CONTATTI

EN

Privacy Policy

Information on the processing of personal data pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR)

1. Data Controller

The Data Controller is Gaetti e Associati S.r.l., with registered office at Via Benedetto Giovanelli, 23, 38122 Trento (TN), Italy, Italian Tax Code and VAT No. 01878310224.

For information regarding the processing of personal data or to exercise your rights, please contact info@gaettiassociati.it.

2. Categories of Personal Data Collected

Gaetti e Associati S.r.l. may collect and process the following categories of personal data:

  • Identification and contact details: name, surname, email address, telephone number and other information voluntarily provided.

  • Professional information: CVs, employment history, education, skills, qualifications, references and career-related information.

  • Recruitment information: details provided through unsolicited applications, recruitment processes, interviews and related communications.

  • Consulting and coaching information: data required to manage requests and deliver professional services.

  • Browsing data: technical information collected when using the website, including IP addresses, browser information and technical access logs.

CVs and candidate communications may contain special categories of personal data under Article 9 of the GDPR, such as health-related information or trade union membership.

Such information will only be processed where necessary and where an appropriate legal condition applies.

Candidates are encouraged not to include sensitive information that is not relevant to the position or recruitment process.

3. Purposes and Legal Bases for Processing

Personal data may be processed for the following purposes:

Recruitment and executive search

Managing unsolicited applications, assessing professional profiles, arranging interviews and conducting recruitment and selection activities.

Legal basis: taking steps at the request of the data subject prior to entering into a contract and, where applicable, the legitimate interests of the Data Controller, subject to the rights of the individuals concerned.

Business and client relationships

Responding to enquiries, preparing proposals, managing contractual relationships and providing consulting services.

Legal basis: performance of a contract, pre-contractual measures, compliance with legal obligations and, where applicable, legitimate interests.

Professional coaching services

Managing enquiries, scheduling meetings and delivering agreed coaching activities.

Legal basis: performance of a contract or pre-contractual measures.

Legal and administrative obligations

Compliance with accounting, tax, administrative and other statutory requirements.

Legal basis: compliance with legal obligations.

Website operation and security

Technical management of the website, prevention of unauthorised access and protection of information systems.

Legal basis: legitimate interests of the Data Controller, within the limits of applicable law.

Any additional processing activities, including marketing communications, will only be carried out where an appropriate legal basis exists and applicable information requirements have been met.

4. Processing of CVs and Job Applications

Personal data submitted through unsolicited applications or specific recruitment processes is used to assess candidates' qualifications, experience and suitability for professional opportunities.

Data may be processed by authorised personnel of Gaetti e Associati S.r.l. and, where relevant to a recruitment process, disclosed to client companies involved in evaluating candidates, subject to applicable legal requirements.

Where appropriate, recipient companies may act as independent Data Controllers and process personal data in accordance with their own privacy notices.

Special categories of personal data will only be processed where permitted by applicable legislation, including relevant employment-related provisions.

5. Processing Methods and Data Security

Personal data is processed using electronic systems and, where necessary, paper-based records, in accordance with the principles of lawfulness, fairness, transparency, data minimisation and confidentiality.

Gaetti e Associati S.r.l. implements appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction or unlawful disclosure.

6. Recipients of Personal Data

Personal data may be made available to:

  • Authorised employees and collaborators of Gaetti e Associati S.r.l.

  • Client companies involved in recruitment and selection processes.

  • IT, hosting, email and other technical service providers.

  • Professional advisers providing administrative, legal or organisational services.

  • Public authorities and other entities where disclosure is required by law.

External providers processing personal data on behalf of the Data Controller are appointed as Data Processors where required under Article 28 of the GDPR.

7. Data Retention

Personal data is retained only for as long as necessary to fulfil the purposes for which it was collected, in accordance with the principles of proportionality and storage limitation.

In particular:

  • CVs and job applications: [specify the actual retention period adopted by the company, for example 24 months, only if consistent with its internal procedures].

  • Contractual and administrative data: for the periods required by applicable legislation.

  • Enquiries: for the time necessary to respond and fulfil any related obligations.

  • Technical browsing data: according to the retention periods applicable to the systems and services used.

Once the applicable retention periods have expired, personal data will be deleted or anonymised, unless further retention is required by law.

8. International Data Transfers

Where service providers involve the transfer of personal data outside the European Economic Area, such transfers will be carried out in accordance with Chapter V of the GDPR and subject to appropriate safeguards.

[Verify and specify any actual international transfers and applicable safeguards.]

9. Data Subject Rights

Under the conditions established by the GDPR, individuals may exercise the following rights:

  • Access to their personal data.

  • Rectification of inaccurate or incomplete data.

  • Erasure of personal data.

  • Restriction of processing.

  • Data portability, where applicable.

  • Objection to processing, where applicable.

  • Withdrawal of consent, where processing is based on consent, without affecting the lawfulness of previous processing.

Requests may be submitted to info@gaettiassociati.it.

Individuals also have the right to lodge a complaint with the Italian Data Protection Authority, the Garante per la protezione dei dati personali (www.garanteprivacy.it).

10. Provision of Personal Data

Providing personal data is generally voluntary. However, failure to provide information necessary for a particular purpose may prevent Gaetti e Associati S.r.l. from assessing an application, responding to an enquiry or delivering the requested services.

11. Cookies and Tracking Technologies

The website may use technical cookies and other technologies necessary for its operation.

Any analytical, profiling or third-party cookies are subject to applicable legislation and, where required, the user's consent.

Further information about the technologies actually used is available in the Cookie Policy [insert link].

12. Changes to This Privacy Policy

Gaetti e Associati S.r.l. may update this Privacy Policy to reflect changes in legislation, business practices or technical operations.

Last updated: 6 November 2026.

Gaetti e Associati S.r.l.

Via Benedetto Giovanelli, 23, 38122 Trento (TN), Italy

Italian Tax Code / VAT No. 01878310224

Email: info@gaettiassociati.it

Authorised by the Italian Ministry of Labour to carry out personnel search and selection activities, authorisation No. 19181/RS of 7 December 2006.