Privacy Policy
  • Advertising

    This type of services allows User Data to be utilized for advertising communication purposes 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 Cookies 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.

    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.

    Google AdSense (Google LLC)

    Google AdSense is an advertising service provided by Google LLC. This service uses the “DoubleClick” Cookie, which tracks use of this Website and User behavior concerning ads, products and services offered.
    Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: United States – Privacy PolicyOpt Out.

    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.

  • 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.

    Branch Attribution (TUNE, Inc.)

    Branch Attribution is an analytics service provided by Branch Metrics, Inc.

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

    Place of processing: US – Privacy PolicyOpt Out.

    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.

    Google Analytics (Google LLC)

    Google Analytics is a web analysis service provided by Google LLC (“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.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: United States – Privacy PolicyOpt Out.

    Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)

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

    Personal Data processed: Cookies; Usage Data.

    Place of processing: United States – 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 .

  • 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.

  • 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 (Twitter, Inc.)

    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.

  • Location-based interactions

    Geolocation (This Website)

    This Website 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.

    Personal Data processed: geographic position.

    Non-continuous geolocation (This Website)

    This Website 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.
    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.

  • 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 (Twitter, Inc.)

    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 Facebook, Inc. or by Facebook Ireland Ltd, depending on the location this Website is accessed from, 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 the location this Website is accessed from, 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.

  • 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 (This Website)

    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.

    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.

  • 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.

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.

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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