Jobrapido S.r.l., with registered offices in via Paleocapa, n. 7, 20121 – Milan (“Jobrapido”), is committed to protecting the online privacy of its clients who purchase the Services offered by the same through the site https://corporate.jobrapido.com (the “Site”). This document (the “Privacy Policy”) has been prepared to allow you to understand how your Personal Data, as defined below, will be processed in the context of the purchase of our Services, as indicated below in par. 3, pursuant to art. 13 of EU Regulation 2016/679 (“Regulation”). This Privacy Policy is intended to provide you with the information you need to provide your explicit and informed consent, where necessary and if you deem it appropriate.

In general, any information or personal data that you provide Jobrapido through the Site, or that is otherwise collected in the context of the use of the services offered by Jobrapido (the “Services”), as better defined in the General Conditions (“GTC” or “General Conditions”), where applicable to our Services, displayed here, will be processed according to the internationally recognized principles of lawfulness, correctness, transparency, purpose and storage limitation, data minimization, accuracy, integrity and confidentiality.

This Privacy Policy refers to the GTC, where applicable, and should be read in conjunction with them. If you have not already done so, we invite you to view them by clicking on the link above. Capitalized terms in this Policy that are not defined herein have the same meaning that they are attributed in the GTC.

INDEX

1. 1. Data Controller and Data Protection Officer
   2. Personal data subject to processing
      1. Name, contact details, payment details and other Personal Data
      2. Data provided voluntarily by the data subject
      3. Browsing data
      4. Cookies
   3. Purposes of processing
   4. Legal basis and mandatory or optional nature of the processing
   5. Sending your application for a job in Jobrapido
   6. Recipients of Personal data
   7. Transfer of Personal data
   8. Retention of Personal data
   9. Data subject’s rights
   10. Amendments

1. Data Controller and Data Protection Officer

Jobrapido, as identified at the beginning of this Privacy Policy, is the Data Controller for all personal data processed in the context of the use of the services offered by Jobrapido through the Site.

You can contact the Data Protection Officer (“DPO”) of Jobrapido at the following e-mail address: dpo@jobrapido.com.

2. Personal data subject to processing

Following navigation of the Site and in the context of the activities related to the Services purchased from Jobrapido and you and/or the company you represent or for which you act (hereinafter, the “Client”) we inform you that Jobrapido will process your personal data, which may be constituted – also depending on your decisions regarding how to use the Services – by an identifier such as your name, surname, e-mail, an identification number such as a customer code, an online identifier or one or more elements characteristic of your physical, physiological, mental, economic, cultural or social identity capable of making you identified or identifiable (hereinafter “Personal Data”).

We will collect your Personal Data that you voluntarily provide to us (e.g. when you contact us to receive more information about our Services or when you create an account on behalf of the Client in order to purchase a Service).

The Personal Data processed in the context of the use of the services offered by Jobrapido through the Site are as follows:

a. Name, contact details, payment details and other Personal Data

In various sections of the Site, in order to provide you with our Services, you will be asked to enter:

In order to create the Employer Account:

• an e-mail address, name, telephone number and the address of the Client’s registered office.

Within the User profile:

• e-mail address, first and last name of the User.

When you participate in surveys or any promotions that are made available through the Site, as well as when you communicate with Jobrapido through the contacts you find on the Site, Jobrapido may also collect additional information from you which you decide to provide to us.

Please note that payment for the Services are made through a third-party platform (depending on the country in which you are located, Stripe, Paypal or others), which operates as an independent data controller and does not allow us to access your payment information, such as credit card number or other data that you must provide to complete the purchase.

We will, however, use your billing information, which will be requested at the time of purchase, for all tax and accounting obligations and to send you the invoice relative to your purchase.

b. Data provided voluntarily by the data subject

In some parts of the Site you are allowed to communicate information of various kinds to Jobrapido, which may contain the Personal Data of other people.

Once you have created an Employer Account, you can also add Users to your team by sending them an invitation by email.

With reference to the Postings on the Site, we inform you that Jobrapido will proceed, as far as possible, before their publication, to the removal from the same of any Personal Data relating to third parties – other than those belonging to the Client (e.g. the recruiting manager within your company). There is, however, a risk that third parties who see the Posting you have published may be able to trace the information contained therein to your identity or that of other people by combining the information with other data in their possession.

Jobrapido therefore reserves the right to pre-emptively modify or remove the Posting (if already published) in the event that it deems, at its sole discretion, that such Posting contains Personal Data, or to fulfil a request of the person concerned whose Personal Data are present in the Posting.

In any case, with respect to the voluntary provision of Personal Data of third parties, you are the independent data controller, assuming all the obligations and responsibilities provided for according to law. In this sense, you hereby grant Jobrapido the widest possible indemnity in respect of any dispute, claim, request for compensation for damage caused by processing, etc., that Jobrapido may be subjected to by third parties whose Personal Data have been processed through your use of the functions of the Site in violation of the applicable regulations on the protection of Personal Data. In any case, should you provide or in any other way process Personal Data of third parties in your use of the Site, you guarantee as of now – assuming all related liability – that in this particular case, the processing is based on the documented consent of such third party or on another suitable legal basis that legitimizes the processing of the information in question.

c. Browsing data

The computer systems and software procedures used to operate the Site acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified parties, but by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of computers used by users connecting to the Site, URI (Uniform Resource Identifier) of requested resources, 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 from the server (successful, error, etc..) and other parameters relating to the operating system and computer environment. These data are used only to obtain anonymous statistical information on the use of the Site and to check its proper functioning, to identify anomalies and / or abuse, and are deleted immediately after processing. The data could be used to identify responsibility in the event of alleged computer crimes against the Site or third parties: except for this possibility, the data on web contacts do not currently persist beyond the time strictly necessary for the purposes described above.

    d. Cookies (cookie policy)

3. Purposes of processing

Jobrapido will use your Personal Data collected through the Site for the following purposes:

• • provide Services such as: i) to allow you to register as an Employer to access the Client personal area, where you can benefit from post-contractual assistance, purchase additional Services or manage Postings already purchased and/or published by one of the members of your team; ii) verify your identity and help you, in the event that you lose or forget the login/password details of your account on the Site; iii) to allow you to view and manage your purchase data, to view the expiration date of the Postings you have paid for; (v) to allow you to contact Jobrapido in order to obtain, by providing your Personal Data in the relevant contact form, additional information about specific Jobrapido’s products, Services and initiatives, as well as download information and documents provided for by Jobrapido (such as white papers, leaflets, etc.) and v) to manage any other type of support request – technical, commercial and/or contractual and to provide you with any other Service you request (“Provision of Service”);
  • to send you marketing communications, promotions and advertising, market research and surveys, by e-mail, SMS, telephone, by way of banners, paper mail, instant messaging, through an operator, through the official social media pages of Jobrapido, as well as for marketing activities in the broadest sense, including prize contests, games and competitions, relating to products and/or services related to Jobrapido or promoted by Jobrapido (“Marketing”);
  • to send you email marketing communications regarding Jobrapido’s products and services similar to those you purchased through the Site (“Soft Opt-In”);
  • to comply with legal obligations that require Jobrapido to collect and/or further process certain types of Personal Data (“Compliance”);
  • to prevent or detect any abuse in the use of the Site or within the scope of the Services, or any fraudulent activity and therefore allow Jobrapido to defend itself in court, to manage claims, litigation and/or pre-litigation (“Abuse/Fraud/Litigation”).

4. Legal basis and mandatory or optional nature of the processing

The legal bases used by Jobrapido to process your Personal Data, according to the purposes indicated in Paragraph 3 above, are as follows:

• • • Provision of the Service: the processing for this purpose is necessary to provide the Services and, therefore, for the execution of the agreement with you or with the Client on whose behalf you act and represent. It is not compulsory to provide Jobrapido with your Personal Data for this purpose, but if you do not provide Jobrapido with such data, we may be unable to provide you with the relevant Service (including contacting Jobrapido for requesting additional information about specific products, Services and initiatives, downloading information and documents provided for by Jobrapido).
    • Marketing: the processing for this purpose is based on your consent, to be expressed by flagging the specific tick box in the relevant form. It is not compulsory to give your consent to Jobrapido for this purpose, since it does not affect the provision of the Services to you by Jobrapido, and you are free to revoke it at any time without any consequence, except for the fact that you will no longer receive marketing communications from Jobrapido. You can revoke your previously given consent by following the indications given in Paragraph 9 of this Policy.
    • Soft Opt-In: the processing for this purpose is based on Jobrapido’s interest in sending you marketing communications via e-mail (to the email address provided by you in the context of the previous purchase) regarding Jobrapido’s products and services similar to those you have already purchased through the Site, representing a legitimate processing under current applicable legislation on the protection of personal data, which does not require your consent. You may interrupt the receipt of these communications at any time by using the link at the bottom of each of these e-mails without any consequence for you, other than the fact that you will no longer receive further communications of this kind from Jobrapido.
    • Compliance: processing for this purpose is necessary for Jobrapido in order to fulfil any legal obligations. When you provide Personal Data to Jobrapido, they must be processed in accordance with the applicable legislation, which may involve their storage and communication to the Authorities for accounting, tax or other obligations.
    • Abuse/Fraud/Litigation: the information collected for this purpose will be used exclusively to prevent and/or detect any fraudulent activity or abuse in the use of the Site and therefore allows Jobrapido to defend itself in court, to manage claims, litigation and/or pre-litigation.

5. Sending your application for a job in Jobrapido

Jobrapido also offers Users the opportunity to send their application by e-mail to work in Jobrapido through the “Work with us” section of the Site. To this end, Jobrapido will acquire and use the information provided by the User for the exclusive purposes of selecting and managing applications. The legal basis for the collection and processing of Personal Data contained in the applications is the execution of pre-contractual measures adopted at the request of the User. In any case, the User is invited not to include in his resume and/or in the relevant form any Personal Data of a sensitive nature and/or particular categories of Personal Data (such as data relating to the state of health, political opinions, sexual life, etc.), if not those strictly necessary according to the law for the purposes of selecting and evaluating the resume and application (such as the belonging to protected categories). Should the User accidentally provide Jobrapido with such data, which are not necessary for the evaluation of the application, Jobrapido will not take them into account.
Jobrapido will keep the personal data of the Users who have sent their application and job positions in Jobrapido after [●] months from the provision of data, in the event that the candidate does not establish a working/collaboration relationship with Jobrapido.

6. Recipients of Personal data

Your Personal Data may be shared with the parties listed below (the “Recipients”):

• • • persons who typically act as data processors, i.e.: i) persons, companies or professional firms that provide assistance and advice to Jobrapido in accounting, administrative, legal, tax, financial and debt collection matters relating to the provision of Services; ii) persons with whom it is necessary to interact for the provision of Services (e.g. hosting providers or suppliers of platforms for sending e-mails); iii) persons delegated to carry out technical maintenance activities (including the maintenance of network equipment and electronic communication networks);
    • persons authorised by Jobrapido to process Personal Data necessary to carry out activities strictly related to the provision of the Services, who are committed to confidentiality or have an adequate legal obligation of confidentiality (e.g. employees of Jobrapido);
    • companies of the Jobrapido Group for internal administrative purposes;
    • subjects, entities or authorities to whom it is mandatory to disclose your Personal Data for the purposes of Compliance, Abuse or Fraud, or by order of the authorities.

7. Transfer of Personal data

Given Jobrapido’s international presence, some of your Personal Data is shared with Recipients who may be located outside the European Economic Area.

Jobrapido ensures that the processing of Personal Data by these Recipients takes place in compliance with applicable legislation. The transfers rely on adequate guarantees, such as adequacy decisions, the Standard Contractual Clauses approved by the European Commission, or other safeguards. More information on data transfers can be obtained from Jobrapido by writing to the following address: dpo@jobrapido.com.

8. Retention of Personal data

The Personal Data processed for the purpose of the Provision of Service will be kept by Jobrapido for the time strictly necessary for that purpose. In any case, since such Personal Data is processed to provide the Services to you, Jobrapido may keep it for a longer period of time, in particular as may be necessary in order to protect Jobrapido’s interests from possible claims, litigation, pre-litigation relating to the Services.

The Personal Data processed for the purpose of Marketing will be kept by Jobrapido until you revoke your consent. Once your consent has been revoked, Jobrapido will no longer use your Personal Data for such purpose, but it may nevertheless keep them, in particular as far as may be necessary in order to protect Jobrapido’s interests from possible claims based on such processing. Please note that the revocation of consent does not affect the lawfulness of the processing based on the consent which took place before such withdrawal.

Personal Data processed for the purposes of Soft Opt-In will be kept by Jobrapido until you object to such processing through the link at the bottom of each Soft Opt-In email or by writing to dpo@jobrapido.com.

The Personal Data processed for Compliance purposes will be kept by Jobrapido for the period provided for by specific legal obligations or applicable legislation.

The Personal Data processed for the purpose of Abuse/Fraud/Litigation prevention shall be kept by Jobrapido for the time strictly necessary for the aforesaid purpose and therefore until Jobrapido is required to keep them in order to protect itself in court, in litigation and/or pre-litigation and communicate said data to the competent Authorities.

9. Data subject’s rights

You have the right to ask Jobrapido, at any time:

• • • to access your Personal Data, or a copy of such Personal Data, as well as further information about the ongoing processing of such Personal Data;
    • the rectification or updating of your Personal Data processed by Jobrapido, if they are incomplete or not updated;
    • the cancellation of your Personal Data from Jobrapido’s databases in the cases provided for by art. 17 of the Regulation;
    • the restriction of the processing of your Personal Data by Jobrapido in the cases provided for by art. 18 of the Regulation;
    • to obtain your Personal Data in a structured, commonly used and machine-readable format as provided for by art. 20 of the Regulation;

you can also:

• • • oppose the processing of your Personal Data by Jobrapido (e.g. Soft Opt-In);
    • revoke your consent for Marketing.

Jobrapido will use, as mentioned above, several communication channels through which you can be contacted for marketing purposes (i.e. telephone, text message, e-mail, certified e-mail, print mail, social media). You may revoke your Marketing consent for all contact channels or for individual channels.

You can revoke your consent to Marketing sent by e-mail and stop receiving Soft Opt-In by using the appropriate link at the bottom of each e-mail received.

The rights listed above can, where available, be managed in the reserved area of the Site.

In addition to the above, you can also exercise your rights by writing to Jobrapido at the following address: dpo@jobrapido.com.

In any case, you are always entitled to lodge a complaint with the competent Authority (the Italian Data Protection Authority, Garante per la Protezione dei Dati Personali) if you believe that the processing of your Personal Data is contrary to the legislation in force.

10. Amendments

This Policy has been in force since January 5, 2019 Jobrapido reserves the right to modify or simply update the content, in part or in full, also due to changes in applicable legislation. Jobrapido will inform you of such changes as soon as they are introduced and they will be binding as soon as they are published on the Site. Jobrapido therefore invites you to regularly visit this section to become aware of the most recent and updated version of the Privacy Policy so as to always be updated on the data collected and the use that Jobrapido makes of such data.

PRIVACY POLICY ANNEX COOKIE LIST