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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

This type of cookie allows the proper operation of certain sections of the site and they are essential to enable the user to navigate through the site and to use its functionalities without acquiring personal identification data. Without these cookies, certain services will not run properly.

About “technical cookies”, which do not require explicit consent for their use, the Data Protection Authority included:

  • navigation or session cookies;
  • “analytic cookies”, include the anonymous information used for statistical purposes and for evaluating the use of the website by the visitor and report on the activities carried out on the site;
  • “functionality cookies”, that allow the website to store some user settings (such as the language in which to display the text of the site) in order to propose them automatically during future visits.

Consent banner cookies

The website uses the following cookies for which explicit consent is required from the user who visits the site.

__hstc
The main cookie for tracking visitors. It contains the domain, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number.
(Expires: 2 years)

hubspotutk
This cookie is used to keep track of a visitor’s identity.
(Expires: 10 years)

__hssc
This cookie keeps track of sessions. It contains the domain and session start timestamp.
(Expires: 30 minutes)

__hssrc
Used to determine if the visitor has restarted their browser.
(Expires: session)

Third Party Cookies

This type of cookie incorporates features developed by a third party (eg: Facebook, Twitter, YouTube, etc.) within the pages of the website in order to share website contents or for the use of specific software services.

Third parties have their own policy on the use of cookies and their own privacy policy; different from the one adopted by the Proge-Software website and for which Proge-Software is totally extraneous and not responsible.

User’s Consent

The consent is required via a pop-up banner.

All technologies allow you to manage the cookies of your browser. This means that you can delete cookies from your browser once terminated the visit to the site or you can turn them off before you visit our website. However, please remember that certain areas or features of the site depend on the use of cookies and their deactivation could impede the user of the correct display of the site or of the use of specific features.

You can authorize, block or delete (in whole or in part) cookies through the specific functions of your browser (Internet Explorer, Firefox, Chrome, Safari, etc.), by consulting the relevant instructions.

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.