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  3. How we process personal data for each Data Subject

Students (e.g., applicants and enrollees in Talent Garden courses)

 

What categories of personal data do we process?

Talent Garden process: Common data (e.g. name and surname, tax ID code, telephone numbers, e-mail addresses, CV and professional information, pictures).

Why do we process personal data, what is the legal basis for the processing, and how long do we retain the data?

                           Purposes                           (For what purposes)

Categories of data (What)

Legal basis
(basis of legitimacy)
1 Managing participation in training courses (including application, selection and organisation, career advisor). Common Data Fulfilment of contractual or pre-contractual obligations (Art. 6.1.b GDPR)
2 Publication of CVs and professional information of students enrolled in full-time Masters programmes on the Talent Garden Talent Page, for the purpose of obtaining a job interview. Common Data Consent of the data subject (Art. 6.1.a GDPR)
3 Dissemination of images/videos/audio on the Talent Garden website and social channels. Common Data Consent of the data subject (Art. 6.1.a GDPR)
4 Possible contact via WhatsApp related to application and/or selection management for the chosen training course, e.g. reminder of recruitment interviews. Common Data Consent of the data subject (Art. 6.1.a GDPR)
5 Sending e-mails and messages containing information, of a commercial and promotional nature, relating to Talent Garden and its services. (Marketing). Common Data Consent of the data subject (Art. 6.1.a GDPR)
6 Evaluation of participants' satisfaction with the quality of training courses and the services provided by Talent Garden. Common Data Legitimate interest of the Joint Data Controllers (Art. 6.1.f GDPR)
7 Recording calls to gather customer satisfaction opinions regarding the service provided. Recording calls to gather customer satisfaction opinions regarding the service provided. Common Data Consent of the data subject (Art. 6.1.a GDPR)
8 Sending of commercial communications by e-mail ("soft spam") relating to Talent Garden services and products similar to those already used by the data subject. Common Data Legitimate interest of the Joint Data Controllers (Art. 6.1.f GDPR)
9 Defence of a right in court or in front of an authority. Common Data Legitimate interest of the Joint Data Controllers in defending an interest of their own against the data subject (Art. 6.1.f GDPR)
10 Fulfilment of legal obligationsFulfilment of legal obligations Common Data Fulfilment of legal obligations (Art. 6.1.c GDPR)

 

Are you obliged to provide your personal data?

The provision of personal data for the above-mentioned purposes is: 

  • indispensable for the execution of the contract, with the consequence that any refusal to provide it, in whole or in part, may make it impossible for the Joint Data Controllers to execute the relationship established and to correctly carry out all the fulfilments connected with it, such as, by way of example, those of a contributory, fiscal and insurance nature;
  • indispensable to fulfil a legal obligation to which the Joint Data Controllers are subject and does not require the user's consent;
  • optional for processing that requires your consent. Failure to provide your consent does not prevent you from using the services of the Joint Data Controllers, but you will not be able to receive such initiatives and/or offers.

How are your data processed?

Personal data is processed, by electronic and paper means, in such a way as to minimise the risk of destruction, loss (including accidental loss), unauthorised access/use or use incompatible with the initial purpose of collection. This is achieved by the technical and organisational security measures implemented by Talent Garden.
 

How long do we store your data?

Talent Garden stores your data for the minimum time necessary to achieve the above-mentioned purposes, except for the need to comply with obligations imposed by laws, regulations or national and EU legislation or imposed by the competent authorities. By way of example, the data collected for the performance of a contract and/or for the fulfilment of pre-contractual commitments with you will be processed for the entire duration of the contract and, thereafter, for a period of 10 years from the termination of the contract, unless an extension of this period is necessary for the defence of a right, whether legal or not, of the Data Controller.
 
Once the retention period has expired, the data shall be erased or rendered anonymous.