Policy on the processing of applicant personal data Art. 13 and 14 GDPR 679/2016 Compliant

The company Pro Gamma S.p.A., pursuant to art. 13 of EU regulation 2016/679 “European regulation on the protection of personal data” as well as pursuant to and in accordance with the “Code regarding the protection of personal data”, integrated with modifications introduced by Italian Legislative Decree 10 August 2018, #101, is required to provide specific information on the processing of your personal data regarding the rights due to persons who submit their application for hire by the Controller (“Applicants”). We therefore invite you to read carefully the information that follows.


1. Data controller

The Data Controller, meaning the subject with decision-making authority over purposes of processing, methods of processing personal data, and the tools that will be used, is Pro Gamma SpA, with registered offices in Bologna, Italy in Via D’Azeglio Nr. 51, tax code and VAT number 01985091204, Tel. +39 051.538429 Fax: +39 051.6014132 – E-mail: privacy@instantdeveloper.com – Pec: amministrazione@pec.progamma.it


2. Purposes of the processing / Legal basis for the processing

All data that you provide are collected and used within the limits established by the law and the regulations regarding the processing of personal data, and are processed for the following purposes with the corresponding legal basis:


1. Purposes regarding evaluation of the CV, recruitment, and/or selection of personnel and professionals, in order to evaluate professional submissions received.

Legal basis

1. Conferral of this data has as its legal basis the pre-contractual obligations between the data subject and the Controller under point b) of article 6.1 of the GDPR. Any special data will be processed in accordance with point a) of article 9 of the GDPR.

The processing of data for these purposes is necessary to correctly manage the relationship, and their conferral is optional but necessary to fulfill the purposes indicated above. Any refusal to provide your data will result in a failure to establish the relationship, conduct it correctly, or to fulfill possible legal obligations. In the event that the data you provide is incomplete or incorrect, the correctness of the processing cannot be guaranteed.


3. Categories of data processed

The processing concerns or can concern the following categories of data: personal information, domiciliary data, contact information (email and telephone number), information regarding the applicant’s educational and professional history (curriculum vitae) as well as other data entered here at the applicant’s discretion exclusively to fulfill the purposes of this processing. If the applicant enters it, processing may also involve special information (such as belonging to protected categories of workers) strictly useful for and limited to achieving the purposes indicated.


4. Processing methods for Personal Data

Your data will be processed at the Controller’s premises (or if it should be necessary, at the premises of the subjects indicated in item 6) using paper and electronic instruments on the basis of principles strictly correlated with the purposes and in such a way as to ensure the security and confidentiality of those data. These instruments are organized in order to reduce to a minimum the risk of data distribution or loss, unauthorized access to them, or processing that is not compliant with the purposes described in this policy.

Your data are collected exclusively for the purposes described above. Said data are adequate, pertinent, complete, and do not exceed the purposes of the processing; if necessary, they may be updated to consistently ensure their accuracy. Please be advised also that no automated decision-making process concerning your information will be performed, and no profiling regarding your person will be done.


5. Data Storage Periods

Your information will be saved for the period necessary to achieve the purposes, save for the exercise of the rights listed below. In any case, the Controller and processors it designates may also store your data for an additional period solely for the purposes of fulfilling specific legal obligations, and upon the end of this period arrange for their deletion. The storage period is generally set at 1 year.


6. Categories of Subjects with which data may be shared or who may come to have knowledge of it as processors or authorized entities

In order to pursue the purposes described above, the personal data will be processed by the Data Controller, by the Processors it nominates, and those nominated as authorized for processing.Your data may be shared for the sole purpose of permitting the fulfillment of the purposes:

  1. Subjects whose authority to access the data is recognized by law, secondary legislation, and EC regulations;
  2. Collaborators, employees, suppliers, and consultants of the Controller, in the area of their corresponding responsibilities and/or contractual obligations where applicable, including Processors and those Authorized;
  3. Physical and/or legal persons, public and/or private, when the communication is necessary or functional to the performance of the Controller’s activity or to execution of the contract in the ways and for the purposes illustrated above;

Your data are not subject to further circulation.


7. Transfer of Data to a Third Country

Personal data will not be transferred to third parties outside the EU. In the event that, for new reasons connected to achieving the purposes, meaning fulfilling the law, it should become necessary to transfer to a country and/or international organization outside the EU, said transfer will take place in observance of the conditions set by the GDPR, and if necessary, subject to consent from the data subject.


8. Data subjects’ rights

Please be informed that the law assigns to you specific rights listed in art. 15 and ff of the GDPR, which you can exercise at any time, including: to know whether or not your personal data exist, and how they will be used; to request their deletion, anonymization, or to block data processed in violation of the law as well as that they be updated, rectified, or, where interested therein, integration of the data and to oppose the processing itself for legitimate reasons, as well as to oppose, in full or in part, for legitimate reasons, to the processing of personal data about you even if they are pertinent to the purpose of the collection, by contacting our Company, at the number +39 051.538429, or by fax to the number +39 051.6014132.

In any event requests under this section can be presented in writing via electronic mail sent to the address privacy@instantdeveloper.com, or via certified email (Pec) to the address amministrazione@pec.progamma,it, or by postal mail to: Company “Pro Gamma SpA”, with registered offices in Italy, Bologna (BO) – 40123 – Via D’Azeglio #51.

You will always have the right to submit a complaint with the Italian Privacy Authority, located in Piazza Venezia # 111 – 00186 Rome (RM), Italy – Tel. +39 06 696771 – Email: garante@gpdp.it – Certified email: protocollo@pec.gpdp.it.

We also inform you that the company Pro-Gamma SpA has arranged for the nomination of the DPO – Data Protection Officer – as the Attorney Giovanni Crocetti Bernardi, the individual with whom you can exercise your rights, as well as ask any question regarding the protection of personal data, with the following contact information: Via De Gasperi Nr. 5 – 48121 – Ravenna (RA), Italy, email: dpo@instantdeveloper.com, pec: gcrocetti@pec.it.