The information and data which you may provide, or which may otherwise be collected in the context of your use of Frigel’s services (hereinafter, the "Services"), will be used by Frigel in compliance with the Regulation. This means, in particular, that any personal data processing carried out by Frigel will respect the principles of lawfulness, fairness, transparency, purpose limitation, storage limitation, data minimization, accuracy, integrity and confidentiality.
- Data controller
- Personal Data processed
- Browsing data
- Special categories of Personal Data
- Data provided voluntarily by the data subject
- Purpose of the processing
- Legal bases and mandatory / discretionary nature of the processing
- Recipients of Personal Data
- Transfers of Personal Data
- Retention of Personal Data
- Data subjects’ rights
1. Data Controller
As you use the Website, we inform you that Frigel may collect and process information related to you as an individual and which allows you to be identified (either directly, or together with additional information), or which is related to other individuals (“Personal Data”), such as your name, an identification number, an online ID or one or more characteristic elements of your physical, physiological, mental, economic, cultural or social identity.
Personal Data which may be processed by Frigel through the Website are as follows:
a. Browsing Data
The Website’s operation, as is standard with any website on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation. While Frigel does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information is also considered Personal Data.
This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on.
These data are used exclusively to compile anonymous, statistical information on the use of the Website, as well as to ensure its correct operation and identify any faults and/or abuse of the Website – the data is deleted immediately after processing, unless it must be used to identify responsible parties in the event of cybercrime committed which harms the Website or third parties, in which case information on web contacts may be kept for a period of 7 (seven) days.
b. Special categories of Personal Data
In the "Work with Us" section of the Website, you are allowed to submit Personal Data which may fall under the category of Personal Data referred to in Art. 9 of the Regulation – i.e. “[...] 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 a natural person's sex life or sexual orientation”.
While this should not prevent you from submitting your CV for a job application through the Website, Frigel asks that you do not disclose any such types of Personal Data, unless you consider this to be strictly necessary. Indeed Frigel remind you that if you disclose such special categories of Personal Data in absence of an explicit consent to process them, Frigel may not in any case be held liable and cannot receive complaints in this regard because in such case the processing is permitted as it is based on the fact that you have publicly disclosed this information, according to Art. 9(1)(e) of the Regulation.
In any case, Frigel would stress the importance of providing your explicit consent to process this sort of Personal Data, if you decide, nonetheless, to share it.
Please note that, for purposes of selection of an applicant to a certain position, Frigel may decide to analyse the professional social media profiles which you make freely available on the Internet (e.g. LinkedIn).
c. Data provided voluntarily by the data subject
When using some of the Website’s Services, you are allowed to submit Personal Data related to other persons.
In any situation where you decide to share Personal Data related to other persons through the Website, you will be considered as an independent data controller regarding that Personal Data, and must assume all inherent legal obligations and responsibilities. This means that you must also must make sure that you have these third parties’ consent to their Personal Data being used in this manner before providing them to Frigel or another appropriate legal basis which may allow for lawful processing of this information.
To this end, you must fully indemnify Frigel against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, initiated by the third parties whose information is processed via the Website by your initiative.
Definitions, characteristics and application of the legislation
Cookies are small text files that may be sent to and registered on your computer or mobile device by the websites you visit, to then be re-sent to those same sites when you visit them again. It is thanks to these cookies that those websites can “remember” your actions and preferences (e.g., login data, language, font size, other display settings, etc.), so that you do not need to configure them again when you next visit the website, or when you change pages within a website.
When browsing a website, you may also receive cookies from websites or web servers other than the website being visited (i.e., third-party cookies).
There are various types of cookies, depending on their characteristics and functions, which may be stored on your computer or mobile device for different periods of time: “session cookies”, which are automatically deleted when you close your browser, and “persistent cookies”, which will remain on your device until their pre-set expiration period passes.
According to the law which may be applicable to you, your consent may not always be necessary for cookies to be used through the Website. In particular, “technical cookies” – i.e. cookies used exclusively to transmit messages over an electronic communications network, or otherwise strictly necessary to provide a service specifically requested by you – typically do not require this consent. In other words, cookies which are indispensable for operation of the Website or required to perform activities you request may be used without your consent. This may include cookies used for analytics purposes (used to collect aggregated information on the number of users of a website, and how those users visit the website), browsing or session cookies (used to allow users to login) and function cookies (used to allow memorisation of choices made by a user when accessing the website, such as language or products selected for purchase, in order to improve the user’s experience).
On the other hand, “profiling cookies” – i.e., cookies used to create profiles on users and to send advertising messages in line with the preferences revealed by users while browsing websites – typically require specific consent from users, although this may vary according to the applicable law.
- Analytics cookies, when used directly by a website operator to collect information, in an aggregate form, on the number of users and how they use a website;
- Browsing or session cookies, to identify and authenticate users of a website;
- Function cookies, which allow users to browse a website according to a series of selected criteria (e.g., a certain language, products selected for purchase, etc.), in order to improve the services provided to those users.
On the other hand, "profiling cookies" – i.e., cookies used to create profiles on users and used to send advertising messages in line with the preferences revealed by users while browsing websites – require users’ prior consent.
- Types of cookies used by the Website
The Website uses the following types of cookies:
- Browsing or session cookies, which are strictly necessary for the Website’s operation and/or to allow you to use the Website’s content and services;
- Analytics cookies, which allow Frigel to understand how users make use of the Website, and to track traffic to and from the Website. The information collected by these cookies is processed in an aggregate and anonymous form, with no information on your specific ID being collected – therefore, the use of these cookies does not involve the use of your Personal Data.
- Function cookies, which are used to activate specific Website functions and to configure the Website according to your choices (e.g., language), in order to improve your experience;
CAUTION: If you block or delete technical and/or function cookies used by the Website, the Website may become impossible to browse, certain services or functions of the Website may become unavailable or other malfunctions may occur, in which case you will have to modify or manually enter some information or preferences every time you visit the Website
- Frigel also uses third-party cookies – i.e. cookies from websites / web servers other than the Website, and which are used for specific purposes of the third parties owning those websites / webservers (including profiling of users). These third parties will typically be considered independent data controllers regarding their cookies, and therefore you must refer to their privacy policies, information notices or other materials to obtain more information on them. Frigel cannot control or ascertain the use which may be made, by these third parties, of third-party cookies, nor their exact characteristics or purpose.
The following section lists the links to information on third-party cookies:
Cookies used by the Website are available at the following link: Cookies Policy
- Cookie settings
You can block or delete all or some of the cookies used on the Website via your browser options. Your cookie preferences will be reset if different browsers are used to access the Website. For more information on how to set the preferences for cookies via your browser, refer to the following instructions:
3. Purpose of the processing
Frigel intends to use your Personal Data, collected through the Website, for the following purposes:
- To provide Services you request (such as responding to any of your requests for assistance or information, subscription to newsletters etc.) and allow you to use the Website;
- To analyse CVs submitted through the Website, as well as to contact any candidates who submit their applications;
- For compliance with laws which impose upon Frigel the collection and/or further processing of certain kinds of Personal Data.
- Entities acting as data processors on Frigel’s behalf, in particular:
- Persons, companies or professional firms providing Frigel with advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services;
- Entities engaged in order to provide the Services (e.g., hosting providers or e-mail platform providers); and
- Persons authorised to perform technical maintenance (including maintenance of network equipment and electronic communications networks).
- Public entities, bodies or authorities to whom your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities;
- Persons authorised by Frigel to process Personal Data needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of Frigel)
2. Legal basis and mandatory / discretionary nature of the processing
Frigel’s legal bases to process your personal data, according to the purposes identified in Section 3, are as follows:
Section 3(a) and 3(b): processing for these purposes is necessary to provide the Services and, therefore, the applicable legal basis is the necessity of the processing for the performance of a contract with you, as well as to take steps at your request prior to entering into a contract with you – Art. 6(1)(b) of the Regulation. It is not mandatory for you to give Frigel your Personal Data for these purposes; however, if you do not, Frigel will not be able to provide any Services to you, nor will Frigel be able to answer any requests or assess any CVs you may submit. Specifically regarding Section 3(b), in particular as to Frigel’s analysis of professional social media profiles which you make freely available on the Internet, Frigel relies on Art. 6(1)(f) of the Regulation – i.e., the necessity of the processing for the purposes of Frigel’s legitimate interest in verifying whether there are any risks related to the candidate’s suitability for a given open position.
Section 3(c): processing for this purpose is necessary for Frigel to comply with its legal obligations and, therefore, the applicable legal basis is the necessity of the processing for compliance with the data controller’s legal obligations – Art. 6(1)(c) of the Regulation. When you provide any Personal Data to Frigel, Frigel must process it in accordance with the laws applicable to it, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations.
3. Recipients of Personal Data
Your Personal Data may be shared, for the purposes listed in Section 3, with different persons / entities (hereinafter and collectively, “Recipients”):
4. Transfers of Personal Data
Some of your Personal Data are shared with Recipients who may be located outside the European Economic Area. The Company ensures that your Personal Data are processed by these Recipients in accordance with the Regulation. Under the Regulation, these transfers can be based on an adequacy decision or on the Standard Contractual Clauses approved by the European Commission. Further information is available at the Company at the following address: [email protected]
5. Retention of Personal Data
Personal Data processed for the purposes set out in Section 3(a) will be kept by Frigel for the period deemed strictly necessary to fulfil such purposes – in any case, as these Personal Data are processed for the provision of the Services, Frigel will keep them for as long as the statute of limitations on liability related to the provision of the Services (as determined by the applicable law) lasts, so as to protect its interests.
Personal Data contained within CVs sent via the Website, as mentioned in Section 3(b), will be kept as long as the position for which the CV was sent remains open. As for spontaneous applications, this Personal Data may be kept for up to 1 (one) year. Frigel may contact candidates before the mentioned periods end, in order to request an extension of this retention period.
Personal Data processed for the purposes set out in Section 3(c) will be kept by Frigel for the period required by the specific legal obligation or by the applicable law.
For more information on Frigel’s Personal Data retention periods and the criteria adopted in determining these periods, please contact: [email protected]
6. Data subject rights
Under Articles 15 and following of the Regulation, you, as a data subject, are entitled to request from Frigel at any time, access to your Personal Data, the correction and erasure of your Personal Data, as well as to object to its processing. You are also entitled to request the restriction of the processing of your Personal Data in the cases set out in Article 18 of the Regulation, as well as to obtain the Personal Data you have provided to Frigel in a structured, commonly used and machine-readable format, in the cases set out in Article 20 of the Regulation.
Requests should be made in writing to Frigel at [email protected]
In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data, if you believe that the processing of your Personal Data carried out through this Website violates applicable law.