TIP srl, with registered office in Piazza Walter 22, 39100 Bolzano (hereinafter Topbooking), is constantly committed to protecting the online privacy of its users. This document was drawn up pursuant to art. 13 of EU Regulation 2016/679 (hereinafter: “Regulation”) in order to allow you to know our privacy policy, to understand how your personal information is managed when you use our website (hereinafter “Site“) and , where appropriate, to give express and informed consent to the processing of your personal data. (validly provided only by people over 16 years of age). The information and data provided by you or otherwise acquired as part of the use of our services on the site – hereinafter “Services” – will be processed in compliance with the provisions of the Regulation and the confidentiality obligations that inspire the activity. of the owner.

According to the rules of the Regulation, the processing carried out by Topbooking will be based on the principles of lawfulness, correctness, transparency, limitation of purposes and conservation, data minimization, accuracy, integrity and confidentiality.

Index

1. Data controller
2. The personal data being processed
   Browsing data
   Special categories of personal data
   Data provided voluntarily by the interested party
3. Purpose of the processing
4. Legal basis and mandatory or optional nature of the processing
5. Recipients of personal data
6. Transfers of personal data
7. Storage of personal data
8. Rights of the interested party
9. Changes

1. Data controller

The owner of the processing carried out through the Site is Easisoft SRL as defined above. For any information relating to the processing of personal data by the owner, including the list of data controllers who process data, you can write to the following address: info@topbooking.it

2. The personal data being processed

Following navigation of the Site, we inform you that the owner will process personal data which may consist of an identifier such as the name, an identification number, an online identifier, a postal address, an e-mail address, a telephone number ( fixed and/or mobile) or to one or more characteristic elements of your physical, physiological, psychological, economic, cultural or social identity suitable for making the interested party identified or identifiable (hereinafter only “Personal Data“).

The Personal Data processed through the Site are as follows:

a. Browsing data

The computer systems and software procedures used to operate the Site acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties, but which by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the Site, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user’s IT environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning, to identify anomalies and/or abuses, and are deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the site or third parties: except for this eventuality, the data collected by the site is currently removed within a short period of time.

b. Special categories of personal data

When using our Site (or sending via e-mail) for your application, there may be a provision of your Personal Data falling within the group of special categories of Personal Data referred to in art. 9 of the Regulation, literally “[…] personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as […] genetic data, biometric data intended to identify uniquely a natural person, data relating to the person’s health or sexual life or sexual orientation”. We invite you not to publish such data unless strictly necessary. Indeed, we remind you that in the event of the transmission of special categories of Personal Data, but in the absence of specific expression of consent each way are such data (an eventuality which obviously allows you to send a curriculum vitae), the owner cannot be held responsible in any way, nor will he be able to receive any complaints, since in this case the processing will be permitted as it concerns data returned manifestly public by the interested party, in compliance with the art. 9(1)(e) of the Regulation. However, we specify the importance, as already indicated above, of expressing explicit consent to the processing of special categories of Personal Data, should you decide to share such information.

We also inform you that, for selection purposes, the owner may analyze professional social profiles made freely available on the Internet (e.g. LinkedIn).

c. Data provided voluntarily by the interested party

When using some of the Site’s Services (for example the request/contact/booking form), the Personal Data of third parties sent by you to the owner may be processed. With respect to these hypotheses, you act as an independent data controller, assuming all legal obligations and responsibilities. In this sense, it grants the broadest indemnity on this point with respect to any dispute, claim, request for compensation for damage caused by treatment, etc. that should reach the owner from third parties whose Personal Data have been processed through their use of the Site’s functions in violation of the applicable personal data protection regulations. In any case, if it provides or otherwise processes the Personal Data of third parties when using the Site, it guarantees from now on – assuming all related responsibility – that this particular processing hypothesis is based on an appropriate legal basis pursuant to art. . 6 of the Regulation which legitimizes the processing of the information in question.

3. Purpose of the processing

The processing we intend to carry out, with your specific consent, where necessary, has the following purposes:

1. allow the provision of the Services requested by you;
2. respond to requests for assistance, information or reservations;
3. analyze CVs and contact the candidates who have sent their applications;
4. fulfill any legal, accounting and tax obligations.
5. marketing purposes: the data provided may be processed, subject to explicit and specific consent, for the sending of promotional and marketing communications, including the sending of newsletters and market research, through automated tools (sms, mms, e-mail , push notifications) and otherwise (paper mail, telephone with operator). The legal basis for the processing of your data for these purposes is art. 6, paragraph 1, letter. a) of the Regulation. Direct marketing treatment is optional and depends on your free choice; therefore failure to provide your consent for this purpose will not affect the use of the services.
6. marketing purposes with profiling: the data provided may be processed, subject to explicit and specific consent, for commercial profiling purposes and the formulation of personalized offers and targeted advertising, based on purchases made and/or browsing behavior and/or other consumption details and/or data provided when registering on the site and/or responses given to market surveys. Marketing processing with profiling is optional and depends on your free choice; therefore failure to provide your consent for this purpose will not affect the use of the services.

4. Legal basis and mandatory or optional nature of the processing

The legal basis for the processing of Personal Data for the purposes referred to in section 3 (a-b-c) is art. 6(1)(b) of the Regulation (execution of a contract) as the processing is necessary for the provision of the Services or for responding to requests from the interested party. The provision of Personal Data for these purposes is optional but failure to provide it would make it impossible to activate the Services provided by the Site, respond to requests or evaluate CVs. With specific reference to purpose 3.c and the related analysis of professional social profiles made freely available on the Internet referred to in section 2.b, the legal basis of the processing is art. 6(1)(f) of the Regulation, i.e. the legitimate interest of the owner in verifying any risks regarding the suitability of the candidate to cover the specific open position.

The purpose referred to in section 3.d represents legitimate processing of Personal Data pursuant to art. 6(1)(c) of the Regulation (complying with a legal obligation). Once the Personal Data has been provided, the processing is indeed necessary to fulfill a legal obligation to which the owner is subject.

The legal basis of the processing for the purposes referred to in section 3.e is art. 6(1)(a) of the Regulations (user consent). For treatments carried out for the same purposes that involve the direct sending of your own advertising or direct sales material or for carrying out your own market research or commercial communications in relation to the owner’s products or services similar to those purchased by you, the Owner may use , without your consent, the email and paper mail addresses, pursuant to and within the limits permitted by art. 130, paragraph 4 of the Code and the provision of the Guarantor Authority for the protection of personal data of 19 June 2008. The legal basis for the processing of your data for this purpose is art. 6(1)(f) of the Regulation (legitimate interest).

The legal basis of the processing for the purposes referred to in section 3.f is art. 6(1)(a) (user consent).

5. Recipients of personal data

Your Personal Data may be shared, for the purposes referred to in section 3 above, with:

1. subjects who typically act as data controllers, i.e.: i) people, companies or professional firms who provide assistance and consultancy to the owner in accounting, administrative, legal, tax, financial, debt collection, marketing and communication matters relating to the provision of the Services; ii) subjects with whom it is necessary to interact for the provision of the Services (for example hosting providers) iii) or subjects delegated to carry out technical maintenance activities (including maintenance of network equipment and electronic communications networks); (collectively “Recipients”);
2. subjects, bodies or authorities to whom it is mandatory to communicate your personal data pursuant to legal provisions or orders of the authorities;
3. persons authorized by the owner to process Personal Data necessary to carry out activities strictly related to the provision of the Services or to the other purposes referred to above in section 3, who are committed to confidentiality or have an adequate legal obligation of confidentiality (e.g. employees of the owner).

6. Transfers of personal data

Some of your Personal Data is shared with Recipients who may be located outside the European Economic Area. The owner ensures that the processing of his Personal Data by these Recipients takes place in compliance with the Regulation. Indeed, transfers can be based on an adequacy decision, on the Standard Contractual Clauses approved by the European Commission or on another suitable legal basis. Further information is available from the owner by writing to the following address: info@topbooking.it

7. Data retention

The Personal Data processed for the purposes referred to in section 3(a-b) will be kept for the time strictly necessary to achieve those same purposes. In any case, since these are treatments carried out for the provision of Services, the owner will process the Personal Data for up to the time permitted by Italian legislation to protect its interests (Art. 2946 of the Civil Code et seq.). With regard to CVs transmitted through the Site or via e-mail referred to in section 3.c, the Personal Data will be retained for a period deemed appropriate with respect to the purpose for which the data is acquired. This is without prejudice to the possibility for the owner to contact the candidate again shortly before the indicated deadline to request an extension of this retention period.

The Personal Data processed for the purposes referred to in section 3.d will be kept for the time required by the specific obligation or applicable law.

The Personal Data processed for the purposes referred to in sections 3.e and 3.f will instead be retained until the interested party revokes consent, or, in the absence of such revocation, for a maximum time deemed appropriate.

Further information regarding the data retention period and the criteria used to determine this period can be requested by writing to the owner at the following address: info@topbooking.it

8. Rights of interested parties

Pursuant to articles 15 and following of the Regulation, you have the right to ask the owner, at any time, access to your Personal Data, rectification or cancellation of the same or to oppose their

processing, you have the right to request the limitation of processing in the cases provided for by the art. 18 of the Regulation, as well as to obtain the data concerning you in a structured format, commonly used and readable by automatic device, in the cases provided for by the art. 20 of the Regulation.

Requests must be sent in writing to the owner at the following address: info@topbooking.it

In any case, you always have the right to lodge a complaint with the competent Supervisory Authority (Guarantor for the Protection of Personal Data), pursuant to art. 77 of the Regulation, if you believe that the processing of your Personal Data is contrary to the legislation in force.

9. Changes

This Privacy Policy is in force from 02/12/2018. The owner reserves the right to modify or simply update its content, in part or completely, also due to changes in applicable legislation. The content of the site and of this privacy policy may be subject to changes, therefore the Owner invites you to regularly visit this section to become aware of the most recent and updated version of the privacy policy in order to always be updated on the data collected and on the use that is made of it.

Information on the use of Cookies

This site uses cookies and allows the sending of third-party cookies (Google Analytics), which are necessary for its operation and to improve the service offered.

If you want to know more about what cookies are and what they are used for, visit the cookies policy page. By closing this banner, scrolling the page, continuing browsing, the user accepts the use of cookies.