PRIVACY POLICY
Information on the protection of personal data pursuant to articles 13 and 14 of Regulation (EU) 2016/679
Gentes S.r.l. Benefit company with registered office at Via Madonna dei Cieli 40, 88100 Catanzaro, Italy, VAT number 12115260965, email
info@refugeerestart.com, certified email as
Data Controller (hereinafter, the “
Company” or the “
Controller“), provides below the common information regarding the processing of personal data carried out in the context of its institutional website accessible online from the address:
https://refugeerestart.com/ (hereinafter, the “
Website“). In this regard, it is specified that the information is provided only for the Company’s website and not for other websites possibly accessed through hypertext links published on the Website but referring to resources outside the Company’s domain. For the provision of certain services, specific information may be published on the corresponding pages of the Website, which constitutes an integral part of this information.
Categories of Users and processed personal data
The Controller processes the personal data of:
- individuals (hereinafter, the “Entrepreneurs“), who access the Website and voluntarily register in order to take advantage of the web services offered by the Controller aimed at identifying all potential talents and aspiring entrepreneurs (mainly among refugees and migrants) and facilitating their integration into the labor market according to the occupational demand or meeting potential investors and funders, also offering them a personalized training path to strengthen and update their skills (hereinafter, the “Services“);
- other individuals who visit the Website without accessing the sections dedicated to Entrepreneurs (hereinafter, the “Other Users“). (hereinafter, the Trainees and the Other Users collectively referred to as “Users“). The personal data processed are:
a. with exclusive reference to Entrepreneurs:
a.1.)
common data, such as:
- Personal data, contact details including electronic contact details and banking details;
- Citizenship and any immigrant status as well as additional “ordinary” information related to such status (such as transit regions);
- Data relating to education (qualification, language skills, etc.) and work experience;
- Professional and personal skills (including milestones achieved in the activities of the Controller) and areas of interest;
- Further information denoting a situation of particular vulnerability (such as refugee status; having undergone detentions during the journey to Europe; acts of persecution suffered, etc.) but not falling within the category of special data under art. 9 GDPR nor related to criminal convictions and offenses under art. 10 GDPR
(hereinafter, the “
Ordinary Personal Data“)
a.2.)
geolocation data: the Website may collect geolocation data (thus allowing the real-time geographical location of the Entrepreneur’s device to be identified) with evidence of only the IP address (hereinafter, the “
Geolocation Data“)
a.3.)
special data, such as:
- Information concerning refugee status (for example, the reason for seeking asylum);
- Any information concerning racial or ethnic origin;
- Any information concerning health status.
(hereinafter, the “
Special Personal Data“).
b. with reference to all Users:
b.1.) browsing data: the computer systems and software procedures used to operate the Website acquire, during their normal operation, certain personal data, the transmission of which is implicit in the use of Internet communication protocols. In this category of data are: IP addresses or domain names of the computers and terminals used by users, the URI/URL addresses (Uniform Resource Identifier/Locator) of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user’s IT environment.
With regard to Entrepreneurs, implicit browsing data also includes qualitative and quantitative data regarding the actions performed on the Website (with particular reference to available training activities), that is, which activities the Entrepreneur has carried out, for how long, etc. (hereinafter, all, the “
Browsing Data“).
b.2.) Communicated Data: the optional, explicit and voluntary sending of messages through the completion of forms on the Website, as well as to the contact addresses of the Company and private messages sent by Users to the institutional profiles/pages on social media (where this possibility is provided for) entails the acquisition and processing of the sender’s contact details necessary to respond as well as all personal data included in the communications and in the registration forms (hereinafter, the “
Communicated Data“)
(all Ordinary Personal Data, Special Personal Data, Geolocation Data, Browsing Data, and Communicated Data, collectively, the “
Personal Data“).
c. Cookies and other tracking systems: refer to the
cookie policy on the Website.
Categories of Users and processed personal data
- Execution of the Services and activities connected and instrumental to them (such as carrying out “preliminary screenings” on the skills of Entrepreneurs to identify strengths and weaknesses, monitoring recorded performances, etc.) and the fulfillment of organizational and managerial obligations (including sending communications regarding the Services).
- Fulfillment of a legal obligation connected to civil, tax and administrative provisions, community regulations, rules, codes or procedures approved by Authorities and other competent Institutions, as well as to comply with requests from the competent administrative or judicial authority and, more generally, from public entities in compliance with legal formalities.
- To assert and defend one’s rights, also through out-of-court initiatives and also through third parties, as well as to prevent crimes (such as fraud, identity theft, immigration-related crimes, computer crimes, etc.).
- Limited to data under par. 1 point b): the related processing is necessary to allow Users to browse the Website, guarantee the functioning of the Website and provide the Services requested by Users.
- For the purposes set out above, the processing is based on the consent expressed by the Data Subjects, which must be collected and documented separately in a suitable manner, in accordance with art. 7 GDPR.
Recipients and categories of recipients of personal data
As part of the purposes described, Personal Data may be disclosed to:
- all employees and collaborators of the Controller, as well as to the subjects who carry out instrumental activities on behalf of the Controller;
- legal and tax consultants and, in general, all subjects who provide services necessary for the provision of Services;
- competent authorities for the fulfillment of legal obligations and/or provisions of public bodies, upon request;
- subjects to whom the right to access Personal Data is recognized by provisions of law or secondary or community regulations.
Security measures
Personal Data are processed by the Data Controller, with the help of its employees and/or collaborators, who act on the basis of specific instructions provided for the purposes and methods of the processing itself. Security measures are taken to prevent data loss, illicit or incorrect use, and unauthorized access.
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**The Data Controller** is **Gentes S.r.l.** with registered office at **Via Madonna dei Cieli 40, 88100 Catanzaro, Italy**, VAT number **12115260965**. You can contact the Data Controller by sending a letter to the address above or an email to **info@refugeerestart.com** or **certified email.**
This document is visible at the internet address: **https://refugeerestart.com/privacy-policy**
