Customer Policy

Calenti & Partners S.r.l. (hereinafter, for brevity, referred to as the “Company” or “the Data Controller”), in its capacity as the Data Controller, wishes to inform you, pursuant to the applicable data protection legislation, including European Regulation 679/2016 on the protection of personal data (the “Regulation”), that the personal data you provide at the time of establishing the relationship and throughout its duration will be processed in accordance with the applicable legislative and contractual provisions for the purposes and in the manner set forth below. In certain circumstances, some data may also be collected from third parties, where necessary and always in compliance with the applicable legislation.

1. Identity and Contact Details of the Data Controller
The Data Controller is Calenti & Partners S.r.l., with its registered office at Via Plinio No. 11, Milan, Italy.

2. Categories of Personal Data, Purposes, and Legal Basis of Processing
The Company may process:

  • Identification and Contact Data: first and last name or company name, tax code or VAT number, residence or registered office, email address, phone number;
  • Tax-related data or any other data necessary to process or receive payments..

The aforementioned personal data are processed for the following purposes and under the following legal bases:
a. To fulfill obligations arising from the law and/or the existing contract with the Company, to which this notice is attached, and to provide the requested consulting and assistance services. In this case, the lawfulness of processing is based on the necessity to comply with legal obligations related to the establishment and management of the employment relationship (Article 6.1, letters b and c of the Regulation).
b. To manage potential disputes and protect the rights of the Company. In this case, the lawfulness of processing is based on the necessity of pursuing the Company's legitimate interest (Article 6.1, letter f of the Regulation).
No consent is required for these purposes.
c. The provided data may also be processed for the purpose of sending newsletters, informational communications, or for marketing purposes. In this case, the lawfulness of processing is based on your consent (Article 6.1, letter a of the Regulation).

3. Data Processing Methods and Nature of Data Provision
The Company will process personal data using both digital and paper-based systems, in accordance with the principles of fairness, integrity, and transparency established by applicable data protection regulations. The Company is committed to safeguarding your confidentiality and rights by implementing appropriate technical and organizational measures to ensure a security level appropriate to the risk.

The provision and updating of your personal data is mandatory under applicable laws (e.g., tax regulations or others) or for the execution of the contractual relationship. Without such data, it will not be possible to establish or, in certain cases, continue the relationship.

The provision of data for the purposes outlined in section 2.c. is optional, and failure to provide such data or withdrawal of consent will not affect the contractual relationship but will only result in the inability to process the data for the specified purposes.

4. Data Retention
All data relating to you will be stored in compliance with civil and tax obligations (e.g., the civil law obligation to retain accounting records and additional business correspondence for 10 years) and, in any case, only for the duration of the existing contract. Once the contractual relationship has ended, to protect the Company's rights, data will be retained—accessible only in case of necessity—for a period corresponding to the statute of limitations for any rights you may claim against the Company. This period varies depending on the type of data and any circumstances that may interrupt or suspend the limitation period.

If you consent to the processing of your data for the purposes outlined in section 2.c., such data will be retained for a maximum of 24 months from the date of collection.

5. Data Recipients
Your data will not be disclosed but, for the purposes outlined above and in compliance with the principles of the Regulation, may be shared with: the Company's employees, its collaborators, consultants, and professionals (including, but not limited to, accountants and communication agencies). In compliance with legal obligations, contractual requirements, or upon your request, data may be shared with public entities or governmental authorities.

6. Data Transfer
Your data will be stored at the Company's headquarters and its servers (both located in Italy), as well as on the servers of communication agencies within the EU. In any case, your data will not be transferred outside the EU.

7. Data Subject Rights
The data subject may exercise, in relation to the data processing described herein, the rights provided by the applicable data protection legislation, including the right to:

  • To receive confirmation of the existence of your personal data and access its content (right of access);
  • To update, modify, and/or correct your personal data (right to rectification);
  • To request the deletion or restriction of the processing of data processed in violation of the law, including data that is no longer necessary for the purposes for which it was collected or otherwise processed (right to erasure and right to restriction of processing);
  • To object to processing based on legitimate interest (right to object);
  • To withdraw consent, where given, without prejudice to the lawfulness of processing based on consent provided before the withdrawal;
  • To lodge a complaint with the Supervisory Authority in case of a violation of data protection regulations;
  • To receive a copy of their personal data in electronic format, as provided in the context of the employment contract (e.g., salary data, internal mobility services), and to request that such data be transferred to another data controller (right to data portability).

To exercise these rights, you may contact the Company at any time by sending your request to the following email address: privacy.emaitaly@ema-partners.com, or by registered mail with return receipt to the following address: Via Plinio No. 11, Milan, Italy.

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Candidate Policy

1. Why We Need Your Data
The data provided will be processed, using both digital and paper-based tools, for the specific purpose of pursuing the legitimate interest, shared by both parties, of offering you professional opportunities. Providing data for these purposes is necessary, and failure to provide such data or any request for their deletion will result in the inability to pursue the legitimate interests mentioned above and, in any case, to fulfill any mandate granted to EMA Partners Italy | Calenti & Partners as the Data Controller within the limits specified above.

2. What Personal Information We Collect
EMA Partners Italy | Calenti & Partners may process the following personal data: first and last name, tax code or VAT number, residence, email address, phone number, education details, academic qualifications, language skills, IT skills, professional skills of any kind, previously held job positions, hobbies and interests, and any other data included in your CV or otherwise provided by you for the purposes and legitimate interests outlined above. The company also informs you that it may process data obtained from third parties, duly authorized by you, to more effectively pursue the interests outlined in Section 1.

In particular, the company may process your personal data related to professional skills and aptitudes provided by the following companies: Gallup Inc., Six Seconds Inc., Hogan, and Decision Dynamics AB, in case you have completed any questionnaires requested by us. The interview may occasionally be recorded solely for the purpose of verifying the accuracy of the interviewer's notes against the actual responses given.

Within a maximum of one month, after the verification process has been completed, the audio recording will be deleted from the archives.
Pursuant to Article 6, paragraph 1, letter f) of the Regulation, the processing of the provided data is lawful as it is necessary for the pursuit of the Data Controller’s legitimate interest or to better assess your profile and present you to our clients for new opportunities.

3. How We Use Your Data
The data provided will be collected, used, and stored for the specific purpose of pursuing the legitimate interest, shared by both parties, of offering selection and recruitment services, as outlined in Section 1.

Data will be processed using appropriate tools and procedures to ensure maximum security and confidentiality, on both digital and paper-based media.
The data provided, stored in our databases, will be used to communicate with you regarding opportunities that match your professional profile.

4. With Whom We Share Your Data
Personal data will be processed not only by the Data Controller but also by the following potential recipients: the Data Controller's employees, collaborators, consultants, and professionals, always within the scope of the purposes outlined in Section 1 and upon their designation by the Data Controller. This designation includes specific instructions necessary to comply with data protection regulations, particularly regarding security aspects. Specifically, data may be processed by the Data Controller's service providers, such as, but not limited to, companies managing the Data Controller's database, companies managing the website and web platforms used by the Data Controller, and companies managing the Data Controller's email servers.

The data provided will not be publicly disclosed. However, where necessary, they may be subject to mandatory disclosures required by law.

5. Where We Store Your Data
The management and storage of personal data will take place on servers owned by the Data Controller or third parties, made available to the Data Controller by its service providers. Currently, the servers owned and managed by the Data Controller are located within the European Union.
Data will be transferred to the United States of America, where it will be stored on servers operated by the company providing the database management services used by the Data Controller: Lever Inc. There is currently an agreement in place with Lever Inc. based on the standard contractual clauses approved by the European Commission, ensuring that such data is processed in compliance with European regulations.

6. What Are Your Rights
You have the following rights:

  1. the right to request from the Data Controller, or its representative, access to personal data and the rectification or deletion of such data, or the restriction of processing;
  2. right to object to the processing of personal data;
  3. right to data portability;
  4. the right to withdraw consent at any time without affecting the lawfulness of processing based on consent given before the withdrawal.

You may exercise the aforementioned rights at any time by sending a registered letter to the following address: Via Plinio No. 11, Milan, Italy or by sending an email to privacy.emaitaly@ema-partners.com. You also have the right to file a complaint with the Data Protection Authority if you believe that your rights have been violated.

7. How Long Do We Retain Your Data?
The data provided for the purposes outlined in section 1 will be retained for 36 months from the date they are communicated to the Data Controller.

Any audio recordings will be deleted within a maximum of 30 days from the date of the interview.

Upon expiration of this retention period, the collected data will be deleted from all electronic and/or paper records, unless otherwise indicated by you.

8. What Are the Principles and Safeguards of Data Processing
The information regarding the processing of your data complies with the requirements set forth in Article 13 of European Regulation 679/2016 on privacy (Article 13).
The processing of personal data will be conducted in accordance with the principles of fairness, lawfulness, and transparency. It may also be carried out through automated means for storing, managing, and transmitting data and will be performed using appropriate tools, to the extent reasonably possible and in line with the current state of technology, to ensure security and confidentiality. Suitable procedures will be implemented to prevent the risk of data loss, unauthorized access, unlawful use, and disclosure.

9. Who is the Data Controller
The Data Controller is Calenti & Partners S.r.l., with its registered office at Via Plinio No. 11, Milan, Italy.

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Supplier Policy

Calenti & Partners S.r.l. (hereinafter, for brevity, referred to as the “Company” or “the Data Controller”), in its capacity as the Data Controller, wishes to inform you, pursuant to the applicable data protection legislation, including European Regulation 679/2016 on the protection of personal data (the “Regulation”), that the personal data you provide at the time of establishing the relationship and throughout its duration will be processed in accordance with the applicable legislative and contractual provisions for the purposes and in the manner set forth below. In certain circumstances, some data may also be collected from third parties, where necessary and always in compliance with the applicable legislation.

1. Identity and Contact Details of the Data Controller
The Data Controller is Calenti & Partners S.r.l., with its registered office at Via Plinio No. 11, Milan, Italy.

2. Categories of Personal Data, Purposes, and Legal Basis of Processing
The Company may process:

  • Identification and Contact Data: first and last name or company name, tax code or VAT number, residence or registered office, email address, phone number;
  • Tax-related data or any other data necessary to process or receive payments..

The personal data mentioned above are processed for the following purposes and on the basis of the following legal grounds:

  1. to fulfill obligations arising from the law and/or the existing contract with the Company, to which this notice is attached; in this case, the lawfulness of processing is based on the necessity of meeting the legal obligations related to the establishment and management of the employment relationship (Article 6.1, letters b and c of the Regulation);
  2. management of potential disputes and protection of the Company's rights; in this case, the lawfulness of processing is based on the necessity of pursuing the Company's legitimate interest (Article 6.1, letter f of the Regulation);

For these purposes, your consent is not required.

3. Methods of Processing and Nature of Data Provision
Personal data will be processed by the Company using both digital and paper-based systems in accordance with the principles of fairness, integrity, and transparency as established by the applicable data protection regulations, while safeguarding your privacy and rights through the implementation of appropriate technical and organizational measures to ensure a level of security commensurate with the risk.

The provision and updating of your personal data is mandatory under applicable laws (e.g., tax regulations or others) or for the execution of the contractual relationship. Without such data, it will not be possible to establish or – in certain circumstances – continue the relationship.

4. Data Retention
All data relating to you will be stored in compliance with civil and tax obligations (for example, the legal obligation to retain accounting records and additional business correspondence for 10 years) and, in any case, only for the duration of the existing contract. Once the relationship has ended, to safeguard the Company's rights, the data will be retained – accessible only when necessary – for a period corresponding to the limitation period for any rights you may claim against the Company. This period varies depending on the type of data and any factors that may interrupt or suspend the limitation period.

5. Data Recipients
Your data will not be disclosed publicly but, for the purposes indicated above and in compliance with the principles of the Regulation, may be communicated to: the Company's employees, its collaborators, consultants, and professionals (including, by way of example, accountants). In fulfilling legal obligations, contractual requirements, or at your request, data may be disclosed to public entities or governmental authorities.

6. Data Transfer
Your data will be stored at the Company's headquarters and its servers (both located in Italy) and will not be transferred outside the EU.

7. Data Subject Rights
The data subject may exercise, in relation to the data processing described herein, the rights provided by the applicable data protection legislation, including the right to:

  • To receive confirmation of the existence of your personal data and access its content (right of access);
  • To update, modify, and/or correct your personal data (right to rectification);
  • to request the erasure or restriction of processing of data processed in violation of the law, including those for which retention is not necessary in relation to the purposes for which the data were collected or otherwise processed (right to erasure and right to restriction of processing);
  • to object to processing based on legitimate interest (right to object);
  • To withdraw consent, where given, without prejudice to the lawfulness of processing based on consent provided before the withdrawal;
  • To lodge a complaint with the Supervisory Authority in case of a violation of data protection regulations;
  • To receive a copy of their personal data in electronic format, as provided in the context of the employment contract (e.g., salary data, internal mobility services), and to request that such data be transferred to another data controller (right to data portability).

To exercise these rights, you may contact the Company at any time by sending your request to the following email address: privacy.emaitaly@ema-partners.com or by registered mail with return receipt to the following address: Via Plinio No. 11, Milan, Italy.

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