cell. + 39 349 1719446 | barbara@talent-up.it

PRIVACY POLICY

Thank you for taking interest in www.talent-up.it!
Before sharing your personal data, we would like you to read the following information about the processing of your personal data, in compliance with the GDPR providing for the protection of personal data n. 679/2016 (article 13, paragraph 1, and 14, paragraph 1) and the Legislative Decree n. 196/2003 of the personal data protection Code, as updated by the Legislative Decree n. 101/2018.

We think that protecting the personal data of the individuals who interact with us is very important.
While the information we herewith provide applies to the website www.talent-up.it and its subdomains, the same does not apply to third party’s websites you may visit through the links present in the website. If you wish to take the emotional intelligence test, please be advised that you will be redirected to the website https://survey.6seconds.org/Quest/c9f4d01e-b3ee-4096-869d-0984efd7eceb and that the company Six Seconds is the Data Controller of the data you shall provide by completing the form available in that website.

We shall be the Data Controller of the data either you or Six Seconds will provide us with upon completion of the test.

As to the regulations updates that will be implemented, please regularly read and reference the section “privacy policy”.

DATA CONTROLLER

The data controller is Barbara Galli – VAT Number: 10781120968, domiciled in Melegnano, Via Battisti, 47, e-mail barbara@talent-up.it, mobile number + 39 3491719446.

Do not hesitate to contact us at any time if you have any queries about your personal data and we will be glad to give you the information you are entitled to.

LEGAL GROUNDS FOR PROCESSING PERSONAL DATA

In order to process your personal data, we must be legitimated to do so. Such legitimisation may stem from:
• your consent;
• the law;
• our legitimate interest

DATA WE PROCESS

TECHNICAL DATA

During navigation, technical data such as IP address (Internet Protocol), Date and time of visit, Browser used, Number and position of clicks, physical address of the device used for the connection (so-called MAC Address), Uniform Resource Identifier, cookies will be automatically collected. The collection of technical data underlies the website functioning and never implies the identification of the data subject.

Cookies

“Cookies”, too, fall in the category of technical data. They are small files that either the website or a third-party website directs to the data subject’s device where they are stored and forwarded to the same websites when necessary. The website uses the following types of cookies:
Technical cookies: anonymous cookies the acquisition of which is necessary to allow the data subject to browse across the website and use all of its functions. Furthermore, their presence allows the website navigation to be faster, because they contribute to facilitate some procedures when shopping online, logging in to a reserved area or when a website automatically recognizes the preferred language option.

In greater detail the technical cookies used are:
• Functionality or preference cookies (they allow to save the functionality choices previously selected by the user, for instance language or geographic area)
• Navigation cookies (guarantee standard navigation of the website)

Technical cookies will be available for automatic deletion from the browser depending on what provided by the browser itself.

Profiling cookies: other than anoymous, the acquisition of such cookies is necessary to keep track of the user’s website navigation with a mind to gathering information about the website’s query execution time, the choices made and, in general, behaviour during navigation. In greater detail, the profiling cookies used are provided by the following services. Please reference the privacy policy for relevant information purposes:
• Google analytics: https://support.google.com/analytics/answer/2838718?hl=it
• Smartlook: https://www.smartlook.com/help/privacy-statement/

Social networks

The website comes with a plug-in for the following social networks: Facebook, Twitter, LinkedIn, Instagram. Cookies might be enabled if the relevant social network provides so and only when the user intentionally uses such plug-in or in the event they have accessed the social network before navigating the website and the session is still under way.

As to the processing of the personal data collected by the social, please reference the relevant privacy policy:
• Facebook: https://www.facebook.com/policy.php
• Twitter: https://twitter.com/it/privacy
• LinkedIn: https://www.linkedin.com/legal/privacy-policy?_l=it_IT
• Instagram: http://instagram.com/legal/privacy/
• Youtube: https://www.youtube.com/static?template=privacy_guidelines

PERSONAL DATA

Personal data: data you have deliberately and intentionally provided upon completing the form available in the website or any other electronic device:
• first name and last name;
• e-mail address
• mobile phone number

By pressing the button “TAKE THE EMOTIONAL INTELLIGENCE TEST” you will be redirected to the website https://survey.6seconds.org/Quest/c9f4d01e-b3ee-4096-869d-0984efd7eceb, run by Six Seconds, PO Box 1985, Freedom, CA 95019, USA, who is also the data controller of the data you will provide to take the test. We remind you that this privacy policy does not concern that website. Please carefully read the privacy policy before completing the test form.

We shall be the data controller of the data we will be communicated by Six Seconds or yourself and, therefore, we might process also the following data:
• Age
• Country
• Gender
• Education
• Industry
• Job
• Role

DATA PROCESSING PURPOSE

The data collected will be used for the following purposes:
• allow you to request information;
• allow you to receive information, either written or oral;
• recontact you if you have requested information;
• help you when providing the professional services advertised in the website (free coaching session);
• send you personalised communications;
• send you commercial and marketing communications;
• carry out statistical analyses;
• defend our rights.

NATURE OF THE PROVISION

You can and, indeed, must decide of your own will to provide your data and, when required, give consent to its processing. In some cases the data provision is a contractual obligation and a necessary requirement for the conclusion and fulfilment of the contract, in other cases it is optional.

Anyway, unless you provide all the data required, we will not be able to deliver the Services you have requested.

PERSONAL DATA RETENTION PERIOD

Your personal data will be stored for a limited period of time, connected to the processing purpose and, anyway, for no longer than is necessary for the purposes for which the data were collected or subsequently processed.
Unless required by law and in the event of legitimate interest on our part, the retention period is the following:
• request of information: 12 months from the latest information requested
• free coaching sessions: 6 months after completion of the free coaching session, unless you have decided to access the pay-for coaching service
• pay-for coaching sessions: 5 years after completion of the pay-for coaching session
At the end of the period, your data will be deleted or anyway made irreversibly anonymous.

PROCESSING FACILITIES

We shall process your personal data at our premises. For organizational and security reasons, we also avail ourselves of external IT service providers (e.g. website hosting, cloud service, etc.).

All of our suppliers qualify to meet the strictest security standards and are based either in Italy or in the EU. Your data will be processed within Europe.

PROCESSING METHODS

Processing of your data is carried out both on paper and via electronic media. Your data will always be:
• processed lawfully and fairly;
• collected and recorded for specifed, explicit and legitimate purposes, and used at other stages of the processing compatible with said purposes;
• correct or, anyway, match the information you have provided us with;
• pertinent, complete and limited to the purposes for which they have been collected or subsequently processed;
• retained in such a way to allow identification of the data subject for no longer than is necessary for the purposes for which the data were collected or subsequently processed.
The staff of www.talent-up.it have been trained and updated vis-à-vis personal data processing criteria.

SECURITY MEASURES

We attach great importance to the processing of personal data. Your data are our data and we want to protect them like our own. For this reason we have adopted adequate technical and organizational measures meant to reduce the risk of destruction, loss, wrongful or unfair use, unauthorised access or processing other than for the purposes for which they have been collected.
PERSONAL DATA COMMUNICATION
Under some circumstances, we might have to pass your personal data on to third parties designated to carry out all related activities on our behalf.

In the case in point, the third parties we refer to are: co-workers, professionals we collaborate with, tax consultant, administration staff.
The above individuals are fully qualified and will not have the faculty to use your data for purposes other than they have been designated for. You will not receive any communication from the above subjects. Please be advised that, in other circumstances, your data might be communicated to other subjects, bodies or Authorities pursuant to the law provisions or regulations in force.

PERSONAL DATA CIRCULATION

Your personal data will not be communicated (e.g. published in the web, entered in the newsletter, etc.).

TRANSFER OF DATA ABROAD

Your personal data will neither be transferred abroad nor do we intend to do so.
However, usage on the part of the data subject of plugin and profiling services available in the website inherently implies that some of the data collected will be shared with the service providers. As to the transfer of such data, consent of the data subject is not necessary in keeping with what provided by the Italian and European authorities (Ruling n. 1250/2016 – Privacy Shield).

DATA SUBJECT’S RIGHTS

We attach great importance to your rights, so please find them listed below. Also, be advised that you will always have the faculty:
• to access your personal data and information as well as to apply for receiving a copy thereof;
• to rectify incorrect data or integrate incomplete data;
• to demand the erasure of your personal data;
• to demand the restriction of processing of the personal data you have provided;
• to apply for and obtain – in the event that the legal basis of processing be a contract or consent and the same is given by means of telematic tools – the personal data in a structured or unstructured form readable from an automated device, also to the aim of communicating such data to a different data controller (namely right to data portability);
• object at any time to the processing of personal data;
• withdraw consent to processing personal data at any time. Processing based on consent and carried out prior to consent withdrawal is anyway lawful.
• forbid us, in the event of your early death, to let people having vested interests or acting on your behalf as proxy, or for family reasons worthy of protection, exercise the above rights limitedly to the services of the brand/company holding your personal data and information. In this case, you will have to notify us in writing.

All requests are to be submitted to Barbara Galli – VAT Number 10781120968, domiciled in Melegnano, Via Battisti, 47, e-mail barbara@talent-up.it, mobile phone number. + 39 3491719446.
LODGING A COMPLAINT

We also remind you that you are entitled to lodge a complaint with the Supervisory Authority for the protection of personal data (https://www.garanteprivacy.it/home/diritti/come-agire-per-tutelare-i-nostri-dati-personali).