PRIVACY & COOKIE POLICY

Information document pursuant to and for the purposes of art. 13 of Regulation (EU) 2016/679 (GDPR)

WHY THIS INFORMATION

Pursuant to Regulation (EU) 2016/679 (hereinafter “GDPR”), this page describes the methods of processing personal data. This information shall not be considered valid for other third-party websites, which may be consulted through links on this website and for which no responsibility is assumed. This information is provided pursuant to Article 13 of EU Reg. 2016/679 (European Regulation for the protection of personal data) and is also inspired by the provisions of Directive 2002/58/EC, as amended by Directive 2009/136/EC on Cookies, as well as the provisions of the Italian Data Protection Authority’s guidelines of 08.05.2014 concerning cookies.

PERSONAL DATA THAT CAN BE PROCESSED

  • Personal data: any information relating to an identified or identifiable natural person (“data subject“); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, or physical identity of that natural person, genetic, psychological, economic, cultural or social (Recitals 26, 27, 30 GDPR).
  • Contractors/Users Data.
  • Navigation data: the computer systems and software procedures used to operate this site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This category of data includes the IP addresses or domain names of the computers and terminals used by users, the URI/URL (Uniform Resource Identifier/Locator) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, successful, error, etc.) and other parameters related to the user’s operating system and computer environment. This data, necessary for the use of web services, is also processed for the purpose of:
    • obtaining statistical information on the use of the services (most visited pages, number of visitors per time slot or day, geographical areas of origin, etc.);
    • checking the correct functioning of the services offered.
    • Browsing data does not persist for more than thirty days (except for any need to determine offences by the judicial authority).
  • Data communicated by the user: the optional, explicit and voluntary sending of messages to contact addresses, private messages sent by users to institutional profiles/pages on social media (where this possibility is provided), as well as the completion and submission of forms on the Data Controller’s websites, involve the acquisition of the sender’s contact data, necessary to provide a response, as well as all the personal data included in the communication.

SPECIFIC INFORMATION

Specific privacy policy will be published on the Data Controller’s websites pages dedicated for the provision of certain services or for participation in specific initiatives.

COOKIES AND OTHER TRACKING SYSTEMS

Cookies are text files that the sites visited by users send to their terminals and that are retransmitted to the sites themselves on the next visit. Cookies can be divided into two macro-categories: “profiling cookies” and “technical cookies”. For more information, please visit www.youronlinechoices.eu page.

  • Profiling cookies: this site does not use profiling cookies, i.e. cookies aimed at creating user profiles in order to send messages in line with the preferences expressed while browsing the site.
  • Technical cookies: the site uses technical cookies to allow safe, fast and efficient exploration of the site itself and to provide users with the services requested. The prior consent of users is not required for the installation of these cookies.
  • Technical session cookies: session cookies are used for navigation and authentication to online services and restricted areas. The use of these cookies (which are not stored permanently on the user’s computer and disappear when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to allow effective navigation of the site.
  • Third-party cookies: no third-party cookies are installed

 

The use of permanent cookies, with pseudonymized data, is strictly limited to the acquisition of statistical data useful for understanding the level of use of the individual site.

The configuration adopted, in order to exclude the processing of identification data, collects the following information:

  • The IP address, which is masked by zeroing out the last 2 bytes (xxx.xxx.0.0)
  • The operating system used
  • The type of browser
  • The type of device (PC, smartphone, etc.)

COOKIES USED BY THIS SITE 

Technical cookies that do not require consent: relating to activities strictly necessary for the functioning of the site and the provision of the service

LAWFULNESS OF PROCESSING: For non-technical cookies and similar non-technical technologies, the processing is necessary for the pursuit of the legitimate interests of the Data Controller or third parties, (Art. 6(1)(f) GDPR). Since there are no non-technical cookies, it is not necessary to obtain the user’s consent.

NATURE OF THE PROCESSING: The provision of data is necessary for browsing the website.

INFORMATION ABOUT THE PROCESSING OF PERSONAL DATA CARRIED OUT THROUGH SOCIAL MEDIA PLATFORMS

With regard to the processing of personal data carried out by the operators of the Social Media platforms used by the Data Controller, please refer to the information provided by these operators through their respective privacy policies, including with respect to the transfer of data to non-EEA countries. The Data Controller processes the personal data provided by users through the dedicated pages of its Social Media platforms, to manage interactions with users (comments, public posts, etc.) and in compliance with the applicable legislation. Please also refer to the social media policy available in the footer of the website.

WHO IS THE DATA CONTROLLER? HOW TO CONTACT HIM

The Data Controller is Labor Project S.r.l., with registered office in Via Brianza n. 65, 22063, Cantù (CO), Italy, in the person of the Chief Executive Officer. To contact the Data Controller: Tel. 031 704381, e-mail: privacy@laborproject.it.

HAS THE DATA PROTECTION OFFICER BEEN APPOINTED? WHAT ARE THE CONTACT DETAILS

Labor Project S.r.l. has appointed its Data Protection Officer (DPO) pursuant to Articles 37, 38 and 39 of the GDPR. The DPO can be contacted at the Data Controller’s office indicated above and by e-mail to: dpo@laborproject.it.

PURPOSE OF THE PROCESSING, LEGAL BASIS, DATA RETENTION PERIOD, NATURE OF THE PROCESSING

A. NAVIGATION ON THIS WEBSITE: THE DATA NECESSARY FOR THE USE OF WEB SERVICES ARE ALSO PROCESSED FOR THE PURPOSE OF:

  • obtaining statistical information on the use of the services (most visited pages, number of visitors by time slot or day, geographical areas of origin, etc.);
  • checking the correct functioning of the services offered;
  • The data will be used to ascertain responsibility in the event of alleged cybercrimes against the site.
 

LAWFULNESS OF PROCESSING: the data will be used to ascertain responsibility in the event of alleged cybercrimes against the site. The processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by third parties, provided that such interests are not overridden by the fundamental rights and freedoms of the data subject that require the protection of personal data,  taking into account the reasonable expectations of the data subject and the activities strictly necessary for the operation of the website and for browsing purposes. (Art. 6(1)(f) and Recital 47 GDPR). data subjects are guaranteed the opportunity to obtain, upon request, information regarding the legitimate interest assessment.

RETENTION PERIOD: the storage of browsing data will take place for the duration of the browsing session. In any case, such data will not be stored for more than one month (except where require for the investigation of offences by the judicial authority).

NATURE OF THE PROCESSING: the provision of data is necessary for browsing the website.

B. COLLECTION OF YOUR CONTACT DETAILS: 

you provided during trade fairs, events and/or conferences you attended, for the purpose of subsequent follow-up.

LAWFULNESS OF PROCESSING: adoption of precontractual measures upon data subjects request (Art 6 (1) (b) GDPR;

RETENTION PERIOD: for a period of up to 12 months from the date of collection, unless opt out;

NATURE OF THE PROCESSING: free and voluntary based – failing to provide your contact details will prevent us from contacting you.

C. MANAGEMENT OF REQUESTS and requests from other data subjects (natural persons), pursuant to Articles 15 et seq. of the GDPR (rights of the data subject).

LEGAL BASIS: The processing is necessary for compliance with a legal obligation to which the Data Controller is subject (Recital 45). Art. 6(1)(c) GDPR.

RETENTION PERIOD: 5 years from the closure of the request, except for disputes

NATURE OF THE PROVISION: The provision of personal data is mandatory, as it is essential for complying with legal obligations.

TO WHOM WILL PERSONAL DATA BE COMMUNICATED? DATA RECIPIENTS

Personal data will be communicated to parties who will process the data as independent Data Controllers, or Data Processors (art. 28 GDPR) and processed by people (art. 29 GDPR) who act under the authority of the Data Controller and the Data Processors on the basis of specific instructions provided regarding the purposes and methods of processing. The data will be communicated to recipients belonging to the following categories:

  • Parties based in EEA countries, who provide services for the website and communication networks, including e-mail, hosting and website management;
  • Freelancers, firms or companies in the context of assistance and consultancy relationships, including in Switzerland;
  • Competent authorities for the fulfilment of legal obligations and/or requests from public authority, upon request.

 

The list of Data Processors (ex article 28) is available by writing to privacy@laborproject.it or to the other addresses indicated above.

WILL THE DATA BE TRANSFERRED TO NON-EEA COUNTRIES?

Personal data will be transferred to countries within or outside the EU, in particular Switzerland, in order to fulfil the contractual obligations and purposes within the limits and under the conditions set out in Art. 44 (General Principle for Transfers); Art. 45 (Transfers on the basis of an adequacy decision). It should be noted that the data will be stored in Italy for hosting, management, development and maintenance services of the site. The data subcjets can obtain information regarding the guarantees on the transfer of data to the headquarters of Labor Project S.r.l. or by sending an e-mail to privacy@laborproject.it.

If you agree to the use of cookies and other technologies, please see the above section regarding cookies for data transfer. Lastly, please refer to the paragraph “Information about the processing of personal data carried out through Social Media platforms” for the use of Social Networks.  

IS THERE AUTOMATED PROCESS?

Personal data will be subjected to traditional, electronic and automated manual processing. Please note that fully automated decision-making processes are not carried out.

WHAT ARE YOUR RIGHTS? HOW CAN YOU EXERCISE THEM?

Data subjects can exercise their rights as expressed by Articles 15 et seq. GDPR, by contacting the DPO at the following e-mail address: dpo@laborproject.it or by contacting the Data Controller at the following e-mail address: privacy@laborproject.it, or by writing to the contacts indicated above.

The Data Controller guarantees data subjects the possibility to request, at any time, access to their personal data (art.15), rectification (art.16), erasure (art.17), restriction of processing (art.18). The Data Controller shall notify (art. 19) to each recipient to whom the personal data have been transmitted any correction, deletion or restriction of the processing. The Data Controller will also inform the data subjects of the identities of such recipients upon request. The Data Controller guarantees the right to object (art.21), at any time, to the processing of data based on legitimate interests, by writing to the above-mentioned contacts with the subject line “objection”. In the event of exercising this right, the data subjects are entitled, upon request, to receive information about the balancing test performed.

In the event that the data subject believes that the processing of personal data carried out by the Data Controller is in violation of the Regulation (EU) 2016/679, the data subject can lodge a complaint with the National Supervisory Authority, in particular in the Member State where s/he habitually resides or works, or in the place where the alleged violation occurred (Italian Data Protection Authority https://www.garanteprivacy.it/), or to bring the matter before the appropriate courts.

CHANGES TO THE POLICY

The Data Controller may change, modify, add or remove any part of this Privacy Policy. In order to facilitate the verification of any changes, the policy will contain the last update.

Last update: 15/04/2026