PRIVACY PROTECTION POLICY WITH REGARD TO THE WWW.K23.IT WEBSITE
- Types of Data collected
- Mode and place of processing the Data
- The purposes of processing the Data
- Detailed information on the processing of Personal Data
- The rights of Users
- Additional information about Data collection and processing
- Definitions and legal references
TYPES OF DATA COLLECTED
Among the types of Personal Data that we collect through a Contact Form or if the User decides to send their curriculum vitae, are: first name; last name; email address; postal address; place of work or study; as well as cookies and usage data.
We will also confirm whether you have any relatives or close connections working at K23 so that we can consider potential conflict of interests and if identified how to manage these, in accordance with our statutory and regulatory obligations.
Personal Data may be freely provided by you, or, in case of Usage Data, collected automatically when using this site.
Users are responsible for any third-party Personal Data obtained, published or shared through this site and confirm that they have the third party’s consent to provide the Data to us.
MODE AND PLACE OF PROCESSING THE DATA
Methods of processing
K23 takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to us, in some cases, the Data may be accessible to certain types of persons in charge, involved with the management of this site (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by us. The updated list of these parties may be requested from us at any time.
Legal basis of processing
K23 may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes;
- Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- Processing is necessary for compliance with a legal obligation to which K23 is subject;
- Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in K23;
- Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at K23’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by K23 to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with K23 using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
- Personal Data collected for purposes related to the performance of a contract between K23 and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of K23’s legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by K23 within the relevant sections of this document or by contacting us.
K23 may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, K23 may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
THE PURPOSES OF PROCESSING THE DATA
The Data concerning the User is collected to allow K23 to: Contacting the User, Assess Professional Candidates, Platform services and hosting and Analytics.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
DETAILED INFORMATION ON THE PROCESSING OF PERSONAL DATA
Personal Data is collected for the following purposes and using the following services:
Contacting the User and Provide Information requested
Contact link (link)
By filling in the e-mail with your Data, you authorize K23 to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s sections.
Personal Data collected: email address; first name; last name.
Assess Professional Candidates
Work with us
Platform services and hosting
These services have the purpose of hosting and running key components of this website, therefore allowing the provision of this website from within a unified platform. Such platforms provide a wide range of tools to K23 – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
WordPress.com (Automattic Inc.)
WordPress.com is a platform provided by Automattic Inc. that allows K23 to build, run and host this website.
The services contained in this section enable K23 to monitor and analyse web traffic and can be used to keep track of User behaviour.
WordPress Stats (Automattic Inc.)
WordPress Stats is an analytics service provided by Automattic Inc.
Personal Data collected: Cookies; Usage Data.
THE RIGHTS OF USERS
Users may exercise certain rights regarding their Data processed by K23.
In particular, Users have the right to do the following:
- Withdraw their consent at any time.Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data.Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data.Users have the right to learn if Data is being processed by K23, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification.Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data.Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, K23 will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed.Users have the right, under certain circumstances, to obtain the erasure of their Data from K23.
- Lodge a complaint.Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in K23or for the purposes of the legitimate interests pursued by K23, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether K23 is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to K23 through the contact details or by writing to email@example.com. These requests can be exercised free of charge and will be addressed by K23 as early as possible and always within one month.
ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING
The User’s Personal Data may be used for legal purposes by K23 in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.
The User declares to be aware that K23 may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data
System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from K23 at any time. Please see the contact information at the footer of this Website.
How “Do Not Track” requests are handled
This Website does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Should the changes affect processing activities performed on the basis of the User’s consent, K23 shall collect new consent from the User, where required.
DEFINITIONS AND LEGAL REFERENCES
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Website) and the details about the path followed within the Website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
Data Controller (K23)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
The means by which the Personal Data of the User is collected and processed.
The service provided by this Website as described in the relative terms (if available) and on this site/website.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Small sets of data stored in the User’s device.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
Latest update: August 27, 2019