Privacy Policy
Arts. 13-14 Regulation (EU) 2016/679 (“GDPR”)
Origina Website – “Contact” and “Careers – Spontaneous application” forms
1. Data Controller
PROINTEGRA Srl, represented by its legal representative pro tempore, with registered office at Via Caravaggio 125, 65125 Pescara (PE) – tel. 085.388801 – fax 085.3888200 – email: info@carlomaresca.it – PEC: carlomarescaspa@legpec.it (hereinafter, the “Data Controller”).
2. Data Protection Officer (DPO)
The Data Controller has appointed a Data Protection Officer (DPO), who can be contacted at the following address: rpd@carlomaresca.it.
3. Subject and scope
This policy, provided pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (“GDPR”) and Legislative Decree no. 196 of June 30, 2003 (“Privacy Code”), as amended by Legislative Decree no. 101 of August 10, 2018, governs the processing of personal data of users who, through the Carlo Maresca Group website (hereinafter, the “Site”), use the following data collection forms:
• “Contact” form (Contact section), for general information requests;
• “Careers – Spontaneous application” form (Careers section), for submitting spontaneous applications.
Information regarding the use of cookies and tracking technologies is excluded from the scope of this policy; these are governed by the Cookie Policy published on the Site and managed via the Iubenda platform, which can be consulted via the “Cookies Policy” / “Cookie Settings” links found at the bottom of each page of the Site (see point 14 below).
4. “Contact” form – purposes and data processed
The Contact form collects the following personal data: first name, last name, email address, and phone number (mandatory fields), as well as any free text entered in the “Message” field (optional field). The data is processed for the following purposes:
a) to respond to requests for information, clarification, or contact submitted by the user;
b) manage any pre-contractual relationships resulting from the contact;
c) comply with obligations under law, regulations, or EU legislation, where applicable;
d) establish, exercise, or defend a legal claim.
5. "Careers – Unsolicited Application" form – purposes and data processed
Through the Careers form, the following personal data is collected: first name, last name, email address, and phone number (mandatory fields), as well as any free text entered in the "Message" field (optional), in which the candidate may describe their professional profile, experience, and/or provide their curriculum vitae.
Should the candidate include, in the Message field or in subsequent communications, data belonging to special categories (e.g., health-related data, trade union membership) or data relating to criminal convictions and offenses, such data will be processed exclusively to the extent necessary for the selection purpose, based on the legal basis provided for in Art. 9, par. 2, letters b) and h) GDPR.
The data is processed for the following purposes:
a) evaluate unsolicited applications for the purposes of potential recruitment and selection processes, including for profiles not immediately available;
b) verify skills with a view to potential hiring or the establishment of a collaborative relationship with the Data Controller;
c) comply with legal or contractual obligations;
d) establish, exercise, or defend a legal claim;
e) perform statistical analysis, including in aggregated form.
In the standard course of operations, the management of applications (collection, screening, storage, and organization of interviews) will take place via the "Aliboo" Applicant Tracking System platform, provided by a third party appointed as a Data Processor pursuant to Art. 28 GDPR (see point 9 below).
6. Legal basis for processing
The processing of data collected through the Site's forms is based on one or more of the following legal bases, depending on the purpose pursued:
• Art. 6, par. 1, letter b) GDPR: performance of pre-contractual measures taken at the request of the data subject (management of the contact/application and potential establishment of a relationship);
• Art. 6, par. 1, letter c) GDPR: compliance with legal obligations to which the Data Controller is subject;
• Art. 6, par. 1, letter f) GDPR: legitimate interest of the Data Controller to respond to requests received, evaluate unsolicited applications, and protect their rights;
• Art. 9, para. 2, letters b) and h) of the GDPR, limited to any special categories of data voluntarily provided as part of a job application.
7. Nature of data provision and consequences of refusal
Providing the data marked as mandatory in the forms (first name, last name, email, phone number) is necessary to process your contact request or job application; failure to provide this information will prevent the Data Controller from responding. The "Message" field is optional. No automated decision-making processes, including profiling, are used in the processing of this data that would produce legal effects for the data subject or similarly significantly affect them.
8. Processing methods and security measures
Data processing is carried out using electronic and, where necessary, paper-based tools by individuals authorized by the Data Controller, in compliance with the principles of lawfulness, fairness, transparency, adequacy, relevance, and data minimization as set out in Art. 5 of the GDPR, and through the adoption of technical and organizational measures appropriate to ensure a level of security commensurate with the risk.
To prevent automated requests from being sent via the website forms, we use the reCAPTCHA service provided by Google LLC. This involves the transmission of certain technical data (e.g., IP address, device identifiers) to Google LLC in accordance with their privacy policy and terms of service, which are linked at the bottom of the form pages.
9. Data disclosure and recipients
For the purposes indicated above, personal data may be disclosed to the following parties, who are appointed as Data Processors pursuant to Art. 28 of the GDPR when acting on behalf of the Data Controller, or who are duly authorized pursuant to Art. 29 of the GDPR when operating under the direct authority of the Data Controller:
• the Data Controller's internal staff responsible for managing contacts and recruitment activities;
• Aliboo, provider of the Applicant Tracking System platform used for managing job applications, limited to data collected via the Careers form;
• companies within the Carlo Maresca Group, including subsidiaries, parent companies, or other affiliates of the Data Controller, where necessary for recruitment or contact response activities;
• IT service, hosting, and website maintenance providers;
• Google LLC, as the provider of the reCAPTCHA service;
• consultants and independent professionals (such as lawyers or accountants) engaged by the Data Controller in the course of their business;
• public bodies or authorities to whom disclosure is required by law (e.g., judicial authorities, police forces, Chambers of Commerce).
Personal data will not be disseminated.
10. Data transfer to third countries
As a rule, there is no systematic transfer of personal data to third countries outside the EEA. The use of Google LLC’s reCAPTCHA service may involve a transfer of data to the United States; such transfer takes place on the basis of the adequate safeguards provided by Google (including adherence to the EU-U.S. Data Privacy Framework and/or standard contractual clauses approved by the European Commission). Any further transfers outside the EU, where necessary, will be carried out in compliance with the safeguards provided for by Arts. 44-50 of the GDPR.
11. Data retention period
In accordance with the principles of purpose limitation and data minimization (Art. 5 GDPR), data is stored for the time necessary to achieve the aforementioned purposes:
• data collected via the Contact form: stored for the time necessary to handle the request and, in any case, for a period not exceeding 24 months from receipt, without prejudice to longer periods required by legal, accounting, or tax obligations, or for the establishment, exercise, or defense of legal claims, in which case the data will be stored until the statutory limitation period expires;
• data collected via the Careers form: stored for a period not exceeding 24 months from receipt, unless otherwise specified by the data subject for future recruitment purposes, without prejudice to longer periods required by law or for the legal protection of the Data Controller.
12. Data subject rights
As a data subject, you have the right to obtain from the Data Controller, in the cases provided for by applicable law, access to your personal data (Art. 15 GDPR), rectification (Art. 16 GDPR), erasure (Art. 17 GDPR), restriction of processing (Art. 18 GDPR), data portability (Art. 20 GDPR), as well as the right to object to processing (Art. 21 GDPR) and not to be subject to a decision based solely on automated processing (Art. 22 GDPR).
These rights may be exercised by written communication addressed to the Data Controller (Carlo Maresca S.p.A., Via Caravaggio 125, 65125 Pescara, email: info@carlomaresca.it, PEC: carlomarescaspa@legpec.it) or to the Data Protection Officer (rpd@carlomaresca.it). You also have the right to lodge a complaint with the competent supervisory authority (Garante per la protezione dei dati personali, www.garanteprivacy.it).
13. Minors
The Site’s forms are not intended for minors. The Data Controller does not knowingly collect personal data from minors; should it become aware that it has collected such data without the consent of a parent or legal guardian, it will proceed to delete it.
14. Cookies and tracking technologies
For information regarding the use of cookies and similar technologies on the Site, please refer to the Cookie Policy, managed via the Iubenda platform and available via the “Cookies Policy” / “Cookie Settings” links at the bottom of each page of the Site.
15. Changes to this policy
The Data Controller reserves the right to modify or update this policy, in whole or in part, including in response to regulatory changes. Any such changes will be made available on the Site in the same section.