1. Definitions

Cookies, CRM, Personal Data, Form, Information, Cookies Information, Platform, Profiling, Regulation, Services, Site, Treatment, Users.

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1.1 Cookies

cookies are text files (letters and / or numbers) that contain information packets that are stored on the user’s computer or mobile device every time he or she visits a website through a browser. At each subsequent visit, the browser sends cookies to the website that originated them. Cookies can be stored only for the time of use of a specific site (i.e. session cookies) or for a longer period of time independent of the session (i.e. persistent cookies).

1.2 CRM

is the “Customer Relationship management” software, used by the Company to monitor the activity relating to the Services carried out in favor of Users and to send personalized commercial communications based on the type and reference market of the User.

1.3 Personal Data

any information relating to a natural person, identified or identifiable, directly and indirectly, by reference to the name, an identification number, location data, an online identifier or elements characteristic of his physical, physiological, genetic, psychological identity economic, cultural or social identity.

1.4 Form

are the forms on the Site and aimed, respectively, at allowing the User to: a) send a contact request; b) request the demo version of the Platform; c) become a partner of the Company.

1.5 Information

is this document, consisting of the information on the processing of Personal Data and the information on Cookies.

1.6 Cookies information

is the information relating to Cookies available on the Site.

1.7 Platform

is the “nCore HR” software which the Company licenses to its customers and through which it provides the Services.

1.8 Profiling

Personal Data Processing by evaluating the personal aspects of Users with the use of fully or partially automated procedures.

1.9 Regulations

EU Regulation 2016/679 of 27 April 2016.

1.10 Services

are the services provided by nCore to customers through the Platform.

1.11 Site

is this website.

1.12 Treatment

is any operation or set of operations concerning Personal Data, such as, by way of example, the collection, organization, structuring, storage, modification, extraction, consultation, use, communication, interconnection, limitation, cancellation and destruction.

1.13 Users

are the users of the Site.

2. Data Controller

nCore S.r.l., DPO: Gianluca Lombardi

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The Data Controller referred to in this Notice is nCore S.r.l. with registered office in Milan (MI), 20124, Via Vittor Pisani 15, Tax Code / VAT No. 10144420964 (“nCore” or “Company”). The data protection officer as contact person for the Data Controller is Dr Gianluca Lombardi with his contact e-mail: ncore@segnalazionidpo.it.

Any request from Users relating to the processing carried out by nCore concerning their Personal Data (including the exercise of the rights referred to in point 7 below) will be addressed to nCore by post at the registered office or by e-mail to the following address privacy@ncoreplat.com

3. Purpose and legal basis of the processing

  1. navigation on the Site: consent;
  2. management of contact requests: consent;
  3. management of requests relating to and sending of the demo version of the Platform: consent;
  4. management of requests from Users interested in becoming a partner of the Company: consent;
  5. sending communications and commercial and promotional initiatives through the use of a CRM: consent;
  6. improvement of the Site: legitimate interest.

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NCore collects and uses the Personal Data of Users for the achievement of the following purposes:

  1. To allow navigation on the Site, essentially through the use of Cookies.
    • The collection of Personal Data for the purposes referred to in letter a) is governed by the Cookies Policy, available at the following Cookie Policy link, which nCore recommends reading.
  2. To manage contact requests received on the Site by filling in the contact form by Users.
    • The collection of Personal Data for the purposes referred to in letter b) is necessary for the management of contact requests sent by the User. This processing is based on the free, specific, informed and unequivocal consent of the User, expressed by means of a declaration or positive action (eg flag) on ​​the Site. The withdrawal of consent can be exercised at any time, following the indications referred to in point 7 lett . a) of this Notice.
  3. To manage the requests relating to the receipt of the demo version of the Platform received by the Site by filling in the corresponding Form by the Users and sending the aforementioned demo version to the latter.
    • The collection of Personal Data for the purposes referred to in letter c) is necessary for managing the request to receive the demo version of the Platform and for sending the latter to the User. This processing is based on the free, specific, informed and unequivocal consent of the User, expressed by means of a declaration or positive action (eg flag) on ​​the Site. The withdrawal of consent can be exercised at any time, following the indications referred to in point 7 lett . a) of this Information.
  4. To manage requests for collaboration as a “partner” received on the Site by filling in the corresponding Form by Users.
    • The collection of Personal Data for the purposes referred to in letter d) is necessary for the management of requests from Users interested in becoming a partner of the Company and receiving any appropriate information in this regard from nCore. This processing is based on the free, specific, informed and unequivocal consent of the User, expressed by means of a declaration or positive action (eg flag) on ​​the Site. The withdrawal of consent can be exercised at any time, following the indications referred to in point 7 lett . a) of this Information.
  5. Subject to optional consent, to perform statistical analysis and market research, send information and advertising material based on the type and target market of the User, monitor the potential use of the Services by Users and verify the response to requests for sending the version demo of the Platform, also through the use of a CRM, but without Profiling activities by nCore.
    • The collection of Personal Data for the purposes referred to in letter e) is optional and any refusal by the User prevents the latter from receiving personalized commercial communications from nCore based on the type and reference market in which the ‘User operates himself. This processing is based on the free, specific, informed and unequivocal consent of the User, expressed by means of a declaration or positive action (eg flag) on ​​the Site. The withdrawal of consent can be exercised at any time, following the indications referred to in point 7 lett . a) of this Notice.
  6. To perform statistical analysis on the use of the Site to improve the Site. Where possible, to achieve this purpose nCore uses anonymous Personal Data (Personal Data that does not identify or make Users identifiable).
    • The processing referred to in letter f) is based on the legitimate interest of nCore consisting of the benefit that nCore can obtain from the improvement of the Site and from the offer of Services more relevant to the preferences expressed by Users while browsing the Site, which nCore believes to be prevalent with respect to the Users’ right to privacy. Opposition to this processing (if it does not have anonymous data) can be exercised at any time by following the indications in point 7 lett. g) of this Information.

4. Methods of data collection

  1. Personal Data collected automatically by the Site (through Cookies);
  2. Personal Data communicated to nCore by Users in online or offline mode.

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NCore collects Personal Data in the following ways:

  1. Personal Data collected automatically by the Site: Personal Data collected automatically by the Site through, but not limited to, Cookies (for more information, nCore recommends reading the Cookies Policy);
  2. Personal Data spontaneously communicated to nCore by Users in online or offline mode: these are Personal Data provided by Users by way of example to send contact requests by filling in the Forms or by e-mail or directly communicated to nCore employees and collaborators.

5. Any categories of recipients of the Personal Data

Employees and / or collaborators, third party IT service providers, technical and commercial third parties.

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Personal Data are processed by nCore and / or by third parties, selected for reliability and competence and to which they can be disclosed as necessary or appropriate, provided that they are within the European Union. In particular, nCore informs Users that Personal Data may be processed by, and / or communicated to:

  1. employees and / or collaborators of nCore;
  2. third party service providers necessary to guarantee the functioning of the Site (by way of example: company that deals with hosting services, IT technicians);
  3. third parties who provide website navigation data analysis services;
  4. subject to the optional consent of the User, third parties who provide automatic services for sending newsletters and / or any other type of commercial communication, marketing, promotion, analysis of habits and consumption choices.

6. Retention period of Personal Data (or criteria for determination)

  1. Cookies: see Cookies Policy;
  2. Personal Data collected for contact requests: 3 months from receipt of the request;
  3. Personal Data collected for sending the demo version of the Platform: 12 months from receipt of the request;
  4. Personal Data collected the management of the request to collaborate with the Company: 12 months from receipt of the request;
  5. Data for commercial purposes: 24 months from the last User interaction with the Company.

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Personal Data are kept by nCore for the period of time strictly necessary to achieve the purposes for which they were collected, as indicated in point 3 above. In particular, subject to the exercise of the right to revoke the consent referred to in the following point 7 lett. a) and the right to object as per point 7 lett. g), nCore retains Personal Data for the following terms of duration:

  1. Cookies: for the purposes referred to in point 3 letter a), it is recommended that you read the Cookies Policy;
  2. Personal Data spontaneously sent to nCore through the “Contacts” Form: for the purposes referred to in point 3 letter b), for the period of 3 months from receipt of the contact request, in order to verify if the User needs further assistance on the same theme. Notwithstanding this deadline, in the event of a complaint or complaint being sent via the “Contact” form, the User’s Personal Data will be kept for the period referred to in letter f) below;
  3. Personal Data spontaneously sent to nCore via the “Request demo” form: for the purposes referred to in point 3 letter c), for the period of 12 months from receipt of the request to send the demo version of the Platform, in order to allow nCore to customize the demo version for the User and to check if the User is interested in using the “full” version of the Platform;
  4. Personal Data spontaneously sent to nCore through the “Become a partner” form: for the purposes referred to in point 3 letter d), for the period of 12 months from receipt of the request by the User to become a partner of the Company, in order to allow nCore to provide further information about the User and to evaluate the possibility of cooperating with the User;
  5. Personal Data for commercial communications: for the purposes referred to in point 3 letter e), for a period of 24 months following the last interaction with nCore by the User, suitable for demonstrating an interest in receiving communications relating to the Company, such as the collection of consent, the request for the provision of Services or the compilation of one of the Forms;
  6. in any case, nCore is authorized to keep, in whole or in part, the Personal Data for a maximum period of 10 years from collection, limited to the information necessary to fulfill legal obligations and allow nCore itself to verify, exercise and defense of one’s own right in court.

Once these terms have elapsed, nCore will automatically cancel the Personal Data collected or transform them into an anonymous form in an irreversible manner.

7. Rights of Users

Withdrawal of consent, access to Personal Data, rectification or integration of Personal Data, cancellation of Personal Data, limitation of Processing, opposition to Processing, portability of Personal Data, data breach, complaint to the competent authorities

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Pursuant to and for the purposes of the Regulation, for the period referred to in point 6 of this Notice, each User has the right to:

  1. with reference to the Treatment referred to in point 3 lett. b), c), d) and e), withdraw consent at any time without prejudice to the lawfulness of the processing, by sending an e-mail to nCore, exercising the opt-out option (see art.7 of the Regulation);
  2. ask nCore for access to Personal Data and information relating to the related Processing and any copy in electronic format, unless otherwise specifically requested by Users (see Article 15 of the Regulations);
  3. request the correction and / or integration of Personal Data, without undue delay (see Article 16 of the Regulation);
  4. for specific reasons (for example, unlawful processing, withdrawal of consent, non-existence of the purpose of the processing), request the cancellation of Personal Data, without undue delay (see Article 17 of the Regulation);
  5. in case of specific hypotheses (for example inaccuracy of Personal Data, illegality of processing, exercise of a right in court), request the limitation of processing (Article 18 of the Regulation);
  6. receive the Personal Data concerning him in a structured, commonly used and readable format and, consequently, exercise the right of portability and transmit such data to another holder (Article 19 of the Regulation);
  7. with reference to the processing referred to in point 3 letter f) (if it does not concern anonymous data), oppose the processing of personal data at any time, by sending an e-mail to nCore (see art.21 of the Regulation);
  8. be informed by nCore without undue delay of any violations or unauthorized access by third parties to their systems containing Personal Data (so-called data breach – 34 of the Regulation);
  9. propose a complaint to the supervisory authority of the EU country in which he resides, works or where he believes the violation of his rights has occurred (see Article 77 of the Regulation).

For more information on the terms and conditions for exercising the rights recognized to Users, the latter can consult the text of the EU Regulation published at the following link https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016R0679&from=EN, or contact nCore in the manner provided for in point 2 of this Notice