PRIVACY POLICY PURSUANT TO ARTICLE 13 EU REGULATION 2016/679
VGA Limited, with its registered office in 71 - 75 Shelton Street WC2H 9JQ, London, UK has committed itself in protect its users’ on-line privacy. This notice has been drafted pursuant to Article 13 of EU Regulation No. 2016/679 (“Regulation”), in order to inform you about our privacy policy, and make you understand how your personal data are processed while you’re using our website (“Website”). Information and data you provide or otherwise collected while using VGA Limited’s website will undergo processing, pursuant to Regulation provisions and to confidentiality commitments of VGA Limited.
According to Regulation provisions, processing operations carried out by VGA Limited will be based on lawfulness, fairness and transparency, purpose and storage limitation, data minimisation, accuracy, integrity and confidentiality.
1. CONTROLLER
Data Controller is VGA Limited, with its registered office in 71 - 75 Shelton Street WC2H 9JQ, London, UK. To exercise any of the rights provided for in clause 6), the Data Controller can be contacted at the registered office of the Company.
2. PURPOSE OF PROCESSING
Personal data supplied will be processed pursuant to lawfulness conditions (EU Regulation 2016/679), for the following purposes:
3. PERSONAL DATA PROCESSED AND LEGAL BASIS
a. Web surfing data
Computer systems and software procedures of the Website may collect, under normal operating conditions, some Personal Data the transmission of which is necessary while using internet communication protocols. Such Data are not linked to the identified data subject, but, by their very nature, they could, with third-party data processing and combination, make it possible to identify users. This category includes IP addresses, domains from which users access the Website, addresses in URI (Uniform Resource Identifier) string of requested resources, date and time of request, how you made the request to the server, size of the obtained file, numerical code of the response from server (completed, failure, etc.) and other parameters related to the user’s operating system and IT environment.
These data are used only for obtain anonymous statistical information on the use of the Website and to control its proper functioning, to identify anomalies and/or abuses; these data are deleted immediately after processing. Data could be used for assessing liability in case of hypothetical cybercrimes against the site or third parties. Legal basis of processing is point (f) of article 6(1) (Controller’s legitimate interest).
b. Personal data considered ‘sensitive’
When using the "Work with us" section of the Site, there may be a supply of your Personal Data falling under the special categories of Personal Data referred to in art. 9 of the Regulation, "[...] data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as processing genetic data, biometric data intended to uniquely identify a natural person, data relating to the health or sexual life or sexual orientation of the person ". Indeed, we remind you that in the face of the transmission of special categories of Personal Data, but in the absence of a specific manifestation of consent to process such data (an eventuality that obviously allows you to send a curriculum vitae), VGA Limited cannot be held responsible, nor will it be able to receive disputes of any kind, since in this case the processing will be allowed as it relays to data made public by the interested party, in accordance with art. 9, co. 1, lett. e) of the Regulations.
The legal basis for the processing of Personal Data for such data is art. 6, co. 1, lett. b) of the Regulations as the processing is necessary for the response of requests from the interested party. Failure to provide it would make it impossible to evaluate the CVs. However, we specify the importance, as already indicated above, of expressing at the bottom of the request your explicit consent to the processing of special categories of Personal Data, should you decide to share such information.
We also inform you that, for the purposes of selection, VGA Limited could analyse your professional social profiles freely available on the Internet (eg LinkedIn).
c. Data provided voluntarily by the data subject
In “contact us” page the data subject is asked to fill in some personal data (first and last name, email address, company). Providing such data is necessary to allow VGA Limited to respond to the request.
Legal basis of such data processing is point (b) of Article 6(1) of the Regulation, since the processing operations are necessary for service provision or to respond to the requests of the data subject. Providing personal data for such purposes is optional but failing in provide data could make impossible to respond the requests.
4. CATEGORY OF RECIPIENTS OF DATA
In pursuing the above-mentioned purposes, Data may be shared with:
5. TRANSFER OF PERSONAL DATA
The personal data provided will be communicated to recipients, who will process the data as data processors (Article 28 of EU Reg. 2016/679) and/or as natural persons acting under the authority of the Data Controller and the Data Processor (Article 29 of EU Reg. 2016/679), for the purposes listed above, and to third parties.
Namely, the data will be communicated to:
6. PERIOD OF DATA STORAGE OR CRITERIA FOR DETERMINING THIS TIME PERIOD
Data processing will be carried out in an automated and manual way, with methods and tools aimed at guaranteeing maximum security and confidentiality, by subjects specifically appointed to do so. In compliance with the provisions of Article 5, paragraph 1 letter e) of EU Reg. 2016/679, the personal data collected will be stored in a form that allows identification of data subjects for a period of time not exceeding the achievement of the purposes for which the personal data are processed. The retention of personal data provided depends on the purpose of the processing:
Timing determined on the basis of criteria that the interested party can have information on by writing to the Company’s e-mail.
7. RIGHTS OF THE INTERESTED PARTIES
You can assert your rights as expressed in art. 15 of the Regulation, by asking VGA Limited, at any time, to access your Personal Data, to rectify or cancel them or to oppose their processing; you also have the right to request the limitation of processing in the cases provided for by art. 18 of the Regulation, as well as to obtain the data concerning you in a structured format, commonly used and readable by an automatic device, in the cases provided for by art. 20 of the Regulation.
Requests must be sent in writing to the company headquarters.
In any case, you always have the right to lodge a complaint with the competent Supervisory Authority (Guarantor for the Protection of Personal Data), pursuant to art. 77 of the Regulation, if you believe that the processing of your Personal Data is contrary to the legislation in force.
The Data Controller
VGA Limited
COOKIE POLICY
Cookies
Cookies are portions of code that are placed in your browser in order to support the Owner in providing the service according to the described purposes. Some of the purposes for installing cookies may also require the User’s consent.
Technical and aggregate statistics cookies
Other type of Cookies and third parties tools that may use Cookies
Some of the services listed below collect statistics in aggregate form and may not require the User’s consent or may be managed directly by the Owner – depending on what is described – without the support of third parties. If among the tools listed below there are services managed by third parties, these could – in addition to what is specified and also without the knowledge of the Owner – perform User tracking activities. For detailed information we suggest to consult the privacy policies of the listed services.
The services contained in this section allow the Controller to monitor and analyse traffic data and are used to track User’s behaviour.
Below the list of Cookies used by default from the website builder:
How to express consent to the installation of Cookies?
In addition to what is described in this document, the User can manage the preference for Cookies directly from the browser and prevent – for example – third parties installation. Through the browser preferences it is also possible to delete Cookies installed in the past, including the Cookie in which the consent to the installation of Cookies by this site is eventually saved. It is important to note that by disabling all Cookies, the operation of this website could be compromised.
The User can find information on how to manage Cookies with some of the most popular browsers such as the following addresses: Google Chrome, Mozilla Firefox, Apple Safari and Microsoft Windows Explorer. In the case of services provided by third parties, the User may also exercise his/her right to object to the tracking by inquiring through the third party's privacy policy, through the opt out link if explicitly provided or by contacting them directly. Notwithstanding the above, the Owner informs that the User may take advantage of Your Online Choices. Through this service it is possible to manage the tracking preferences for most of the advertising tools. The Owner thus recommends that the User takes advantage of this resource in addition to the information provided in this document.
Since the installation of Cookies and other tracking systems operated by third parties through the services used within this Application cannot be technically controlled by the Owner, any specific reference to Cookies and tracking systems installed by third parties should be considered indicative. To obtain complete information, please consult the privacy policy of any third parties services listed in this document. Given the complexity linked to the identification of technologies based on Cookies and their very close integration with the operation of the web, the Users are encouraged to contact the Owner if they wish to receive any further information on the use of Cookies and about the eventual use of Cookies – for example by third parties – carried out through this site.
Personal data retention terms
Personal data will be processed until any opposition request of the interested party will be received from the Owner.
Rights of the Interested Party as expressed in Article 15 and followings of the EU Regulation 679/2016.
We inform you that the legislation on the protection of personal data gives to the Interested Parties the possibility to exercise specific rights. In particular, each interested party has:
Data Controller
Data Controller is VGA Limited, with its registered office in 71 - 75 Shelton Street WC2H 9JQ, London, UK. To exercise any of the rights, the Data Controller can be contacted at the registered office of the Company
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