Privacy Policy
The purpose of this document is to inform Users with regard to Personal Data collected from the website (hereinafter, the Application).
The Data Controller, as identified below, may amend or simply update, wholly or in part, this privacy policy
informing the Users about the changes. The amendments or updates shall be binding as soon as they are
published on the Application. Therefore, the User is invited to read the Privacy Policy at every access to the
If the User does not accept any amendments to the Privacy Policy, the User must terminate the use of the
Application and he may ask to the Data Controller to remove his Personal Data.
1. Personal Data collected by the Application
The Data Controller shall collect the following categories of Personal Data:
A. Voluntary contents and information provided by the User
Contact information, credentials, contents: for example biographical data, e-mail address or
postal address or other contact details, password and security information used for authentication
and access to the account, personal interests and preferences and any other personal contents, etc.
Sensitive Data: Personal Data revealing racial or ethnic origin, political opinions, religious or
philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data
for the purpose of uniquely identifying a natural person, data concerning health or data concerning
concerning the sex life or sexual orientation of a natural person.
Personal Data from Social Media: the Users may share with the Application Data communicated
to social media. The User can monitor Personal Data which the Application may have access to when
granting access to its social media accounts and through the privacy settings of the relevant social
media website. By way of connecting accounts managed by social media to the Application and by
way of authorizing the Data Controller to have access to its Personal Data, the User gives its consent
to the acquisition, processing and retention of Data provided by the same social media, in
accordance with this Privacy Policy.
Any failure of the User to provide Personal Data may prevent this Application to provide its services.
The User takes any responsibility regarding Personal Data of third parties published or shared through
this Application and the User ensures to be entitled to communicate or release them, holding the Data
Controller harmless from any liability toward third parties.
Whether the processing of Personal Data is based on the consent of the User, he can revoke it at any
B. Data and contents automatically acquired while using the Application
Technical Data: the computer system and the software procedures functional to this Application
may acquire, in the course of their ordinary activity, any Personal Data, whose communication is
implicit in the use of internet communication protocols. Such information is not collected to be
associated with identi􀀞ed third parties, however, due to the nature of these Data, the same Data
may identify Users, in the Processing and through the association, with Data held by third parties.
This category includes IP addresses or domain names used by Users who connect to the
Application, addresses of Uniform Resource Identifier (URI) of the requested resources, time of the
request, method used submitting the request to the server, size of the file obtained, etc.
C. Personal Data collected through cookies or similar technologies
1 di 3 © 2018
This Application uses cookies, web beacons, unique identifiers and any other similar technologies to
collect Data regarding pages, visited links and other actions, which you may perform while using our
Services. They are stored for being communicated back to the same websites at the next visit of the
The Data subject may read the complete Cookie Policy at the following address:
2. Purposes of the processing
Collected Data may be used for the following purposes:
Servizi di elaborazione paghe e consulenza del lavoro communicating Data to Sistemi S.p.A. ,
3. Personal Data processing methods
The Processing of Personal Data is performed with IT and/or digital tools, with methods of organizations
and with logics strictly related to the indicated purposes.
In certain cases, subjects other than the Data Controller which are involved in the organization of the
Application may access to Data in the assistance of the management of the Application and of the activity
or in the assurance of the performance of services to the User.
These subjects may be appointed, if necessary, as Data Processors by the Data Controller, may access to
Personal Data of the Users whenever required and shall be contractually obliged to keep them
The updated list of Data Processors may be requested via email at the email address
4. Legal basis for the processing
The Data Controller processes Personal Data regarding the User whether one of the following applies:
the User has given consent for one or more specific purposes;
Processing is necessary for the performance of a contract with the User and/or for the performance of
pre-contractual measures;
Processing is necessary to comply with a legal obligation to which the Data Controller is subject;
Processing is necessary for the performance of a task carried out in the public interest or for the
exercise of public authority vested in the Data Controller;
Processing is necessary for the purposes of the legitimate interest pursued by the Data Controller or by
a third party.
It is always possible to ask the Data Controller to clarify the concrete legal basis of each processing.
5. Place
Personal Data are processed in the operative offices of the Data Controller and in any other place in which
the parties involved in the Data processing are located. For further information, you may contact the Data
Controller at the following email address
6. Security of processing
The Data Processing is performed with adequate methods and tools to ensure the security and
con􀀞dentiality of the relevant Data, since the Data Controller has implemented appropriate technical and
organizational measures which ensure, in a provable way, that the performance of the Processing is compliant with the applicable law.
7. Period of storage of Data
The Data Controller shall store Personal Data for the time necessary to perform the purposes connected
with the performance of the agreement in force between the Data Controller and the User and, in any
case, Data shall not be stored beyond the duration of years 5 after the termination of the agreement with
the User.
When the Processing of Personal Data is necessary for the purposes of the legitimate interests pursued by
the Data Controller, Personal Data shall be stored until the performance of the relevant interest.
When the Processing of Personal Data is based on consent of the User, the Data Controller may store
Personal Data untile their withdrawal.
Personal Data may be stored for a longer period of time in order to perform a legal obligation or an order
of the public authority.
All Personal Data shall be deleted at the end of the period of storage. At the expiration of such period, the
rights of access, rectification, erasure and data portability of Data can not be exercised.
8. Automated individual decision-making
All collected Data shall not be subject to automated individual decision-making, including pro􀀞ling, which
may produce legal effects concerning the Data Subject or may significantly affect the Data Subject.
9. Rights of the User
The Users may exercise specific rights with respect to Personal Data processed by the Data Controller. In
particular, the User has the right to:
withdraw its consent at any time;
object the Processing of its Data;
access its Data;
monitor and request the rectification of Data;
obtain a restriction of Processing;
obtain the erasure or remotion of its Personal Data;
receive its Data or obtain the transfer to a different Data Controller;
lodge a complaint before the supervisory authority for the protection of personal data or start legal
In order to exercise their rights, the Users may send a request to the contact information of the Data
Controller indicated in this document. These requests are free of charge and performed by the Data
Controller in the shortest possible time, in any case no later than 30 days.
10. Data Controller
The Data Controller is Alberto Ciuccoli, Via delle Macere 20, 00060 Roma (Italia), Tax Code
CCCLRT70C31H501R, VAT Code 10835831008, e-mail;
Latest update: 25/05/2018