PRIVACY NOTICE

DATA CONTROLLER

Company name: Flexrem S.r.l.

VAT Number: 12971200014 

Registered office: CORSO GIACOMO MATTEOTTI 12 - TORINO, TO - 10121

Data Controller’s e-mail: flexrem@legalmail.it

The present Privacy Notice is provided to users (hereinafter, "Users" or "User") of the website, accessible at the following link www.flexrem.com or the "Flexrem" application (hereinafter "Website," or "App") owned by the Data Controller (hereinafter, “Flexrem” or the "Data Controller"). This Privacy Notice provides an overview of how the Flexrem Website or App handles the processing of Users' personal data. In particular, it is designed to assist Users in understanding the purposes and methods of processing their personal data (referred to as "Data" or "Personal Data") by the Data Controller.

1. User types 

Guest users can freely browse the Website or App without the need for an account (e.g., to explore job opportunities). 

Companies, upon acceptance of the Terms and Conditions and this Privacy Notice, have access to specific services tailored for them, exclusively available on the Website (e.g., creating a company's profile, posting job offers, etc.).

Candidates, upon acceptance of the Terms and Conditions and this Privacy Notice, have access to specific services tailored for them, available on both the Flexrem Website and App (e.g., seeking job offers, applying for job positions, etc.).

2. Types of Data, purposes and lawfulness of processing 

A. GUEST USERS

Types of Data processed

By interacting with the content of the Website or App, the Data Controller may process certain categories of Data freely provided by the Guest User in specific forms (e.g. contact form) and the usage data generated indirectly through the use of the Website/App and navigation on the App/ Website. 

The App can furthermore trace the Guest user's device by storing the "universal unique identifier" (UUID) for statistical analysis. In addition, further device data and technical information about the Guest user’s network (e.g. IP address) may be processed.

Purposes and Lawfulness of Processing 

The Data of the User will be processed by the Data Controller for the following purposes:

a) Allow the User to navigate through the Website/ App; 

b) Manage User’s requests;

c) Exercise the rights of the Data Controller (e.g., defense of legal claims);

d) Monitor the correct operation of the Website/ App.

The lawful bases of the processing operations listed above are the following:

• In relation to purposes a) and b) the processing is necessary for the fulfillment of contractual or pre-contractual obligations;

• In relation to purposes c) and d), the lawfulness is grounded in the legitimate interest of the Data Controller, e.g., monitoring the correct operation of the Website/ App and exercising the rights of the Data Controller (such as the defense of legal claims).

The provision of Data for the aforementioned purposes is mandatory. In the event of non-disclosure of the Data, the Data Controller will not be able to allow the User to interact with the Website/ App.

The User's Data may also be processed through the use of Cookies. For further information about the processing, please consult the Cookie Policy: www.flexrem.com/cookie-policy.

B. COMPANIES

Types of Data processed

To access the services offered by the Website, the User is required to provide the following Data upon accepting the Terms and Conditions and this Privacy Policy:

• Contact details (e.g., email, phone number, etc.)

• Company information (company name, VAT number, place of business, etc.)

• Company Image/ Log

By interacting with the content of the Website, the Data Controller may process the usage data generated indirectly through the use of the Website and navigation on the Website.

Purposes and Lawfulness of Processing 

The Data of the Company will be processed by the Data Controller for the following purposes:Allow the User to navigate through the Website; 

a) Allow the User to register on the Website through the registration form;

b) Send the User strictly functional messages and communications to ensure interaction with the Website (e.g., registration confirmation email, password recovery emails, etc.);

c) Send the User messages and communications related to the execution of the contract to the registered email address, or the mobile number provided during registration;

d) Allow the User to interact with the content on the Website (e.g., creating the company's profile, posting job offers, accessing the company's dashboard, viewing the list of posted job offers, reviewing candidates' applications, reviewing analytics, etc.);

e) Manage User’s requests;

f) Fulfill pre-contractual, contractual, accounting and tax obligations resulting from existing relationships with the User; 

g) Fulfill the obligations required by law, regulation, European legislation or an order of the Data Protection Authority; 

h) Exercise the rights of the Data Controller (e.g. defense of legal claims);

i) Monitor the correct operation of the Website.

j) The lawful bases of the processing operations listed above are the following:

• in relation to purposes a), b), c), d), e), f) and g) the processing is necessary for the fulfillment of contractual or pre-contractual obligations.

• with regard to the purpose g) and h), the processing is necessary to comply with legal obligations.

• In relation to purposes i) and j), the lawful basis is the legitimate interest of the Data Controller, e.g., monitoring the correct operation of the Website and exercising the rights of the Data Controller (such as the defence of legal claims).

The provision of Data for the aforementioned purposes is mandatory. In the event of non-disclosure of the Data, the Data Controller will not be able to allow the User to interact with the Website.

In addition, the User's data may be processed only with the explicit consent of the User for marketing and statistical purposes.

k) To receive emails and promotional communications for commercial purposes, etc.

l) Statistical Purposes (upon consenting to cookies).

Moreover, regarding the purpose l), the data will be collected through Matomo Analytics (https://matomo.org/privacy- policy/) and Google Analytics. If a specific consent is required for certain analysis, it will be collected through the Cookie Banner.

The provision of Data for Marketing and Statistical purposes is optional. Therefore, the User may choose not to provide any Data or subsequently deny the processing of Data already provided. In such a case, the User will not be able to receive offers related to the services offered by the Data Controller or the Controller’s partners. The User may revoke consent to the Data processing at any time without affecting the lawfulness of the processing based on consent before revocation. This can be done by clicking on the link provided in each commercial email or by contacting the Data Controller at support-business@flexrem.com.

The User’s Data may also be processed through the use of Cookies. For further information about the processing, please consult the Cookie Policy: www.flexrem.com/cookie-policy.

C. CANDIDATES

Types of Data processed

To access the services offered by the Website/App, the User may be required to provide the following Data upon accepting the Terms and Conditions and this Privacy Policy:

• Identification data (e.g., name, surname, etc.) 

• Contact details (e.g., email, phone number, etc.)

By interacting with the content of the Website or App, the Data Controller may process the usage data generated indirectly through the use of the Website/App and navigation on the App/website.

Additionally, the App can trace the User’s device by storing the "universal unique identifier" (UUID) for statistical analysis and further device data and technical information about the User’s network (e.g., IP address) may be processed.

Purposes and Lawfulness of Processing 

The Data of the Candidate will be processed by the Data Controller for the following purposes:

a) Allow the User to navigate through the Website/ App; 

b) Allow the User to register on the Website/App through the registration form;

c) Send the User strictly functional messages and communications to ensure interaction with the Website/App (e.g., registration confirmation email, password recovery emails, etc.);

d) Send the User messages and communications related to the execution of the contract to the registered email address, or the mobile number provided during registration;

e) Allow the User to interact with the content on the Website/App (e.g., seeking job offers, applying for job positions, etc.).

f) Manage User’s requests;

g) Allow the User to send messages to other Users of the App using the chat available on the App;

h) Fulfill pre-contractual, contractual, accounting, and tax obligations resulting from existing relationships with the User; 

i) Fulfill the obligations required by law, regulation, European legislation or an order of the Data Protection Authority; 

j) Exercise the rights of the Data Controller (e.g. defense of legal claims);

k) Monitor the correct operation of the Website/ App.

The lawful bases of the processing operations listed above are the following:

• in relation to purposes a), b), c), d), e), f), g) and h) the processing is necessary for the fulfilment of contractual or pre-contractual obligations.

• with regard to the purpose h) and i), the processing is necessary to comply with legal obligations.

• In relation to purposes j) and k), the lawful basis is the legitimate interest of the Data Controller, e.g., monitoring the correct operation of the Website/ App and exercising the rights of the Data Controller (such as the defence of legal claims).

The provision of Data for the aforementioned purposes is mandatory. In the event of non-disclosure of the Data, the Data Controller will not be able to allow the User to interact with the Website/ App.

In addition, the User's Data may be processed only with explicit consent, for the following purposes: 

l) To receive emails and promotional communications for commercial purposes, etc.;

m) Statistical Purposes (upon consenting to cookies).

The communication of Data for Marketing and Statistical purposes is optional. Therefore, the User may choose not to provide any Data or subsequently deny the processing of Data already provided. In such a case, the User will not be able to receive offers related to the services offered by the Data Controller or the Controller’s partners. The User may revoke consent to the Data processing at any time without affecting the lawfulness of the processing based on consent before revocation. This can be done by clicking on the link provided in each commercial email or by contacting the Data Controller at support-business@flexrem.com.

The User’s Data may also be processed through the use of Cookies. For further information about the processing, please consult the Cookie Policy: https://www.flexrem.com/cookie-policy.

3. Storage period

Personal data of the Flexrem Website/ App Users will be kept for the time necessary to fulfill the purposes indicated in this Privacy Notice. 

The Data Controller will store for 10 (ten) years copies of correspondence of legal and commercial relevance. Finally, the User's Data may be kept for the time necessary to ensure the defense in court or to prosecute any abuse in the use of the Website/App.

Data relating to marketing consents will be kept for a period not exceeding 5 years from the moment when the consent was given by the User.

In the event of a request for information, the data will be stored for a period of 24 months (exclusively for data that has no legal or commercial value).

With regard to data deletion, the personal data of Users will be deleted after the deletion of the User's personal account, a specific request from the User, or after 36 months from the User's last interaction with the Website/Application. The Data Controller will retain any data for which a legal obligation for data retention exists.

The User's personal Data processed through the use of cookies will be deleted in the ways indicated in the Cookie policy: https://www.flexrem.com/cookie-policy.

4. Communication, dissemination and transfer of Data

User’s data will not be disclosed but may be made accessible, where necessary for the provision of services or by law:

• to employees and consultants of the Data Controller in Italy and abroad, as authorized subjects to the processing of personal data and/or system administrators; 

• to third party companies or other subjects (for example, credit institutions, professional firms, computer consultants, etc.) that perform outsourcing activities on behalf of the Data Controller, as external Data Processors. 

The Data Controller may communicate the User’s data for the purposes of Art. 2 to supervisory bodies, judicial authorities, public bodies to which it is mandatory to communicate the Data, as well as to those subjects to whom the communication is required by law. 

Please see below the list of the Data Processor and Sub-Processors involved in the operation of the platform:

5. Permissions requested by the Application

To enable the Users to use the Flexrem App, the Data Controller requests the following permissions:

6. Data Transfer

Users from the EEA, Switzerland, and the UK

The User’s Data are stored on servers located within the European Union, managed by third party companies duly appointed as Data Processors.

For specific purposes, the User’s Data may be transferred by the Controller to countries outside the EEA, Switzerland or the UK. The Data will be transferred exclusively to countries considered “adequate” - and therefore “safe” - by the European Commission or to companies that have adhered to specific international standards (e.g., Standard Contractual Clauses, Data Privacy Framework, etc.).

7. Rights of the Data Subject

The Data Subject may exercise, in relation to the Data Processing, the following rights:

a) Access rights – the right to receive confirmation that the User’s Data is held by the Data Controller, and access its content;

b) Right of rectification – the right to update, modify and/or correct the User’s Data;

c) Right to be forgotten and right to limitation - request the cancellation of Data and/or limitation of the Data Processing if the User believe that the Data is being processed in ways that do not comply with the present Privacy Notice;

d) Right to object – the right to oppose the processing of the User’s Data;

e) Submit a complaint to the relevant Supervisory Authority;

f) Right to Data Portability – the right to receive an electronic copy of the Data concerning the User (when such Data has been rendered in the context of the contract) and request that the Data in question be transmitted to another data controller

g) Right to opt-out of the sale or sharing of personal data – request the Data Controller to cease selling or sharing the User’s personal information.

8. Contact details of the Data Controller

Data controller of User's personal data Flexrem S.r.l. , VAT Number 12971200014

E-mail: flexrem@legalmail.it

Address: Corso Giacomo Matteotti, 12 - Torino (TO) - 10121

The User may exercise his/her rights at any time by sending:

• a registered letter with acknowledgment of receipt to: Flexrem SRL 

• an e-mail to: support-business@flexrem.com

9. Data Protection Officer

Flexrem has appointed a Data Protection Officer (DPO). The DPO can be contacted by sending an e-mail to the following address: dpo.flexrem@argobs.com. 

10. Information not contained in this Policy 

Further information regarding the processing of personal data may be requested to the Data Controller using the contact information provided in this Privacy Policy. 

11. Amendments to this Privacy Policy

This Policy may be modified. The User is therefore advised to regularly check this Policy at the following link: https://www.flexrem.com/privacy-policy.