The Privacy Policy - EMA Partners

Privacy Policy For Clients

Calenti & Partners S.r.l. (Hereinafter, “Company” or “the Data Controller”), in its capacity as Data Controller wishes to inform you, pursuant to applicable legislation governing the protection of personal data, including European Privacy Regulation 679/2016 relating to the protection of personal data (“Regulation”), that the personal data provided by you when entering into relations with the Company and during the course of the agreement, shall be processed in accordance with applicable legislative and contractual provisions for the purposes of and in the manner set forth hereinbelow. In certain circumstances data may also be retained at third parties, where necessary, and always in accordance with applicable legislation.

1. Identity and contact information of the Data Controller

The Data Controller is Calenti & Partners S.r.l., having its registered office in Via Plinio n. 11, Milan.

2. Category of personal data, purpose and legal basis of processing

The Company may process:

identity and contact information: name and surname or company name, tax ID or VAT number, residence or registered office, email address, telephone number;
tax data or data required for remitting or receiving payments.

The above personal data is processed for the following purposes and subject to the following lawful conditions:

a. to comply with obligations arising under law and/or the agreement with the Company to which this policy is annexed, and in all cases so as to provide the consultancy and assistance requested; in such case the lawfulness of data-processing is based on the need to comply with legal obligations relating to the establishment and management of work relations (Article 6, paragraph 1, subpart (b) and (c) of the Regulation);

b. to deal with any disputes and to protect the Company’s rights; in such eventuality, the legality of processing is based on the need to pursue the Company’s lawful interests (Article 6, paragraph 1, subpart (f) of the Regulation);

Your consent is not required for these purposes.

c. The data provided may also be processed in order to send newsletters, informational communications or for marketing purposes; in such eventuality the lawfulness of processing requires your consent (article 6.1, subparagraph a of the Regulation).

3. Manner of processing and type of data provided

Personal data shall be processed by the Company using computerised and hardcopy systems in accordance with tenets of fairness, good faith and transparency as provided for by applicable legislation governing the protection of personal data and in order to safeguard your confidentiality and your rights through the adoption of appropriate technical and organisational measures in order to ensure a level of security which is appropriate to the risk.

The provision and updating of your personal data is mandatory under applicable legislation (governing tax and other matters) or in order to perform the contractual agreement. Without such data, it will not be possible to initiate or – in certain circumstances – continue relations.

The provision of data for the purposes referred to in point 2.c is optional and failure to provide your data or withdrawal of your consent to the processing of your data shall not entail consequences to the contractual relations, but shall only render it impossible to process the data for the above-mentioned purposes.

4. Retention of data

All data referring to you shall be retained in accordance with civil law and fiscal obligations (for example the civil law obligation to retain accounts records and additional corporate correspondence for 10 years) and in all cases only for the duration of the ongoing agreement. Once the agreement is terminated, in order to protect the Company’s rights, the data shall be retained – so as to be accessible only if needed – for a period of time until the prescription period for any rights which you may claim against the Company, expires. This period varies according to the type of data and any interruption or suspension of the prescription period.

Should you allow the processing of your data for the purposes referred to in point 2.c this data shall be retained for no more than 24 months after the date on which it is provided.

5. Recipients of data

Your data shall not be disclosed to others but, for the aforementioned purposes and in compliance with the principles informing the Regulation, it may be forwarded to: employees of the Company, its associates, consultants and outsourced professionals (chiefly, by way of non-limiting example: certified public accountants; communication agencies). In order to comply with legal duties, obligations arising under the contractual relationship or when requested by you, the data may be forwarded to public bodies or authorities.

6. Transfer of data

Your data shall be retained at the Company’s registered office and on its servers (both located in Italy), and on the servers belonging to communication agencies web platform located within the European Union and, under no circumstances shall it be transferred outside the European Union.

7. Data Subject’s Rights

With regard to the processing of the data described herein, the data subject may exercise his or her rights in accordance with applicable legislation governing the protection of personal data, including the right to:

receive confirmation of the existence of your personal data and to access the contents of same (access rights);
update, amend and/or correct your personal data (right of correction);
request erasure of or limitations on the processing of data processed in breach of legislation including data which it is not necessary to retain for the reasons for which it is collected or otherwise processed (right to be forgotten and right to limitations);
object to data processing grounded on legitimate interests (right to oppose);
revoke consent, when given; such revocation of consent shall not prejudice the lawfulness of any processing based on consent provided prior to such revocation;
file complaints with the supervisory authority in the event of breach of the provisions governing protection of personal data;
receive copies of the data relating to the data subject in an electronic format when such data is provided within the context of an employment agreement (for example data relating to salaries, internal mobility services) and to request that this data be sent to another data controller (right to data portability).

In order to exercise these rights, at any time, you may contact the Company, sending your request to the following email address privacy.emaitaly@ema-partners.com or by means of registered mail with return receipt to the following address: Via Plinio n. 11, Milan.

Privacy Policy for Candidates

Download privacy policy for candidates

1. Why do we need your data

Personal data shall be processed, using both electronic and hard-copy instruments, in the pursuit of a legitimate interest – jointly shared, as it were, by the parties – to suggest professional opportunities to you. In some cases, with your express consent to the same, processing may be undertaken in order to provide you with coaching services. These are intended as personal-development services. Your submission of data for such purposes is required; any failure to submit the required data, or any request to have such data erased, will make it impossible for us to pursue the aforementioned, legitimate objective, or otherwise to fulfil the aforementioned activity, limited as described supra, with which the Data Controller has been tasked.

2. What personal data we collect

Calenti & Partners may process the following personal data: first name, surname, tax ID or VAT number, home address, email address, telephone number, data relating to training, education, languages spoken, IT skills, any type of professional expertise, previous jobs, hobbies and special interests, and any other item of information you have included in your resume or CV, or otherwise disclosed by you for the purposes and legitimate interests noted supra. The company herewith discloses that data sourced from third parties may also be processed – provided you have previously authorised the same – in order to manage the interests described in point 1, supra, in the most effective manner possible. More specifically, the company may process personal data relating to your professional expertise and aptitudes as provided by the following companies: Gallup Inc, Six Seconds Inc. and Decision Dynamics AB or, with respect to coaching projects, from your own employer.

Pursuant to Art. 6, paragraph 1, subpart (f) of the Regulation, the processing of submitted personal data is lawful in that it is necessary to pursue the Data Controller’s legitimate interest – as well as your personal interest, with respect to coaching projects – or to be able to better assess your profile, and to show it to our customers for new professional opportunities.

3. How do we use your data

Data provided shall be collected, used and retained for the specific purpose of pursuing the lawful interests of both parties, as per point 1; this involves offering selection and executive search, consultancy and coaching services.

Data shall be processed through appropriate procedures and using appropriate instruments to ensure the utmost security and confidentiality, on digital and hardcopy storage media.

Data provided, which shall then be entered in our databases, shall be used for communicating with you regarding opportunities matching your professional profile for personal development projects.

4. Who do we share your data with

Personal data shall be processed by – in addition to the Data Controller – by the following potential recipients: the Data Controller’s employees, associates, consultants, and outsourced professionals, albeit solely for the purposes listed in point 1, and only with such parties being duly delegated specific authority by the Data Controller. Such delegation of authority shall invariably include explicit instructions as needed for them to comply with privacy regulations, especially in terms of data security. Moreover, the personal data may be processed by the Data Controller’s vendors, including but not limited to companies who manage the Data Controller’s database, companies who manage the Data Controller’s website and web platforms, and those who manage the Data Controller’s email server.

Submitted personal data shall not be subject to dissemination.

It may, however, if and when needed, be subject to disclosure as required by law.

4. Where do we retain your data

Your personal data shall be managed and retained on the Data Controller’s servers, or on a third-party server made available to the Data Controller by its vendors. Currently, the Data Controller’s servers, and those managed by the same, are all located in the European Union.

Personal data shall be subject to transfer into the U.S., to the servers held by the company who provides database-management services for the Data Controller: Lever Inc. Currently, our agreement with Lever Inc. includes standard contractual clauses approved by the EU Commission, which ensures data processing in accordance with European privacy regulations.

6. What are your rights

You have the right to:

Request the Data Controller, or its representative, allow you to access your personal data, as well as correct/erase the same, or to limit processing on the same;

Object to the processing of personal data;

Data portability;

Revoke consent at any time; such revocation of consent shall not prejudice the lawfulness of any processing based on consent provided prior to such revocation.

You may exercise the aforementioned rights at any time by sending a certified letter to the following address: Via Plinio n. 11, Milan, or by sending an email to privacy.emaitaly@ema-partners.com

Moreover, you have the right – if you believe your rights have been violated – to file an appeal with the Data Protection Authority.

7. How long do we retain your data

Data submitted for the purposes listed in point 1 shall be retained for thirty-six (36) months after such data has been disclosed to the Data Controller.

Once that retention period has expired, all collected data shall be erased/deleted from any electronic device and/or hard-copy medium, absent any instructions from you to the contrary.

8. What are the principles and guarantees governing data processing

Information on the processing of your data shall comply with the provisions of article 13 of European Regulation 679/2016 governing privacy (article 13).

The processing of your personal data shall be governed by the tenets of fairness, lawfulness, and transparency. Such processing may be performed in an automated fashion for the purpose of storing, managing, and forwarding the personal data. If so, it shall be performed using proper instruments, both in terms of reasonableness, and technical sophistication, in order to ensure the security and confidentiality of the same, with all proper protocols to avoid the risk of loss, unauthorized access, and unlawful use or disclosure.

9. Who is the data controller

The Data Controller is Calenti & Partners S.r.l., having its registered office in Via Plinio n. 11, Milan.

Privacy Policy for Vendors

Download privacy policy for vendors

Calenti & Partners S.r.l. (hereinafter, “Company” or “the Data Controller”), in its capacity as Data Controller wishes to inform you, pursuant to applicable legislation governing the protection of personal data, including European Privacy Regulation 679/2016 relating to the protection of personal data (“Regulation”), that the personal data provided by you when entering into relations with the Company and during the course of the agreement, shall be processed in accordance with applicable legislative and contractual provisions for the purposes of and in the manner set forth hereinbelow. In certain circumstances data may also be retained by third parties, where necessary, and always in accordance with applicable legislation.

1. Identity and contact information for the Data Controller

The Data Controller is Calenti & Partners S.r.l., having its registered office in Via Plinio n. 11, Milan.

2. Category of personal data, purpose and legal basis of processing

The Company may process:

identity and contact information: name and surname or company name, tax ID or VAT number, residence or registered office, email address, telephone number;
tax data or data required for remitting or receiving payments.

The above personal data is processed for the following purposes and subject to the following lawful conditions:

to comply with obligations arising under law and/or the agreement with the Company to which this policy is annexed; in such case the lawfulness of data-processing is based on the need to comply with legal obligations relating to the establishment and management of work relations (Article 6, paragraph 1, subpart (b) and (c) of the Regulation);
to deal with any disputes and to protect the Company’s rights; in such eventuality, the legality of processing is based on the need to pursue the Company’s lawful interests (Article 6, paragraph 1, subpart (f) of the Regulation);

Your consent is not required for these purposes.

3. Manner of processing and type of data provided

4. Retention of data

All data referring to you shall be retained in accordance with civil law and fiscal obligations (for example the civil law obligation to retain accounts records and additional corporate correspondence for 10 years) and in all cases only for the duration of the ongoing agreement. Once the agreement is terminated, in order to protect the company’s rights, the data shall be retained – so as to be accessible only if needed – for a period of time until the prescription period for any rights which you may claim against the company, expires. This period varies according to the type of data and any interruption or suspension of the prescription period.

5. Recipients of data

Your data shall not be disclosed to others but, for the aforementioned purposes and in compliance with the principles informing the Regulation, it may be forwarded to: employees of the Company, its associates, consultants and outsourced professionals (chiefly, by way of non-limiting example: certified public accountants). In order to comply with legal duties, obligations arising under the contractual relationship or when requested by you, the data may be forwarded to public bodies or authorities.

6. Transfer of data

Your data shall be retained at the Company’s registered office and on its servers (both located in Italy), and, under no circumstances shall it be transferred outside the European Union.

7. Data Subject’s Rights

receive confirmation of the existence of your personal data and to access the contents of same (access rights);
update, amend and/or correct your personal data (right of correction);
request erasure of or limitations on the processing of data processed in breach of legislation including data which it is not necessary to retain for the reasons for which it is collected or otherwise processed (right to be forgotten and right to limitations);
object to data processing grounded on legitimate interests (right to oppose);
revoke consent, when given; such revocation of consent shall not prejudice the lawfulness of any processing based on consent provided prior to such revocation;
file complaints with the Supervisory Authority in the event of breach of the provisions governing protection of personal data;
receive copies of the data relating to the data subject in an electronic format when such data is provided within the context of an employment agreement (for example data relating to salaries, internal mobility services) and to request that this data be sent to another data controller (right to data portability).

In order to exercise these rights, at any time, you may contact the Company, sending your request to the following email address privacy.emaitaly@ema-partners.com or by means of registered mail with return receipt to the following address: Via Plinio n. 11, Milan.