pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR) – courtesy translation of the Italian notice
This notice concerns the personal data of people who send an application through the “Let's talk about your path” form in the Academy section of convergo.it. For browsing and the other forms on the Website, the general privacy notice applies (/en/privacy-policy-en/).
1. Data controller
The Data Controller is GBSAPRI S.p.A. a Socio Unico, an insurance broker operating under the Convergo brand, in the person of its legal representative, with registered office at Viale Erminio Spalla 9, 00142 Rome, Italy (RUI no. B000054892, PEC gbsapri@legalmail.it). Privacy contact: privacy@convergo.it.
2. Data Protection Officer (DPO)
The Data Protection Officer can be reached at dpo@convergo.it.
3. What data we process
We process the data you enter in the form: first name, last name, e-mail address, phone, city of interest, and the documents you attach (CV and, if you wish, an introduction). The CV contains the data you choose to write in it.
Please do not include in your CV or introduction special categories of data (for example health, political opinions, religious beliefs, trade-union membership) or data on criminal convictions and offences, and do not attach identity documents or photographs that are not needed. If they become useful, we will ask for them later, with the safeguards required.
4. Why we process data and on what legal basis
- To contact you using the data entered in the form.
- To assess your application for the Academy and, where useful, for other job or collaboration positions at the Controller and the group companies, including in the future.
- To let you send your application spontaneously from the Website.
The legal basis is the performance of pre-contractual measures taken at your request (Art. 6(1)(b) GDPR) and in the applicable national and EU legislation (Art. 6(1)(f) GDPR). Providing the data marked as mandatory in the form is necessary to examine the application; without it we cannot assess it. We do not use the data for decisions based solely on automated processing.
5. How we process data
Data are processed with IT and electronic tools, with adequate security measures (Art. 32 GDPR), by persons authorised and instructed by the Controller and by suppliers appointed as data processors. The application is not saved on the Website: the form forwards it by e-mail, with attachments, to the mailbox academy@convergo.it.
6. Who we may share data with
Data may be accessed by staff and collaborators of the Controller and of the group companies who handle selection, and by IT service suppliers appointed as data processors: Website hosting (Kinsta), sending of the form e-mail (Elementor's Site Mailer, which uses the SendGrid service) and e-mail (Microsoft 365). Data are not disseminated and are not transferred to third parties for purposes other than those stated.
7. Transfers outside the European Economic Area
The Website servers are in Milan. However, the application also passes through suppliers listed in section 6 (SendGrid, Microsoft) that have offices or infrastructure outside the European Union: in these cases the transfer takes place only to countries with a European Commission adequacy decision or with the safeguards of Articles 46 ff. GDPR. You may ask the Controller for a copy of the safeguards adopted.
8. How long we keep data
Your data are kept for 2 years from receipt of the application. After that they are deleted or anonymised.
9. Your rights
Where the conditions are met, you may ask the Controller (privacy@convergo.it) or the DPO (dpo@convergo.it) for: access to your data and a copy; rectification and completion; erasure; restriction of processing; portability; objection to processing (Arts. 15-22 GDPR).
10. Complaint to the Authority
You have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali, www.garanteprivacy.it) or to take legal action. If you prefer, you may first write to the Controller or the DPO.
11. Updates
This notice may be updated; the version in force is the one published on this page.