INFORMATION ON THE PROCESSING OF PERSONAL DATA

Pursuant to Article 13 of Regulation (EU) 2016/679, General Data Protection Regulation (“GDPR”)

This notice is provided for the processing of data collected through the “Careers” page of the website www.myair.io, owned and operated by AIR S.r.l., with registered office in Milan (20124), Via Vittor Pisani 16, hereinafter referred to as the “Website”.

Through the above-mentioned web page, users may submit unsolicited applications for employment or collaboration opportunities with the company.

DATA CONTROLLER

AIR S.r.l.

Registered office: Via Vittor Pisani, 16 – 20124 Milan
VAT No. 08745320963

Hereinafter referred to as the “Company” or the “Controller”.

DATA PROTECTION OFFICER

In compliance with the provisions of the Regulation, the Company has appointed its own Data Protection Officer, who may be contacted regarding matters relating to the processing of personal data, as well as at the AIR S.r.l. address indicated above, using the following contact details:

Email: dpo@myair.io

PERSONAL DATA PROCESSED

In addition to anything else provided for on other pages, the following data may be collected and processed through the “Careers” web page of the Website:

common and identifying personal data: this category includes first name and surname, email address and telephone number;

personal data contained in the curriculum vitae uploaded electronically;

any additional data acquired through the completion of the electronic form, such as, by way of example only, the position applied for and data that may be obtained from the candidate’s LinkedIn profile, where provided.

Except where knowledge of certain data belonging to “special categories” is required by law or is strictly necessary for the establishment of the employment or collaboration relationship and does not conflict with specific legal provisions, such as those set out in Law No. 300/1970, the Workers’ Statute, and regulations on equal opportunities or aimed at preventing discrimination, the Company does not collect such data during recruitment and selection processes. Candidates are invited not to provide or include in documents and CVs uploaded through the Website any personal data belonging to “special categories”, such as, by way of example only, data concerning health conditions, membership of protected categories, or information relating to membership of political parties, trade unions or other organisations or associations of a religious nature.

Any data belonging to “special categories” will be immediately deleted unless the candidate provides a written declaration after having read this information notice.

LEGAL BASIS AND PURPOSES OF PROCESSING

The processing of personal data is based on the existence of a pre-contractual or legal obligation and is carried out exclusively for the following purposes:

(i) to fulfil pre-contractual obligations — to manage and evaluate the application submitted through the Website for the purpose of possible placement within the Company, expressly including contacting the candidate and arranging and managing an interview, thereby following up on a specific request made by the candidate;

(ii) to fulfil legal obligations — to comply with obligations arising from applicable national and/or EU laws or regulations, including in the tax field, as well as from provisions issued by competent authorities and bodies.

MANDATORY OR OPTIONAL NATURE OF DATA PROVISION

The provision of data for the purposes indicated above is entirely optional. However, since such processing is necessary to evaluate the request relating to the submission of an application, failure to provide the data, or the partial or inaccurate provision of such data, will make it impossible, depending on the case, to manage and proceed with the selection process.

DATA DISCLOSURE

The data may be disclosed to the following categories of recipients:

to all parties, including Public Authorities, that have access to personal data by virtue of legal or administrative provisions;

to all public and/or private parties, natural and/or legal persons, to whom disclosure is necessary or functional for the proper fulfilment of a contractual or legal obligation.

In addition to the above, for the pursuit of the purposes described above, personal data may be made available to employees of the Company’s Human Resources Department or to parties acting on behalf of the Company, such as, by way of example and without limitation:

companies, consultants or professionals appointed to install, maintain, update and generally manage the Website’s hardware and software;

the Company’s legal and tax professionals and consultants,

who will process the data, depending on the case, as independent controllers or external data processors.

In any case, personal data will not be transferred to countries outside the EU or outside the European Economic Area.

PERSONAL DATA RETENTION PERIODS

Personal data will be retained for the time necessary to evaluate the application and for the entire selection process. Subsequently, it will be retained for a period not exceeding 6 months, for contact purposes and any future interviews, and in any case for the maximum period provided for by applicable laws on limitation periods and/or forfeiture of claims, including in administrative and tax matters, and, more generally, for the exercise or defence of the Company’s rights in disputes brought by public authorities, public bodies/entities and private parties.

CHILDREN UNDER 14

The “Careers” web page does not contain information, functions or services directly intended for users under the age of 14.

Minors must not provide information or personal data without the consent of the persons exercising parental responsibility over them.

All users under the age of 14 are therefore invited not to disclose their personal data under any circumstances without the prior authorisation of a parent or person exercising parental responsibility. If the Company becomes aware that personal data has been provided by a minor under the age of 14, the Company will immediately delete such data or request the transmission of specific consent from the parents, or the person exercising parental responsibility. The Company also reserves the right to prevent access to the services available on the Website to any user who has concealed their minor age or who has otherwise provided personal data without the consent of their parents, or the person exercising parental responsibility.

RIGHTS

As a data subject, the user has the right to ask the Controller to exercise the following rights:

Right of access

You may request confirmation as to whether or not your personal data is being processed and, if so, access to such data and specific information. You may also request a copy of your data.

Right to rectification

You have the right to request and obtain the rectification of personal data concerning you and/or the completion of incomplete personal data.

Right to erasure

You may obtain the deletion of your data, without undue delay, including where: (i) such data is no longer necessary for the purposes for which it was collected; (ii) you object to the processing of your data, as indicated below, and there is no overriding legitimate reason for the processing; (iii) the data is being processed unlawfully; or (iv) the data must be deleted pursuant to a legal obligation. This right does not apply where the processing of the data is necessary, among other things, for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.

Right to restriction of processing

You have the right to obtain restriction of the processing of personal data, meaning that the processing of the data will be suspended for a certain period of time. Circumstances that may give rise to this right include situations in which the accuracy of the personal data has been contested, but we need time to verify its accuracy or inaccuracy. This right does not prevent the continued storage of personal data.

Right to data portability

In the case of automated processing or processing based on consent, you have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format and to transmit such data to another controller.

You also have the right to obtain the direct transmission of the data from one controller to another, where technically feasible.

This is without prejudice to the possibility of obtaining the deletion of the data, as indicated above.

Right to object

You have the right to object at any time to processing based on the legitimate interest of the Controller, unless the Controller demonstrates compelling legitimate grounds for the processing that override the interests, rights and fundamental freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

Finally, you have the right to lodge a complaint with the Supervisory Authority: http://www.garanteprivacy.it/, in the cases referred to in Article 77 of the GDPR.

The rights listed above may be exercised by submitting a request to the Controller, without any formalities. The request may be sent to the Controller by letter or email using the addresses indicated above, or by email at privacy@myair.io.

This information notice was last updated in May 2019.

This notice may be subject to further updates. The Controller therefore invites users to visit this page periodically to stay informed of any changes or updates.