The following privacy policy directed at users of the website (hereinafter referred to as “information”) is intended to inform you about how your personal data is processed when you visit our website (hereinafter referred to as “site”).

In this regard, we inform you that Recrytera S.r.l., which is located at Via Erasmo Piaggio No. 35 – 66100 Chieti, acts as the data controller for your personal data.

1-WHAT PERSONAL DATA DO WE COLLECT

When you browse our website, we may collect the following categories of personal data:

• Technical data (e.g., IP address, type of browser used, etc.).
• Personal data (name, surname, email address, phone number, and any other personal information contained in any correspondence sent to us via email or through the completion of forms on the website for information requests.

Technical cookies cannot be refused by the Site user, as they are strictly functional to the Site itself.

The provision of your other personal data is voluntary, but without them, we will not be able to provide you with the services and information you have requested: a contact and/or forwarding request through the completion of forms on the website involves the acquisition of the user’s e-mail address, required for establishing communication, as well as any other personal data entered.

In any case, we will inform you when it is mandatory to provide your personal data.

Furthermore, if you provide us with personal data belonging to third parties, you undertake to ensure that such individuals have been duly informed of the processing of their personal data in accordance with this policy and, if required, have consented to the processing of their personal data. 

2-WHY DO WE USE YOUR PERSONAL DATA? FOR HOW LONG ARE THEY RETAINED?

We use the technical data mentioned above exclusively to ensure the proper functioning of the website. Technical data is not stored and remains active only until the browser is closed.

We use the personal data mentioned above to respond to requests and inquiries that you may submit through the website. We will retain your personal data for a maximum of 1 year from our last contact with you.

In any case, we remind you that we will not process your personal data for any purpose incompatible with the purposes mentioned above.

3-WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

In the context of our processing operations, we may disclose your personal data to the following recipients:

• To our suppliers, agents, and contractors, to the extent they assist us in carrying out the purposes outlined in this policy (for example, we use IT service providers to store your personal data on our behalf).
• To other companies within the Dromedian Group.
• To competent courts, public authorities, government agencies, and law enforcement (including when required to comply with legal or regulatory requests). Regardless of the recipient, we will only disclose to them the personal data necessary and only to the extent that the purposes identified in this notice are fulfilled.

4-DO WE TRANSFER DATA OUTSIDE THE EUROPEAN ECONOMIC AREA?

We do not transfer data outside the European Economic Area.

If your personal data were to be transferred outside the European Economic Area (‘EEA’), we will ensure that the level of protection for your personal data is not negatively affected by such transfers.

This specifically means that each of the anticipated transfers is based on at least one of the following mechanisms:

• the existence of an adequacy decision issued by the European Commission for the country to which your personal data is being transferred; or alternatively,
• the conclusion of standard contractual clauses reproducing the models adopted by the European Commission; or alternatively,
• the existence of an exemption relating to one of the specific situations exhaustively provided for by the General Data Protection Regulation 2016/679 (‘GDPR’) (for example, if you have given your consent to such transfer having been informed of the absence of safeguards, if the transfer is necessary for the performance of a contract concluded between you and us, if the transfer is necessary for the conclusion or performance of a contract concluded in your interest between us and a third party, or if the transfer is necessary for the establishment, exercise, or defense of our legal rights, etc.).

5- DO WE USE COOKIES?

We exclusively use technical cookies on our website. Technical cookies are those that are used for navigation or to provide a service requested by the user. They are not used for additional purposes and do not require the user’s consent. The user can decide whether to disable technical cookies using their browser settings. However, the total or partial disabling of technical cookies may affect the use of the site’s features.

For more information, please refer to our Cookie Policy.

6-THIRD-PARTY PLUGINS

The site incorporates third-party plugins and/or buttons: Plugins from well-known social networks, solely for the purpose of allowing the user to continue following our content on other channels.

These services enable interactions with social networks or other external platforms directly from the pages of this website. If a service for interacting with external platforms is installed, it is possible that, even if users do not use the service, it may collect traffic data related to the pages on which it is installed.

The collection and use of information by such third parties are governed by their respective privacy policies, to which please refer:

• Facebook- Meta ( privacy policy ; cookie policy)
• Twitter/X- X Corp. ( privacy policy; cookie policy)
• LinkedIn-LinkedIn corporation ( privacy policy ; cookie policy)
• Telegram- Telagram LLC (privacy policy; cookie policy)
• WhatsApp-Meta (privacy policy; cookie policy)

7- WHAT ARE YOUR RIGHTS?

In accordance with the applicable legal framework for data protection, especially with the GDPR, as a data subject, you have the following rights:

• You can request access to your personal data and request its correction or deletion.
• You also have the right to request that the processing of your personal data be restricted or to object to it.
• You have the right to the portability of your personal data.
• If the processing of your personal data is based on your consent, you can withdraw it at any time, without affecting the lawfulness of the processing based on the consent given prior to the withdrawal.

To exercise your rights, please contact us using the contact details provided in section 8 (How can you contact us?). To process your request as efficiently as possible, we may ask you for additional information to confirm your identity and/or help you locate the personal data that is the subject of your request.

In any case, we remind you that you can lodge a complaint with the competent supervisory authority.

The supervisory authority in Italy can be contacted at https://www.garanteprivacy.it/.

8- HOW CAN YOU CONTACT US?

You can contact our Privacy Team at the following email address: privacy@concorsismart.it

9- CHANGES TO THIS PRIVACY POLICY

The data controller reserves the right to make changes to this Privacy Policy at any time, making them known to users on this page.

v.1.2 January 2024

The purpose of this notice is to inform you about the processing of your personal data when acting on behalf of a customer or potential customer of Recrytera (e.g., employee, intern, company representative, etc.).

In this regard, we inform you that Recrytera S.r.l., which is located at Via Erasmo Piaggio No. 35 – 66100 Chieti, acts as the data controller for your personal data.

1-WHAT PERSONAL DATA DO WE COLLECT

We collect the following categories of personal data about you:

• Personal details (name, tax code, etc.);
• Contact information (address or residence, phone number, email, etc.);
• Bank details (IBAN number, the bank with which the account is held, etc.);
• Various data involved in potential disputes.

In most cases, providing your personal data is mandatory; without it, we will be unable to properly manage our business relationship with the entity you are acting on behalf of. For example, if you refuse to provide your contact information so we can send you an agreement to sign, we will not be able to enter into a contract with the entity you are acting on behalf of.

In any case, we will inform you when it is mandatory to provide your personal data.

Furthermore, if you provide us with personal data belonging to third parties (for example, if you provide the data of a signatory so we can prepare the agreement to be signed), you guarantee that these individuals have been duly informed about the processing of their personal data in accordance with this policy and, if required, that they have consented to the processing of their personal data.

2-WHY DO WE USE YOUR PERSONAL DATA? FOR HOW LONG ARE THEY RETAINED?

PURPOSE
Establishment and management of the relationship with customers
Recrytera processes personal data for the establishment and subsequent management – until termination – of the relationship with its customers and/or for possible subsequent direct marketing activities within the limits of Art. 130 (4) of Legislative Decree 196/2003. Personal data of customers are generally provided to Recrytera by third parties (other than the data subjects), by the data subjects themselves following requests for a specific service, or collected from publicly accessible sources (such as the internet).

LEGAL BASIS
Art. 6 (1) (b) of GDPR: The processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject.

RETENTION PERIOD
Personal data related to economic aspects: Up to 10 years after the termination of the business relationship.
Contact details: Until the business activity ceases, subject to the possibility for the data subject to request their deletion/destruction.

PURPOSE
Management of potential disputes
Recrytera processes personal data for the management of disputes that may arise with employees/collaborators, suppliers,customers, and/or third parties. The data is collected from both the data subject and third parties.

LEGAL BASIS
The processing is necessary for the pursuit of the legitimate interest of the data controller or third parties, provided that the interests or fundamental rights and freedoms of the data subject requiring the protection of personal data do not prevail, particularly if the data subject is a minor, ex Art. 6 (1) (f) of GDPR (where the legitimate interest is represented by the need to exercise or defend a right in court); the processing is necessary to establish, exercise, or defend a legal claim, ex Art. 9 (2) (f) of GDPR

RETENTION PERIOD
Until the purpose is achieved (final resolution of the legal dispute, properly fulfilled settlement, etc.)

We will not process your personal data for any other purpose that is incompatible with the purposes mentioned above. We retain your personal data for no longer than necessary for the purpose of the relevant processing. Once the applicable retention period has passed, we will irreversibly delete or anonymize your personal data so that you can no longer be identified.

3-WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

As part of our processing operations, we may share your personal data with the following recipients:

• Our suppliers, agents, and contractors, to the extent they assist us in carrying out the purposes outlined in this notice (e.g., we use IT service providers to store your personal data on our behalf; in the case of unpaid invoices, we may use the services of providers specializing in debt collection, etc.)
• Other entities of the Dromedian Group (e.g., in the context of our accounting/tax obligations, we may need to share a certain amount of information, including personal data about you, for consolidation purposes at the Dromedian Group level).
• Where applicable, investors/buyers and their advisors (e.g., in the context of mergers and acquisitions).
• Competent courts, public authorities, government agencies, and law enforcement bodies (including when we are required to comply with legal or regulatory requests).

Regardless of the recipient, we will only disclose your personal data on a strict need-to-know basis and only to the extent necessary to fulfill the purposes identified in this notice.

We do not sell your personal data.

4-DO WE TRANSFER DATA OUTSIDE THE EUROPEAN ECONOMIC AREA?

Regarding the processing operations described in this notice, we want to inform you that we do NOT transfer your personal data outside the European Economic Area (“EEA”). Should the need arise, we ensure that each planned transfer is based on at least one of the following mechanisms: (i) the existence of an adequacy decision issued by the European Commission for the country to which your personal data is transferred; or alternatively (ii) the signing of standard contractual clauses that replicate the models adopted by the European Commission; or alternatively (iii) the existence of a derogation relating to one of the specific situations exhaustively provided for by the General Data Protection Regulation 2016/679 (“GDPR”) (e.g., if you have given your consent to such transfer having been informed of the lack of guarantees, if the transfer is necessary for the performance of a contract between you and us, if the transfer is necessary for the conclusion or performance of a contract concluded in your interest between us and a third party, or if the transfer is necessary to establish, exercise or defend our legal rights, etc.).

You can obtain copies of these documents by sending an email to our Data Protection Officer (“DPO”), whose contact details are provided in section 6 (How can you contact us?) below.

5-WHAT ARE YOUR RIGHTS?

In accordance with the applicable legal framework on personal data protection (particularly the GDPR), you, as a data subject, have the following rights:

(i) You may request access to your personal data and request its correction or deletion.

(ii) You also have the right to request that the processing of your personal data be restricted or to object to it.

(iii) You have the right to the portability of your personal data.

(iv) If the processing of your personal data is based on your consent, please note that you can withdraw your consent at any time, without affecting the lawfulness of the processing based on consent before its withdrawal.

Please note that some of the rights mentioned above are subject to specific conditions dictated by the applicable legal framework on personal data protection. Therefore, if your particular situation does not meet those conditions, we will not be able to fulfill your request.

To exercise your rights, you can contact our DPO using the contact details provided in section 6 (How can you contact us?). To process your request most efficiently, we may ask you for some additional information to confirm your identity and/or help you locate the personal data that is the subject of your request.

In any case, we remind you that you can lodge a complaint with the competent supervisory authority.

The supervisory authority in Italy can be contacted at: https://www.garanteprivacy.it/

6-HOW CAN YOU CONTACT US?

If you have any questions or requests regarding our processing operations with your personal data under this notice, you can contact the Privacy Office and our DPO at privacy@concorsismart.it.

v.1.2 January 2024

The purpose of this notice is to inform you about the processing of your personal data when you act on behalf of a supplier or business partner of Recrytera (e.g., employee, intern, company representative, etc.).

In this regard, we inform you that Recrytera S.r.l., which is located at Via Erasmo Piaggio No. 35 – 66100 Chieti, acts as the data controller for your personal data.

1-WHAT PERSONAL DATA DO WE COLLECT

We collect the following categories of personal data about you:

• Identifying Data (e.g., last name, first name, contact information, etc.).
• Professional Data (e.g., your job title, identity of your employer, etc.).

In most cases, providing your personal data is mandatory; without it, we will not be able to properly manage our collaborative relationship with the entity you represent. For example, if you refuse to provide us with your contact details to send you an agreement to sign, we will not be able to enter into a contract with the entity you represent. In any case, we will inform you when it is mandatory to provide your personal data.

Furthermore, if you provide us with personal data belonging to third parties (e.g., the details of a signatory so we can prepare the agreement to be signed), you guarantee that such individuals have been duly informed of the processing of their personal data in accordance with this policy and, if required, that they have consented to the processing of their personal data.

2-WHY DO WE USE YOUR PERSONAL DATA? FOR HOW LONG ARE THEY RETAINED?

The table below outlines the purposes for which we process your personal data, along with the legal basis for each processing operation and the retention period:

PURPOSE
Management of relationships with suppliers (including potential ones), service providers, and business partners (e.g., agents, etc.), including but not limited to:(i) preparation and execution of agreements; (ii) order management and follow-up; (iii) invoicing; etc.

LEGAL BASIS
Processing is necessary for the performance of a contract or to take steps, at your request, to enter into a contract.

RETENTION PERIOD
According to national legislation, no more than 10 years after the end of our contractual relationship with the supplier, service provider, or business partner on whose behalf you are acting.

PURPOSE
If applicable, the study, organization, and execution of transactions related to our activities, particularly in the context of mergers and acquisitions, spin-offs, etc.

LEGAL BASIS
Our legitimate interest in finding and managing investors/acquirers/other interested parties who may be interested in our business.

RETENTION PERIOD
Your data will be retained only as long as necessary to evaluate the potential of the proposed transactions and, if applicable, to carry them out.proposte e, se necessario, a realizzarle.

PURPOSE
Data analysis for business intelligence purposes to improve our understanding of internal business processes, evaluate the effectiveness and efficiency of our management system, and assess initiatives.

LEGAL BASIS
Our legitimate interest in analyzing our organization and improving internal processes.

RETENTION PERIOD
For the time necessary to carry out the business intelligence analysis.

PURPOSE
Compliance with the applicable legal framework.

LEGAL BASIS
The necessity to comply with a legal obligation to which we are subject.

RETENTION PERIOD
Your data will be retained for the duration of the statute of limitations for the obligations to which we are subject.

PURPOSE
Management and follow-up of unpaid invoices, as well as potential disputes with you or third parties.

LEGAL BASIS
Processing is necessary to manage the contract and to pursue our legitimate interest in collecting amounts owed and defending our interests, including through legal actions and, where applicable, if certain categories of data are processed (e.g., convictions, offenses, security measures), the necessity to establish, exercise, or defend our legal rights.

RETENTION PERIOD
Your data will be retained for the duration of the recovery/dispute and until all potential remedies are exhausted.

We will not process your personal data for any other purpose that is incompatible with the purposes mentioned above. We retain your personal data for no longer than necessary for the purpose of the relevant processing. Once the applicable retention period has passed, we will irreversibly delete or anonymize your personal data so that you can no longer be identified.

3-WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

As part of our processing operations, we may share your personal data with the following recipients:

• • Our suppliers, agents, and contractors, to the extent they assist us in carrying out the purposes outlined in this notice (e.g., we use IT service providers to store your personal data on our behalf; in the case of unpaid invoices, we may use the services of providers specializing in debt collection, etc.)

• Where applicable, investors/buyers and their advisors (e.g., in the context of mergers and acquisitions).
• Competent courts, public authorities, government agencies, and law enforcement bodies (including when we are required to comply with legal or regulatory requests).

Regardless of the recipient, we will only disclose your personal data on a strict need-to-know basis and only to the extent necessary to fulfill the purposes identified in this notice.

We do not sell your personal data.

4-DO WE TRANSFER DATA OUTSIDE THE EUROPEAN ECONOMIC AREA?

Regarding the processing operations described in this notice, we want to inform you that we do NOT transfer your personal data outside the European Economic Area (“EEA”). Should the need arise, we ensure that each planned transfer is based on at least one of the following mechanisms: (i) the existence of an adequacy decision issued by the European Commission for the country to which your personal data is transferred; or alternatively (ii) the signing of standard contractual clauses that replicate the models adopted by the European Commission; or alternatively (iii) the existence of a derogation relating to one of the specific situations exhaustively provided for by the General Data Protection Regulation 2016/679 (“GDPR”) (e.g., if you have given your consent to such transfer having been informed of the lack of guarantees, if the transfer is necessary for the performance of a contract between you and us, if the transfer is necessary for the conclusion or performance of a contract concluded in your interest between us and a third party, or if the transfer is necessary to establish, exercise or defend our legal rights, etc.).

You can obtain copies of these documents by sending an email to our Data Protection Officer (“DPO”), whose contact details are provided in section 6 (How can you contact us?) below.

5-WHAT ARE YOUR RIGHTS?

In accordance with the applicable legal framework on personal data protection (particularly the GDPR), you, as a data subject, have the following rights:

(i) You may request access to your personal data and request its correction or deletion.

(ii) You also have the right to request that the processing of your personal data be restricted or to object to it.

(iii) You have the right to the portability of your personal data.

(iv) If the processing of your personal data is based on your consent, please note that you can withdraw your consent at any time, without affecting the lawfulness of the processing based on consent before its withdrawal.

Please note that some of the rights mentioned above are subject to specific conditions dictated by the applicable legal framework on personal data protection. Therefore, if your particular situation does not meet those conditions, we will not be able to fulfill your request.

To exercise your rights, you can contact our DPO using the contact details provided in section 6 (How can you contact us?). To process your request most efficiently, we may ask you for some additional information to confirm your identity and/or help you locate the personal data that is the subject of your request.

In any case, we remind you that you can lodge a complaint with the competent supervisory authority.

The supervisory authority in Italy can be contacted at: https://www.garanteprivacy.it/

6-HOW CAN YOU CONTACT US?

If you have any questions or requests regarding our processing operations with your personal data under this notice, you can contact the Privacy Office and our DPO at privacy@concorsismart.it.