Euren InterSearch S.R.L. DATA PROTECTION POLICY
Notice pursuant to Art.  13 of  EU Regulation 2016/679 (GDPR) on the processing of personal data acquired through the website www.intersearch.it

GENERAL PRINCIPLES

Having regard to the specific nature of its business, Euren InterSearch S.R.L. (“Euren”) considers the protection of the personal data of its stakeholders (such as customers, candidates, employees, suppliers and partners) to be of fundamental importance and a key strategic factor in achieving its mission.

For this reason, Euren has put in place a system to comply with and adhere to the principles and provisions of EU Regulation 679/2016. In all processing carried out by it as the Data Controller, Euren ensures that the data are:

1. processed lawfully, fairly and in a transparent manner in relation to the data subject (“lawfulness, fairness and transparency”);
2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (“purpose limitation”);
3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (“data minimisation”);
4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (“accuracy”);
5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (“storage limitation”);
6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (“integrity and confidentiality”).

COMMITMENT FROM MANAGEMENT

In order to achieve the above principles, Euren organises its business and organisation by adopting appropriate technical and organisational measures, which are periodically reviewed by management to ensure that they are effective and efficient in achieving the purposes for which they were designed.

The Company ensures that measures are put in place and reviewed periodically with a view to continuous improvement, including by drawing on the support of external consultants with proven professional skills.

COLLECTION OF PERSONAL DATA

Euren InterSearch srl (whose registered office is in Corso Marconi 13 – 10125 Turin, tax code and VAT no. 04953990019, e-mail euren@intersearch.it) as Data Controller of the data collected through its website www.intersearch.it  provides data subjects with the following information pursuant to Art.  13 of EU Regulation 2016/679.

Legal basis for processing
The personal data of users who visit our website are processed on the basis of the user’s request to make use of the website’s content by accessing it. Processing also takes place on the basis of the user’s consent, which is expressed, for example, through the tools on the home page of our website with reference to cookies (options on the banner) or in any forms provided for specific contact purposes.

Navigation data
During their normal operation, the computer systems and software processes used to operate the www.intersearch.it website collect certain data, the transmission of which is inherent in the use of Internet communication protocols. This information is not collected for the purpose of associating it with identified data subjects, but by its very nature could, through editing and association with data held by third parties, make it possible to identify users.

This category of data includes the IP addresses or domain names of the computers used by users connecting to the website, the URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used in submitting 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 User’s operating system and computer environment.

These data are used for the sole purpose of obtaining anonymous statistical information on website usage and to check that the website is working properly, and are deleted immediately after processing.
The data could be used to ascertain responsibility in the event of hypothetical computer offences against the website.

Cookies and other tracking systems
For our cookie policy and to find out about the types of cookies we use, please read the specific information available at the following link: Cookie Policy.

Data for the delivery of business services
Euren collects personal data from its customers, suppliers, employees and candidates for the purposes of recruitment and selection, training and consulting, and for the management of its business processes. In such cases, Euren always provides data subjects with complete and specific information regarding the processing carried out on their data by the Company, ensuring that the processing is always supported by an appropriate legal basis.

With specific reference to research and selection activities, Euren ensures that the advertisements published in the specific section of its website contain the appropriate form for providing information and, where necessary, obtaining consent.

Unsolicited contact with the Company
If, for any reason, data subjects contact the Company by e-mail at euren@intersearch.it, Euren may use their personal data for the following purposes:
a. to respond to the data subject’s request, including by providing information about the Company and the services provided;
b. to send noncommercial informational communications (newsletters).

For the purposes referred to in point a., Euren informs data subjects that their data (name, surname, contact details, other personal data included in communications) will be processed only to the extent necessary to process the requests submitted and for the time strictly necessary, which may be determined on the basis of the specific request. If the Company decides not to respond to a request for information, any data relating to the data subject will be deleted without delay. The legal basis for processing data used for the purposes referred to in point a. is the request by the data subject to be contacted by the Company (Art. 6, paragraph 1, letter b of the GDPR).  

The processing referred to in point b. is based on the data subject’s request to receive a free service (Art. 6, paragraph 1, letter b. of the GDPR) or, if sent to customers who already receive newsletters relating to services similar to those already used, on the legitimate interest of the data controller (Art. 6, paragraph 1, letter f. of the GDPR).    Data subjects’ personal data will be processed until such time as consent is revoked by the data subject or if the “opt-out” option is exercised.

The data will be processed only by the Data Controller and any authorised data processors, using both paper and electronic means. For a list of these entities, please contact the Data Controller by any written means of communication. The personal data collected are also processed by the data controller’s authorised staff, who act on the basis of specific instructions regarding the purposes and methods of processing.

For candidates: please send your CV or application using only the specific form in the Executive Search / Open positions section to the following address: https://eurenintersearch.intervieweb.it/it/career

Any data on applications not submitted through the dedicated channels will be deleted.

DATA SUBJECT RIGHTS

Within the scope of the processing carried out by Euren, the data subject will always have the right to obtain from the data controller access to their personal data, including confirmation as to whether or not personal data concerning them exist and the provision of such data in an intelligible and portable form. Specifically, the data subject shall have the right to obtain:

1. a) information on the origin of the personal data;
   b) information about the purposes and methods of processing;
   c) information about how the data will be processed if processed electronically;
   d) the updating, rectification or supplementation of data;
   e) the erasure of data or the restriction of processing of data concerning the data subject (conversion into anonymous form, restriction of processing of data processed in breach of the law, including data that does not need to be retained for the purposes for which it was collected or subsequently processed);
   f) the right to obtain confirmation that the updating, rectification, supplementation and erasure of data have been brought to the attention of those to whom the data were disclosed, including as regards their content, except where this proves impossible or involves disproportionate effort compared to the rights being protected.

The data subject also has the right to object to the processing, even if only in relation to specific purposes, and to request data portability.

The data subject has the right to revoke consent to the processing of personal data at any time by sending a simple written notice. In cases where consent is the only legal basis for processing, withdrawing consent will no longer allow personal data to be used for research and selection purposes, and the data subject will therefore not be able to receive any services aimed at finding a work position. In any event, withdrawing consent to processing does not affect the lawfulness of processing based on consent given prior to withdrawal.

The data subject has the right to lodge a complaint with the Supervisory Authority, which in Italy is the Garante per la Protezione dei Dati Personali (Personal Data Protection Authority). For further information, data subjects are invited to visit the Authority’s website at www.garanteprivacy.it.