PERSONAL DATA PROCESSING POLICY CV SUBMISSION

The company Industrie De Nora S.p.A. (hereinafter, for the sake of brevity, "De Nora" or the "Company") is aware of the importance of protecting the personal data of its customers. In compliance with the European and the Italian legislation in this area and inspired by the recommendations of the Group established by art. 29 of the directive n. 95/46 / EC, and to the documentation and measures published by the Italian Data Protection Authority, De Nora informs that the personal data collected through the forms present in the sub-sections of the page "Careers" of www.denora.com, will be processed in compliance with the law regarding the protection of personal data.

Therefore, with reference to the methods of management and processing the personal data of its customers who visit this site, pursuant to Article 13 of EU Regulation no. 679/2016, De Nora provides the following information:

1. Types of data collected

Data provided voluntarily by the user

Upon submitting your application for one of the positions opened at De Nora, data entered voluntarily by the user will be collected in the form on the page, including:

  • personal and contact details;
  • data relating to professional qualifications;
  • other documents (curriculum vitae, letter of presentation, etc.).

The data subject / candidate is requested not to insert or indicate data relating to the "health sphere", "religious orientation", "trade union", "philosophical", "political", "sexual" in the registration form, in the curriculum and in the letter of presentation or in the text of the e-mail message that may be sent.

2. Purpose and legal basis of the processing

Personal data provided by the subject and collected by De Nora in the "Careers" section of the www.denora.com website will be processed for the following purpose of carrying out personnel selection activities. The legal basis that legitimizes the processing of personal data for this purpose is to be found in the hypothesis provided for by art. 6 par. 1, lett. b) of the EU Regulation no. 679/2016, since the processing is necessary for the performance of a contract of which the data subject is a part of or for the performance of pre-contractual measures adopted at the request of the same. The same data may also be used to fulfil legal obligations or requests from the judicial authority.  The legal basis that legitimizes the processing of personal data for this purpose is to be found in the hypothesis provided for by art. 6 par. 1, lett. c) of the EU Regulation no. 679/2016, or as the processing is necessary to fulfil a legal obligation to which the data controller is subject.

3. Data retention period

Personal data collected and processed as a result of their submission through the "Careers" section of the www.denora.com website will be retained for the time necessary to complete the selection of personnel and in any case canceled within 6 months, with the exception of those necessary to comply with fiscal, accounting and administrative regulations or to comply with other legal obligations and to document the activities performed.

4. Modalities for data processing

The personal data collected will be stored and processed with electronic tools and will be saved both electronically and on paper, organized in a database, and on any other type of appropriate support.

Specific security measures are followed to prevent data loss, illicit or incorrect use and unauthorized access. The processing of personal data carried out by De Nora does not involve automated decision-making processes.

5. Reporting and providing personal data

The communication and / or the provision of personal data is a necessary requirement to evaluate the professional characteristics of the candidate, and therefore mandatory for this purpose: failure to communicate and / or provide personal data from the data subject, for this purpose, it will make it impossible for De Nora to carry out the candidate’s selection procedure.

6. Entities to whom personal data may be disclosed

The personal data collected will not be disseminated and may be disclosed, not only to individuals who are entitled and the have  interest to access your personal data by law or secondary and / or EU Legislation, but also to the controller’s internal staff, as well as to companies, associations or professional offices that provide services and activities on behalf of the Controller as the Data Processor for the fulfilment of legal obligations, as well as for every organizational and administrative need necessary to provide the services requested. The Data Controller, on the basis of its legitimate interest, may transmit personal data collected on the site to companies belonging to its own business group for internal administrative purposes.

The names of the subjects who can learn about may your personal data as "Data Processors" are listed in an updated list available at De Nora (to be requested at the addresses indicated in point 9).

7. Transfer of data abroad or to international organizations

De Nora does not transfer the personal data of data subjects collected through the "Careers" page of the www.denora.com website and the tools provided therein to international organizations. The Data Controller may transfer to countries outside the EU, to companies belonging to their business group, the data collected following the use of the services provided by the site pursuant to art. 49, par. 1, letter b) of EU Regulation no. 679/2016, or to perform a contract between the data subject and the data controller or the execution of pre-contractual measures taken at the request of the data subject.

8. Rights of the data subject

In relation to the aforementioned data processing, the data subject has the right to exercise at any time the rights provided for by EU Regulation no. 679/2016, including, for example, to obtain the indication:

  • of the data source;
  • of the purposes and methods of processing;
  • of the logic applied in case of processing carried out with the aid of electronic instruments;
  • identifying details of the Data Controller, of the Data Processors and  the appointed representative.

The data subject has the right to obtain:

  • access, updating, correction or, when interested, integration of data;
  • deletion, transformation into anonymous form or blocking of data processed in violation of the law;
  • the limitation of data processing concerning him/her is to ask the data controller or the data processor to reduce the purposes or the manner in which their data are processed.

The data subject may also request a copy of their data in standard format (so-called "Data portability right").

The subject to whom the data refers, finally, is also entitled to object at any time and at no cost, in whole or in part:

  • for legitimate reasons the processing data concerning him, even if pertinent to the purpose of the collection;
  • to the processing of personal data concerning him / her carried out pursuant to Article 6, paragraph 1 of the GDPR, letters e. ("Processing is necessary to fulfil a legal obligation to which the data controller is subject") or f. ("Processing is necessary for the pursuit of the legitimate interest of the data controller or third parties") including profiling on the basis of these provisions.
  • to the processing of personal data concerning him for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication (direct marketing), including profiling in so far as it is connected to it.

The data subject has the right to revoke his / her consent to the processing, when this is based on the hypothesis provided for by the art. 6, paragraph 1, letter a. (when "the data subject has given consent to the processing of their personal data for one or more specific purposes"), or by Article 9, paragraph 2, letter a. (when the data subject explicitly consented to the processing of such personal data for one or more specific purposes) of EU Regulation 679/2016, at any time without prejudice to the lawfulness of the treatment based on the consent given prior to the revocation.

If the data subject  considers that the processing concerning him/her is in violation of the legislation in force, he has the right to lodge a complaint with a supervisory authority, particularly in the Member State in which he/ she usually resides, works or where the alleged violation has occured. The Italian Supervisory Authority can be reached at the addresses on its own website.

9. Data controller - Contact details

The data controller is Industrie De Nora S.p.A., Via Bistolfi, 35, Milan (MI), VAT number 03998870962, in person of the legal representative pro tempore. The Company may also be contacted at the e-mail address industriedenora@denora.com and at PEC industriedenora@actaliscertymail.it.

To exercise the rights listed above, the data subject may make a request using the e-mail account industriedenora@denora.com.

De Nora retains the right to update this Personal Data Processing Policy .