Privacy Policy

This page outlines the way in which this site manages the processing of personal user data. The following statement is made in accordance with Article 13 of the EU Regulation 2016/679 which came into force on May 25th 2018 – the General Data Protection Regulation (subsequently to be referred to as the GDPR) for all those using Konvergence services online, which can be accessed at https://www.konvergence.it/

The information set out here applies only to the site www.konvergence.it and does not cover any other websites which users may consult via links for which Konvergence S.r.l. bears no liability.

DATA CONTROLLER

In accordance with Article 4 point 7) of the GDPR 2016/679, the DATA CONTROLLER is Konvergence S.r.l. with registered offices in Via Nazionale, 111/B – 65012 Villanova di Cepagatti (PE), which can be contacted by phone: 0874 775816 or email: info@konvergence.it.

DATA PROTECTION OFFICER (DPO)

Konvergence S.r.l. in compliance with Article 37 of the GDPR 2016/679 has nominated a Data Protection Officer (DPO). The DPO is the main point of contact within the company for all matters regarding privacy legislation, including the protection of personal data and compliance data protection rights. The DPO can be contacted as follows: email: dpo@konvergence.it.

LOCATION OF DATA PROCESSING

Processing relating to the web services for this site takes place at the premises of the owner and is solely handled by officially authorised in-house personnel.

TYPES OF DATA PROCESSED

Browsing data

During the routine course of operation, the computer systems and software processes used to run this website gather various types of personal data, the transmission of which is implicit in the use of Internet communication protocols. Such information is not gathered in order to be associated with identified individuals, but by its very nature could, through processing and association with data held by third parties, make it possible to identify users. This range of data includes the IP addresses or domain names of any computers employed by users who connect to the site, the URI (Uniform Resource Identifier) addresses of the required resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating systems and IT systems of users. Such data is used solely for gathering anonymous statistical information on the use of the site and checking that this is working correctly, this data is deleted immediately after processing. Data may also be used to ascertain liability in the event of any potential computer crimes perpetrated against the site: with the exception of this case, data on web contacts is currently not stored for more than thirty days.

Data voluntarily supplied by users

The optional, explicit and voluntary communication of user emails to the addresses provided on this site entails the subsequent collection of their addresses, necessary for answering user queries, as well as any other personal data included in such messages. Specific summaries of information will be progressively reported or displayed on the pages of the site set up for special services on request.

The voluntary compilation of data acquisition forms to request information, register or book activities entails the subsequent processing of the personal data provided in order to ensure the fulfilment of a contract to which the user in question is party, or the execution of pre-contractual measures at the request of the individual concerned.

In the context of processing activities carried out by the Data Controller, there is no need to process any personal data from the special categories set out in Article 9 (1) of the GDPR such as data relating to health, for example. Users are therefore invited not to provide such types of personal data.

The company has taken specific measures to ensure that the processing of data is preceded by confirmation by users that they have read this privacy policy.

COOKIES

See Cookie policy

MEANS OF PROCESSING

Personal data is processed using computers and other IT tools for the time needed to achieve the purposes for which data is being gathered. Strict security measures are in place to prevent loss of data, or illicit or incorrect use and unauthorised access.

PURPOSE, LEGAL BASIS AND NATURE OF CONFERMENT

The Personal Data provided by users through the website in question will be processed by KONVERGENCE S.r.l. for the following purposes:

  1. to request information or to book an appointment via the “Contact Us” form to find out about company activities, products and services. The legal basis for such processing is based on Article 6 paragraph 1 letter b) of the GDPR 2016/679, i.e. the processing is necessary for the execution of pre-contractual measures at the request of the user. Consent Not Required;
  1. to sign up for the Konvergence S.r.l. Newsletter and receive regular promotional or sales communications. The legal basis of this processing is based on Article 6 paragraph 1 letter a) of the GDPR 2016/679, i.e. this type processing requires explicit User Consent;
  1. for purposes related to the selection of personnel upon the receipt of CVs and personal data relating to application forms in the “Work With Us” section for the evaluation of a potential job application at the company. This legal basis is based on Article 111 bis of Legislative Decree 196/2003 and in accordance with Article 6 paragraph 1 letter a) of the GDPR 2016/679 and requires explicit User Consent;
  1. in order to use the services offered online via the website limited to authorised suppliers. The legal basis for the processing is based on Article 6 paragraph 1 letter b) of the GDPR 2016/679, i.e. the processing is necessary for the performance of a contract to which the user is party. Consent Not Required;
  1. for the purposes of research and statistical analysis on anonymous aggregate data, aimed at measuring the proper working of the Site, measuring traffic and assessing usability and interest in order to make it more functional and efficient; Consent is not required given that no processing of personal data takes place;
  1. for purposes relating to compliance with laws and regulations. The legal basis is Article 6 (1) (c) of the GDPR 2016/679 i.e. the processing is necessary for compliance with a legal obligation to which the Data Controller is subject. Consent Not Required.
  1. for purposes necessary for establishing, exercising or defending company rights in court or whenever judicial authorities exercise their duties. The legal basis is Article 6 (1) (f) of the GDPR 2016/679 i.e. the processing is necessary for the pursuit of the legitimate interest of the Data Controller. Consent Not Required.

TRANSFER OF PERSONAL DATA TO NON-EU COUNTRIES OR INTERNATIONAL ORGANISATIONS

The Data Controller undertakes to restrict the areas of circulation and processing of personal data (e.g. storage, archiving, conservation of data on its servers) to countries belonging to the European Union, with an express ban on transferring such data to any non-EU countries which do not guarantee (or in the absence of) an adequate level of protection, i.e., in the absence of protective measures provided for by EU Regulation 2016/679 – CHAPTER V (adequacy ruling, Standard Contractual Clauses, Binding Corporate Rules or explicit consent by the data subject) or adherence to the EU-US Data Privacy Frameworks.

Further information and clarification may be obtained by consulting the Konvergence S.r.l DPO.

DATA STORAGE

Konvergence S.r.l. will process personal data for the time strictly necessary to fulfil the purposes set out in this notice.

By way of example, although not limited to just this example, Konvergence S.r.l. will process personal user data unless the user opts to cancel the service by simply clicking on the unsubscribe link in the email received.

Query messages will be deleted within a month after they have been sent.

Any CVs sent will be held on record for up to 24 months.

With the exception of those examples cited above, Konvergence S.r.l. will process personal data for as long as it is permitted by Italian law to protect its interests (Art. 2947(1)(3) Civil Code).

Further information concerning the period of storage for Personal Data and the criteria used to determine that period may be obtained upon request by writing to the DPO.

PROCESSING CVS

The following statement which has been drawn up in keeping with Article 13 of the GDPR 2016/679, may be used by Konvergence S.r.l. for any listings published for the purpose of recruitment on sites or portals not directly managed by Konvergence S.r.l.

The company will process CVs received by email or through third-party recruitment companies (publications on portals, etc.) in order to evaluate potential applications within the company or any which may come up in the near future.

Processing will be carried out electronically with the exception of any hardcopy CVs sent by mail.

Any CVs of interest to the company will be stored at the company’s premises for a period of no longer than 24 months and will be processed in full compliance with the security measures provided for in Article 32 of the GDPR 2016/679.

All those CVs deemed to be unsuitable as well as those that have been stored for up to 24 months will be deleted.

The same CVs may be evaluated by HR or those nominated and authorised to process them

(ex art. 29 and 32 paragraph 4 of the GDPR 2016/679 and art. 2-quaterdecies of Legislative Decree 196/2003).

When it comes to compiling CVs, candidates are requested to kindly adhere to the following rules:

  • compile the CV using the European format CV
  • submit the CV as a pdf
  • avoid including any details set out in special categories of personal data in the CV as defined by Article 9 of the GDPR 2016/679 (relating, in particular, to health status, religious, philosophical or political beliefs) that are not relevant to the job offer
  • give consent to the processing of special categories of personal data relating to health status as defined in Article 9 of the GDPR relevant to the establishment of an employment relationship (e.g. membership of protected categories).

The company reserves the right to delete any CVs which do not meet the above requirements.

Any processing related to the handling of CVs will involve activities strictly related to the evaluation, recruitment or selection of personnel, with the aim of collaboration, recruitment on a fixed-term or open-ended basis, internships, or to enable successful candidates to work on their dissertations at our Offices.

In keeping with Article 111-bis of Legislative Decree 196/2003, the information referred to in Article 13 of the GDPR, in cases of receipt of CVs voluntarily submitted by interested parties for the purpose of entering into employment, is provided at the time of the first useful contact, upon submission of the CV.

AUTOMATED PROCESSING AND PROFILING

The Data Controller does not conduct any automated processing, including profiling, on personal data gathered via forms on this website.

For any profiling activities carried out via cookies, please refer to the relevant Cookie Policy.

RIGHTS OF INTERESTED PARTIES

Those who have submitted personal data have the right at any time to obtain confirmation of the existence or non-existence of such data and to be informed of its content and origin, verifying its accuracy or request that this be integrated, updated, or corrected (Chapter III GDPR 2016/679). In accordance with the same article, users have the right to request the deletion, transformation into an anonymous form or blocking of data processed in violation of the law, as well as to oppose in any case, for legitimate reasons, the processing of their data. Any such requests should be addressed to Konvergence S.r.l. with registered office Via Nazionale, 111/B – 65012 Villanova di Cepagatti (PE) for the attention of the Data Protection Officer.

Users may freely exercise their rights under Articles 15 et seq. of the GDPR 2016/679, which we cite in full, in other words users may:

  • withdraw consent at any time. Users may revoke the consent previously given for the processing of their Personal Data;
  • object to the processing of their Data. Users may object to the processing of their Data when this is done on a legal basis other than consent;
  • access their Data. Users have the right to obtain information on the Data processed by the Controller, on certain aspects of the processing and to receive a copy of the Data processed;
  • verify and request of rectification. Users may verify the veracity of their Data and request that this be updated or corrected;
  • obtain the limitation of processing. Under certain conditions, Users may request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any purpose other than that of its retention;
  • obtain the deletion or removal of their Personal Data. Under certain conditions, Users may request the deletion of their Data by the Data Controller;
  • receive their Data or have it transferred to another data controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to have this transferred without hindrance to another controller. This provision is applicable when the Data is processed by automated means and the processing is based on the Users’ consent, on a contract to which the Users are party or on contractual measures related thereto;
  • object to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or which affects them in a similarly significant way.

Requests should be addressed to the Data Protection Officer, who can be contacted at the following e-mail address: dpo@konvergence.it

RIGHT OF COMPLAINT

Any interested parties who consider the processing of personal data relating to them carried out on this site to be in breach of the provisions set out in this Regulation have the right to lodge a complaint with the Personal Data Protection Authority, as provided for in Article 77 of the Regulation itself, or to take legal action (Article 79 of the Regulation).

UPDATES AND REVISION

This privacy policy was updated on 11 October 2023 and may be subject to further revisions in the future.