Pursuant to and for the purposes of Articles 13 and 14 of Regulation (EU) No. 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such Data (General Data Protection Regulation, hereinafter also GDPR).
Openwork places great importance on the right to privacy and the protection of your personal data. This document (hereinafter the Privacy Policy ), drafted in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, GDPR) and the "Personal Data Protection Code" pursuant to Legislative Decree no. 196 of 30 June 2003, as amended, provides all the information you need to understand how Openwork processes your personal data.
1. Definitions
List of Definitions
Where mentioned in the Privacy Policy , the terms listed below have the meanings indicated below.
Personal data . Any information relating to an identified or identifiable natural person; 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, genetic, mental, economic, cultural or social identity of that natural person.
Common personal data . e.g., personal details (name, surname, date of birth, citizenship, marital status, address, professional qualification); identity documents (ID, driving license, passport); tax identification codes (CF, VAT number for natural persons); contact details (telephone number, email address, physical address); worker identification codes (registration number, IT system access credentials); bank details (CC number, IBAN code); vehicle license plate; multimedia data (video, audio); internet browsing data (cookies, logs, IP address); Geolocation data; profiling data.
Specially identified personal data . e.g., data revealing membership in political parties, trade unions, religious or philosophical organizations; genetic data; biometric data; health data (e.g., pregnancy, illness, membership in protected categories).
Judicial personal data . e.g., data relating to criminal convictions, offenses, and related security measures (e.g., data relating to criminal records, records of administrative sanctions resulting from offenses, and related pending charges).
Processing . Any operation or set of operations, performed even without the aid of electronic tools, concerning the collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, deletion, and destruction of data, even if not recorded in a database. Personal Data is sufficient personal data
processing in progress . Data Controller The entity (the natural or legal person, public authority, agency, or other body) which, alone or together with others ( Joint Controller ), determines the purposes and means of the processing of personal data.
Data Subject . The identified or identifiable natural person to whom the data refers.
Data Processor . The entity (the natural or legal person, public authority, agency, or other body) external to the Data Controller's organization that processes personal data on its behalf.
1. Data controller
The data controller of your personal data is Openwork srl, with registered office at Via Marco Partipilo n.38 – 70124 Bari. For specific information regarding privacy management and to exercise the rights relating to the processing of personal data summarized in this Policy, you can contact Openwork at the following email address: privacy@openworkbpm.com .
2. Categories of data subjects and personal data collected
We collect Personal Data from our customers, potential customers, suppliers, business contacts, users of our websites, employees and potential employees, and employees and collaborators of other organizations that collaborate with us in various capacities.
Specifically, the Personal Data collected belongs to the category of Common Data such as email, address, telephone number, etc. If the data collected is not listed in this Policy , we provide data subjects (where required by law) with adequate notice of what other data will be collected and how it will be used.
Except for certain information required by law, your decision to provide us with personal data is voluntary, however it is sometimes necessary and indispensable for the execution of contracts and supplies.
Generally we do not collect Special Data or Judicial Data , in the limited exceptional cases where this is necessary we do so in compliance with privacy law requirements and with your consent.
If you provide us with the Personal Data of another person (for example, a contact person in your organization), you are responsible for ensuring that that person is informed of the information contained in this Policy and that they have given you consent to share their Personal Data with Openwork .
The aforementioned Personal Data is provided directly by you (for example, to receive product information or sign a supply contract) or obtained indirectly from third parties such as public authorities, public websites and social media, suppliers and vendors.
3. Purpose of the processing
The personal data provided, subject to the explicit consent of the interested party , are processed by us for the execution of contracts; for the supply/acquisition of products/services; for the sending of commercial, corporate, or product information; to process online job applications; to request information, including by telephone, regarding the quality of our services and/or products or regarding the cancellation/transfer of the same; to fulfill requests for white papers, articles, newsletters, or other content; to improve your interaction with Openwork ; and to comply with legal requirements or those required by the competent authorities.
4. Use of personal data for marketing purposes
In addition to the purposes listed above, we use your Personal Data for marketing purposes. Most of the Personal Data collected for marketing purposes refers to individual employees/collaborators of our clients and clients of other companies with whom we have an existing business relationship or partnership. Contact information may also be obtained from public sources, including content posted on websites and social media, and is intended to establish initial contact with a person of interest. The following sections describe how we use your Personal Data for marketing purposes.
4.1. Do we send targeted emails? We send commercial emails to individuals who are members of our clients or other companies with whom we wish to develop or maintain a business or partnership relationship, in accordance with applicable laws. Targeted emails typically include web beacons, cookies, and similar technologies that allow us to determine whether you open, read, or delete the message, as well as links you may click. When you click a link in a marketing email we send, we record which pages you view and what content you download from our websites, even if you are not registered on the site. Targeted emails may include additional data privacy information, as required by applicable laws.
4.2 Do we use a Customer Relationship Management (CRM) system? Like most companies, we use a Customer Relationship Management (CRM) application. The CRM collects personal data from individuals relating to our individual customers and other companies with whom we have or wish to develop business relationships and partnerships. The personal data used for these purposes includes business information, such as publicly available information (e.g., company title and public posts on social media sites, if relevant to business purposes), responses to targeted emails (including web activity originating from links in our emails), registered users' website activity, and other business information obtained by Openwork based on their personal interactions with Data Subjects . Please contact us if you wish to be excluded from our CRM.
4.3 Do we combine and analyze Personal Data? Subjects via email, websites, and in person . We combine this data to improve your interaction with Openwork and to perform the other activities described in the Policy .
4.4 What are your rights regarding marketing communications? You can exercise your right to opt out of receiving marketing communications using the specific options on the forms we use to collect Personal Data or using the opt-out mechanisms in the emails we send. You can also exercise the right to stop receiving marketing communications; in this case, we will retain the minimum amount of personal data to track your choice and avoid contacting you again.
5. Transfer to third parties
We may transfer Personal Data to public and government authorities in compliance with legal or regulatory obligations and upon request from the competent authorities. Personal Data Openwork 's third-party suppliers to manage and execute the provision of services or products.
Before proceeding in this way, we take the necessary measures to ensure that your Personal Data is adequately protected, as required by privacy laws and the Processing of Personal Data Openwork 's internal policies .
6. Data retention
We will retain your personal data only for as long as necessary. We maintain specific database management and retention policies and procedures so that personal data is deleted after a reasonable period of time in accordance with legal and contractual obligations.
7. Rights of the interested party
List of rights
The Data Subject has the right (in the circumstances and under the conditions, and subject to the exceptions, established by applicable law) to:
- – obtain information on what data is processed by the Data Controller ;
- – request and obtain in tangible form the data held by the owner;
- – obtain confirmation of whether or not personal data concerning him or her exists;
- – request rectification of your Personal Data if it is inaccurate or incomplete;
- – request the deletion, transformation into anonymous form, or blocking of data processed in violation of the law, including data whose retention is not necessary for the purposes for which the data was collected or subsequently processed;
- – request certification that the operations referred to in the two previous points have been brought to the attention, including with regard to their content, of those to whom the data were communicated and disseminated, except in cases where such compliance proves impossible or involves the use of means manifestly disproportionate to the right being protected;
- – object to the processing of your Personal Data ;
- – request the deletion of your Personal Data even if they are no longer suitable for processing;
- – request the restriction of the processing of your Personal Data so that it is processed only in limited circumstances, including with your consent.
- – request the portability of your Personal Data or the right to receive a copy of it in an intelligible form or request to transmit such personal data to another Data Controller .
To the extent that the processing of your personal data is based on your consent, you have the right to withdraw that consent at any time by contacting us via email at privacy@openwork.it Openwork 's right to process personal data obtained before your consent was withdrawn, or its right to continue processing certain aspects of the data based on legal obligations.
8. Use of Openwork products by organizations
Openwork products/services are intended for use by organizations, such as government agencies and businesses.
If you belong to an organization that allows you to access Openwork products/services, your use of Openwork products/services is subject to the organization's policies, if any. You should therefore direct privacy inquiries, including requests to exercise your data protection rights, to the organization's administrator.
If the organization uses Openwork products/services to store or process personal data, the organization acts either as a Data Controller, if it is itself responsible for the purpose and means of the processing, or as a Data Processor , if it processes personal data on behalf of a third party.
In any case, Openwork is the Data Controller for the Personal Data managed by the organization and is therefore not responsible for its privacy practices and the processing of personal data , which may differ from those in the Information Notice .
On our web portals www.openowrkbpm.com , www.jamio.com , instruments.jamio.com , players.jamio.com you will find additional data privacy conditions as required by applicable laws.
If, despite our commitment and efforts to protect your Personal Data , you believe that your data privacy rights have been violated, we encourage you to contact us to resolve any complaint.
Finally, we inform you that you may contact the Italian Data Protection Authority or other competent authorities for any complaints arising from the processing of your personal data.
Rev 1.5 dated 06.21.2021
jamio.com
