Brunello Cucinelli S.p.A., in our capacity as Data Controller (hereinafter referred to as: “Brunello Cucinelli” o Data Controller) according to Legislative Decree no. 196/2003 ("Code"), as well as EU Regulation 679/2016 (hereinafter referred to as "Regulation) – considers the privacy and protection of personal data to be one of our company's main objectives. Consequently, we invite you to carefully read this Privacy Policy before communicating any personal data to the Data Controller, because it contains important information regarding the protection of your personal data.
This Privacy Policy:
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The processing of personal data shall follow the principles of correctness, lawfulness, transparency, purpose and retention limitation, minimisation, accuracy, integrity and confidentiality, as well as the principle of accountability pursuant to art. 5 of the Regulation. Therefore, your personal data will be processed in accordance with the legislative provisions stipulated in the Regulation and the confidentiality obligations prescribed therein.
Personal data processing means any operation or set of operations which is carried out on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
INDEX
Below is the index of this Privacy Policy so that you can easily find the information pertinent to the processing of your personal data that concerns you.
1. DATA CONTROLLER AND DATA PROTECTION OFFICER
2. PERSONAL DATA SUBJECT TO PROCESSING
a. Web browsing data
b. Data voluntarily provided by the user
c. Third party data voluntarily provided by the user
d. Cookies
e. Special categories of personal data
f. Job Applications
3. PURPOSE OF DATA PROCESSING
4. LEGAL BASIS AND MANDATORY OR OPTIONAL NATURE OF PROCESSING
5. PERSONAL DATA RECIPIENTS
6. TRANSFERS OF PERSONAL DATA
7. RETENTION OF PERSONAL DATA
8. DATA SUBJECT'S RIGHTS
9. MODIFICATIONS
10. CONTACT US
1. DATA CONTROLLER AND DATA PROTECTION OFFICER
The Data Controller is Brunello Cucinelli S.p.A. with registered office in Corciano (PG, Italy), hamlet of Solomeo, Viale Parco dell'Industria no. 5, tax code and registration number of the Perugia Register of Companies 0188612054.
The Data Protection Officer of Brunello Cucinelli S.p.A. can be contacted at the headquarters of the Data Controller at the address indicated above and by email at:
dpo@brunellocucinelli.it
2. PERSONAL DATA SUBJECT TO PROCESSING
We inform you that the personal data being processed may consist of a form of identification, such as a name, an identification number, location data, an online identifier or one or more characteristic elements of the data subject's physical, physiological, psychological, economic, cultural or social identity that can be used to render you identified or identifiable, (hereinafter only referred to as "personal data").
The following personal data is processed through the Website:
a. Web browsing data
During their normal course of operation, the computer systems and software procedures used to operate this Website acquire certain personal data, the transmission of which is implicit in the use of internet communication protocols. This information is not collected with the intent of associating it with identified users but, by its nature, it could lead to the identification of users through processing and association with data held by third parties. This category of data includes IP addresses or domain names of computers used by users who connect to the Website, URI addresses (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 received in reply, the numerical code indicating the status of the reply given by the server (successful, error, etc.) and other parameters regarding the user's operating system and computer environment. This data is only used to obtain anonymous statistical information about the use of the Website and to check its correct functioning, to identify anomalies and/or misuse; it is deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes to the detriment of the Website or third parties.
b. Data voluntarily provided by the user
Except for specific information contained therein, this Privacy Policy is also intended for the processing of data that you voluntarily insert when filling out the forms contained on the Website. With reference to the latter, we invite you not to include information that may fall within the group of special categories of personal data pursuant to art. 9 of the Regulation, if not strictly necessary (
see sub. e) (
[...] personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data intended to uniquely identify a natural person, data relating to a person's health, sex life or sexual orientation).
c. Third party data voluntarily provided by the user
Third parties may process the personal data that you communicate to Brunello Cucinelli (such as, for example, the name of the legal representative of your former company of employment or the name of the university professor who supervised your degree thesis, etc.). With respect to these hypotheses, you become the autonomous data controller, assuming all legal obligations and responsibilities. To this effect, you fully indemnify us against any objection, claim, request for compensation for damages from processing, etc. that the Data Controller receives from third parties whose personal data has been processed in violation of the applicable rules on the protection of personal data. In any event, if you provide or otherwise processes the personal data of a third party, as of now, you assume all related liability and guarantees that this particular hypothesised data processing is based, where necessary, on the prior acquisition - by you - of the third party's consent to process information concerning him/her.
d. Cookies
Information about cookies used on the Website is available
here.
e. Special categories of personal data
While using the Website, the transfer of your personal data, which falls into the special categories of personal data pursuant to art. 9 of the Regulation, may occur (
cfr. sub c), textually i "[...]
data which may reveal a person's racial or ethnic origin, political opinions, religious or philosophical beliefs, or union membership, as well as processing genetic data, biometric data intended to uniquely identify a physical person, related data to the health or sexual life or sexual orientation of the person >". We invite you to refrain from publishing such data unless strictly necessary. In fact, we remind you that, in the event of submission of special categories of personal data but in the absence of a specific demonstration of consent to process such data (a possibility that obviously allows users to send a curriculum vitae), Brunello Cucinelli cannot be held responsible for any reason whatsoever, nor can we receive any complaints of any kind, since, in this case, we will not process the data in question. We, therefore, specify the importance, as already indicated above - for you to express explicit consent to the processing of the special categories of personal data, if and when you decide to share such information.
f. Job Applications
When you register on the Website to submit a job application to Brunello Cucinelli, you will be asked to provide, through a form (the "Application"), your professional/work details (e.g., training, area of competence, knowledge of foreign languages, current employment, level of experience, etc.) and to upload, via the specific function, your CV and, possibly, other files.
Upon receipt of an Application, Brunello Cucinelli will be able to evaluate your professional profiles on social networks (e.g., Linkedin) or professional websites attributable to you, if publicly accessible, to obtain further information to help us assess your compatibility with the position for which you have applied.
3. PURPOSE OF DATA PROCESSING
Your personal data will be processed for the following purposes, where applicable:
3.1. to allow navigation of the Website and the delivery of services made available by the Data Controller, including the management of the Website's security;
3.2. to fulfil any obligations stipulated by applicable laws, regulations or European legislation, or to satisfy requests from authorities;
3.3. to analyse the CVs and re-contact the candidates who submitted their job applications.
Specific security measures have been implemented in order to prevent data loss, illicit or incorrect use of data and unauthorised access.
4. LEGAL BASIS AND MANDATORY OR OPTIONAL NATURE OF PROCESSING
The legal basis for processing personal data for the purposes set out in section 3.1 is art. 6 (1)(b) of the Regulation ([...]
processing is necessary for the performance of a contract to which the data subject is a party or for the execution of pre-contractual measures adopted at the request of the same), inasmuch as processing is necessary for the provision of services or to respond to requests made by the interested party.
Conversely, the legal basis for processing personal data for the purposes referred to in section 3.2 is art. 6(1)(c) of the Regulation ([...]
processing is necessary to comply with a legal obligation to which the Data Controller is subject).
With reference to the purposes referred to in section 3.3 and the related analysis of the professional social profiles freely available on the Internet as per section 2.c, the legal basis of the processing is art. 6(1)(f) of the Regulation, namely, Brunello Cucinelli's legitimate interest to verify any risks regarding the suitability of the candidate to occupy the specific vacant position.
The provision of personal data for these purposes is optional, but failure to provide it would make it impossible to activate the services provided by the Website, reply to requests or evaluate CVs.
5. PERSONAL DATA RECIPIENTS
Your personal data may be shared, for the purposes set out in section 3 of this Privacy Policy, with:
5.1. subjects that typically act as data controllers pursuant to articles 29 of the Code and 28 of the Regulation, namely, subjects who cooperate with the Data Controller for the fulfilment of the above-mentioned aims, including subjects who are delegated to carry out technical maintenance activities;
5.2. individuals, entities or authorities who require the communication of your personal information as mandated by law or by order of the authorities;
5.3 persons authorised by the Data Controller, pursuant to articles 30 of the Code and 29 of the Regulation, to process the personal data necessary to carry out activities strictly related to the provision of services, who are committed to respecting the data subject's confidentiality or have an appropriate legal confidentiality obligation.
These subjects are collectively defined as “
Recipients”.
A complete list of data processing supervisors is available by sending a written request to the Data Controller at the addresses indicated in the "Contact Us" section of this Privacy Policy.
6. TRANSFERS OF PERSONAL DATA
Some of your personal data is shared with Recipients who may be situated outside the European Economic Area. The Data Controller ensures that these Recipients process your personal data in compliance with articles 43 and 44 of the Code, as well as articles 44 - 49 of the Regulation. Indeed, transfers can be based on an adequacy decision or on the
Standard Contractual Clauses approved by the European Commission. Further information is available by sending a written request to the Data Controller at the addresses indicated in the "Contact Us" section of this Privacy Policy.
7. RETENTION OF PERSONAL DATA
Personal data that is processed for the purposes set out in section 3.1 will be kept for the time strictly necessary to achieve those same purposes. With regard to information processed for the provision of services, the Data Controller will keep this personal data for the period of time envisaged and permitted by Italian law to protect their interests (Article 2946 of the Italian Civil Code and ff.).
Personal data processed for the purposes set out in section 3.2 will be retained up until the time stipulated by the specific obligation or applicable law.
Personal data processed for the purposes set out in section 3.3 will be retained as long as the position for which the CV was sent is available or, in the case of a spontaneous application, up to 3 (three) years. It is without prejudice to the possibility for Brunello Cucinelli to contact the candidate shortly before the deadline indicated to request an extension of this retention period.
Further information regarding the data retention period and the criteria used to determine this period may be requested via a written request sent to the Data Controller at the addresses indicated in the "Contact Us" section of this Privacy Policy.
In any case, it is without prejudice to the possibility for the Data Controller to store your personal data for the period of time provided and allowed for by Italian law to protect their interests (Article 2947(1)(3) of the Italian Civil Code).
8. DATA SUBJECT'S RIGHTS
Pursuant to art. 7 of the Code, at any time, you reserve the right to obtain confirmation of the existence or otherwise of your personal data and to know its content and origin, verify its accuracy or request its integration, updating, or rectification; you have the right to request the cancellation, transformation into anonymous form or blocking of data processed in breach of the law and to oppose, in any event, for legitimate reasons, its processing. Starting from May 25th, 2018, you also have the right to request access to your data, to oppose its processing, to request the limitation of its processing in the cases provided for by art. 18 of the Regulation, where technically possible, as well as obtaining the data concerning yourself in a structured common-use format that is readable via an automatic device, in the cases provided for by art. 20 of the Regulation.
Requests should be sent in writing to the Data Controller at the addresses indicated in the "Contact Us" section of this Privacy Policy.
In any case, you are always entitled to lodge a complaint with the competent supervisory authority (Italian Data Protection Authority), pursuant to art. 77 of the Regulation, if you consider the processing of your data to be in violation of the existing legislation.
9. MODIFICATIONS
The Data Controller reserves the right to modify or simply update the content of this Privacy Policy, wholly or partially, also as a result of variations in the applicable legislation. Therefore, the Data Controller invites you to regularly visit this section to keep up-to-date with the most recent and updated version of the Privacy Policy in order to always be informed on the data collected and how Brunello Cucinelli uses it.
10. CONTACT US
To exercise the above rights or for any other request, you can write to the Data Controller at the address indicated above, or through the
dedicated contact, preferably, inserting the wording “
request to exercise privacy rights” as the subject of the communication.
