PRIVACY POLICY
The following notice has been prepared pursuant to Articles 13 and 14 of the EU Regulation 2016/679 (“GDPR”) in order to enable you to understand how your personal data, as more fully defined below, will be processed in the context of your use of the website https://www.totallyimported.it (hereinafter, “Site”), and to learn about our privacy policy. In general, any information or personal data that you provide through the Site, or that is otherwise collected through the Site, as part of your use of the services offered (e.g., submitting an unsolicited application, requesting information and/or legal assistance or counseling services, hereinafter “Services”), will be processed in strict compliance with the principles of lawfulness, fairness, purpose limitation and storage, minimization, accuracy, integrity, while ensuring maximum transparency about the procedures and security measures adopted.
INDEX
- Data controller
- Type of personal data being processed
- Purpose and legal basis for processing
- Modalities and mandatory or optional nature of processing
- Sharing and transfer of personal data
- Retention of personal data
- Rights of the data subject
- Complaint to the Regulatory Authority
- Updates and possible changes
DATA CONTROLLER
Totally Imported s.r.l (henceforth, “Totally Imported”, “We” or the “Data Controller”), C.F. and P. IVA n. 13750921002, with registered office in Bologna, Via Mirasole 12, zip code 40124, is the data controller of the personal data collected as part of the use of the Site
TYPE OF PERSONAL DATA BEING PROCESSED
(a) Contact details and identification data
As part of your use of the Site and Services, we may process personal data that may consist of your name, contact details, and/or an online identifier. In some sections of the Site (e.g. Contact Us), you may be asked to enter information such as your first name, last name, phone number, e-mail address, etc.
(b) Data collected as part of the submission of an application.
In the “Work with us” section, you may also submit a spontaneous application for a job position, also attaching your Curriculum Vitae. In this context, you may provide – in addition to common personal data – also personal data referable to you that falls under the special categories of personal data referred to in Art. 9 GDPR (i.e., “[…] data capable of revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as […] genetic data, biometric data intended to uniquely identify a natural person, data concerning a person’s health or sex life or sexual orientation”). We urge you not to provide personal data falling under the special categories of personal data unless strictly necessary. Without prejudice to the need to process special categories of personal data for specific job positions, Totally Imported has no interest in receiving such information and will refrain from any processing in the event that you have provided special categories of personal data as part of your application.
(c) Third-party data voluntarily provided by the data subject
In some parts of the Site (such as, for example, in the “Contact” section) you may enter text messages or information that may contain personal data of other people. With respect to such hypotheses, you stand as autonomous data controller, assuming all the obligations and responsibilities of the law. In this sense, it confers on this point the widest indemnity with respect to any dispute, claim, request for compensation for damages from processing, etc., that may be received by Totally Imported from third parties whose personal data have been processed through its use of the functions of the Site in violation of the applicable data protection regulations. In any event, should it provide or otherwise process personal data of third parties in its use of the Site, it hereby warrants as of now – assuming all related liability – that such particular instance of processing is based on the consent of such third party concerned or other appropriate legal basis legitimizing the processing of such information.
(d) Navigation data
This is information that is not collected to be associated with identified interested parties, but which by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the Site, the URI (Uniform Resource Identifier) notation addresses of the resources requested, 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 user’s operating system and computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning, to identify anomalies and/or abuses, and are deleted immediately after processing.
e) Cookie
More information about the cookies served through the Site is available within the dedicated policy, available here.
METHODS, PURPOSES AND LEGAL BASIS FOR PROCESSING
Your personal data will be processed – by manual, computerized or telematic means however suitable to guarantee the security and confidentiality of the data – for:
(a) Provision of Services
To provide you with the Services provided by the Site, such as – by way of example – responding to a request from you. In the event that you have requested legal assistance or advice, your personal data and/or those of the additional data subjects involved will be processed for the execution of the professional assignment received, whether in judicial or extrajudicial settings. In such circumstances, the processing is based on the need to execute a contract or pre-contractual measures within the meaning of Article 6(1)(b) GDPR. It is not mandatory to provide your personal data for this purpose, but otherwise it will not be possible to provide you with the requested Services.
(b) Application management
In the event that you have submitted an application, your personal data will be processed to analyze the CV transmitted and contact you again to initiate the selection process. Again, the processing is based on the need to execute a contract or pre-contractual measures under Article 6(1)(b) GDPR, and thus be able to consider your application to initiate the selection process. It is not mandatory to provide your personal data for this purpose, but otherwise we will not be able to consider your application. We reiterate the request not to provide, unless strictly necessary, special categories of personal data relating to you (e.g., data concerning your health status, religious beliefs, etc.). In the event that you nevertheless provide us with such information, Totally Imported will refrain from processing such data unless it is strictly necessary for the evaluation of your application in the context of a specific job position: in this case, the processing will be based on the need to fulfill specific obligations and/or exercise your rights in the field of labor law and social security and social protection, pursuant to Article 9(2)(b) GDPR and the pro tempore authorization of the Data Protection Authority.
(c) Fulfillment of legal obligations
Your personal data may be processed in order to comply with legal or regulatory obligations incumbent on Totally Imported under applicable industry regulations, as well as to comply with any additional obligations incumbent on Totally Imported’s professionals in the performance of legal assistance or advice services. Processing for this purpose is then carried out by Totally Imported in order to fulfill any legal obligations under Article 6(1)(c) GDPR. When it provides personal data, it will indeed have to be processed in accordance with applicable law, which may involve its storage and disclosure to the Authorities for accounting, tax or other obligations.
d) Sending promotional or informative communications of a professional or cultural nature
Your personal data may also be processed to send you promotional or informative communications of a professional or cultural nature as part of the activities in which Totally Imported is involved, by e-mail and/or through Totally Imported’s social pages. Processing for this purpose is based on your consent in accordance with Article 6(1)(a) GDPR. You are not required to provide your consent for this purpose and you are free to withdraw it at any time without any consequence (except that you will no longer receive promotional or informational communications from Totally Imported). Should you wish to object to the processing of your personal data for this purpose or revoke your consent for such processing performed by the means set forth herein, you may do so at any time by contacting Totally Importedat the contact details set forth in this Privacy Policy, without affecting the lawfulness of the processing based on your consent given prior to revocation.
(e) Audits for safety and security
Finally, your personal data may be processed as part of internal verification activities aimed at preventing or detecting any misuse in the use of the Site and ensuring the security of the Services provided, based on Totally Imported’s legitimate interest under Art. 6(1)(f) GDPR aimed at adequately protecting its reasons where necessary.
SHARING AND TRANSFER OF PERSONAL DATA
We may share your personal data with individuals expressly authorized by us who are bound in this regard by specific confidentiality agreements.
In addition, your data may be shared with companies, entities, or lending institutions that provide us with specific services in accounting or administration, as well as with consultants, accountants, banking and insurance institutions, or other lawyers who provide functional services for the Services.
This is without prejudice to the fact that your personal data may also be disclosed to individuals, entities or authorities in order to comply with specific legal provisions or orders of the competent authorities.
As a general rule, we do not intend to transfer your personal data, but in the event that it is necessary to share your personal data with one of the above parties located outside the European Economic Area, we assure you that the transfer will take place by putting in place appropriate safeguards (including, depending on the circumstances, adequacy decisions, the use of the Standard Contractual Clauses approved by the European Commission, and/or any additional safeguards).
STORAGE OF PERSONAL DATA
The personal data processed for the purpose of the Provision of Services, including therefore the personal data of those who avail themselves of Totally Imported’s legal assistance or advice services (both in judicial and extrajudicial settings), are retained for the entire duration of the contract or mandate for the professional assignment received and, thereafter, for as long as Totally Imported and/or the professionals involved in the activity result to be subject to specific retention obligations provided for by industry regulations (e.g., for tax purposes, etc.) or other legal or regulatory obligations. This is without prejudice to additional retention periods provided for by applicable regulations (e.g., art. 2946 of the Civil Code) to protect Totally Imported with respect to possible civil or criminal actions or claims for the Services rendered.
Personal data processed as part of the purpose of Application Management will be retained for 12 months after receipt and deleted thereafter.
Personal data processed for the purpose of Compliance with Legal Obligations will be retained by Totally Imported for the period required by specific legal obligations or applicable regulations.
For the purpose of Sending promotional or informative communications of a professional or cultural nature, personal data will be kept until your consent is revoked or until you wish to object to processing for that purpose.
Personal data processed for the purpose of Verifications for Safety and Security will be processed for the time strictly necessary to achieve this purpose, and in any case for no longer than 12 months.
RIGHTS OF THE DATA SUBJECT
You have the right to ask us at any time:
- Access to your personal data;
- The rectification or deletion of your personal data;
- To object to the processing of your personal data in the cases provided for in Article 21 GDPR;
- To request the restriction of the processing of your personal data in the cases provided for in Article 18 GDPR;
- to obtain in a structured, commonly used and machine-readable format the personal data concerning you, in the cases provided for in Article 20 GDPR.
To exercise any of the above rights, you may write to us at info@totallyimported.it
COMPLAINT TO THE CONTROL AUTHORITY.
In any case, you always have the right to lodge a complaint with the competent supervisory authority (Garante per la Protezione dei Dati Personali), in accordance with Article 77 GDPR, if you believe that the processing of your personal data is contrary to the regulations in force.
We also reiterate that you have the right to revoke your consent at any time, in cases where consent is the legal basis for processing. You may formulate revocation of consent without special formalities by writing to the address given above.
This Privacy Policy is effective as of August 2024. Totally Imported reserves the right to change or simply update its content, in part or in full, including due to changes in applicable regulations. Totally Imported encourages you to visit this section regularly to become aware of the most recent and up-to-date version of the Privacy Policy so that you are always up-to-date on the data collected and how it is used.
License
The icons featured in this policy were developed by the Maastricht European Centre on Privacy and Cybersecurity – ECPC, whose graphic design was among the winners of the “Informative Clarity” contest sponsored by the Data Protection Authority. Use of the icons is subject to the terms of the CC BY 4.0 license.
UPDATES AND POSSIBLE CHANGES
Last update: 01/08/2024