STATEMENT ACCORDING TO ART. 13 OF PERSONAL DATA PROTECTION CODE

According to section 13 of Italian Legislative Decree No. 196 of 30 June 2003, Personal Data Protection Code (hereafter referred to as Privacy Code), ROBERTO COIN S.p.A. (hereafter referred to simply as “Roberto Coin”), with registered office at viale Trieste no. 13, in Vicenza, Italy, (registered at the company registry of Vicenza under number 02193150246, REA Register No. 26090 company’s capital EUR 1.500.000,00 fully paid-up capital), herewith informs that personal data disclosed in the “Curriculum” section has the sole purpose of company’s own personnel search and selection.

Controller of data processing is Roberto Coin S.p.A.

It is herewith specified, that Roberto Coin does not request any sensitive data for filling out and submitting applications. We herewith remind you, that sensitive data are such that can reveal racial and ethnic origins; religious, philosophical or other kind of beliefs; political opinions, party or union affiliation, or affiliation with associations or organizations of religious, philosophical, political or union nature, as well as personal data that can reveal state of health and sexual life.

Therefore, visitors to the site are kindly requested to abstain from disclosing any sensitive data

in the curricula vitae they submit.

However, if sensitive data was spontaneously communicated by visitors to the site, Roberto Coin herewith informs that, according to art. 26 of the Privacy Code, sensitive data can only be processed with data subject’s written authorization, and without specific authorization by the Guarantor, considering the general authorization issued by the Guarantor (according to art. 40 of the Privacy Code) which is renewed yearly.

Therefore, in case sensitive data was included spontaneously in the curriculum, Roberto Coin will proceed to delete curriculum from its own database unless written consent for data processing of disclosed sensitive data by data subject arrives within 30 days of submitting curriculum.

For such purpose, the data subject must display the specific statement of the “Curriculum”/”Careers” section, enclosing the following footnote, stating: “ I herewith consent to the processing of my data – (signature)” and send the written consent to Roberto Coin S.p.A, viale Trieste 13, 36100 Vicenza, Italy, by registered mail with return receipt. No data processing will take place between the date the curriculum containing sensitive data is submitted and the date the written consent is received, or rather during the 30 days after submitting the curriculum, however, the usual safety measures shall be applied for the protection of the received data.

Data processing will take place at Roberto Coin S.p.A., viale Trieste 13, 36100 Vicenza, Italy, and will be processed by specially assigned Roberto Coin staff, or by people in charge of occasional maintenance operations, with use of electronic procedures, within the modalities and limits necessary to fulfilling abovementioned purpose. Data will be kept in paper and/or electronic archives, in order to locate it. Data will be kept only for the time necessary to the purpose of personnel search and selection, and however, not beyond 6 months. After this if not specifically requested by the subject the data will be destroyed.

 

Data Controller is Roberto Coin S.p.A.

Roberto Coin will not disclose collected personal data to third parties.

Disclosure of personal data is voluntary, however, failure to disclose such data will make it impossible to assess submitted curricula in the process of personnel selection, making it impossible for Roberto Coin to take such applications into consideration.

 

Data subjects have the right, under art. 7 of the Privacy Code, and in particular the right to request access to own personal data; to request rectification, updating and deleting of own data, where incomplete, faulty or collected unlawfully; as well as the right to object to processing of data, for legitimate reasons, addressing such requests to Roberto Coin S.p.A., viale Trieste 13, 36100 Vicenza, Italy, or to the company’s e-mail: [email protected]

 

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Following are art. 7 and 13 of the Privacy Code, to complete the Statement (Legislative Decree 196/03):

 

Art. 7 -(Right to Access Personal Data and Other Rights)

1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form.

2. A data subject shall have the right to be informed

a) of the source of the personal data;

b) of the purposes and methods of the processing;

c) of the logic applied to the processing, if the latter is carried out with the help of electronic means;

d) of the identification data concerning data controller, data processors and the representative designated as per Section 5(2); e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing.

3. A data subject shall have the right to obtain

a) updating, rectification or, where interested therein, integration of the data;

b) deletion, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;

c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disclosed, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.

4. A data subject shall have the right to object, in whole or in part,

a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;

b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication survey

 

 

 

Art. 13 - (Information to Data Subjects)

1. The data subject as well as any entity from whom or which personal data are collected shall be preliminarily informed, either orally or in writing, as to:

a) the purposes and modalities of the processing for which the data are intended;

b) the compulsory or voluntary nature of providing the requested data;

c) the consequences if (s)he fails to reply;

d)the entities or categories of entity to whom or which the data may be communicated or who/which may get to know the data in their capacity as data processors or persons in charge of the processing, and the purpose of disclosure of said data;

e) the rights as per Art. 7;

f) the identification data concerning the data controller and, where designated, the data controller’s representative in the State’s territory pursuant to Art. 5 and the data processor. If several data processors have been designated by the data controller, at least one among them shall be referred to and either the site on the communications network or the mechanisms for easily accessing the updated list of data processors shall be specified. If a data processor has been designated to provide answers to data subjects in case the rights as per Art. 7 are exercised; such data processor shall be referred to.

2. The information as per paragraph 1 shall also contain the items referred to in specific provisions of this Code and may fail to include certain items if the latter are already known to the entity providing the data or their knowledge may specifically impair supervisory or control activities carried out by public bodies for purposes related to defence or State security, or else for the prevention, suppression or detection of offences.

3. The Guarantor may issue a provision to set out simplified information arrangements as regards, in particular, telephone services providing assistance and information to the public.

4. Whenever personal data is not collected from the subject, information as per paragraph 1, also including the categories of processed data, shall be provided to the data subject at the time of recording such data or, if its communication is envisaged, no later than when the data is first communicated.

5. Paragraph 4 shall not apply

a) if the data is processed in compliance with an obligation imposed by a law, regulations or Community legislation.

b) if data is processed either for carrying out investigations by defense counsel as per Act no. 397 of 07.12.2000 or to establish or defend a legal claim, provided that data is processed exclusively for said purposes and for no longer than is necessary for that purpose;

c) if the provision of information to the data subject involves an effort that is declared by the Guarantor to be manifestly disproportionate compared with the right to be protected, in which case the Guarantor shall lay down suitable measures, if any, or if it proves impossible in the opinion of the Guarantor.