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’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.

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; 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 following a full-time Master’s degree (“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”).
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 (“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:

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

• 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.
• 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.
• Newsletter subscribers: Fulfilment of legal obligations, Contacting the user, Exercise of rights, Management of user databases, Managing addresses and sending email messages, Advertising, Statistics.
• Visitors to Talent Garden venues: Access to Talent Garden spaces, Fulfillment of legal obligations, Exercise of rights, Location-based interactions, Advertising, Statistics.
• 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, Advertising.
• Visitors to the App: Fulfillment of legal obligations, Exercising rights, Social features, Location-based interactions, Registration and authentication, Management of user databases.
• Training course participants: Fulfillment of legal obligations, Dissemination of images/ footage/audio, CV sharing, Contacting you, Exercise of rights, Course participation.

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.