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INFORMATION ON THE PROCESSING OF PERSONAL DATA

This privacy policy ("Policy"), made pursuant to Articles 13 and 14 General Data Protection Regulation (EU) 2016/679 ("Regulation" or "GDPR"), describes the processing of your personal data put in place company Studio Woow Italia S.r.l. ("SW", the "Company" "we", "our") in the capacity of data controller.

In particular, this Notice is intended to explain to you how we process information about you ("Personal Data") that you transmit to us or that we collect about you as part of your browsing on the website www.studiowoow.com (the "Site") and for Studio Woow's newsletter service to which you may optionally subscribe through the Site (the "Newsletter").

This notice is also intended to explain how information about you is processed for the purpose of applying for job positions within Studio Woow through the dedicated "Work with Us" area.

DATA CONTROLLER

Pursuant to this Notice and the treatments taken into account by it, the Data Controller (ex art. 4, no. 7 of the Regulations) is Studio Woow with registered and administrative office in Milan, Via Francesco Soave 24a (Cap 20136).

DATA PROCESSED, PURPOSES AND LEGAL BASIS FOR PROCESSING, RETENTION PERIODS

Through the Site, SW may process the categories of Personal Data relating to you indicated in this paragraph, in pursuit of the purposes and based on the legal bases described below.

Data you provide when you contact us
Categories of Personal Data processed

When you decide to contact us through the contact channels indicated on the Site (e-mail, toll-free number, pec, postal address) we may acquire and process Personal Data about you such as:

Biographical information (e.g., first and last name);
Contact Information (phone number, e-mail address, fax, mailing address);
Other Personal Data you provide when contacting us (e.g., information and/or multimedia content contained in your messages).
Purposes of processing

Personal Data provided to us in such circumstances will be processed for the purpose of providing a response to your requests.

Legal basis for processing

The legal basis for the processing described in this section is your consent. In this regard, the circumstance that you decide to contact us for an inquiry will be considered an unequivocal positive action equivalent to a written declaration of consent within the meaning of Article 4, No. 11 of the GDPR.

Consequences of not providing Personal Data

Providing the data described in this paragraph is necessary, and without it, we will not be able to provide a full response to your requests.

Retention period

Your Personal Data will be kept for the period of time strictly necessary to provide a response to your request. In any case, SW-as well as our vendors who handle requests forwarded to us-has set up its professional e-mail systems so that old correspondence is deleted two years after the last interaction.

Your Personal Data may be kept for a longer period if this is necessary to fulfill a legal obligation or to exercise our right before a judicial, administrative or other authority.

Newsletter Subscription
Categories of Personal Data processed

When you subscribe to our Newsletter, SW may collect and subsequently process the following Personal Data:

Biographical information (first name, last name);
Contact information (e-mail address, phone number);
Name or company name of your employer (in case you use a professional e-mail address to subscribe to the Newsletter).
Purposes of the processing

The Personal Data referred to in this paragraph will be processed to send you communications about SW's services, projects and activities within the Newsletter.

Legal basis of processing

The legal basis for the processing described in this paragraph is your consent under Article 6(1)(a) GDPR.

Consequences of not providing Personal Data

The provision of the data described in this paragraph is purely optional and its absence will not affect your use of the Site or prevent you from benefiting from SW's services but only from receiving SW's Newsletter communications.

Retention period

Your Personal Data will be retained until the end of 24 (twenty-four) months from the time you have given your consent to its processing. Upon the expiration of this period, SW will request the renewal of your consent for an additional period of 24 (twenty-four) months and, if you refuse, will promptly delete your Personal Data.

Applications for job positions
Categories of Personal Data processed

When you apply for job positions within SW, including by using the services of SW's third party partners, and throughout the selection process, SW may collect and subsequently process the following Personal Data:

Biographical information (first name, last name, date of birth and residence);
Contact information (e-mail address, phone number);
Personal photograph/portrait (where attached to CV);
Data related to your qualifications, education and professional career;
Any other information that you decide to provide to us during the application process (e.g. by sending your CV) and during any subsequent selection process. Among this information, there may be special categories of data under Article 9 GDPR, i.e. information that may reveal your health conditions, religious beliefs, membership in trade unions and political opinions, sexual orientation (also "Sensitive Data").
Purposes of the processing

The Personal Data reported in this paragraph will be processed for the purpose of assessing whether your profile may be in line with SW's professional needs and to make selections to that effect among various candidates.

Legal basis of processing

With regard to your Common Personal Data, the legal basis on which the relevant processing is based is the execution of pre-contractual measures aimed at the establishment of a possible employment relationship between you and SW (Art. 6(1)(b) GDPR).

The processing of your Sensitive Data, on the other hand, is based on your consent (Art. 6(1)(a) GDPR), which will be appropriately requested from you.

Need for the provision of your data

The provision of your common personal data is necessary and without it SW will not be able to evaluate your application for job positions within the Company.

With regard to Sensitive Data, failure to provide your consent will not preclude SW from evaluating your profile without considering such data, with the exception of particular selections in which the possession of such Sensitive Data is to be considered indispensable (e.g., selections related to protected categories).

Retention period

The personal data you provide to us in response to advertisements for specific job positions within SW will be kept for the period necessary to carry out the selection activities for the specific position for which you have applied and, in any case, for no more than two years after the end of the selections in question. In the case of a spontaneous application, SW will promptly delete your data in the event that there are no open job positions or your profile is not deemed to be in line with SW's professional needs.

With your consent, SW may extend the retention of your data with a view to future employment opportunities within the Society.

Retention periods for your personal data may also be extended if this is necessary to fulfill a legal obligation or for the protection of our rights.

Navigation data

When you visit the Site, we collect the following browsing data:

Technical information, including IP address, information about devices used by visitors to the Site, browser and operating systems, etc.
Site browsing information, including URLs of pages visited and activities that are performed on the page, dates and times of browsing, time spent on the Site, clickstream

This information is collected for the proper operation, management, maintenance and improvement of the Site, as well as to ensure that your browsing is safe and to be able to ascertain liability in the event of cyber-security breaches. It is also used to enable us to obtain statistical analysis of the use of the Site with the possibility of analyzing the data also in aggregate form and to enable you to receive promotional announcements in line with your desires and interests.

You are always free to decide whether to provide us with your browsing information, for example by choosing to disable cookies through your browser settings or our cookie policy. However, refusal to provide information necessary for browsing purposes may make it impossible to carry out activities strictly related to the browsing itself and, therefore, also to consult and interact with our Site.

We keep such data only as long as is strictly necessary for the purposes for which it is collected.

Browsing data is collected through the use of cookies. To learn more about how cookies work, how to enable and disable them, please see our cookie policy accessible at the following link

Social network plug-ins and interactions with third-party sites

The Site allows interaction with third-party sites such as social networks (e.g., Instagram, Twitter, LinkedIn, YouTube) through hyperlinks, share buttons, social plug-ins, and other similar tools.

By accessing any of the areas of the Site equipped with these kinds of tools, your Internet browser will connect you directly to the servers of the third-party sites in question, thereby transferring your Personal Data to the operators of those sites.

The transfer in question will be made on the basis of your consent, unambiguously expressed in accordance with Article 4, No. 11) GDPR at the time you click on a specific hyperlink, plug-in button or other similar tool.

Regarding the privacy protection methods and treatment of Personal Data collected by the operators of third-party sites with which the described interactions take place, please refer to the relevant sites.

MODE OF TREATMENT

Your Personal Data will be processed through computer, telematic and/or paper tools in accordance with the principles of fairness, lawfulness, transparency, accuracy, integrity, data minimization and purpose and storage limitation, as well as in accordance with the provisions of the GDPR and current legislation on the protection of personal data, and with the adoption of appropriate security measures.

HOW WE PROTECT YOUR DATA

The processing and storage of your Personal Data will take place in the manner and with the appropriate tools to ensure the security and confidentiality of the same, in accordance with the provisions of the GDPR. In particular, appropriate technical, IT, organizational, logistical and procedural security measures will be taken, allowing access only to the persons in charge of the processing by the data controller or the data processors designated by the data controller.

TO WHOM WE DISCLOSE YOUR PERSONAL DATA

In the event that it is necessary for the pursuit of the purposes set forth in this Notice, your Personal Data may be disclosed to the following entities:

SW Newsletter Service Provider;
Technicians and Site managers;
IT consultants;
SW's service providers (e.g., back-up services, call-center service providers, and others who handle communications and requests on SW's behalf);
Professionals such as lawyers, accountants, accounting firms;
Competent judicial and/or administrative authorities, law enforcement agencies where this is necessary to comply with a legal obligation or a lawful order of a competent authority;
In the context of extraordinary transactions, including merger/acquisition transactions, SW may sell, acquire, or transfer corporate assets. In the context of such transactions, your Personal Data may be transferred to third parties, to the extent permitted by applicable law.

Entities in the above categories may process your Personal Data as autonomous data controllers, joint data controllers or data processors, depending on the specific agreements in place between those entities and SW.

You may request the identity and contact details of the individuals to whom your Personal Data is disclosed by contacting us as indicated in the "How to Contact Us" section.

DATA TRANSFER OUTSIDE THE SEE

For the purposes of the processing operations described in this Notice, your Personal Data is not normally transferred to countries outside the European Economic Area ("EEA"), comprising all member states of the European Union, Norway, Liechtenstein and Iceland.

Should the aforementioned transfers take place instead, we assure that they will be carried out in such a way as to ensure the full protection of your rights and freedoms. In particular, with regard to the third country to which the data is transferred, if no adequacy decision has been taken by the European Commission, the transfers will be carried out by adopting appropriate safeguards in accordance with Article 46 of the GDPR. In addition, an impact assessment of the transfer of Personal Data will always be carried out in consideration of the applicable legislation of the third country in question, so as to determine the effective protection of your Personal Data in the event of a transfer outside the EEA or the need for additional security measures.

WHAT YOUR RIGHTS ARE AND HOW TO EXERCISE THEM

In accordance with applicable law, and in particular with the provisions of the GDPR, your rights in relation to the Personal Data that SW processes pursuant to this Notice are as follows:

Access: you may obtain information about the processing of your Personal Data and a copy of such data (Art. 15 of the GDPR);
Rectification: if you believe that your Personal Data is inaccurate or incomplete, you may request that such data be corrected or amended according to your instructions (Art. 16 of the GDPR);
Deletion (cd. "right to be forgotten"): except as provided by applicable laws, you have the right to request the erasure of your Personal Data when: (i) the data is no longer necessary for the purposes for which it was collected and processed; (ii) you withdraw your consent to the processing if the processing is based on your consent; (iii) you object to the processing for direct marketing purposes or the processing carried out for other purposes and there are no overriding legitimate reasons to continue the processing; (iv) your data is processed unlawfully; (iv) deletion is required by law (v) you are a minor and your Personal Data was collected in connection with the direct offering of information society services (Art. 17 of the GDPR);
Limitation: you may request the restriction of the processing of your Personal Data when: (a) you dispute the accuracy of the Personal Data for the period necessary to verify its accuracy; (b) the processing is unlawful and you request the restriction of its use instead of erasure; (c) the controller no longer needs the Personal Data for the purposes of the processing but you need it to establish, exercise or defend a legal claim; (d) you have objected to the processing under Article 21, para. 1 pending verification of whether the data controller's legitimate grounds prevail over yours (Art. 18 GDPR);
Objection: for reasons related to your particular situation, you have the right to object to the processing of your Personal Data based on the legitimate interest of the data controller (Art. 6(1)(f) of the GDPR), and the data controller will continue to process your data only for compelling legitimate grounds that override your interests and rights and/or to promote, exercise or defend a legal claim. Your right to object to direct marketing purposes is absolute and can be exercised at any time in the manner indicated in the "How to Contact Us" section. Your objection to processing carried out by automated means is also valid for processing carried out by traditional means (Art. 21 of the GDPR);
Withdrawal of consent: if the processing of your personal data is based on consent, you have the right to withdraw your consent at any time (Art. 7 of the GDPR);
Data portability: if the processing is based on consent or on a contract and is carried out by automated means, you have the right to obtain - in a structured, commonly used and machine-readable format - the personal data you have provided to us and, if technically feasible, to have it transmitted to another data controller.
HOW TO CONTACT US

To exercise your rights and for any questions or clarifications on how your Personal Data are processed and used under this Policy, you may contact SW at the following channels:

E-mail address: info@studiowoow.com

In case you decide to contact SW, all the data you provide us with will be processed solely for the purpose of giving you prompt feedback and to ensure the proper handling of your requests.

PROTECTION OF HIS RIGHTS

In order to protect your rights and to protect your Personal Data, you may, at any time, decide to file a complaint with the competent supervisory authority, namely the Data Protection Authority (tel. +39 06.696771, e-mail address: protocollo@gpdp.it or urp@gpdp.it; pec: protocollo@pec.gpdp.it) or to bring an action before the competent national courts.

AMENDMENTS TO THIS POLICY

This Disclosure is subject to periodic update. For this purpose, the latest update date is shown at the beginning of the Disclosure.

Any change that substantially affects the processing of your Personal Data will be communicated to you through the appropriate channels, always in such a way as to ensure that you are effectively aware of the methods of processing, with a view to full transparency of the processing itself and full and adequate protection of your rights.