Pursuant to Article 13 and Article 14 of Regulation (EU) No. 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals 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 your right to privacy and the protection of your personal data. In this document (hereinafter Disclosure), drafted in application of the legislation set forth in Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals 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, c.d. GDPR) and the "Personal Data Protection Code" referred to in Legislative Decree No. 196 of June 30, 2003, as amended, you will find all the information you need to know about how Openwork processes your personal data.
1. Definitions
Definitions List
Where mentioned in theNotice, the terms below take the meanings given below.
Personal data. Any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, with particular reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more features of his or her physical, physiological, genetic, mental, economic, cultural or social identity.
Common personal data. e.g. biographical data (first name, last name, date of birth, citizenship, marital status, address, occupational qualification); identity documents (CdI, driver's license, passport); tax identification codes (CF, VAT number individuals); contact data (phone number, e-mail address, physical address); worker identification codes (matricula, computer system access credentials); bank details (CC number, IBAN code); vehicle license plate; multimedia data (vide, audio); internet browsing data (cookies, log, IP address); geolocation data; profiling data.
Particular personal data. e.g., data disclosing 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 on criminal records, registry of administrative sanctions dependent on crime and related pending charges).
Processing. Any operation or set of operations, carried out even without the aid of electronic instruments, concerning the collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, erasure and destruction of data, even if not registered in a database. It suffices even one of the listed operations on a Personal Data to deem a processing of Personal Data
Data Controller to be in progress. The entity (the natural or legal person, public authority, service or other body) which, individually or jointly with others(Data Controller), determines the purposes and means of the processing of Personal Data.
Data Subject. The identified or identifiable natural person to whom the data refer.
Data Processor. The entity (the natural or legal person, public authority, service or other body) outside the structure of the Data Controller that processes personal data on behalf of the latter.
1. Data controller
The data controller of your Personal Data is Openwork s.r.l. with registered office in via Marco Partipilo n.38 - 70124 Bari. For specific information concerning privacy management and to apply your rights regarding the processing of Personal Data summarized in this Policy you may 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 contractors of other organizations that work with us in various capacities.
Specifically, the Personal Data collected belongs to the category of Common Data such as e-mail, address, phone number, etc. If the data collected is not listed in this Notice, we provide data subjects (when required by law) with adequate notice of what other data will be collected and how it will be used.
With the exception of certain information required by law, your decision to provide us with personal information is voluntary; however, it is sometimes necessary and essential for the performance of contracts and supplies.
We generally do not collect Special Data or Judicial Data, in the limited exceptional cases where this is necessary we do so in accordance with the requirements of the Privacy Act and with your consent.
If you provide us with the Personal Data of another person (such as a contact person in your organization), you are responsible for ensuring that that person is informed of the information in this Notice and has provided you with consent to share their Personal Data with Openwork.
This Personal Data is either provided directly by you (e.g., to receive product information or sign a supply contract) or obtained indirectly from third parties such as public authorities, public and social media websites, suppliers, and vendors.
3. Purpose of processing.
Personal Data provided, subject to the explicit expression of consent by theData Subject, are processed by us for the execution of contracts; for the supply/acquisition of products/services; to send commercial, corporate or product information; to process online job applications; to request information, including by telephone, relating to the quality of our services and/or products or relating to the cancellation/transfer of same; to fulfill requests for white papers, articles, newsletters or other content; to improve your interaction with Openwork; for compliance as required by law or requested by the competent Authorities.
4. Use of personal data for marketing purposes
In addition to the above purposes we use your Personal Data for marketing purposes. Most of the Personal Data collected for marketing purposes relates to individual employees/collaborators of our customers and customers of other companies with whom we have an existing business relationship or partnership. Contact information may also be obtained from public sources, including content made public on websites and social media, and is intended to make 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 E-mails? We send commercial e-mails to individuals pertaining to our customers or other companies with whom we wish to develop or maintain a business or partnership relationship in accordance with applicable laws. Targeted e-mail messages typically include web beacons, cookies, and similar technologies that let us know whether you open, read, or delete the message and the links you may click on. When you click on a link in a marketing e-mail sent by us we record what pages are viewed and what content downloaded from our Web sites, even if the recipient is not registered on the site. Targeted e-mails 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 of individuals afferent to individual customers of ours and other companies with whom we have or want to develop business relationships and partnerships. Personal Data used for these purposes includes business information, such as: publicly available information (e.g., company role and public posts on social media sites, if commercially relevant), responses to targeted emails (including web activity originated by links in our emails), activity on our registered users' websites, and other business information obtained by Openwork professionals 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? We may combine data from publicly available sources and obtained from our various email, website, and personal interactions with Data Subjects. We combine this data to improve interaction with Openwork and to perform the other activities described in theNotice.
4.4 What are your rights regarding marketing communications? You can exercise your right to stop us from sending marketing communications through the specific options on the forms we use to collect Personal Data or with the opt-out mechanisms in the emails we send. You can also exercise your right to stop marketing communications, in which case we will retain minimal Personal Data to track your choice and avoid contacting you again.
5. Transfer to third parties
We may transfer Personal Data to public and governmental authorities in fulfillment of our obligations under the law or regulations and upon request by the competent authorities. It is possible that Personal Data may also be transferred to third party suppliers of Openwork to manage and perform the provision of services or products
Before doing so, we take the necessary steps to ensure that your Personal Data is adequately protected, as required by privacy and Processing of Personal Data laws, Openwork's internal policies.
6. Retention of data
We will retain your Personal Data only as long as necessary. We maintain specific database management and retention policies and procedures so that Personal Data is deleted after a reasonable time according to legal and contractual obligations.
7. Rights of the data subject
List of Rights
TheInterested Party has the right (under the circumstances and conditions, and subject to the exceptions, set forth in applicable law) to:
- - Obtain information about what data are processed by the Data Controller;
- - To request and obtain in tangible form the data held by the owner;
- - Obtain confirmation of the existence or non-existence of Personal Data concerning him/her;
- - Request a correction of your Personal Data if 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 in relation to the purposes for which the data were collected or subsequently processed;
- - require certification that the operations referred to in the two previous points have been brought to the attention, also as regards their content, of those to whom the data have been communicated and disseminated, except where this proves impossible or involves the use of means manifestly disproportionate to the protected right;
- - Object to the processing of your Personal Data;
- - request the deletion of your Personal Data even where it is no longer suitable for processing;
- - Request restriction of the processing of your Personal Data so that it is processed only in limited circumstances, even with your consent.
- - Request the portability of your Personal Data, i.e., the right to receive a copy of your Personal Data 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 by e-mail at privacy@openwork.it. This will not affect Openwork 's right to process Personal Data obtained prior to withdrawal of consent, or the right to continue parts of the processing based on legal obligations.
8. Use of Openwork products by organizations.
Openwork products/services are intended for use by organizations, e.g., government agencies and corporations.
If you belong to an organization that allows you access to 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 operates either as a Data Controller, if it is itself responsible for the purpose and manner of processing, or as a Data Processor, if it processes personal data on behalf of a third party.
In any case, Openwork acts as a Data Processor in relation to the Personal Data managed by the organization and is therefore not responsible for the organization's privacy and data processing practices, which may be different from those in the Policy.
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 best efforts and efforts, to protect your Personal Data, you feel that your data privacy rights have been violated, we encourage you to contact us to resolve any complaints.
Finally, we inform you that you can apply to the 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
