Privacy Policy of *.talentgarden.org and *.talentgarden.com
unless otherwise specified in the individual service policies

This Site collects certain Personal Data of its Users.


Data Controllers

The organisations that jointly decide the means and purposes of the processing of Personal Data are the Talent Garden Group Companies (hereinafter „Talent Garden“), subsidiaries and/or affiliates, namely:

Parent Company:: Talent Garden S.p.A., Piazza Città di Lombardia n. 1, 20124 Milan, Italy

Group companies:

  • Talent Garden Italia S.r.l.
    Piazza Città di Lombardia 1
    20124 Milano (MI) Italy
    Nr. Iscrizione al Reg. Imprese Milano, CF 03249821202
    P.IVA/VAT ID IT03249821202
  • Talent Garden Isola S.r.l.
    Piazza Città di Lombardia 1,
    20124 Milano (MI) Italy
  • Talent Garden Torino S.r.l.
    Via Giacosa 38
    10125 Torino (TO) Italy
    Nr. Iscrizione al Reg. Imprese Milano, CF 10914320014
    P.IVA/VAT ID IT10914320014
  • Talent Garden Fondazione Agnelli S.r.l.
    Via Giuseppe Giacosa 38
    10125 Torino (TO) Italy
  • Talent Garden Brescia S.r.l.
    Via Cipro 66
    25124 Brescia (BS)
    Italy
  • Talent Garden Denmark
    Danneskiold-Samsøes Allé 41
    1434 Copenhagen K
    Denmark
    VAT number: DK29218633
    CVR: 29218633
  • Talent Garden Ireland Ltd.
    Claremont Avenue, Glasnevin
    Dublin 11, D11 YNR2, Irlanda
  • Talent Garden Spain S.r.l.
    Calle Juan de Mariana, 15
    28045 Madrid, Spain
    Spanish Tax Identification Number (N.I.F.) B-66398637
    VAT number ESB66398637
  • Talent Garden AT GmbH
    Liechtensteinstraße 111-115
    1090 Vienna, Austria
  • Talent Garden Genova S.r.l.
    Via Enrico Melen 83
    16152 Genova, Italy
  • Talent Garden Med S.r.l.
    Via Alberto Savinio
    87036 Rende, Italy
  • Talent Garden Cosenza S.r.l.
    Via Alberto Savinio
    87036 Rende, Italy
  • Talent Garden Pordenone S.r.l.
    Piazzetta Ado Furlan 4
    33170 Pordenone, Italy
  • Talent Garden France SARL
    14 Rue du Vieux Faubourg
    59042 Lille Cedex, France
  • Talent Garden Kaunas S.r.l.
    Laisvės av. 59 – 3rd floor
    44305 Kaunas, Lituania

Talent Garden’s email address: [email protected]

Email address of the Talent Garden S.p.A. Data Protection Officer (DPO): [email protected]


Categories of Interested Parties

This policy refers to the following categories of interested parties (which, collectively, may also be referred to as „Users“):

  1. Visitors to the Site: individuals who browse the pages of the Site, to the extent that use is made of data collection technologies (e.g. cookies) that allow their identification.
  2. Information Requesters: individuals who fill in the forms on the Site to request information about Talent Garden services.
  3. Newsletter subscribers: individuals who receive emails containing information, including commercial and promotional information, about Talent Garden services.
  4. Visitors to Talent Garden locations: individuals who use the services provided at Talent Garden locations (e.g. cafeteria).
  5. Participants in events/open days: individuals who register for events or open days organized by Talent Garden.
  6. Visitors to the App: individuals who access the Talent Garden App.
  7. Training participants: individuals participating in courses provided by Talent Garden.
  8. Training lecturers: individuals who participate in courses provided by Talent Garden as lecturers.

Types of Data collected

The Personal Data collected by (or through) this Site or by (or through) our App, either independently or through third parties, include: email address; first and last name; tax code; vat number; usage data; phone number; profession/company and role within the company; province; country; postcode; gender; place and date of birth; city; address; company name; username and password; geographic location; images/film/audio; unique advertising device identifiers (e.g. Google Advertiser ID or IDFA identifier); interests/preferences; CV; LinkedIn profile.
Full details on each type of data collected are provided in the relevant sections of this privacy policy or by means of specific information texts displayed prior to data collection.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected during the navigation of this Site.
Failure to provide the requested Data may make it impossible for Talent Garden to provide its Services.
The possible use of Cookies – or of other tracking tools – by this Site or by the owners of third party services used by this Site, unless otherwise specified, has the purposes described in this document and in the Cookie Policy.
You assume responsibility for the Personal Data of third parties obtained, published or shared through this Site or our App and you warrant that you have the right to disclose or disseminate them, releasing Talent Garden from any liability to third parties.


Legal basis of processing

Pursuant to Article 6 of the GDPR, the legal basis for the processing is the following:

  1. The consent of the data subject with respect to subscribing to the newsletter or mailing list service and contacting him/her via telephone for commercial or promotional purposes („contacting the user“); commenting on content through Facebook Inc. („commenting on content“); the fact that the Site or the App uses your personal data to invite or suggest friends („social features“); the fact that Talent Garden may create user profiles from the information you provide to the Site or to the App as well as track your activities through statistical features („user database management“); the interaction with social networks and external platforms directly from the pages of the Site („Interaction with social networks and external platforms“); the geolocation of the User in order to allow him/her to use location-based services („location-based interactions“); the fact that Talent Garden uses services to communicate, optimize and serve advertisements based on your past use of this Site („remarketing and behavioural targeting“); the ability to view and interact with content from external platforms directly from the pages of this Site („viewing content from external platforms“); the dissemination of images/film/audio collected in the context of participation in events or training courses; to the communication of personal and contact data to business partners for the marketing purposes of such partners („third-party marketing“); to the elaboration of statistical and market studies and research („studies and research“); to the sharing of information within the CV and/or cover letter and/or professional profile description with companies in the Talent Garden network in order to obtain a job interview („CV sharing“).
  2. The legitimate interest of Talent Garden to manage a database of contacts to communicate with the User („address management and sending email messages“); to optimize and distribute traffic; to analyze and monitor traffic data to track User behavior („statistics“); to perform performance tests of content and functionalities (A/B testing); to defend the data subject in court or before an authority („exercise of rights“); to control the access and stay of visitors at Talent Garden’s premises („access to Talent Garden’s premises“); satisfaction survey.
  3. The execution of pre-contractual and contractual measures with respect to the registration and authentication of the User in order to allow the Site or the App to identify the User and give him/her access to dedicated services („registration and authentication“); with respect to the request of visitors to use Talent Garden’s spaces („access to Talent Garden’s spaces“); with respect to the requests made by Users through the appropriate contact forms („management of contact form requests“); with respect to the management of requests to participate in events; with respect to the enrollment and participation in the chosen training course also as a lecturer („course participation“).
  4. The need to comply with a legal obligation to which Talent Garden is subject.

Data transfer

Data is processed at Talent Garden’s operational headquarters and at any other location where the organisations involved in the processing are located.
The User’s Personal Data may be transferred to a country outside the European Economic Area (EEA). Talent Garden guarantees that any transfer of data to companies and/or third parties located in countries outside the EEA is always made within the limits and conditions set out in Articles 44 et seq. of the GDPR. In particular, the transfer will be made to countries that guarantee an adequate level of protection for which there is an adequacy decision of the European Commission pursuant to Article 45 GDPR, or by adopting the other guarantees provided for in Chapter V of the GDPR (such as, for example, the stipulation of standard contractual clauses with the entity importing the data).
To obtain further information on the location of the processing, the User may refer to the section „Purposes of the processing of Personal Data“ or contact Talent Garden.


Period of retention

The Data are kept for the period of time necessary to pursue the purposes set out in this policy. In particular, the data collected through the contact forms will be kept for the time necessary to process the request made by the User and to allow Talent Garden to prove that it has responded to the request made by the User. Data processed for commercial or promotional purposes shall be stored until consent is revoked and, in any case, no longer than 24 months from the collection of the data. Data relating to participation in events/open days will be kept for 12 months after the event. Your CV, for the purpose of sharing it with network companies, will be kept for 12 months from the date of course completion. In any case, the data may be retained for a longer period if this is necessary to comply with legal obligations to which Talent Garden is subject or for the defence of a right, judicial or otherwise, of Talent Garden. At the end of the retention period, the Personal Data will be irreversibly deleted or anonymised.


Recipients of Personal Data

It is possible that for the purposes set out above Talent Garden may disclose Personal Data to:

  • subjects whose involvement is necessary for the performance of activities connected with and consequent to the provision of services (e.g. suppliers of services for the management of the event and its communication, photographic and/or video production, suppliers of IT, accounting, tax, legal services, etc.), who act as data processors or autonomous data controllers, which are subjects whose involvement requires prior consent from the data subject;
  • natural persons duly authorised and instructed to process the data and bound by contract or by law to confidentiality;
  • public organisations and authorities, if and to the extent that this is required by applicable legislation or by their orders, or for the exercise, ascertainment and/or defence of a right in judicial or other proceedings;
  • authorities or public bodies if required and in any case in accordance with the law, for purposes of defence or state security or for the prevention, investigation or prosecution of criminal offences.

Further information on the recipients is provided in the section „Purposes of the processing of Personal Data“ or by means of specific information texts displayed prior to the collection of the data.


Purposes of the processing of Personal Data

Personal Data are collected for the following purposes in the use of the following services:

  • Advertising

    This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Website, possibly based on User interests.
    This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
    Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Website. For more information, please check the privacy policies of the relevant services.
    Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

    Direct Email Marketing (DEM) (This Website)

    This Website uses the User Data to propose services and products provided by third parties or unrelated to the product or service provided by this Website.

    Personal Data processed: email address.

    Facebook Audience Network (Facebook, Inc.)

    Facebook Audience Network is an advertising service provided by Facebook, Inc. In order to understand Facebook's use of Data, consult Facebook's data policy.

    This Website may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User's ad preferences. The User can control this in the Facebook ad settings.

    Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.

    Personal Data processed: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

    Place of processing: United States – Privacy PolicyOpt Out.

    Meta ads conversion tracking (Meta pixel) (Meta Platforms, Inc.)

    Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms, Inc. that connects data from the Meta Audience Network with actions performed on this Website. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: United States – Privacy PolicyOpt out.

    Microsoft Advertising (Microsoft Corporation)

    Microsoft Advertising is an advertising service provided by Microsoft Corporation.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: United States – Privacy PolicyOpt Out.

    TikTok conversion tracking (TikTok Inc.)

    TikTok conversion tracking is an analytics and behavioral targeting service provided by TikTok Inc. that connects data from the TikTok advertising network with actions performed on this Website. The TikTok pixel tracks conversions that can be attributed to TikTok ads and enables to target groups of Users on the base of their past use of this Website.

    Personal Data processed: Trackers.

    Place of processing: United States – Privacy Policy.

    TradeTracker conversion tracking (TradeTracker Nederland B.V.)

    TradeTracker conversion tracking is an analytics service provided by TradeTracker Nederland B.V. that connects data from the TradeTracker advertising network with actions performed on this Website.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: See the TradeTracker privacy policy – Privacy Policy.

    LinkedIn conversion tracking (LinkedIn Insight Tag) (LinkedIn Corporation)

    LinkedIn conversion tracking (LinkedIn Insight Tag) is an analytics and behavioral targeting service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on this Website. The LinkedIn Insight Tag tracks conversions that can be attributed to LinkedIn ads and enables to target groups of Users on the base of their past use of this Website.

    Users may opt out of behavioral targeting features through their device settings, their LinkedIn account settings or by visiting the AdChoices opt-out page.

    Personal Data processed: device information; Trackers; Usage Data.

    Place of processing: United States – Privacy Policy.

  • Analytics

    The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

    Analytics collected directly (This Website)

    This Website uses an internal analytics system that does not involve third parties.

    Personal Data processed: Cookies; Usage Data.

    Wordpress Stats (Automattic Inc.)

    Wordpress Stats is an analytics service provided by Automattic Inc.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy Policy.

    HubSpot Analytics (HubSpot, Inc.)

    HubSpot Analytics is an analytics service provided by HubSpot, Inc.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: United States – Privacy PolicyOpt Out .

    Google Analytics 4 (Google Ireland Limited)

    Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
    Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
    In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.

    Personal Data processed: number of Users; session statistics; Trackers; Usage Data.

    Place of processing: Ireland – Privacy PolicyOpt Out.

  • Commercial affiliation

    This type of service allows this Website to display advertisements for third-party products or services. Ads can be displayed either as advertising links or as banners using various kinds of graphics.
    Clicks on the icon or banner posted on the Application are tracked by the third-party services listed below, and are shared with this Website.
    For details of which data are collected, please refer to the privacy policy of each service.

    TradeTracker (TradeTracker.com)

    TradeTracker is a commercial affiliation service provided by TradeTracker.com.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: See the TradeTracker privacy policy – Privacy Policy.

  • Contacting the User

    Mailing list or newsletter (This Website)

    By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Website. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase.

    Personal Data processed: address; city; company name; Cookies; country; date of birth; email address; first name; gender; last name; phone number; profession; province; Usage Data; ZIP/Postal code.

    Phone contact (This Website)

    Users that provided their phone number might be contacted for commercial or promotional purposes related to this Website, as well as for fulfilling support requests.

    Personal Data processed: phone number.

  • Content commenting

    Content commenting services allow Users to make and publish their comments on the contents of this Website.
    Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
    If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.

    Facebook Comments (Facebook, Inc.)

    Facebook Comments is a content commenting service provided by Facebook, Inc. enabling the User to leave comments and share them on the Facebook platform.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy Policy.

  • Content performance and features testing (A/B testing)

    The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of this Website.

    Google Optimize (Google LLC)

    Google Optimize is an A/B testing service provided by Google LLC ("Google").

    Google may use Personal Data to contextualize and personalize the ads of its own advertising network.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: United States – Privacy Policy.

  • Displaying content from external platforms

    This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.
    This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

    Instagram widget (Instagram, Inc.)

    Instagram is an image visualization service provided by Instagram, Inc. that allows this Website to incorporate content of this kind on its pages.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: United States – Privacy Policy.

    YouTube video widget (Google Ireland Limited)

    YouTube is a video content visualization service provided by Google Ireland Limited that allows this Website to incorporate content of this kind on its pages.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: Ireland – Privacy Policy.

  • Heat mapping and session recording

    Heat mapping services are used to display the areas of this Website that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
    Some of these services may record sessions and make them available for later visual playback.

    Microsoft Clarity (Microsoft Corporation)

    Microsoft Clarity is a session recording and heat mapping service provided by Microsoft Corporation.
    Microsoft processes or receives Personal Data via Microsoft Clarity, which in turn may be used for any purpose in accordance with the Microsoft Privacy Statement, including improving and providing Microsoft Advertising.

    Personal Data processed: clicks; country; device information; diagnostic events; interaction events; layout details; mouse movements; page events; scroll-to-page interactions; session duration; Trackers.

    Place of processing: United States – Privacy Policy.

  • Interaction with external social networks and platforms

    This type of service allows interaction with social networks or other external platforms directly from the pages of this Website.
    The interaction and information obtained through this Website are always subject to the User’s privacy settings for each social network.
    This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
    It is recommended to log out from the respective services in order to make sure that the processed data on this Website isn’t being connected back to the User’s profile.

    Twitter Tweet button and social widgets (X Corp.)

    The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: United States – Privacy Policy.

    Facebook Like button and social widgets (Facebook, Inc.)

    The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: United States – Privacy Policy.

    YouTube button and social widgets (Google LLC)

    The YouTube button and social widgets are services allowing interaction with the YouTube social network provided by Google LLC.

    Personal Data processed: Usage Data.

    Place of processing: United States – Privacy Policy.

    LinkedIn button and social widgets (LinkedIn Corporation)

    The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: United States – Privacy Policy.

  • Interaction with live chat platforms

    This type of service allows Users to interact with third-party live chat platforms directly from the pages of this Website, in order to contact and be contacted by this Website‘s support service.
    If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

    HubSpot Chat (HubSpot, Inc.)

    HubSpot Chat is a service for interacting with the HubSpot live chat platform provided by HubSpot, Inc.

    Personal Data processed: Trackers.

    Place of processing: Germany – Privacy Policy.

  • Location-based interactions

    Geolocation

    The Website or the App may collect, use, and share User location Data in order to provide location-based services.
    Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Website or the App.

    Personal Data processed: geographic position.

    Non-continuous geolocation

    The Website or the App may collect, use, and share User location Data in order to provide location-based services.
    Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Website or this App.
    The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate field and allows the application to detect the position automatically.

    Personal Data processed: geographic position.

  • Managing contacts and sending messages

    This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
    These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

    HubSpot Email (HubSpot, Inc.)

    HubSpot Email is an email address management and message sending service provided by HubSpot, Inc.

    Personal Data processed: email address; Usage Data.

    Place of processing: United States – Privacy Policy.

  • Platform services and hosting

    These services have the purpose of hosting and running key components of this Website, therefore allowing the provision of this Website from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
    Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

    Shopify

    Shopify is a platform provided by Shopify Inc. that allows the Owner to build, run and host an e-commerce website.

    Personal Data processed: billing address; email address; first name; last name; payment info; phone number; shipping address.

    Place of processing: Canada – Privacy Policy; Ireland – Privacy Policy.

  • Registration and authentication

    By registering or authenticating, Users allow this Website to identify them and give them access to dedicated services.
    Depending on what is described below, third parties may provide registration and authentication services. In this case, this Website will be able to access some Data, stored by these third party services, for registration or identification purposes.

    Facebook Authentication (Facebook, Inc.)

    Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network.

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: US – Privacy Policy.

    Auth0 (Auth0, Inc)

    Auth0 is a registration and authentication service provided by Auth0, Inc. To simplify the registration and authentication process, Auth0 can make use of third-party identity providers and save the information on its platform.

    Personal Data processed: Cookies; email address; first name; last name; password; picture; various types of Data as specified in the privacy policy of the service.

    Place of processing: USA – Privacy Policy.

    Google OAuth (Google LLC)

    Google OAuth is a registration and authentication service provided by Google LLC and is connected to the Google network.

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: United States – Privacy Policy.

    Twitter OAuth (X Corp.)

    Twitter Oauth is a registration and authentication service provided by Twitter, Inc. and is connected to the Twitter social network.

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: United States – Privacy Policy.

    Instagram Authentication (Instagram, Inc.)

    Instagram Authentication is a registration and authentication service provided by Instagram, Inc. and is connected to the Instagram social network.

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: United States – Privacy Policy.

  • Remarketing and behavioral targeting

    This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.
    This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
    Some services offer a remarketing option based on email address lists.
    In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

    Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

    Facebook Custom Audience (Facebook, Inc.)

    Facebook Custom Audience is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of this Website with the Facebook advertising network.

    Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.

    Personal Data processed: Cookies; email address.

    Place of processing: US – Privacy PolicyOpt Out.

    Facebook Remarketing (Facebook, Inc.)

    Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy PolicyOpt Out.

    Remarketing with Google Analytics (Google Inc.)

    Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy PolicyOpt Out.

    Google Ads Remarketing (Google LLC)

    Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC that connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie.

    Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: United States – Privacy PolicyOpt Out.

    TikTok Remarketing ( TikTok Information Technologies UK Limited )

    TikTok Remarketing is a remarketing and behavioral targeting service provided by TikTok Information Technologies UK Limited that connects the activity of this Website with the TikTok advertising network.

    Personal Data processed: Trackers.

    Place of processing: United Kingdom – Privacy Policy.

  • Social features

    Inviting and suggesting friends (This Website)

    This Website may use the Personal Data provided to allow Users to invite their friends - for example through the address book, if access has been provided - and to suggest friends or connections inside it.

    Personal Data processed: various types of Data.

    Public profile

    Users may have public profiles that other Users can display. In addition to the Personal Data provided, this profile may contain Users' interactions with this Website or App.

    Personal Data processed: address; city; company name; country; date of birth; email address; first name; gender; geographic position; last name; phone number; picture; profession; province; state; username.

  • Tag Management

    This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralized fashion.
    This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

    Google Tag Manager (Google Ireland Limited)

    Google Tag Manager is a tag management service provided by Google Ireland Limited.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: Ireland – Privacy Policy.

  • Traffic optimization and distribution

    This type of service allows this Website to distribute their content using servers located across different countries and to optimize their performance.
    Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Website and the User's browser.
    Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

    Cloudflare (Cloudflare)

    Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
    The way Cloudflare is integrated means that it filters all the traffic through this Website, i.e., communication between this Website and the User's browser, while also allowing analytical data from this Website to be collected.

    Personal Data processed: Cookies; various types of Data as specified in the privacy policy of the service.

    Place of processing: US – Privacy Policy.

  • User database management

    This type of services allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Website, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving this Website.
    Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Website.

    FullContact (FullContact Inc.)

    FullContact is a User database management service provided by FullContact Inc.

    Personal Data processed: company name; date of birth; Email; first name; gender; last name; various types of Data as specified in the privacy policy of the service.

    Place of processing: US – Privacy Policy.

    HubSpot CRM (HubSpot, Inc.)

    HubSpot CRM is a User database management service provided by HubSpot, Inc.

    Personal Data processed: email address; phone number; various types of Data as specified in the privacy policy of the service.

    Place of processing: United States – Privacy Policy.

    HubSpot Lead Management (HubSpot, Inc.)

    HubSpot Lead Management is a User database management service provided by HubSpot, Inc.

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: United States – Privacy Policy.

  • CV Sharing

    By enrolling in the full-time courses/masters provided by Talent Garden or in the case of participating in the courses as a lecturer, the participant/teacher in the training courses may consent to the sharing of the information within their CV and/or cover letter and/or professional profile description with companies in the Talent Garden network in order to obtain a job interview.

  • Course participation

    Talent Garden may use the personal data provided by the participant in the training courses or the teacher of the same to enable both to participate in them and, for students only, also to enroll and eventually obtain the relevant scholarship.

    Personal data processed: personal data, tax code, e-mail address, VAT number, professional information, CV.

  • Image/image/audio dissemination

    Personal Data shared in the context of participation in events or trainings (including images, footage, or audio) may be disseminated, by posting on websites including social networks, and/or any means of dissemination.

  • Third-party marketing

    Talent Garden, subject to the consent of the data subject, may disclose the data subject's personal data (master data, contact details) to third parties as autonomous data controllers for marketing purposes.

  • Studies and research

    Talent Garden, with the consent of the data subject, may conduct statistical and market studies and research based on qualitative interviews about the respondent's products and expertise.

  • Survey of the degree of satisfaction

    Talent Garden, on the basis of its legitimate interest in doing so, may proceed to survey the degree of satisfaction of the Participants in the training courses on the quality of the latter and of the services provided.

  • Participation in digital initiatives

    Talent Garden, with the prior consent of the data subject, may process the results collected within the scope of the data subject's participation in the digital initiative and communicate them to the data subject via email.

The purposes and services are related to each category of interested parties according to the following breakdown:

  1. Site visitors: Fulfillment of legal obligations, Content commentary, Exercise of rights, Social features, Interaction with social networks and external platforms, Location-based interactions, Traffic optimization and distribution, Advertising, Registration and authentication, Remarketing and behavioural targeting, Statistics, Performance testing of content and functionality (A/B testing), Display of content from external platforms.
  2. Requesting information: Fulfillment of legal obligations, Contacting the user, Exercise of rights, Management of User databases, Address management and sending email messages, Advertising, Statistics, Management of contact form requests.
  3. Newsletter subscribers: Fulfilment of legal obligations, Contacting the user, Exercise of rights, Management of user databases, Managing addresses and sending email messages, Advertising, Statistics.
  4. Visitors to Talent Garden venues: Access to Talent Garden spaces, Fulfillment of legal obligations, Exercise of rights, Location-based interactions, Advertising, Statistics.
  5. Attendees of events/open days: Fulfillment of legal obligations, Contacting you, Dissemination of images/film/audio, Exercise of rights, Management of user databases, Management of event request, Address management and emailing, Marketing by third parties, Advertising.
  6. Visitors to the App: Fulfillment of legal obligations, Exercising rights, Social features, Location-based interactions, Registration and authentication, Management of user databases.
  7. Training course participants: Fulfillment of legal obligations, Dissemination of images/ footage/audio, CV sharing, Contacting you, Exercise of rights, Course participation, Survey of the degree of satisfaction.
  8. Training lecturers: Fulfilling legal obligations, Dissemination of images/images/audio, CV sharing, Contacting you, Exercising your rights, Course participation, Satisfaction survey, Studies and research.

For some of the purposes indicated above, the single Subsidiaries or Affiliates may act as autonomous Data Controllers. Any further information in this regard can be obtained by writing to the address of the Data Controllers above.


User Rights

Users may exercise certain rights with respect to the Data processed by Talent Garden.

In particular, the User has the right to:

  • revoke consent at any time. The User may revoke the consent to the processing of his/her Personal Data previously given, without prejudice to the lawfulness of the processing carried out before the revocation.
  • oppose the processing of their Data. You may object to the processing of your Data when it is done on the basis of Talent Garden’s legitimate interest. Further details on the right to object are set out in the section below.
  • Access to your Data. You have the right to obtain information about the Data processed by Talent Garden, certain aspects of the processing and to
    receive a copy of the Data processed (unless, in the latter case, the exercise of the right infringes the rights and freedoms of other individuals).
  • to verify and request rectification. The User may verify the correctness of his/her Data and request that they be updated or corrected.
    obtain the limitation of processing. The User may request the restriction of the processing of its Data when the hypotheses set out in Article 18.1 GDPR apply. In this case, Talent Garden will not process the Data for any other purpose other than for their storage.
  • obtain the deletion or removal of their Personal Data. You may request Talent Garden to delete your Data in the cases provided for in art.17.1 GDPR and subject to the exclusions set out in art. 17.3 GDPR.
  • receive their Data or have them transferred to another data controller. The User has the right to receive its Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred without hindrance to another owner. This provision is applicable when the Data are processed by automated tools and the processing is based on the User’s consent, or on a contract to which the User is a party or on contractual measures related thereto, and except in the case where the exercise of the right affects the rights and freedoms of other natural persons.
  • Propose a complaint. The User may lodge a complaint with the Guarantor for the Protection of Personal Data (in Italy, www.garanteprivacy.it), or with the Guarantor Authority of the EU country in which he/she resides or works, or of the place where the alleged violation occurred, or take legal action.

The exercise of some of the above rights may also be delayed, limited or excluded in the cases provided for in Article 2-undecies of Legislative Decree no. 196/2003.

Details of the right to object

Where Personal Data are processed in pursuit of a legitimate interest of Talent Garden, Users have the right to object to the processing on grounds relating to their particular situation, unless there are compelling legitimate grounds which prevail pursuant to Article 21.1 GDPR, and unless the processing is necessary for the establishment, exercise or defence of legal claims.

Users are reminded that, where their Data is processed for direct marketing purposes, they may object to the processing without providing any reasons. To find out whether Talent Garden processes data for direct marketing purposes, Users may refer to the respective sections of this document.

How to exercise rights

In order to exercise the User’s rights, Users may address a request to the Talent Garden contact details indicated in this document. Requests are filed free of charge and processed by Talent Garden as soon as possible, in any case within one month.


Cookie Policy

This Site makes use of cookies. To find out more and to read the detailed information, you can consult the Cookie Policy.


Further information on treatment

Specific information
At the User’s request, in addition to the information contained in this privacy policy, this Site may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System logs and maintenance
For operational and maintenance purposes, this Site and any third party services used by it may collect system logs, i.e. files that record interactions and which may also contain Personal Data, such as the User’s IP address.

Information not contained in this policy
Further information in relation to the processing of Personal Data may be requested at any time from Talent Garden using the contact details above.

Responding to „Do Not Track“ Requests
This Site does not support „Do Not Track“ requests.

To find out whether any third party services used support Do Not Track requests, please consult their respective privacy policies.

Changes to this privacy policy
Talent Garden reserves the right to make changes to this privacy policy at any time by informing Users on this page and, if possible, on this Site and, where technically and legally feasible, by notifying Users through one of the contact details Talent Garden has. Therefore, please consult this page regularly, referring to the date of last modification indicated at the bottom.

If the changes affect processing whose legal basis is consent, Talent Garden will collect the User’s consent again, if necessary.


Definitions and legal references

Personal Data (or Data)
Personal data is any information that, directly or indirectly, even in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data
This is the information collected automatically through this Site (including by third party applications integrated into this Application), including: IP addresses or domain names of the computers used by the User who connects with this Site, URI (Uniform Resource Identifier) notation addresses, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.), the country of origin, the characteristics of the browser and operating system used by the User, the various temporal connotations of the visit (e.g. the time spent on each page) and the details of the itinerary followed within this Site, with particular reference to the sequence of pages consulted, the parameters relating to the User’s operating system and computer environment. This data is processed in order to obtain statistical information on the use of the services, to check the correct functioning of the services offered, to improve the quality of the services offered and to optimise the functionality of the Site. Usage data are kept for the time strictly necessary to pursue these purposes.

Data subject
The natural person to whom the Personal Data refer.

Data Processor (or Manager)
The natural person, legal entity, public administration and any other entity that processes personal data on behalf of the Data Controller, as set out in this privacy policy.

Data Controller (or Owner)
The natural or legal person, public authority, service or other body that, individually or jointly with others, determines the purposes and means of the processing of personal data and the instruments adopted, including the security measures relating to the operation and use of this Site. The Data Controller, unless otherwise specified, is the owner of this Site.

This Site
The hardware or software tool through which Users‘ Personal Data are collected and processed.

Service
The Service(s) provided by Talent Garden including through this Website as defined in the relevant terms (if any) on this site.

European Union (or EU)
Unless otherwise specified, any reference to the European Union in this document shall be deemed to include all current member states of the European Union and the European Economic Area.

Cookie
A small piece of data stored on the User’s device.


Legal references

This privacy policy is drawn up on the basis of Articles 13 and 14 of Regulation (EU) 2016/679.

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