Anemocyte s.r.l. (“Anemocyte”) with registered office in Italy, Gerenzano (VA), Via R. Lepetit, 34, is committed to protecting the online privacy of the users of its website. As such, this Privacy Policy has been written under Article 13 of EU Regulation 2016/679 (hereinafter, the “Regulation”) in order to allow you to understand Anemocyte’s policy regarding your privacy, as well as how your personal information will be handled when using our website (www.anemocyte.com/ hereinafter “Website”). This Privacy Policy will also provide you with information so that you are able to consent to the processing of your personal data in an explicit and informed manner, where appropriate.
Privacy & Cookie Policy
In general, any information and data which you provide to Anemocyte over the Website, or which is otherwise gathered via the Website in the context of the use of Anemocyte’s services – e.g., request for information under the section “contact us” of the Website (hereinafter, the “Services”) – will be used by Anemocyte in compliance with the Regulation. This means, in particular, that any personal data processing carried out by Anemocyte will respect the principles of lawfulness, fairness, transparency, purpose limitation, storage limitation, data minimisation, accuracy, integrity and confidentiality.
CONTENTS
- Data controller
- Personal Data processed
A – Special categories of Personal Data
B – Data provided voluntarily by the data subject
C – CookieS - Purpose of the processing
- Legal bases and mandatory / discretionary nature of the processing
- Recipients of Personal Data
- Transfers of Personal Data
- Retention of Personal Data
- Data subjects’ rights
- Amendments
1. Data controller
The data controller regarding all personal data processing operations carried out through the Website is Anemocyte, as identified at the start of this Privacy Policy. For any information regarding the processing of Personal Data by Anemocyte, please contact: privacy@anemocyte.com
2. Personal Data processed
As you use the Website, Anemocyte will collect and process information regarding you which will identify you in particular, by reference to an identifier such as a name, an identification number, location data, an on-line ID or to one or more factors specific to the physical, physiological, mental, economic, cultural or social, an identified or identifiable natural person (“Personal Data”).
Personal Data that can be processed by Anemocyte through the Website are as follow:
a. CV and Special categories of Personal Data
If you will submit your CV spontaneously to the e-mail address info@anemocyte.com to apply for a job position at Anemocyte you may provide to the Data Controller Personal Data which may also fall under the category of Personal Data referred to in Art. 9 of the Regulation – i.e. “[…] data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of 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”. Anemocyte asks that you do not disclose any such types of Personal Data through your CV or any other means; if you nonetheless choose to do so, please mind that Anemocyte, complying with the applicable law, requires your explicit consent to process this special category of Personal Data which can be provided, for example, by including in your CV the following: “I give my consent to Anemocyte for the processing of my Personal Data under the special categories referred to in Art. 9 of EU Regulation 2016/679”
We inform you that for the selection of new personnel, Anemocyte uses the Job Agency QJOB S.r.l. who provides its services as an autonomous Data Controller. If you want to send your job application to Anemocyte, you can do it by filling the website form available on https://www.anemocyte.com/#people, expecting that your Personal Data will also be processed from QJOB S.r.l., in accordance with its privacy policy available on their website https://www.qjob.it/privacy/.
When receiving your CV, Anemocyte may assess your professional social media accounts (e.g., LinkedIn) or professional websites, which are publicly available, in order to gain insight to your suitability for the position applied for.
b. Data, also of third parties, provided voluntarily by the data subject
When using some of the Website’s Services, for example if you send a specific request to Anemocyte, Anemocyte will process your Personal Data in order to respond to your request. Such processing is legally based on art. 6(1(b)) of GDPR (“processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”). Also, in some cases you may share Personal Data related to other persons with Anemocyte. In those situations, you will be considered as a data controller regarding that Personal Data and must assume all inherent legal obligations and responsibilities. This means, among other things, that you must fully indemnify Anemocyte against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, brought by the third parties whose information you provide through the Website.
At any case, when you provide or at any case process third parties’ Personal Data using the Website, you must make sure that you have these third parties’ consent or another appropriate legal basis under art. 6 of the Regulation which may allow for a lawful processing of such information before providing any information regarding them to Anemocyte;
c. Cookies
Definitions, characteristics, and application of standards
Cookies are small text files that may be sent to and registered on your computer or your mobile device by the websites you visit, to then be re-sent to those same sites when you visit them again. It is thanks to these cookies that those websites can “remember” your actions and preferences (e.g., login data, language, font size, other display settings, etc.), so that you do not need to configure them again when you next visit the website, or when you change pages within a website. Cookies are used for electronic authentication, monitoring of sessions and storage of information regarding your activities when accessing a website. They may also contain a unique ID code which allows tracking of your browsing activities within a website, for statistical or advertising purposes. Some operations within a website may not be able to be performed without the use of cookies which, in certain cases, are technically necessary for operation of the website. When browsing a website, you may also receive cookies from websites or web servers other than the website being visited (i.e., “third-party cookies”).
There are various types of cookies, depending on their characteristics and functions, which may be stored on your computer for different periods of time: “session cookies”, which are automatically deleted when you close your browser, and “persistent cookies”, which will remain on your device until their pre-set expiration period passes.
Under Italian law, your express consent is not always required for the use of cookies. In particular, “technical cookies” – i.e., cookies used exclusively to transmit messages over an electronic communications network, or otherwise strictly necessary to provide a service explicitly requested by you – do not require your consent. In other words, cookies which are indispensable for the operation of the Website or required to perform activities you request may be used without your consent.
The Italian Data Protection Authority (as defined in its “Determination of simplified procedures for information and collection of consent for the use of cookies”, 8 May 2014, and subsequent clarifications), has established that, among cookies which can be used without consent, the following are included:
- Analytics cookies, when used directly by a website operator to collect information, in an aggregate form, on the number of users and how they use a website, or provided by third parties in an anonymised form by reducing their identification function and by entering into an agreement between the website operator and the third party in which such third party undertakes not to combine the information collected through the provision of the service with other data available to the same third party;
- Browsing or session cookies, to identify and authenticate users of a website;
- Function cookies, which allow users to browse a website according to a series of selected criteria (e.g., a certain language, products selected for purchase, etc.), in order to improve the services provided to those users.
On the other hand, “profiling cookies” – i.e., cookies used to create profiles on users and used to send advertising messages in line with the preferences revealed by users while browsing websites – require users’ prior consent. The Website does not use this type of cookies.
Cookie settings
You can block or delete cookies used on the Website via your browser options. Your cookie preferences will be reset if different browsers are used to access the Website. For more information on how to set the preferences for cookies via your browser, please refer to the following instructions:
3. Purposes of processing
Anemocyte intends to use your Personal Data, collected through the Website, for the following purposes:
a. To complete the provision of the Service you have requested, for example: to respond to support or information requests sent via the section “contacts” of the Website;
b. To analyse CVs submitted and to get in contact with applicants who have submitted their application via the e-mail address info@anemocyte.it;
c. For compliance with laws which impose upon Anemocyte the collection and/or further processing of certain kinds of Personal Data;
4. Legal basis for processing and mandatory / discretionary nature of processing
Anemocyte’s legal basis to process your Personal Data, according to the purposes identified in Section 3 (a-b), is found in art. 6(1)(b) of the GDPR because the processing is necessary to provide the Services or to respond to your requests. It is not mandatory for you to give to Anemocyte your Personal Data for these purposes; however, if you do not, Anemocyte will not be able to provide any Services to you, to respond to your requests or to evaluate your CV. With specific refence to the analysis of your public professional social media accounts identified in the section 2(b), the legal basis to process such Personal Data is art. 6(1)(f) of the GDPR, namely the legitimate interest of Anemocyte to scrutinise the suitability of candidates to fit the specific job position they have applied for.
The legal basis for processing your Personal Data identified in the Section 3(c) is necessary for Anemocyte to comply with its legal obligations according to art. 6 (1)(c) of the GDPR. When you provide any Personal Data to Anemocyte, Anemocyte must process it in accordance with the laws applicable to it.
5. Recipients of Personal Data
Your Personal Data, according to the purpose identified in section 3 above, may be shared, with:
a. Persons who typically act as data processors on behalf of Anemocyte, namely: i) persons, companies or professional firms providing Anemocyte with advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services; ii) entities engaged in order to provide the Services (e.g., hosting providers or e-mail platform providers); iii) persons authorised to perform technical maintenance (including maintenance of network equipment and electronic communications networks) (collectively “Recipients”);
b. Public entities, bodies or authorities to whom your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities;
c. Persons authorised by Anemocyte to process Personal Data needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of Anemocyte)
6. Transfers of Personal Data
Some of your Personal Data may be transferred to Recipients located outside the European Economic Area. Anemocyte implements appropriate safeguards to ensure the lawfulness and security of these Personal Data transfers, such as by relying on adequacy decisions from the European Commission, standard data protection clauses adopted by the European Commission, or other legal basis. More information on these transfers is available upon written request to Anemocyte at the following address: privacy@anemocyte.com
7. Retention of Personal Data
Personal Data processed for the purposes identified in sections 2 (b) will be kept by Anemocyte for one month and subsequently, it will be deleted. In any case, as these Personal Data are processed for the provision of the Services, Anemocyte may continue to store this Personal Data for the period under which consent is still valid, according to Italian law, in order to guarantee its interest (art. 2946 c.c. e ss). With respect to the CV submitted through the e-mail address info@anemocyte.it of the section 2(a), they will be kept by Anemocyte for as long as the vacancy for which the CV was submitted is still available or, in case of spontaneous applications, for up to 2 years. Anemocyte may contact applicants before the expiration of this period, in order to request an extension of the retention period.
Personal Data identified in section 3(c) will be kept by Anemocyte for the period required by the specific legal obligation or by the applicable law.
For any other information concerning the period of retention and the criteria used by Anemocyte to decide and conclude to this period, Anemocyte is available to further inform you by writing an email at the following address: privacy@anemocyte.com.
8. Data subjects’ rights
According to the articles 15 to 21 of the GDPR, you have the rights to request from Anemocyte, at any time, to access your Personal Data, to correct, rectify and update them, to erase, or to object to the processing of them. Also, you have the right to request the restriction of the processing of your Personal Data in the cases mentioned by art. 18 of the GDPR and to obtain a copy of your Personal Data provided to Anemocyte, in a structured, commonly used and machine-readable format in the cases, as well as the transmission of that Personal Data to another Data Controller, as provided by art. 20 of the GDPR.
You can always exercise your rights described above by sending a written request to Anemocyte at the following address: privacy@anemocyte.com.
In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data (Personal Data Protection Authority), according to art. 77 of the GDPR, if you believe that the processing of your Personal Data carried out through the Website is unlawful.
9. Amendments
This Privacy Policy entered into force on October 17th 2018.
Anemocyte reserves the right to partly or fully amend this Privacy Policy, or simply to update its content, e.g., as a result of changes in applicable law. Anemocyte will inform you if the amendment of this Privacy Policy concerns substantial changes of the Personal Data proceeding or could have high impact on you.
