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Privacy Policy

Information notice and collection of consent pursuant to Article 13 of the General Data Protection Regulation (EU Regulation No. 2016/679)

Dear User,

pursuant to Article 13 of EU Regulation No. 679/2016 (hereinafter the “GDPR”) and Legislative Decree No. 196/2003, as subsequently amended (hereinafter the “Privacy Code”), containing provisions for the protection of individuals and other parties with regard to the processing of personal data, we wish to inform you that your personal data will be processed in compliance with the aforementioned legislation and with the confidentiality obligations binding Giorgiutti Alberto & Associati (Labour Consultancy Firm) and Giorgiutti S.r.l. (data processing, particularly payroll and social security contributions).

Joint Data Controllers

Pursuant to Article 26 of the GDPR, the Joint Data Controllers are Giorgiutti Alberto & Associati (Labour Consultancy Firm) and Giorgiutti S.r.l. (data processing, particularly payroll and social security contributions), which share the following contact details:

  • registered office: Via SS. Francesco d’Assisi, 39 – 33100 Udine – Italy;
  • telephone: 0432.501133 / 0432.292126
  • fax: 0432.506532
  • email: privacy@giorgiutti.it

Purposes of processing

Your personal data is processed for the following purposes:

Managing contact requests submitted through the dedicated form on the Joint Data Controllers’ website.

Lawfulness criteria and legal bases for processing

The processing of your personal data is based on the following lawfulness criteria and legal bases:

Processing is necessary in order to take steps at the request of the Data Subject prior to entering into a contract (Article 6(1)(b) GDPR; Article 24(1)(b) Privacy Code). Where none of the above lawfulness criteria or legal bases applies, processing is based on the Data Subject’s consent (Article 6(1)(a) GDPR and Article 23(1) Privacy Code for ordinary data; Article 9(2)(a) GDPR and Article 26(1) Privacy Code for special-category data).

Ordinary personal data

For the purposes indicated above, ordinary personal data will be processed, including personal, identification and contact details and information relating to the professional nature of the contact request.

Special categories of personal data

Processing special categories of personal data under Article 9 GDPR is not normally envisaged for the purposes indicated, although it cannot be excluded entirely. Such data includes data “revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation”.

Personal data relating to criminal convictions and offences

The processing of personal data relating to criminal convictions and offences under Article 10 GDPR is not envisaged.

Authorised persons, processing methods and categories of recipients

For the purposes indicated above, your personal data will be processed, including by duly appointed and authorised persons and by electronic and IT means, and may be disclosed to the following categories of recipients:

Consultants and independent professionals operating individually, in associations or as companies and providing specialist consultancy in employment law and related matters; email providers; other consultants.

Transfers of data to third countries

For the purposes indicated above, your personal data will not be transferred to countries outside the European Union or to international organisations.

Data retention period

Your personal data will be retained for the purposes indicated above according to the following criteria:

If no professional engagement is established, the data will not be retained for more than one month from the date it is collected.

Automated decision-making

For the purposes indicated above, your personal data will not be subject to any automated decision-making process, including profiling, as referred to in Article 22(1) and (4) GDPR.

Rights of the Data Subject (your rights)

Pursuant to Article 13 GDPR, you have the right to:

  • request access to your personal data from either Joint Data Controller and request its rectification or erasure, restriction of processing concerning you, or object to its processing, as well as exercise your right to data portability;
  • where processing is based exclusively on the Data Subject’s consent, withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal;
  • lodge a complaint with a supervisory authority pursuant to Article 77 GDPR;

Please also note that:

  • where processing is based on a legal or contractual obligation binding one or both Joint Data Controllers, providing the data is mandatory;
  • pursuant to Article 17(1)(b) GDPR, withdrawal of consent gives you the right to erasure only where there is no other legal ground for processing—for example, as in this notice, where processing is necessary in order to take pre-contractual steps requested by the Data Subject;
  • pursuant to Article 17(1)(c) GDPR, exercising the right to object gives you the right to erasure only where there are no overriding legitimate grounds of one or both Joint Data Controllers or third parties;
  • more generally, exercising the rights described above is subject to the restrictions set out in Article 23 GDPR and Article 2-undecies of the Privacy Code.

To exercise the rights described above, you may contact either Joint Data Controller by sending a communication for the attention of its legal representative pro tempore to the contact details shared by both Joint Data Controllers and stated at the beginning of this notice, repeated here for convenience:

  • registered office: Via SS. Francesco d’Assisi, 39 – 33100 Udine – Italy;
  • telephone: 0432.501133 / 0432.292126
  • fax: 0432.506532
  • email: privacy@giorgiutti.it

Finally, please note that failure to provide the data, withdrawal of consent, or exercising the rights to erasure, restriction or objection to processing may make it technically impossible for the Joint Data Controllers to respond to your contact request.