PRIVACY POLICY – AG DIGITAL WEBSITE

This privacy policy includes important information on the protection of your personal data processed by us through our website www.freedamedia.com (“Website”), as data controller, pursuant to Article 13 of Regulation (EU) 2016/679 (General Data Protection Regulation “GDPR”).

Data Controller

The data controller is AG Digital Media S.p.A., with registered office at Corso Italia, No. 22, 20122, Milano, Italy, company number (Codice Fiscale) 09568760962, e-mail address privacy@freedamedia.com (“Data Controller” or “FREEDA”).

Data Protection Officer (DPO)

The Data Controller appointed a Data Protection Officer (“DPO”) who can be contacted via e-mail at dpo@freedamedia.com.

Personal data processed

For the purposes listed in the below section, the Controller will process the personal data that you voluntarily provide through:

• the “Contacts” e-mail address available on the Website;
• the application form available on the Website (such as identification data and contact details, data included in your resume/CV);
• other data collected automatically during navigation.

• Personal data provided by you
  We collect the personal data and contact details that you voluntarily provide us, such as your name, surname and e-mail address, to respond to your requests for information submitted through the "Contacts" e-mail address on the Website.
• Application data
  The data collected refer to the information generally included in your Resume/CV. In addition, information may also be collected from a check of your references (if any) such as membership of any institution, academic background, work history and other information relevant to determine your suitability as a candidate. The Data Controller shall reserve the right to carry out appropriate checks on the accuracy of the data, in particular with regard to qualifications obtained, previous work experiences, and the performance of professional or institutional duties, including by contacting the persons you may have indicated as references, as well as your previous employers.
• Browsing data
  Computer systems and software procedures used for the functioning of the Website may acquire, during their normal operations, some personal data, the transmission of which is an integral part of Internet communication protocols. This information is not collected to be associated with identified data subjects, but, by its very nature, might allow data subjects to be identified by processing and associating such information with data held by third parties. Among the personal data of this category there are IP addresses or the domain names of the devices used by users to connect to the Website, the URI (Uniform Resource Identifier) of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file received as a reply, the numerical code indicating the status of the reply given by the server (successful, error, etc.) and other parameters regarding your operating system and device environment. These data are processed for the sole purpose of obtaining statistical information on the use of the Website and to check its functioning, to allow the proper provision of the various features you requested, to ascertain any liability in case of hypothetical computer crimes; except in this case, these data are deleted after 7 days.

Purposes and legal basis for the processing

Your personal data will be processed to respond to your requests, to manage your job applications, to allow your navigation on the Website and to check its proper functioning, as well as for the purpose of protecting our rights before the judicial authorities or in legal proceedings. In relation to the purposes, the legal grounds for the processing are the performance of a contract or pre-contractual measures, and our legitimate interest

• Manage and respond to your requests for information/services received through the "Contacts" e-mail address on the Website. The legal basis of the processing is the performance of a contract or pre-contractual measures in response to your request.
  You are not obliged to communicate your data for the abovementioned purpose, however, the lack of communication, the consequence is the impossibility to follow up on your requests
• Manage your application received through the "Hiring" section of the Website. The legal basis of the processing is the performance of a contract or pre-contractual measures in response to your application.
  You are not obliged to communicate your data for the above mentioned purpose, however, the lack of communication, the consequence is the impossibility to follow up on your application.
• Allow you to navigate the Website and check its proper functioning. The legal basis of the processing is the performance of a contract or of pre-contractual measures.
  The provision of personal data for this purpose is necessary to allow you to navigate on the Website and to check its proper functioning.
• To exercise or defend a right before the judicial authorities or in legal proceedings. The legal basis of the processing is the legitimate interest of the Data Controller to exercise or defend its rights; the Data Controller has considered that this legitimate interest does not prejudice your rights and freedoms. In this case, you are not required to provide any new and specific data, since the Data Controller will pursue this further purpose, where necessary, by processing the data collected for the abovementioned purposes, which are deemed compatible with this purpose

Methods of processing and data retention period

The processing of your personal data will be based on the principles of lawfulness, fairness, transparency, purpose limitation and storage limitation, data minimisation, accuracy, integrity and confidentiality, in accordance with the GDPR. Your data will be processed through computer and telematic means and are protected by adequate technical and organizational security measures to ensure the respect of the abovementioned principles.We retain personal data only for the time necessary for the purposes for which they were collected or for any other legitimate related purposes. Therefore, if personal data are processed for different purposes, we will retain the data until the purpose with the longer-term ends. In any case, we will no longer process personal data for that purposes for which the retention period has expired. Personal data that are no longer necessary, or for which there is no longer a legal basis for its retention, will be irreversibly anonymised (and thus can be retained) or deleted.

• Personal data processed to manage and respond to your requests are stored for the entire period of time necessary to manage your request and then erased.
• Personal data processed to manage your application (i.e. your Resume/CV) are stored for no longer than 6 months from the collection and then erased.
• Where the data processing is necessary for the purposes of judicial protection, these data are stored for the period for which any claims may be pursued by law.

Categories of data recipients

Your personal data will be processed by persons authorized and trained to process data, who will operate in accordance with the applicable principles and will protect the confidentiality of your data. In some cases, your personal data will be communicated to third parties who/which will act on our behalf as data processors (e.g. companies that provide us with IT support services, cloud services, etc.). You can request the list of the abovementioned third parties to the Data Controller writing to privacy@freedamedia.com.

• employees as persons authorised to process personal data under the direct authority of the Data Controller;
• contractors, consultants and third-party service providers, as well as other entities connected to FREEDA which will process your personal data as data processors or as autonomous data controllers in the event that your application or CV is sent for recruitment or for entering into of a work relationship with one of the entities connected to FREEDA;
• other data controllers, public or private, to which the communication of data is instrumental or compulsory;
• companies that provide us with IT support services for our systems;
• companies that provide us with cloud services;
• authorities to which the right of access is granted by law or regulations (e.g. law enforcement).

Extra-EU Data transfers

The Controller stores personal data on servers located within the European Union. Your data may be transferred in the UK (Third Country considered adequate by the European Commission) if you are applying for an open position based in the UK.

Rights of Data Subjects

In relation to the processing of your personal data you will always be able to exercise your rights under the GDPR (Articles 15-21):

• obtain confirmation of the existence of your personal data and access to their content (right of access);
• update, amend and/or correct your personal data (right to rectification);
• request the erasure or restriction of processing of data processed in breach of law, including those that are no longer necessary in relation to the purposes for which data were collected or otherwise processed (right to erasure and right to restriction);
• in the cases provided for, receive a copy of the data in electronic format concerning you rendered in the context of the contract and request that such data be transmitted to another data controller (right to data portability).

In addition, you have the right to object in whole or in part to the processing of your data (right to object), provided that you meet the requirements of the data protection law.

Should you exercise any of the above mentioned rights, it will be the responsibility of the Data Controller to verify if you are entitled to exercise them, and you will be replied within one month. To exercise the above rights and obtain further information on the processing of your data, you may send an e-mail to privacy@freedamedia.com

Further Rights

If you consider that the processing of your personal data through the Website is in breach of the provisions of the law on the protection of personal data, you always have the right to lodge a complaint with the Italian Data Protection Authority for the protection of personal data (“Garante”).