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Privacy Policy

In accordance with the article 13 of the Regulation (EU) 2016/679 (hereafter: GDPR), this document defines Proge-Software S.r.l.’s privacy policy concerning the management of processed personal data when using our Website.

According to GDPR, the processing carried out by Proge-Software will be based on the principles of lawfulness, transparency, fairness, accuracy, purpose and storage limitation, data minimization, integrity and confidentiality.

1. Data controller

The Data Controller is Proge-Software S.r.l., based in Rome, Via Mentore Maggini n. 50.

For any information regarding the processing of personal data, please contact us at the following email address GDPR@progesoftware.it.

DATA PROTECTION OFFICER

Avv. Isabella Alessandrucci

Email: dpo@progesoftware.it

2.Personal data

Personal data processed through the website are the following:

a) Navigation data.

Personal Data whose transmission is implicit in the use of Internet communication protocols, such as IP addresses or computers domain names used by users who connect to the Website, the URI (Uniform Resource Identifier) addresses of the requested resources, the request timetable , the numerical code indicating the status of the response given by the server (success, error, etc.). These data are used to obtain anonymous statistical information on the use of the website and to check its correct functioning, to identify anomalies and/or abuses, and they are deleted after processing.

b) CV personal data.

You can send your CV via the “Work with us” section of the website.

In accordance with the article 111-bis of the D. Lgs. 196/03 (as amended by D. Lgs. 101/2018) the consent to the processing of CV, voluntarily transmitted by the interested parties for the purpose of establishing an employment relationship, is not due.

The statement pursuant to article 13 of EU Regulation 2016/679 (General Data Protection Regulation) will be provided at the time of the first useful contact.

c) Data provided voluntarily by the data subject.

If, while using some website services, you send Third Parties personal data , you act as Data Controller, assuming all the legal obligations and responsibilities, and conferring to Proge-Software the widest indemnity with respect to any responsibility, dispute, request for compensation, etc., that could reach Proge-Software from third parties whose Personal Data have been processed through the use of the website in violation of GDPR and of the other applicable rules on the protection of personal data.

3. Processing finality and legal basis

The treatment, with its specific consent where necessary, has the following purposes:

  1. respond to requests for information or participation in events, meetings, webinars, workshops, etc., organized by Proge or its subsidiaries, including outside the European Union;
  2. analyze the CV and recontact the candidates who have submitted their application through the “Work with us” section;
  3. fulfill any legal obligations.

The legal basis of the Personal Data processing for the purposes set out in points 1-2 is art. 6 comma 1) letters a)  b) of the GDPR, as the processing is necessary for the response of requests by the interested party. The provision of Personal Data for the purpose set out in point 1 is optional, but failure to provide it would make it impossible to respond to requests.

The legal basis of the Personal Data processing for the purpose set out in point 3 is art. 6 comma 1) letter c) of the GDPR, the processing may be necessary to fulfill a legal obligation.

4. Data retention

The Data Controller will process personal data as long as necessary to fulfill the purposes set out in Section 3 and, in any case, no later than 2 (two) years from receipt.

5. Recipients of personal data

Your Personal Data will not be disclosed.

Your Personal Data may be shared, for the purposes referred to in Section 3 above, with:

  • subjects authorized by Proge-Software to the processing of Personal Data necessary to carry out activities strictly related to the requests (eg: employees, Proge-Software’s collaborators);
  • subjects, public entities or authorities, in accordance with the provisions of law;
  • prior your consent, your personal data may be shared with Proge-Software’s Subsidiaries, also outside the European Union. prior to consent, to partner companies of Proge-Software.

6. Cookies

Proge-Software’s website uses cookies to make navigation easier and more efficient for users who visit the portal pages.

A web cookie is a series of information in small text files that are stored on your computer by the website that you are visiting. In general, they contain the domain name, the cookie life cycle and a value, usually a unique number randomly generated.

Cookies fall into two general categories:

  • Essential/necessary cookies: these cookies do not require consent;
  • Consent banner cookies: there are cookies included in the consent banner under GDPR.

Essential/necessary cookies

These types of cookies are crucial for the proper functioning of the website or are necessary to perform tasks requested by the user. They do not collect any personally identifiable information. Without these cookies, some services may not function properly.

Among technical cookies, which do not require explicit consent to be used, are:

  • Browsing or session cookies

  • Functionality cookies, which allow the website to remember certain user-selected settings (such as the preferred language for viewing the site) and automatically reapply them during future visits.

The only cookie directly managed by Proge-Software is the language preference cookie, which has a duration of 12 months.
All other cookies are managed by third-party platforms:

  • HubSpot: For details on the types of cookies used by HubSpot, please refer to this page.

  • Cloudflare: For information on the types of cookies used by Cloudflare, please refer to this page.

Other Types of Cookies (Optional)

These cookies require explicit user consent, which is requested on the first visit to the site through a dedicated pop-up window. Consent can be modified at any time via the “Cookie Preferences” link in the footer of every page on the website.

These optional cookies are also managed by third-party platforms, such as:

  • HubSpot: For details on the types of cookies used by HubSpot, please refer to this page.

Third-Party Cookies

These cookies incorporate functionalities developed by third parties (e.g., Facebook, Twitter, YouTube) into the website pages to allow content sharing or the use of specific software services.

Each third party has its own privacy and cookie policy, which differs from that of the Proge-Software website. Proge-Software is not responsible for and has no control over third-party cookie policies.

These cookies are also managed through the HubSpot platform used by Proge-Software and have a maximum duration of 13 months. For a detailed list of the cookies used by HubSpot and their purposes, please refer to this page.

User Consent

Consent to the use of cookies is requested upon the user’s first visit to the site via a dedicated banner. This consent can be modified at any time via the “Cookie Preferences” link available in the footer of all site pages.

The choice remains valid for 180 days, after which you will be prompted to provide your consent again.

Cookies can also be managed (in whole or in part) using the specific settings of your browser (e.g., Internet Explorer, Firefox, Chrome, Safari). For more information, please consult your browser’s instructions. This means you can delete cookies after visiting the website or disable them before accessing our site.

However, please note that some areas or functionalities of the website rely on cookies, and disabling them may prevent the site from displaying properly or limit the availability of certain features.

7. Personal data transfer guarantees

Some of your Personal Information could be shared with Proge-Software’s Subsidiaries, also outside the European Union. The Data Controller ensures that the processing of their Personal Data by these recipients takes place in compliance with the GDPR.

8. Data subject rights

You can, in any case, request the correction, the integration of data or oppose yourself to the processing and exercise any other rights provided in artt. 15, 16, 17, 18, 20 of Regulation (EU) 2016/679, by sending an e-mail to GDPR@progesoftware.it.

9. Compliants

In addition to the Data Controller, you shall have the right to lodge a complaint with Italian Data Protection Authority or to another Supervisory Authority.

10. Changes

This privacy policy is effective from 25/05/2018. Proge-Software reserves the right to modify or update its content, in part or completely, also due to changes in the applicable legislation. Proge-Software therefore invites you to regularly visit this section to get to know the updated version of the privacy policy.