Policy on personal data processing based on REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 (GDPR)
This information notice concerns the website www.talentwolf.co (Website) and is provided by Talentwolf Pty Ltd, with registered office in Level 6, 261 George St SYDNEY NSW 2000, (Company), as Data Controller.
The Company shall process the personal data (e.g.: name and surname, address, telephone number, e-mail or other information related to you or your career) provided by you to enable you to register with the Website and make use of the services restricted to registered users.
If you provide your explicit consent, the Company shall process your personal data to send you promotional communications and/or newsletter regarding services offered for sale by the Company or by third parties.
Article 1. Purpose of the processing. Legal basis. Mandatory or optional nature of data provision and consequences of any refusal.
The Company shall process the personal data provided by you for the following purposes:
a. to enable you to register with the Website and make use of the services restricted to registered users and for administrative/accounting purposes. The legal basis for the processing is Company’s commitment to be compliance with a legal obligation or to take steps at the request of the data subject prior to entering into a contract, as the case may be;
b. if you provide your explicit consent, for the Company to send you newsletter and for market research purposes also aimed at evaluating the level of customer satisfaction and to send you promotional communications in relation to the services of the Company and / or third-parties, by email (marketing purposes); The legal basis for the processing is your consent;
c. in order to answer to your requests by email. The provision of data is purely optional. However, as the said processing is necessary in order to respond to your request, your refusal to provide the relevant data will prevent you from obtaining answer from the customer care of the Company. The legal basis for the processing is the Company's legitimate interest to perform these activities. This legitimate interest is equal to the user's interest to receive answer by the Company.
d. for the sending of automatic emails by the Data Controller if you activate your profile, if a new review is published on you by a user of the Site and if a chat message is written to you. The legal basis of the processing is the legitimate interest of the Data Controller in communicating to you the correct opening of your profile or the receipt of a review or a message addressed to you. This legitimate interest is equivalent to the user's interest in receiving communications sent by the Data Controller.
The provision of data for the purposes set out in Point a) is purely optional. However, as the said processing is necessary to register and manage your account, including access to and use of the Services offered on the Site, your refusal to provide the relevant data will make it impossible to register and manage your account.
Consent to marketing purposes is purely optional. Failure to consent will have the following consequences.
Failure to consent to the processing of personal data for marketing purposes will prevent you to receive promotional communication and newsletter regarding services of the Company and/or third-parties and will prevent the Company to carry out market research purposes aimed at evaluating the level of customer satisfaction.
It is understood that the Company may use your personal data to comply with legal obligations and to perform the purchase contract.
You may revoke your consent using the relevant link indicated in any promotional email sent by the Company.
Special Categories of Personal Data. Judicial Data.
The Company does not process special categories of personal data nor judicial data.
Recruiter Public Profile
You, as a user of the Site, can open a profile that can be traced back to a Recruiter. In this case, the Data Controller has the right to delete the content of your review if it finds a violation of the conditions of use of this Site. In any case, the Data Controller is not responsible for the personal data of the Recruiter processed by you in violation of the provisions of GDPR. Therefore, you undertake to indemnify and hold harmless the Data Controller harmless from any liability in this regard.
Otherwise, you may interact with the Site as Recruiter. In this case you will have the opportunity to make your profile public, through which users can view your personal data and publish reviews. You undertake to hold the Data Controller harmless from any damage or prejudice, even potential, that you may have suffered from the publication of personal data published on your profile and from the reviews made by users of the Site.
The Data Controller is not responsible and assumes no liability for the conduct on the Site or the use of the Talentwolf Service by users and other third parties, including any reviews and other content posted by users.
Article 2. Methods of Processing Personal Data
The processing of your personal data will be carried out by electronic or automated means, in the manner and with the appropriate tools to ensure the security and confidentiality in accordance with the GDPR.
The information and methods of processing will be relevant and not excessive in relation to the type of services provided. Data will be managed and protected in environments where access is under constant control.
Article 3. Data Disclosure
• to all those parties (including Public Authorities) that have access to the data by virtue of regulatory or administrative measures
• to companies, consultants or professionals in charge of the installation, maintenance, updating and the management of the Company's hardware and software or which the Company uses for the provision of its services
• to the companies that send the newsletters and/or other informative communications transmitted on behalf of the Company
• to the employees and/or collaborators of the Company
• to all those public and/or private parties, natural and/or legal persons (legal, administrative and tax consultancy firms), where the communication is necessary or of practical use for the correct fulfilment of contractual obligations undertaken in relation to the services provided through the Website, and of legal obligations.
Your data may be disclosed only in anonymous and aggregated form for statistical or research purposes.
Article 4. Data Controller
You can contact the Company, as Data Controller, at the following addresses:
Talentwolf Pty Ltd Level 6, 261 George St SYDNEY NSW 2000
By email, writing to: firstname.lastname@example.org
By selecting the contact form on the Website.
You may address requests relating to the processing of your personal data to both the Data Controller and the Data Protection Officer.
Article 5. Data Storage
Your personal data will be stored and processed for marketing purposes for 24 months. At the end of this period, the Company may ask you to renew your consent to the processing of your data or to make them anonymous and keep them only for statistical or historical purposes.
For all other purposes, personal data will be stored only as long as necessary to ensure the provision of the services offered.
If you close your account, your personal data will be stored for administrative purposes for a period not exceeding 90 days, without prejudice to any legal obligations regarding the storage of accounting documents or for public security purposes.
Article 6. Transfer of Personal Data to Third Countries
The Data Controller will transfer your personal data to the U.S.A.. With reference to this country, the European Commission has not established that the level of protection offered in terms of personal data protection is adequate. Therefore, you acknowledge that the transfer of personal data presents risks due to the lack of an adequacy decision by the European Commission and adequate guarantees. Therefore, you acknowledge and acknowledge that the transfer may in any case take place pursuant to art. 49 of GDPR as the transfer of your personal data may be necessary (i) for the execution of a contract concluded with the Data Controller or the execution of pre-contractual measures taken at your request; (ii) for the conclusion or execution of a contract concluded between the Data Controller and another natural or legal person in your favour.
Article 7. Rights of the Data Subject
Pursuant to GDPR (Article 13), you have the right to:
• request access to and rectification or erasure of personal data or restriction of processing or object to their processing, in addition to the right to data portability
• withdraw consent at any time without prejudice to the lawfulness of processing based on consent given prior to the withdrawal
• lodge a complaint before a supervisory authority (for instance, the Italian Data Protection Authority).
The above-mentioned rights may be exercised by making a request to at the contacts indicated above.
Article 8. Amendments