PRIVACY POLICY (art. 13 EU Reg. 2016/679 “GDPR”)
This policy describes how we handle the personal data of users who visit the website www. https://www.apicallfinance.com (the “Website”).
This policy applies only to the Website and not to any other sites, platforms, links, or social media pages that may be accessible through the Website, which will process user data as independent data controllers.
DATA CONTROLLER
Controller of the personal data of the users of the Website is ApicAll S.r.l. (“ApicAll”), C.F./P.IVA 12165500963, with legal seat in 20139 – Milano (Italy), via Nervesa 21, e-mail: info@apicallfinance.com, PEC: apicall@pec.buffetti.it.
CATEGORIES OF PROCESSED PERSONAL DATA
a) Browsing data:
Collected and processed during each access to the Website and during normal user navigation. Internet protocols automatically record and analyze, without requiring any action from the user, Website access data (e.g., the provider’s IP address, information on the browser used, pages visited, and the date/time of each visit to the Website, as well as Uniform Resource Identifier (URL) addresses, the types of server requests, their responses, etc.).
This data is and remains anonymous and aggregated, and its sole purpose is to obtain statistical information on the use of the Website and to verify its proper functioning. For further information, please see the Cookie Policy
b) Data voluntarily provided by Website users:
Possibly received and processed when users contact ApicAll through the contact channels on the Website. In this case, the processing will be based on the need to respond to their requests.
PURPOSES AND GROUNDS OF THE PROCESSING
a) As to the browsing data:
Processing is carried out based on ApicAll’s legitimate interest in verifying the correct functioning of the Website. Provision of personal data is not mandatory; however, failure thereof may prevent users from exploiting all the Website’s features.
b) As to the data voluntarily provided by Website users:
· if the contact channels on the Website are used by users for general information requests, the processing is carried out pursuant to pre-contractual obligations towards the relevant user; or
· if users use the contact channels on the Website to send to ApicAll unsolicited professional applications, the personal data contained therein (e.g., in a CV) will be processed solely for the purpose of managing and evaluating the application and scheduling a possible interview.
ApicAll will not process, to the extent possible at this stage, any personal data belonging to so-called “special categories” (art. 9 of the GDPR). Providing personal data for this purpose is not mandatory; however, failure in provision may prevent ApicAll from processing the user’s unsolicited application. Providing personal data contained in any presentation documents/in the body of the application email is purely optional, and failure to provide it will have no impact on the application.
DATA RETENTION
a) As to the browsing data:
See Cookie Policy;
b) As to the data voluntarily provided by Website users:
· if the contact channels on the Website are used by users for general information requests, the retention will extend only for the period necessary to process the relevant request; or
· if users use the contact channels on the Website to send to ApicAll unsolicited professional applications, the retention will extend for a period of 12 (twelve) months from receipt of the application itself.
TRANSFERS OF DATA
Personal data will be processed within the European Economic Area.
To the extent necessary for the aforementioned purposes, personal data may also be transferred to other jurisdictions.
In this case, if the transfer occurs to a jurisdiction outside the European Union and the European Economic Area, it will be made to countries that benefit from an adequacy decision from the European Commission. Otherwise, instruments such as “standard contractual clauses” approved by the European Commission or with the user’s consent will be adopted.
Data will not be disclosed or disseminated.
USERS’ RIGHTS
Each user has the right, at any time and to the extent applicable, to:
· obtain confirmation as to whether or not personal data concerning them exists;
· access personal data;
· request rectification, erasure, or restriction of processing;
· object to processing or withdraw consent, if given (which will not affect processing carried out up to that point);
· receive personal data in a structured and readable format;
· request that personal data be transmitted to another data controller (data portability);
· lodge a complaint with the Italian Data Protection Authority, or appeal to the competent judicial authority.
Users are invited to contact ApicAll to exercise their rights or for clarifications regarding the processing of personal data, using the contact details provided in this privacy policy.
UPDATES TO THIS POLICY
ApicAll reserves the right to update this policy from time to time by publishing a new version on the Website.