APPLICATION PERSONAL DATA PROCESSING PRIVACY POLICY PURSUANT TO THE PROVISIONS OF ART. 9, 13 AND 14 OF (EU) REGULATION 2016/679 (“GDPR”) AND OF ITALIAN LEG. DECREE  NO. 196 OF 30/06/2003 ENTITLED “PERSONAL DATA PROTECTION CODE”

WEBSITE www.euroricambigroup.com 

Dear User,

Should you intend to apply for a position (employment contract and/or collaboration of any type), with companies in the EURORICAMBI GROUP, on this website: www.euroricambigroup.com (“Website”), please read the privacy policy (the “Privacy Policy”) herein thoroughly.

In compliance with the applicable personal data protection provisions in force, FA.TA. RICAMBI S.p.A. (“FA.TA”), holding of the EURORICAMBI GROUP, consisting of subsidiaries and/or affiliated companies (in particular, Euroricambi S.p.A., AM Gears S.r.l., Eurotec S.r.l. and Lambert Getriebeteile GmbH), with the Privacy Policy herein, provides you with important information concerning the processing of your personal data (and/or personal data of members of your family), as well as the rights which you and/or members of your family are entitled to as identified or identifiable data subjects whose personal data may be processed by the Company (hereinafter “Data subject”).

FA.TA. operates in its capacity as Data Controller of the personal data collected and/or acquired through this Website and/or in its capacity as Data Processor, appointed by the same subsidiaries and/or affiliated companies, for the processing of the data collected and/or acquired directly or indirectly by the same subsidiaries and/or affiliated companies.

For the above purposes, “Personal data protection code” means (EU) Regulation 2016/679 about the protection of natural persons concerning personal data processing, as well as the free movement of such data (hereinafter “GDPR”), Italian Leg. Decree no. 196/2003, Personal data protection code, subsequent amendments or addenda (hereinafter “Privacy Code”) and any additional legal provision, deed, regulation pro-tempore in force on the subject of personal data protection. 

Pursuant to the provisions of Art. 9, 13 and 14 of the GDPR, please note the following. 
By visiting the Website, filling in the on-line application form and interacting with FA.TA. RICAMBI S.p.A. (and/or with other companies in the EURORICAMBI GROUP and, in particular, the subsidiaries and/or affiliated companies Euroricambi S.p.A., AM Gears S.r.l., Eurotec S.r.l. and Lambert Getriebeteile GmbH), you declare you have read and understood the Privacy Policy herein and that you accept that your Personal Data will be processed in conformity with the aforesaid Privacy Policy.

1. TYPE OF DATA PROCESSED

The personal data collected and/or acquired implicitly with the use of Internet communication protocols and/or provided voluntarily, by filling in the dedicated on-line application forms, on the Website, may be processed in compliance with the Personal data protection code, according to the principles of correctness, lawfulness and transparency, as well as the confidentiality obligations which our activities are based upon. The following categories of personal data (by way of illustrative and not exhaustive example) may be processed: 

  1. navigation data, such as IP addresses, log data or domain names and other parameters relating to computers, to the operating system and the computer environment used; 
  2. data provided voluntarily for the purpose of making the application, such as: (i) personal, identification, contact and access data, such as name, surname, e-mail address, telephone number and access credentials; (ii) data required for negotiating, stipulating and performing the possible contractual relationship with FA.TA. (or other subsidiary and/or affiliated company of the EURORICAMBI GROUP); (iii) payment and bank details, such as the current account number or IBAN code; (iv) data concerning remuneration, consideration, salaries; (v) data concerning tasks, roles, appointments, work experience; (vi) data of an evaluation nature, hobbies, composition of the family unit; all the information that the User intends to provide for the purpose of the application, including pictures (such as a photograph to accompany their professional profile), hereinafter defined jointly as “Personal Data”. 

The processing may also concern “sensitive” personal data included as part of the special categories of personal data specified in Art. 9 of the GDPR (including, for instance, data relating to health and to possible disabilities and/or belonging to “protected categories”).
Further information about the use of cookies and other monitoring technologies and how to control them can be consulted in the cookie policy available on the Website.
The collection or intentional storage of personal data relating to minors does not fall under FA.TA.’s policy.

2. PURPOSES OF DATA PROCESSING - LEGAL BASIS OF PROCESSING – NATURE OF PROVISION AND CONSENT TO PROCESSING

Processing of personal data means any operation or set of operations which is performed on personal data or on sets of personal data, even if not stored in a database, whether or not by automated means, such as archiving, collecting, recording, organising, structuring, storing, adapting or amending, consulting, processing, amending, selecting, extracting, comparing, using, interconnecting, blocking, disclosing by transmission, dissemination, limitation or otherwise making available, erasing or destroying Personal data.

Personal data will be processed as part of the activities of FA.TA. and/or of the subsidiaries and/or affiliated companies of the EURORICAMBI GROUP (in particular, Euroricambi S.p.A., AM Gears S.r.l., Eurotec S.r.l. and Lambert Getriebeteile GmbH), for the purposes set out below:

  1. to perform scouting, recruitment and valuation activities of personnel of FA.TA. and/or of the subsidiaries and/or affiliated companies of the EURORICAMBI GROUP (in particular, Euroricambi S.p.A., AM Gears S.r.l., Eurotec S.r.l. and Lambert Getriebeteile GmbH);
  2. to fulfil pre-contractual and/or contractual obligations, linked to the possible termination, management and performance of the contractual relationship, with FA.TA. and/or with the subsidiaries and/or affiliated companies of the EURORICAMBI GROUP, starting with voluntary applications and/or multi-claimant procedures and other recruitment procedures;
  3. to fulfil the statutory obligations of a fiscal, tax, accounting, administrative and commercial nature deriving from the activity of FA.TA. and/or the subsidiaries and/or affiliated companies of the EURORICAMBI GROUP and of the provisions of the Government Authorities and Supervisory Bodies and administrative procedures;
  4. to improve the Website navigation experience;
  5. directly or via third-party suppliers, for promotional and marketing activities, sending newsletters and communications of a direct marketing nature in the form of e-mails, text messages, MMS messages, push notifications, snail mail, over the phone, in relation to products and/or services of FA.TA. and/or of the companies in the EURORICAMBI GROUP, customer satisfaction surveys, statistical analyses. This activity may also be carried out following User profiling. 

FA.TA. will use the personal data for the purposes specified herein above, as well as: (i) for its own legitimate interests in the provision of its professional activity; (ii) for its own legitimate interests in the efficient and legitimate management of the activity, for as long as these interests do not prevail over the interests of the data subjects; (iii) for the legal and statutory obligations which FA.TA. is subject to. 
Processing of the Personal data for the above-mentioned purposes may also fall under – in addition to the scope of Art. 6, paragraph 1, letters b), c) and f), - the scope of Art. 6, paragraph 1, letter a) and Art. 9 of the GDPR, since it is based on the explicit consent of the Data subject.  

Provision on the part of the User of the Personal data is optional: nevertheless, since it is necessary for the purposes of valuing the application, please express your consent to the processing of your Personal data, including the data that fall under the special categories specified in Art. 9 of the GDPR, recalling that the said consent may be revoked at any time, without prejudice to the compulsory obligations envisaged by the applicable regulations at the time of the request to revoke consent, by contacting the Data Processor at the numbers and addresses specified in the Privacy Policy herein. 

The User may in any event delete his/her registration with the Website or revoke consent to the processing of Personal data, provided at the time of registration and application.

3. PROCESSING RECIPIENTS

The Personal data may, for all the above-mentioned purposes as well as for legal and contractual obligations, be the object of disclosure to third-party subjects, also with contractual relations with the Data Controller and/or with Data Processors, for instance falling under the following categories: authorised persons appointed to perform scouting, recruitment and valuation activities of personnel; professionals or service providers appointed to perform services as part of the computer system; professionals or providers of legal, tax or corporate consulting services and auditing companies; System Administrators; credit management companies, banks and/or credit institutes; Social Security and Insurance Entities, Public Authorities, Public Administrations or Institutions; trade union organisations; doctors and doctors’ surgeries; consultants, trade associations as well as anyone who is a legitimate recipient of communications envisaged by legal or statutory regulations; subjects appointed as Data Processors, representatives, employees or collaborators of some sort, in their capacity as designated and/or authorised to process the Personal Data, of the Controller and/or of the Data Processor. The Personal and other data will nevertheless not be disclosed.

Consequently, FA.TA will notify the above-mentioned categories of recipients of the Personal data provided by the User, even if they fall under the special categories specified in Art. 9 of the GDPR, which will in any case be processed by the same recipients in their capacity as Controller and therefore in full autonomy and/or as Data Processor but, in any case always and only for the purposes specified herein.  The above-mentioned recipients may also include holding companies, subsidiaries and/or affiliated companies belonging to the entrepreneurial group which FA.TA. is part of (in particular, Euroricambi S.p.A., AM Gears S.r.l., Eurotec S.r.l. and Lambert Getriebeteile GmbH) as well as companies whose headquarters are in other Countries, including those outside the European Union, since FA.TA. may have a legitimate interest in transmitting Personal data (including the processing of personal data of customers, suppliers, employees or collaborators) within the entrepreneurial group for internal administrative purposes.

4. DATA PROCESSING METHODS AND DATA STORAGE TIMES

The Personal data will be processed using suitable tools to guarantee security and confidentiality, and may be carried out with either hard-copy instruments or computerised tools. Personal data will be processed in an automated way and/or manually, in compliance with the Personal data protection code, by subjects designated and/or authorised specifically, in accordance with the provisions of the said personal data protection code.

FA.TA. uses a series of physical, electronic and management measures to guarantee the safe, precise and up-to-date storage of the Personal data. 
Although FA.TA. uses suitable security measures, once the Personal data have been received, their transmission over the Internet (including e-mails) is never entirely secure. FA.TA. RICAMBI S.p.A. undertakes to protect the Personal data, but cannot guarantee the security of the Data transmitted to and from the same FA.TA. over the Internet (including e-mails).

The Personal data will be stored for a period of no more than 1 (one) year. In the event that the Personal data are deemed interesting for the purpose of a possible contractual relationship, they can be stored for longer, as specified below: (i) the period necessary for the purposes pertaining to collection; (ii) the storage period envisaged by law; (iii) the period of time during which disputes or investigations may arise in relation to the contractual relationship with the candidate User.

5. RIGHTS OF THE DATA SUBJECTS

Please note that, in relation to the above-mentioned processing, in your capacity as “Data Subject”, you may exercise the rights pursuant to the provisions of Art. 15 and subsequent articles of the GDPR and, in particular, the right to request and obtain confirmation of whether Personal data processing is under way or not, an indication of the origin of the Data, the right to gain access to the Personal data and to the information relating to the processing (purposes, categories of personal data, recipients or categories of recipients, storage period), the amendment, deletion, limitation and objection to the processing at any time and also in the case of processing for direct marketing purposes, the portability of the Data, to object to an automated decision-making process relating to natural persons, including profiling, to lodge a complaint with the Control Authorities, to revoke consent to the processing of the Data (to the extent that the processing is based on consent), to anonymise, to block the Data, to receive without delay notification of the infringement of the Personal Data incurred by the Controller. 

To exercise these rights, you may contact FA.TA. RICAMBI S.p.A. by sending a request to the address: Via Chiesaccia no. 5 - Valsamoggia Loc. Crespellano - Bologna, Italy or by addressing the communication via e-mail to: privacy@fataricambi.com.

6. DATA CONTROLLER AND DATA PROCESSOR

The Data Controller is:
FA.TA. RICAMBI S.p.A. with registered office in Via Chiesaccia no. 5 - Valsamoggia Loc. Crespellano - Bologna, Italy, in the person of the company’s legal representative pro-tempore.

FA.TA. is also appointed the Data Processor for the personal data from the companies in the EURORICAMBI GROUP and, in particular, from the subsidiaries and/or affiliated companies Euroricambi S.p.A., AM Gears S.r.l., Eurotec S.r.l. and Lambert Getriebeteile GmbH.

The list of Data Processors and those designated/authorised to process the personal data can be consulted at the registered office of the above-mentioned Data Processor.

The Privacy Policy herein may be subject to amendments. Any amendments will be notified to the Data Subjects on the Website www.euroricambigroup.com .

Yours Sincerely,

FA.TA. RICAMBI S.p.A.