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PRIVACY AGREEMENT

GENERAL INFORMATION

Michele Bottiglieri Armatore S.p.A is committed to protecting your privacy and treating your data in a clear and transparent manner. We invite you to read this information, prepared in accordance with current regulations on the protection of personal data (EU Regulation 2016/679 - GDPR), to understand how your personal data is processed while navigating the Michele Bottiglieri Armatore S.p.A website.

The document provides details about the nature of personal data collected by Michele Bottiglieri Armatore S.p.A, the purposes of processing, user rights regarding the processed data, and the contacts to obtain more information or make requests.

Michele Bottiglieri Armatore S.p.A may provide specific privacy information that you are encouraged to consult, related to certain services or within the scope of personal data collection forms (such as when submitting job applications for positions posted on the Miboship website).

Our company is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to sell our products and services. Your data may be stored through Wix.com's data storage, databases, and general Wix.com applications. Your data is stored on secure servers, protected by firewalls.

PRIVACY NOTICE ACCORDING TO ARTICLE 13 OF THE EUROPEAN REGULATION (EU) 2016/679

In accordance with Article 13 of the European Regulation (EU) 679/2016 regarding the protection of personal data (hereinafter, the "Regulation"), and national regulations (Legislative Decree 196/2003 – Privacy Code as amended by Legislative Decree 101/2018 and subsequent amendments), including individual measures of the supervisory authority (Italian Data Protection Authority), where applicable, we inform you that the personal data provided by you following the submission of your application in response to job postings on our network will be processed in compliance with the current legislative and contractual provisions for the purposes and in the manner indicated below.

For the "processing" of personal data, it means any operation or set of operations, carried out with or without the use of automated processes and applied to your personal data, such as collection, recording, organization, structuring, storage, adaptation, or alteration, retrieval, consultation, use, communication by transmission, dissemination, or any other form of making available, comparison or interconnection, restriction, erasure, or destruction.

1 - Data Controller and Data Protection Officer​

The data controller for your personal data is MICHELE BOTTIGLIERI ARMATORE S.p.A., with registered office in Italy, Piazza Giovanni Bovio no.22, 80133 - Naples, with tax code and VAT number 06044931217, registered with the Companies Register of Naples, REA 791682 (hereinafter also "MBA").

2 - Nature of processed data, purposes, and legal basis of processing

The processing concerns your personal data - where personal data means any information related to you as a natural person, identified or identifiable even indirectly by reference to any other information in our possession ("Data Subject") - provided to Michele Bottiglieri Armatore S.p.A. during the application process for available positions within Michele Bottiglieri Armatore S.p.A. The data includes personal details (name, surname, gender, date of birth, nationality, address, phone number, email), education-related data, professional experiences, and information on computer and language skills, provided through personal data forms, CVs, and additional documents, if any.

During the application process, you may be asked to indicate your membership in a protected category, meaning individuals eligible for employment based on a disability. This information constitutes data suitable for revealing your health status and falls within the special categories of personal data.

Special categories of personal data also include those related to the sex life, sexual orientation, racial and ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, as well as genetic and biometric data intended to uniquely identify a person.

Except for indicating your membership in a protected category, Michele Bottiglieri Armatore S.p.A. does not process such types of personal data.

The processing of your personal data during the application process has the following purposes: i) recruitment and selection of personnel for positions within Michele Bottiglieri Armatore S.p.A.; ii) management of applications to establish a possible employment relationship; iii) compliance with legal obligations, regulations, and community legislation, in particular, obligations under the National Collective Bargaining Agreement (CCNL) and applicable collective agreements concerning the establishment of the employment relationship; iv) compliance with requests from Authorities, Bodies, and Public Organizations and related measures; v) exercise of rights in judicial proceedings.

The processing of your personal data provided during the spontaneous submission of your application and those included in the transmitted CV does not require your consent under Article 111 bis of the Privacy Code and is carried out by Michele Bottiglieri Armatore S.p.A. to perform pre-contractual measures, upon your request, necessary for the establishment of a potential employment relationship (Article 6.2, letter b of the Regulation).

Similarly, the processing of your personal data regarding your membership in a protected category is carried out by Michele Bottiglieri Armatore S.p.A. to fulfill specific obligations under community and national regulations, regulations, or collective agreements related to labor law, including the protection of disabled workers, safety, and social protection (Article 9.2, letter b of the Regulation).

The legal basis for the processing of your data for purposes i), ii) is the execution of pre-contractual measures taken at your request, for purposes iii), iv) it is the fulfillment of legal obligations, and for purpose v) it is the legitimate interest of the data controller.

3 - Mandatory/Optional nature of data provision​

The provision of your personal data for the above purposes is necessary to carry out activities related to personnel selection and to fulfill legal obligations. Your refusal to provide personal data will make it impossible to submit your application in response to job postings.

4 - Processing methods

Your data will be processed by Michele Bottiglieri Armatore S.p.A. in accordance with the aforementioned regulations, using electronic and manual tools, ensuring the use of suitable measures for the security of processed data and guaranteeing their confidentiality, in accordance with the principles applicable to the processing of personal data under Article 5 of the Regulation, such as lawfulness, fairness, and transparency, data minimization, accuracy, limitation of storage, integrity, and confidentiality.

5 - Duration of processing

The personal data you have provided to Michele Bottiglieri Armatore S.p.A. will be kept for the period necessary to make appropriate assessments regarding the hiring needs and in any case, not beyond 1 year from the date of receipt of your data, within which Michele Bottiglieri Armatore S.p.A. reserves the right to contact you for a possible position within Michele Bottiglieri Armatore S.p.A., subject to what is provided regarding the right to erasure.

6 - Communication and transfer of data

Your data may be communicated to the following categories of recipients, after appropriate appointment as Data Processors or, otherwise, following the recognition of independent data controller status:

  • Third parties supporting Michele Bottiglieri Armatore S.p.A. in personnel selection activities;

  • Service companies entrusted with the management of information systems;

  • Competent authorities (including Courts), for the exercise of their institutional functions within the limits established by law or regulations.

Personal data will be processed by employees and/or collaborators of Michele Bottiglieri Armatore S.p.A. within their respective functions and in accordance with the instructions given by Michele Bottiglieri Armatore S.p.A.

The collected personal data will not be transferred outside the European Union.

7- Rights of the data subject

You, as the data subject, are entitled to the rights under Articles 15-21 of the Regulation, compatibly with the processing needs indicated in this notice and in relation to the described data processing, in particular:

  • Receive confirmation of the existence of your personal data, access their content, and receive information regarding the purposes of processing (right of access);

  • Update, modify, and/or correct your personal data (right of rectification);

  • Request their deletion or restriction of the processing of data processed unlawfully and those for which retention is not necessary in relation to the purposes for which the data was collected or otherwise processed, in case of objection to processing (right to erasure and right to restriction);

  • Object to processing (right to object) at any time;

  • Withdraw consent, if given, without prejudice to the lawfulness of processing based on consent before withdrawal;

  • Receive a copy of the data concerning you in electronic format and request that such data be transmitted to another data controller (right to data portability).

To exercise these rights, you can contact the competent Data Protection Officer as identified in this notice by sending a communication to the relevant email address.

We also inform you that you have the right to lodge a complaint with the Italian Data Protection Authority or to bring a legal action before the judicial authority.

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