send email messages; for hosting and back-end infrastructure and to protect you from spam.
By entering your data on our Website contact form, you are giving us permission to use them to satisfy your requests for information, estimates, or requests of any other nature specified in the heading of the form.
Collected personal data: first name, last name, email address, any other data provided spontaneously by you in the message.
With reference your Data processed by the Controller you can exercise the following rights as specified below:
- Withdraw consent at any time. You can withdraw consent to processing of your Personal Data you gave previously.
- Object to processing of your Data. You can object to processing of your Data when it is done on a legal basis you did not consent to. Additional details on your right to object are given in the section below.
- Access your Data. You have the right to obtain information on the Data processed by the Controller, on certain aspects of processing and to receive a copy of the processed Data.
- Check and ask for rectification. You can check the accuracy of your Data and ask for them to be updated or corrected.
- Obtain restriction to processing. When certain conditions are met, you can ask the Controller to restrict processing of your Data. In such case the Controller shall not process your Data for any other purpose than storage.
- Obtain erasure or deletion of your Personal Data. When certain conditions are met, you can ask the Controller to erase your Data.
- Receive your Data or have them transferred to another data controller. You have the right to receive your Personal Data in a structured format, commonly used and legible by an automatic device and if technically possible, to have the data sent to another data controller without obstacles. This provision applies when Data are processed with automated instruments and processing is based on your consent, on a contract of which you are a party, or on contractual measures connected to it.
- Lodge complaint. You can lodge a complaint with the concerned supervisory authority or take legal action.
Details on your right to object
When your Personal Data are processed in the interest of the public during exercise of official authority vested in the Controller, or for pursuit of a lawful interest of the Controller, you have the right to object to processing for reasons connected to your particular circumstances.
You should remember that when your Data are processed for direct marketing purposes, you can object to processing without giving any reason.
Milan, 29 January 2019
Notice pursuant of EU Regulation 2016/679
Data processing related to submitting applications on the truecompany.it Website or directly to company email addresses.
In relation to the selection process of job applicants, below is some information on processing of the data of job applicants, as required by applicable personal data protection legislation.
Purposes of data processing
Your personal data shall only be used for performing personnel recruitment and selection tasks in the interest of the Companies belonging to the True Company network, i.e. True s.r.l., Sterling Cooper and ChiliPr. s.r.l., (“the Companies”), as well as companies directly or indirectly controlled or invested by the latter, with registered office at Via Carlo Poma 50, Milan.
If you submit an application, your personal data may also be used by external companies that carry out recruiting services on behalf of the Companies and those directly or indirectly controlled or invested.
If you do not give your consent for processing, it shall be impossible for the Companies to take into consideration your application. Your data may also be processed in the cases and for the purposes provided by Art. 24 of the Act, for example fulfilment of legal obligations, even without your consent (consent of the data subject).
Data processing methods
Your data shall be subject to all processing tasks described in Art. 4 of the Act by using hard copies and/or electronic instruments so as to guarantee privacy and prevent loss, destruction, unauthorised access or processing. In the event you are called for a selection process but not hired, your data may be stored for a period of at most five years, only for the purpose of recruitment and selection for other job openings.
Rights of the applicant
The GDPR gives the Applicant the right to obtain confirmation as to whether there are any personal details on file about him or her and to know the content and source, to verify their accuracy and to ask for details to be added, updated or corrected. In addition, he or she has the right to ask for erasure, transformation into anonymous form or blocking of data processed against the law, and to object to processing of personal data for justified reasons.
For any communication on these matters, the Applicant may send correspondence to this email address: email@example.com
Milan, 29 January 2019