The confidentiality of personal data is a right which the Gi Group companies seek to respect, and for this purpose, they wish to make known, even in accordance with Article 13 of the Legislative Decree of the 30 June 2003 no. 196 (regarding the Personal Data Protection Code), the norms and procedures which regulate the processing of personal data as well as the way it is gathered and used, and the choices available to the user. The present declaration on the confidentiality of personal data, available on the Group’s Portal (www.gigroup.com) and in the various home pages of the Group’s companies, applies to all the websites and domains of the Group’s companies [«.it», «.eu», «.com», «.net», «.org» and «.info»] and may be subject to updates.
All the websites of the Group’s companies are structured in a way so as to allow the user to visit them without identifying him/herself or revealing personal information in any way. The present portal contains links to the Group’s companies and is used both as a means of obtaining information of the activities that took place as well as a tool for collecting data.
LINKS TO WEBSITES WHICH ARE NOT PART OF GI GROUP
To give the user more convenience and information, the Group’s Portal and websites of the Group’s companies may contain links to other companies’ websites. If one gains access to these links one leaves the Group’s portal or the website of the Group’s company. The Group’s companies have no control over these sites, neither on the procedures which they apply to respect data confidentiality. These procedures can therefore be different from those adopted by the Group’s companies, which, consequently, do not assume any responsibility in relation to other companies’ websites. The personal data which the client decides to disclose to third parties not linked to the Group’s companies are not covered by the present Declaration of confidentiality. Therefore, before disclosing personal information, the users are invited to consult the regulations on the privacy of the persons with whom they come into contact. Certain companies which are unconnected with the Group may decide to share the personal data they possess with the Group. In this case, the regulation used by the company in question to deal with personal data is applied.
TYPES OF DATA AND METHODS OF COLLECTION
The present Declaration of data confidentiality concerns personal information, the collection of data not considered personal and data known as aggregate data.
This involves information associated with the visitor’s name or personal identity (company or candidate). The Group’s companies use personal information to understand the visitor’s needs and interests better and to provide a better service. If one chooses to disclose the information, the Group’s companies guarantee that they will be used solely in support of the relationship with the visitor or candidate, and since they value the trust shown by their visitors, they commit themselves not to reveal the personal information gathered to third parties.
One some sites of the Group’s companies it is possible to register or present one’s own application, request information, subscribe to informative newsletters, and request for other services. The types of personal information may include name, address, telephone number, email, user ID and password, the preferred ways of being contacted, information on education and training, occupation and professional interests. Relevant information is provided for the processing of this data, and consent is requested in the various pages of the websites which allow its transfer.
In order to personalise the websites, services and communications, and to improve the services offered, visitors may be asked for information on personal or professional interests and on household composition. This supplementary information is optional and its transmission always follows the reading of relevant statements and the consent granted by the visitor.
This involves information regarding the use and operation of the service, which is not associated with a specific personal identity. The Group gathers and analyzes non-personal information in order to evaluate usage by the visitors.
“Non-personal aggregate” data is the information registered about the users and combined in such a way that it is no longer possible to identify the individual users. It is possible that the Group’s Companies share some non-personal aggregate information with third parties, such as the number of users which have submitted a CV on one of our sites, or how many users have clicked on a particular banner. Such information does not allow identification of the user’s personal data.
USE OF DATA
The companies of the Group offer the possibility to receive various kinds of information to complement one’s own core business. The user may subscribe in order to receive some specific information regarding job offers or services, and promotional/publicity and marketing communications of the companies. The communications may include information on new services, participation in events and meetings which could also include training, or invites to participate in market research. This option does not apply to communications regarding the management for support, the services’ security warnings, or data updates.
The Group’s companies do not use personal information for purposes other than those declared at the moment of data collection.
If one chooses not to receive any more communications which have been asked for in a particular way (example a newsletter through email, job offers and so on), it is necessary to click on the email link «opt-out» or «unsubscribe» or to follow the instructions enclosed with every communication that is sent. Alternatively, the user can cancel through the relevant procedure available on the websites, by following the instructions to suspend subscription.
Some services provided by the Group’s companies are linked to others, provided by third-party agencies, and some of these services offer the possibility of giving one’s personal data to the other companies of the Group as well as to third-party agencies. This type of service includes the possibility of registering for a job offer from one single web page, to ask for commercial communications, or to authorize communication for a job interview. The companies will give this personal information to third-party agencies only if the candidate or visitor gives consent.
PROCEDURES REGULATING THE PROCESSING OF DATA
The Group’s companies use personal information to get to know the visitor’s needs and interests and to improve the services on offer. In particular, personal data is used to help the user to complete registrations, to send communications, to provide a service, to update the users on services and advantages on offer, as well as to personalise the job offers and the Group’s companies’ websites. The data provided can occasionally be used to contact clients in the field of market research regarding work possibilities and, in general, the services offered by the Group’s companies.
The personal data collected online can also supplement the information provided to the Group’s companies in another way, for example through a call centre, training meetings, seminars, and other meetings.
Personal data disclosed to the companies can also be transferred abroad, for operations connected with the storage and management of information, in relation to appropriate security measures and in accordance with what has been stated by the existing legislation on the protection of personal data.
Non-personal data is aggregated in reports about the usage, performance and efficiency of the Group’s companies. This data is used to improve the service given to the client, to facilitate the use of websites and to improve the content.
The Group’s companies commit themselves not to disclose the personal information gathered to third parties, and they may communicate this personal information to third parties only to reply to specific requests posed by the candidates or visitors regarding the job possibilities or the services offered. The release of this information on the user’s part depends on his consent.
The Group’s companies conclude contracts with third parties for the provision of services, products and complete solutions for the candidates and visitors, according to what is described in the section entitled «Use of the information». The companies which provide services and the providers are obliged to maintain confidentiality as regards the information received and cannot use it for purposes other than the services which they carry out to this end. The Group’s companies can share personal information with third parties only if the client or the candidate gives consent, unless it is in compliance with the law, the regulation or the community law.
The Group’s companies can merge or be bought by other legal entities and part or all of their goods can be bought. In such cases, each company will inform the candidate or the visitor of the possible need to disclose personal information to such entities so that he/she may continue to take advantage of the service or the information.
The Group’s companies commit themselves to take great care of personal information. For this reason, they have implemented technology, the management processes and the necessary procedures to treat as confidential the data about the candidates or visitors. The client has the possibility of accessing information about him/her; the Group’s companies will work to consent online access and allow clients to edit and update information. To guarantee privacy and user protection, before allowing access to the companies’ data one has to verify identity, for example by means of a password and user ID. Some parts of the Group companies’ websites may limit access to certain persons through the use of a password and other personal identification.
The most efficient way of viewing and modifying personal information consists in going back to the web page in which the data has originally been given and proceed according to the instructions which reappear. The Group’s companies commit themselves to protect the information given by the candidates or visitors. In order to avoid unauthorised access or the spreading of information, to keep the data accurate and to guarantee the appropriate use of the information, the Group’s companies make use of suitable procedures to protect the collected data.
Changes to the present Declaration
In the case of changes to the terms of the present Declaration on the confidentiality of online data, the Group’s companies will make the changes in question public and will update this document’s date of revision, so that the users will always be able to know which information is gathered online, the way in which it is used and the facilities available to them. If significant changes take place to this Declaration, every company of the Group will send a message to candidates and registered users.
Contact the Group’s companies
All the companies of the Group welcome the candidates and visitors’ opinions, who can also ask their own questions, and send their own comments and suggestions about the present Declaration on data privacy to firstname.lastname@example.org
Rev. January 2008
##The URL (Uniform Resource Locator) is the global address of the documents and other resources present on the World Wide Web. For example, http://www.gigroup.com is the URL of the Gi Group home page.
##The IP address identifies a computer or a device on a TCP/IP network (Transmission Control Protocol/Internet Protocol), for example the World Wide Web. The networks use the TCP/IP protocol to direct the information according to the destination IP address. In other words, the IP address is the number assigned automatically to the computer each time it gains access to the Internet and allows Web servers to locate and identify it. In order for users to communicate, use or buy on the Internet, computers have to use IP addresses.
A «cookie» is a small data file transferred from a website to the hard drive of the visitor’s computer. The Group’s societies send cookies when their sites are used, when information is requested or personalized or when one registers for particular services. If the visitor’s computer accepts the cookies used by the sites of the Group’s companies, the visitor does not have the possibility to access his personal information but can use the cookies to identify the computer. Normally, cookies are classified as «temporary» or «permanent». «Temporary» cookies do not remain on the computer once one leaves the website or after the browser is closed. The aggregate information collected allows the Group’s companies to analyse the site’s traffic patterns. In this way, it is possible to improve the site by modifying or personalising the content, thus making it more user-friendly.
«Permanent» cookies, on the other hand, remain on the visitor’s computer. They enable one to facilitate navigation, personalization and registration services. Cookies, for instance, can keep track of services asked for and the pages visited up to that time and enable one to put the password only once in web pages which request user identification. The user can manually remove «permanent» cookies.
Microsoft Internet Explorer: http://www.microsoft.com/info/cookies.htm
Some web pages and some email newsletters in HTML format belonging to the Group’s companies use beacons together with cookies to compile aggregate statistics on the usage of the site. A beacon is an electronic image, called an empty GIF or single pixel GIF (1×1). Beacons can recognize some kinds of information present on the visitor’s computer, for example the number of cookies, time and date when the page was viewed and the page description of where the beacon is found. It is possible to deactivate some beacons by refusing the cookies associated with them.