Policies

Privacy Policy

1. Definitions

Applications, Cookies, Personal Data, Events, Disclosure, Cookie Disclosure, Jobs Disclosure, Regulation, Services, Website, Processing, Users.

1.1 Job Applications

Applications sent by users in response to employment openings published by Simmetrico or spontaneously to offer availability for an interview aimed at establishing a working relationship with Simmetrico.

1.2 Cookies

Cookies are text files (letters and/or numbers) that contain packages of information that are stored on the user’s computer or mobile device whenever he/she visits a website through a browser. At each subsequent visit, the browser sends cookies to the website that originated them. Cookies can be stored only for the time of use of a particular website (session cookies), or for a longer period of time independent of the session (persistent cookies).

1.3 Personal Data

Any information relating to a natural person that is directly and indirectly identified or identifiable by reference to a name, identification number, location data, an online identifier or elements characteristic of his/her physical, physiological, genetic, psychic, economic, cultural or social identity.

1.4 Events

Events: events created and/or managed by Simmetrico on its own behalf or on behalf of its customers.

1.5 Disclosure

This document, consisting of the disclosure on the processing of Personal Data, the disclosure on Cookies and the Disclosure on Job Applications.

1.6 Cookie Disclosure

Disclosure relating to Cookies available on the Website;

1.7 Jobs Disclosure

Disclosure on the processing of personal data collected when job applications are submitted by users through the «Jobs» form on the Website.

1.8 Profiling

Personal Data Processing through the evaluation of personal aspects of Users with the use of fully or partially automated procedures.

1.9 Regulation

EU Regulation 2016/679 of 27 April 2016.

1.10 Services

Design, implementation and management of projects in museums, exhibition pavilions and event planning.

1.11 Website

This Internet site.

1.12 Processing

Any operation or set of operations concerning the Personal Data, such as the collection, organization, structuring, preservation, modification, extraction, consultation, use, communication, interconnection, limitation, cancellation and destruction.

1.13 Users

Users of the Website.

2. Data controller

Simmetrico S.r.l.

The Data Controller referred to in this Disclosure is Simmetrico S.r.l., with registered office in Milan (MI), 20144, Via Vincenzo Forcella no. 13, Tax Code/VAT number 05682780969 («Simmetrico»).
Any request of Users concerning the processing activities performed by Simmetrico on their Personal Data (including the exercise of the rights referred to in point 7) shall be communicated to Simmetrico by post at its registered office, or by e-mail to amministrazione@simmetrico.it.

3. Purposes and legal grounds for processing

Simmetrico collects and uses the Personal Data of Users for the following purposes:

a) Browsing the Website: consent;

To allow browsing on the Website, for which the use of Cookies is required. The collection of Personal Data for the purposes referred to in letter (a) is governed by the Cookie Disclosure, available at the following link (Simmetrico recommends its reading).

b) Analysis and response to contact requests: legitimate interest of Simmetrico;

Manage contact requests received from the Website through e-mail spontaneously sent by the User to the address provided by Simmetrico for such purpose. The collection of Personal Data for the purposes referred to in letter (b) is based on the legitimate interest of Simmetrico, consisting of the benefit that Simmetrico can obtain from the management of contact and/or assistance requests spontaneously sent by Users as regards the Services, which Simmetrico believes to be prevalent with respect to the right to privacy of the Users themselves. Opposition to this processing can be exercised at any time by following the indications in point 7(g) of this Disclosure.

c) Analysis and feedback to Job Applications: consent

With previous optional consent, receipt and reply to the Employment Submissions sent by Users.
The collection of Personal Data for the purposes referred to in letter (a) is governed by the Jobs Disclosure, available at the following link (Simmetrico recommends its reading).

d) Sending of commercial and promotional communications by Simmetrico: consent

With previous optional consent, to perform statistical analysis and market research, send informative and advertising material, report on and send invitations to Events, without any profiling by Simmetrico.
The collection of Personal Data for the purposes referred to in letter (d) is optional; refusal by the User prevents the latter from receiving newsletters from Simmetrico. This processing activity is based on the free, specific, informed and unequivocal consent of the User, expressed through a declaration or positive action (e.g. flag) on the Website. The withdrawal of consent can be exercised at any time by following the indications in point 7(a) of this Disclosure.

e) Improvement of the Website: legitimate interest.

Perform statistical analysis on the use of the Website, to improve the Website, without any profiling activity by Simmetrico. Where possible, to achieve this purpose, Simmetrico uses Anonymous Personal Data (Personal Data that does not identify or make Users identifiable).

The processing activity referred to in letter (e) is based on the legitimate interest of Simmetrico, consisting of the benefit that the Company can obtain from having a Website that facilitates navigation and enhances the User experience, which Simmetrico considers a prevailing right over the right to privacy of Users. Opposition to this processing (if it does not concern anonymous data) can be exercised at any time by following the indications in point 7(g) of this Disclosure.

f) Collection of personal images for Events: consent.

With previous optional consent, the collection of personal images to Events.

The collection of Personal Data for the purposes referred to in letter (f) is optional; any refusal by the User prevents the latter from being filmed/photographed in the foreground or being recognizable in photographic material or videos of Events organized by Simmetrico. This processing activity is based on the free, specific, informed and unequivocal consent of the User, expressed through a declaration on a specific form that will be provided by Simmetrico to the Event together with any disclosure on additional processing activities with respect to this Disclosure. The withdrawal of consent can be exercised at any time by following the indications in point 7(a) of this Disclosure.

4. Data collection method

Simmetrico collects Personal Data in the following ways:

a) Personal Data collected automatically by the Website (via Cookies);

Personal Data collected automatically by the Website: Personal Data collected automatically by the Website through, but not limited to, Cookies (for further information, Simmetrico recommends reading the Cookie Disclosure);

b) Personal Data communicated online and offline to Simmetrico by Users;

Personal Data spontaneously communicated online and offline to Simmetrico by Users: these are the Personal Data provided by Users such as to send contact requests or Job Applications to Simmetrico by e-mail, or directly communicated to Simmetrico employees and collaborators;

c) Personal Data collected during the Events.

Personal Data collected during Events: Personal Data provided by Users during the participation in Events, inclusive of the personal image of the User.

5. Potential categories of recipients of Personal Data

Personal Data are processed by Simmetrico and/or third parties selected for their reliability and competence, to which such data may be disclosed as necessary or appropriate, provided that they are within the European Union. Simmetrico informs Users that Personal Data may be processed by and/or communicated to:

a) Employees and/or collaborators

Employees and/or collaborators of Simmetrico;

b) Third-party IT service providers

Third party suppliers of services required to guarantee the functioning of the Website (such as a company that provides hosting services, IT technicians); third parties who provide services for analyzing the navigation data of the Website;

c) group companies

Companies of the group of which Simmetrico is a part;

d) Customers

Simmetrico customers for whom Simmetrico organizes and manages Events;

e) Technical and commercial third parties.

Subject to the optional consent of the User, third parties providing automatic services for sending newsletters and/or any other type of commercial communication, marketing services, promotion, analysis of habits and consumption choices; with previous optional consent by the User, to third parties involved in the organization and management of Events (such as photographers, security services).

6. Retention period of Personal Data (or criteria for its determination)

Personal Data are kept by Simmetrico for the period of time strictly necessary for the achievement of the purposes for which they were collected, as indicated in point 3 above. Except for exercise of the right to revoke consent as referred to in point 7(a) and the right of opposition referred to in point 7(g), Simmetrico retains Personal Data for the following term:

a) Cookies: see the Cookie Disclosure;

Cookies: for the purposes referred to in point 3(a), we recommend reading the Cookie Disclosure;

b) Personal Data collected for contact requests: 3 months from receipt of the request

Personal Data spontaneously sent to Simmetrico for contact requests: for the purposes referred to in point 3(b), for a period of 3 months from receipt of the contact request, in order to verify whether the User requires further assistance on the matter in question. By way of derogation from this deadline, if a complaint or claim is sent via the contact form, the Personal Data of the User will be retained for the period referred to in letter (d);

c) Personal Data collected for Employment Applications: see the Jobs Disclosure

Personal Data spontaneously sent to Simmetrico for Job Applications: for the purposes referred to in point 3(c), it is recommended to read the Jobs Disclosure;

d) Data for commercial purposes: 24 months from the last interaction of the User with the Company.

Personal Data for commercial communications: for the purposes referred to in point 3(c), for a period of 24 months following the last interaction with Simmetrico by the User that demonstrates interest in receiving communications relating to the Company, such as the collection of consent, participation in Events, or sending contact requests. Simmetrico is authorized to keep Personal Data in whole or in part for a maximum period of 10 years from its collection, limited to the information necessary to comply with legal obligations and allow Simmetrico to investigate, exercise and defend its right in court.

7. Rights of the User

Pursuant to and for the purposes of the Regulation, for the period referred to in paragraph 6 of this Disclosure, each User has the right to:

a) Withdrawal of consent

With reference to the processing activity referred to in point 3(c), (d), and (f), withdraw consent at any time without prejudice to the lawfulness of the Processing, by sending an e-mail to Simmetrico and exercising the opt out option (see Article 7 of the Regulation);

b) access to Personal Data

Ask Simmetrico to access the Personal Data and related processing information and any copy in electronic format, unless specifically requested otherwise by Users (see Article 15 of the Regulation);

c) Correction or integration of Personal Data

Request the rectification and/or integration of Personal Data without undue delay (see Article 16 of the Regulation);

d) Cancellation of Personal Data

Request the cancellation of Personal Data for specific reasons (such as unlawful processing, withdrawal of consent, non-existence of the processing purpose), without unjustified delay (see Article 17 of the Regulation);

e) Limitation of processing activities,

Request the limitation of processing in using specific assumptions (such as the inaccuracy of personal data, unlawful processing, exercise of a right in court) (Article 18 of the Regulation);

f) Portability of Personal Data

Receive the Personal Data relating to him/her in a structured, common and readable format, and consequently exercise the right of portability and send such data to another data controller (Article 19 of the Regulations);

g) Opposition of processing activities

With reference to the processing activities referred to in point 3(b), (d) (if it does not concern anonymous data) and (e), to object to the processing of personal data at any time by sending an e-mail to Simmetrico (see Article 21 of the Regulation);

h) data breach

Be informed by Simmetrico without unjustified delay of any violations or unauthorized access by third parties to their systems containing the Personal Data (data breach — Article 34 of the Regulation);

i) complaint to the competent authorities

File a complaint with the supervisory authority of the EU country in which he/she resides, works or in which the violation of rights is believed to have occurred (see Article 77 of the Regulation);

Jobs Policy

1) Definitions

1.1 Applicants:

individuals who, personally or in the name and behalf of their company, apply voluntarily and spontaneously to a Job Offer, or spontaneously contact Simmetrico to offer their availability for an interview for the purpose of establishing a Job Relationship.

1.2 Company Profile:

cover letter and/or brochure regarding the Applicant’s company sent to Simmetrico.

1.3 Curriculum Vitae:

the curriculum vitae together with any cover letter presented and/or sent to Simmetrico by the Applicant or a third party authorized by the latter.

1.4 Data Processors:

third parties that carry out processing activities and have sufficient guarantees to implement adequate technical and organizational security measures, as appointed by Simmetrico pursuant to Article 28 of the GDPR.

1.5 GDPR:

EU Regulation 2016/679 of 27 April 2016.

1.6 Jobs Policy:

this document provided pursuant to the GDPR.

1.7 Job Offer:

announcement of a job proposal and/or collaboration published by Simmetrico.

1.8 Job Relationship:

the relationship of employment and/or supply of services and/or collaboration established between Simmetrico and the Applicant (personally or by means of its company) following the positive outcome of the selection process.

1.8 Job Relationship:

the relationship of employment and/or supply of services and/or collaboration established between Simmetrico and the Applicant (personally or by means of its company) following the positive outcome of the selection process.

1.9 Personal Data:

any information relating to a natural person that is directly and indirectly identified or identifiable by reference to a name, identification number, location data, an online identifier or elements characteristic of his/her physical, physiological, genetic, psychic, economic, cultural or social identity.

1.10 Processing:

any operation or set of operations concerning Personal Data, such as the collection, organization, structuring, preservation, modification, extraction, consultation, use, communication, interconnection, limitation, cancellation and destruction.

1.11 Sensitive Data:

special categories of personal data pursuant to Articles 9 and 10 of the GDPR, which may reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership and/or data relating to health, criminal convictions or offenses, as spontaneously communicated and/or entered in by the Applicant or detectable in the Curriculum Vitae or Company Profile.

2) Data controller

The Data Controller referred to in this Jobs Policy is Simmetrico S.r.l., with registered office in Milan (MI), 20144, Via Vincenzo Forcella no. 13, Tax Code/VAT number 05682780969 («Simmetrico«).

Any request by the Applicants concerning the Processing performed by Simmetrico on their Personal and/or Sensitive Data (including the exercise of the rights referred to in point 7) shall be communicated to Simmetrico by mail at its registered office, or by e-mail to amministrazione@simmetrico.it.

3) Type of Personal Data, collection and processing methods

Simmetrico collects the Personal and Sensitive Data of Applicants in the following ways: Simmetrico collects the Personal and Sensitive Data of Applicants in the following ways:

a) Personal Data and Sensitive Data provided and/or expressly communicated by each Applicant to Simmetrico are: the Personal and/or Sensitive Data of each Applicant (and/or his/her family member) as directly and spontaneously provided to Simmetrico.

b) Personal Data available from public sources are: the Personal Data of each Applicant available from sources accessible to the public and shared by the Applicant, e.g. through Internet sites.

c) Personal Data and Sensitive Data provided by organizations or third parties involved in the Job Offer selection are: the Personal and Sensitive Data of each Applicant provided by temporary employment agencies.

Simmetrico processes Personal and Sensitive Data with both analogue and telematic means. The communication of Sensitive Data is not required for the purpose of applying to a Job Offer and/or when spontaneous sending a Curriculum Vitae or a Company Profile to Simmetrico. Any Sensitive Data provided spontaneously by Applicants of which Simmetrico should become aware will not be considered by Simmetrico for the purposes of evaluation of the Applicant and the potential establishment of the Job Relationship, without prejudice to the need for Simmetrico to collect the explicit consent of the Applicant in order to carry on such activities.

4) Purposes and legal grounds for the Processing

a) Personal Data: Simmetrico collects and uses the Personal Data of Applicants to carry on the recruitment of Applicants. The collection of Personal Data for this purpose is necessary for the proper performance by Simmetrico of the Applicants’ selection process. The consent of the Applicant to the Processing of Personal Data referred to in letter (a) is not required, as the processing activity is based on the exemption provided by Article 111 bis of the Italian Privacy Code (i.e. Legislative Decree No. 196/2003, as last amended by Legislative Decree No. 101/2018) for spontaneous applications sent by the data subject involved in the Processing.

b) Sensitive Data: even if Simmetrico is not interested and does not take into account any Sensitive Data of Applicants for the purposes of carrying on the selection process aimed to the potential establishment of the Job Relationship, Simmetrico collects and stores any Sensitive Data of the Applicant, which are spontaneously provided by the latter in the Curriculum Vitae or in the Company Profile, solely for the purposes necessary to not prejudice/limit the possibility for the Applicant to participate in the selection process (that would be the consequence in case of impossibility to use the Curriculum Vitae or the Company Profile containing Sensitive Data). Except in the event that the Processing of Sensitive Data of the Applicant is necessary to fulfill obligations in the field of labor law, social security or social protection pursuant to Article 9, paragraph 2(b) of the GDPR, this Processing is based on the explicit consent as freely given by the Applicant pursuant to Article 9, paragraph 2(a) of the GDPR by an express declaration (checking a I agree/I do not agree box) or, if applicable, signing this Jobs Policy.

5) Potential categories of recipients of Personal Data

Within the scope of the purposes indicated in the point 4, Personal and/or Sensitive Data are processed by Simmetrico and/or third parties selected for their reliability and competence, to which such data may be disclosed as necessary or appropriate, provided that they are within the European Union. Simmetrico informs the Applicants that Personal and/or Sensitive Data may be processed by and/or communicated to:

a) employees and/or collaborators of Simmetrico in charge of managing the recruitment of Applicants;

b) third party consultants to enable the establishment of the Job Relationship, such as tax and labor consultants who are appointed as Data Processors.

The Personal and/or Sensitive Data of the Applicants will not be disclosed to the public by Simmetrico.

6) Retention period of Personal Data (or criteria for its determination)

Personal and/or Sensitive Data are kept by Simmetrico for the period of time strictly necessary for the achievement of the purposes for which they were collected, as indicated in point 4 above. Simmetrico retains the Personal and Sensitive Data of the Applicants for the following periods of time, which vary depending on whether the Job Relationship is established or not:

a) in the event of the establishment of the Job Relationship, for the duration of the Job Relationship itself and for 10 years following termination of the Job Relationship for any cause or reason;

b) in the event of failure to establish the Job Relationship, for 24 months from the conclusion of the selection procedure for which the Applicant has sent his/her Curriculum Vitae or his/her Company Profile, or from the receipt by Simmetrico of the spontaneous job offer.

In order to allow Simmetrico to fulfill administrative, contributory, social security, insurance and tax obligations and any verification, exercise and defense of its own rights, even in a court of law, Simmetrico is authorized to keep Personal and Sensitive Data in full or in part for a period of 10 (ten) years from its collection, or for a longer period if the fulfillment of such legal obligations or a dispute requires a longer term. Personal and Sensitive Data will be stored until the complete fulfillment of the obligations after the relative prescription period and/or until the conclusion of the legal case with a final judgment, and/or expiry of the term for any additional appeal (before Court of appeal or Court of Cassation).

Once these terms have elapsed, Simmetrico will automatically delete the Personal and/or Sensitive Data collected or provide for their irreversible transformation into an anonymous form.

7) Rights of the Applicant

Pursuant to and for the purposes of the GDPR, for the period referred to in paragraph 6 of this Jobs Policy, each Applicant has the right to:

a) with reference to the Processing Activities referred to in point 4(a) and (b), revoke consent at any time without jeopardizing the lawfulness of the Processing performed previously, by sending an e-mail to Simmetrico to: amministrazione@simmetrico.it (see Article 7 of the GDPR);

b) ask Simmetrico to access the Personal Data, Sensitive Data, and related Processing information and any copy in electronic format, unless specifically requested otherwise by the Applicant (see art. 15 of the GDPR);

c) request the correction and/or integration of Personal and Sensitive Data without undue delay (see Art. 16 of the GDPR);

d) request the deletion of Personal and/or Sensitive Data for specific reasons (such as unlawful Processing, non-existence of the purpose of the Processing), without unjustified delay (see Article 17 of the GDPR);

e) request the limitation of Processing upon specific assumptions (such as the inaccuracy of Personal Data, unlawful Processing, exercise of a right in court) (Article 18 of the GDPR);

f) for automated processing activities, to receive the Personal and Sensitive Data in a readable format for the purpose of communicating them to a third party, or, where technically feasible, requesting that Simmetrico send the Personal and Sensitive Data directly to such third party (so-called right to the portability of Personal Data — see Article 20 of the GDPR);

g) be informed by Simmetrico without unjustified delay of any violations or unauthorized access by third parties to their systems containing the Personal and/or Sensitive Data (data breach — Article 34 of the GDPR);

h) file a complaint with the supervisory authority of the EU country in which the Applicant has the residence, works or in which the violation of rights is believed to have occurred (see Article 77 of the GDPR).

For further information on the terms and conditions for exercising the rights granted to Applicants, the latter may consult the text of the GDPR published at the following link or contact Simmetrico in the forms provided for in point 2 of this Jobs Policy.

Cookie Policy

Per far funzionare bene questo sito, a volte installiamo sul tuo dispositivo dei piccoli file di dati che si chiamano “cookies”.

What are cookies?

A cookie is a small text file that websites save on your computer or mobile device when you visit them. Thanks to cookies, the site remembers your actions and preferences (e.g. login, language, font size and other display settings) so you do not have to re-enter them when you return to the site or browse from page to page.

How we use cookies?

a) Technical Cookies

a) Owner domain /1.-3. Part
simmetrico.it / 1. Part
Cookie Name/Expiry
_icl_current_language / 24 hours
_cookie_privacy_accepted / 1 year
Purpose
We use these technical cookies to remember the site navigation settings of the user, such as the language of navigation selected and acceptance of the use of analytical cookies. No sensitive information is saved.

b) Google Analytics

b) Owner domain /1.-3. Part
simmetrico.it, youtube.com / 1. part + 3. Part
Cookie Name/Expiry
__utma / 2 years
__utmb / 30 minutes
__utmc / end of session
__utmz / 6 months
__utmv / 2 years
_ga / 2 years
_gat / 10 minutes
Purpose
Google Analytics cookies are used to measure traffic on our site.
No sensitive information is saved. For more information, see: Google Privacy policy, analytics policy, description of Google Analytics cookies by Google.

c) Youtube videos

c) Owner domain /1.-3. Part
youtube.com / 3. Part
Cookie Name/Expiry
APISID,
CheckConnectionTempCookie576,
HSID,
Login_INFO,
PREF,
SAPISID,
SID,
SSID,
VISITOR_ INFO1_LIVE,
YSC,
Demographics,
recently_watched _video_id_list,
use_hitbox,
GED_PLAYLIST_ACTIVITY
mfl.
/ The expiry date varies from the end of the session up to 2 years.
Purpose
These cookies are installed through embedded Youtube videos. They record anonymous statistics on video views by users and display settings.
No sensitive information is saved as long as user is not logged in to their Google account
and active. In this case, the preferences expressed are linked to the user’s Google account, such as liking a video or saving it as a favorite.
For more information, see: Google Privacy policy.

d) Vimeo videos

d) Owner domain /1.-3. Part
player.vimeo.com, f.vimeocdn.com / 3. Part
Cookie Name/Expiry
UID,
UIDR,
__gads,
__utma,
__utmb,
__utmc,
__utmt_player,
__utmv,
__utmz,
aka_debug,
clips,
player,
vuid.
/ The expiry date varies from the end of the session up to 2 years.
Purpose
These cookies are installed through embedded Vimeo videos. They record anonymous statistics on video views by users and display settings.
No sensitive information is saved as long as user is not logged in to their Vimeo account and active. In this case, the preferences expressed are linked to the user’s Vimeo account, such as liking a video or saving it as a favorite.
For more information, see: Vimeo Privacy policy, Vimeo Cookie Policy.

How are cookies managed?

You can check and/or verify cookies as you wish — to find out more, visit aboutcookies.org. You can delete cookies already installed on your computer and set almost all browsers to block their installation. If you choose this option, please note that you will need to manually change some preferences each time you visit the site, and it is possible that some services or certain features may not be available.

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