Circle Brain srl recognizes the importance of personal data protection, undertakes to respect the privacy of users, to treat private data with caution and confidentiality and not to use them for purposes other than those specified below.

To this end, this policy describes how to manage the site with reference to the processing of personal data of users who consult it.

This information is provided, also pursuant to Article 13 of EU Regulation 679/2016, to those who interact with the web services www.circlebrain.com

This Policy may be modified or updated at any time and is provided only for this site and not for other websites that may be consulted by the user via links except for those indicated above.

Data controller

The Data Controller is: Circle Brain srl (hereinafter also “Circle Brain”), also in charge of managing the data provided on the pages of this site.

Data Protection Officer

Circle Brain has appointed a Personal Data Protection Officer who can be contacted at info@circlebrain.com

Data and purpose of the treatment

Circle Brain informs users of the site that the data collected will be used exclusively for the purposes specified below. The data being processed are navigation data and data voluntarily provided by the user.

1. Navigation data

The computer systems used to operate the website acquire some data necessary for the operation of the platform and information whose transmission is implicit in the protocols used for internet connection and navigation.

Some information relating to the browser session and general data relating to the device used by the user are also acquired. All data is acquired anonymously and cannot, in any case, be traced back to a specific user or for profiling purposes.

2. Data provided voluntarily by the user

In order to access some services on the website, the user provides Circle Brain with various types of data spontaneously after having read this information and possibly consenting to the processing for one or more of the purposes envisaged and listed below.

Circle Brain will use the collected data to:

1. purposes related to the use of the services offered by the site (site navigation);
2. activities strictly connected and instrumental to the management of relations with customers and potential collaborators (contact requests);
3. sending newsletters;
4. process data relating to curricula for the evaluation of job applications.

The provision of data for the purposes referred to in letters c) and d) is optional and must be provided in the manner expressly provided for by article 7 of the GDPR, directly from the website.

Methods of treatment

Data processing will be carried out in accordance with Art. 4 no. 2) of the GDPR, by means of the following operations: collection, registration, organization, conservation, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data.

The data will be subjected to both paper and electronic and/or automated processing.

The data, starting from their receipt/update, will be kept for a period congruous with respect to the purposes of the processing indicated above. In particular, the CVs relating to job applications will be kept for a maximum period of 24 months from receipt; the newsletter service will be guaranteed until the opt-out is exercised by the data subject. For more information on data retention terms, you can write to info@circlebrain.com

Data communication and transfer

The data being processed will not be disclosed; however, for the purposes indicated in this disclosure, they may be communicated to third parties, including partners, consultants and freelancers, banks and credit institutions, insurance companies, finance companies, service companies, credit management and recovery companies, auditors of accounts, public bodies, auditing or supervisory bodies, to fulfill obligations deriving from the law, regulations, community regulations or for aspects concerning the management and execution of the legal relationship with you.

The data will be processed by the following subjects:

• Employees who operate as persons authorized to process data according to the duties performed and adequately trained.
• External Managers pursuant to Article 28 of the GDPR.

Rights of the interested party

It should be noted that as an interested party, at any time you may ask:

1. access to personal data;
2. their rectification in case of inaccuracy;
3. cancellation;
4. the limitation of the treatment;
5. the right to object to data processing where the conditions are met;
6. the right to data portability, i.e. to receive the personal data provided in a structured format that is commonly used and readable by an automatic device.

For anything not expressly provided for by the provisions referred to herein, please refer in full to the legislation in force on the subject of Privacy and specifically to the articles 15, 16, 17, 18, 20 and 21 of the GDPR.

Withdrawal of consent

The consent may be revoked at any time, without however this being able to:

• jeopardize the lawfulness of the treatment based on the consent given before the revocation;
• prejudice further processing of the same data based on other legal bases such as contractual or legal obligations.

For further clarifications on this information or on any privacy issue, or if you wish to exercise the rights mentioned above or withdraw your consent, you can write to info@circlebrain.com

Data Controller

Circle Brain srl

Largo Gallarati Scotti, 1 – Milano

P.IVA 11718870964

Owner’s email address: info@circlebrain.com

Data Protection Officer

Email address of the Data Protection Officer: info@circlebrain.com