Beeonjob – Privacy Policy

This statement is provided pursuant to article 13 of Legislative Decree 196/2003 (as amended) specifically for the website and for data processing carried out by Beeonjob, not for third parties such as for co-registration purposes or users accessing via the link.

Data Controller
The Data Controller shall be Triboo Direct Srl, in viale Sarca 336 Ed.16 - 20126 Milan Italy (hereinafter “Triboo Direct srl”).

Sensitive and legal data
At the time of registering with the website or at any time thereafter on the Beeonjob website users are expressly prohibited from providing data, whether directly or indirectly, relating to (I) race or ethnicity; (II) political affiliations; (III) religious or philosophical beliefs; (IV) participation or affiliation with trade unions or political parties; (V) physical or mental conditions; (VI) sexual preferences; (VII) crimes or criminal proceedings.

Purpose of data processing
The main purpose of the requested data that users then provide is to allow them to access a series of services that will assist them in their search for employment, such as receiving the Beeonjob newsletter.

The data that is collected may also be used for the following purposes:

● Sending out newsletters;
● Dealing with requests, grievances and disputes;
● Processing orders and requests with competent authorities to ascertain crimes or other items under investigation
● In order to comply with law and/or tax obligations (invoicing, registration of clients, mandatory reporting obligations, etc.), accounting purpose (keeping accounts, financial excerpts, debt recovery, etc.) or public safety reasons (reporting obligations to public entities appointed by mandatory law orders, e.g. anti-terrorism units, anti-money laundering, etc.).

The processing described above does not require consent for the purpose of article 24 of Legislative Decree 196/03. The necessary data must be provided otherwise it will not be possible to provide the requested services.

Other processing purposes
If specifically authorised, we will also send out selected marketed to users according to their declared interests, in which case Triboo Direct srl will carry out the following activities:

If Triboo Direct srl are specifically authorised to carry out direct marketing, it will entail a broad range of advertising of commercial goods and services and will constitute marketing, telemarketing or web marketing; all actions relating to the market where products, goods and services are aimed.

In particular:
- Direct Email Marketing
- Use of website, mini websites and landing pages for specific promotions
- Banner advertising
- Affiliate marketing
- Competitions and prizes
- Cookies
- Viral marketing and multilevel marketing
- Distribution of promotional communications
- Telemarketing with an operator
- Distribution of promotional messages via text message, MMS and instant messaging
- Commercial, promotional, advertising and information messages, fund raising, institutional and service messages.

Once authorised, Triboo Direct srl will conduct marketing activities using traditional channels (post, telephone) as well as automatically (e-mail, SMS, banner display, etc.). When accepting Triboo Direct srl marketing services, users are accepting all such methods for the distribution of the communications described above. If consent is withdrawn, it will have effect for all such processing methods however in accordance with section 2.6.2 of the Guidelines on promotional activities and safeguarding against spam – 04 July 2013, as amended, after signing up for the service the relevant data subject will continue to be entitled, pursuant to article 7(4)b) of the Data Protection Code to amend the authorisation they had granted for their personal data processing, opting for just one communication method (traditional or automatic), or otherwise for example, opting to receive such communications using automatic channels only. Any such request should be made to Triboo Direct srl using the normal contact details.

If users grant their consent separately, which is voluntary, Triboo Direct srl may be authorised to communicate to third parties that are located in EU countries and/or extra EU countries, the personal data collected via the website, for marketing purposes. Once again, if a user withholds this consent, it will not affect the possibility to access Triboo Direct srl services; it will merely mean that the user’s data will not be communicated to said recipients.

Please see a list of all the partners at the foot of this privacy statement and their respective privacy statements, where we may transfer personal data if authorised in advance.
Please note that third parties located in EU countries and/or extra EU countries in relation to which we are authorised to communicate personal data for the purposes described above, shall act as autonomous data controllers for all processing they carry out. For that reason, the rights provided for by article 7 and following articles of Legislative Decree 196/2003 may be exercised, as and when required, directly with said third party. This data processing is not mandatory and withholding consent shall not prevent the data subject from receiving other requested Triboo Direct srl services. The partners of Triboo Direct srl who would receive your personal data for promotional purposes operate in the following sectors:

● Clothing, fashion, accessories, shoes, eyewear, costume jewellery, fine jewellery, watches
● Contact lenses and eye products
● Underwear, beachwear and accessories
● Tourism, airports, ticket discounts, travelling, hotels, travel planning, restaurants, resorts, agro-tourism, coach/bus operators, bed & breakfasts, hostels
● Leather bags and holdalls
● Event, wedding, party and concert planners
● Children’s goods and services, toys, products and services for babies and new mothers
● Education, culture
● Wedding announcements, advertising of articles for sale, leases and loans
● Services for the home, restructuring, decorating, furniture, doors, fixtures and safety equipment, burglary alarms and safes, private and security guards
● Personal services (investigations, meetings and social events, health and wellbeing, herbalists and perfume stores, assisted hotel services, legal and accounting advice)
● Culture and training courses, specialised courses, masters’ courses, remedial courses, preparation for University, culture exchange programmes
● Financial, banking, social security products, loans and debt restructurings, investments, home banking, investment platforms
● Auxiliary products for individuals: mattresses, hoists and lifts, ergonomic tubs, miscellaneous electrical appliances
● Business services (debt recovery, commercial information, advertising and marketing, translations, interpretation, removal services)
● Recruitment services, employment offers, training and work-experience courses
● Safety prevention and equipment
● Foodstuff, organic products, zero KM agricultural products
● Beverages and soft drinks, wines and liquors
● Energy drinks and supplements (correct diet and fitness)
● Body products, hair stylists, make-up, nail art, beauty centres, treatments, chromo-therapy
● Solarium, gym, thermal treatments, sporting items
● Specialised medical services, dentists, teeth whitening, hair processes, skin treatments and similar
● Tattoos, piercing and microdermal processes
● Healthcare products, pollution monitors, filters and purification
● Air conditioning and environmental processes
● Gardening and floriculture
● Home DIY
● Temporary storage and similar
● Services for pets, food, pet care, accommodation and treatments
● Electricity systems, burglar alarms, telephones, data, satellite, digital and similar systems
● Entertainment and hobbies, videogames, computers, lap tops and IT
● Multimedia
● TV channel subscriptions, pay per view, pay TV, on demand, etc.
● TV channels for children or other specific categories, multimedia content, CDs, DVDs, Bluray, Streaming and downloads.
● Music channels, hobbies, cooking, technical topics, culture, etc.
● Cinema and theatre, cabaret and live performances, concerts, auditions, recordings, registrations, miscellaneous equipment, post-production, editing
● Sports, specialised channels, specialised magazines, subscriptions, discounts, clothing, accessories, gym, sports centres, events and competitions
● Technology, computers, tablets, photo cameras, mobile phones, TV and HiFi
● Electrical appliances, furniture, bedding, creative design
● Interior design and furniture and finishings
● Utilities and commodities, energy suppliers and rates
● Data connection, ADSL, fibre, landlines, satellite, new technology, internet providers, internet services, web design, social network and internet-based services
● Website development, websites, computer and mobile device applications
● Mobile phones, telephone operators, prices and promotions, services and deals
● Associations, groups, partners, volunteers, social welfare projects
● Media including online press, eBooks, newspapers, journals, comics, art and reproductions, collections and stamps
● Home insurance, car insurance, personal insurance, travel insurance, special offers, discounts and promotions
● Driving schools, gaining points back, driving practice, special licenses, license renewal
● Automotive services, tuning, car procedures, sale and purchase of vehicles, car leasing, spare parts, maintenance and services for cars and motorbikes
● Events, competitions, sporting events in the car and bike sector
● Cycling, equipment, events, services, spare parts and similar
● The seaside, lakes and rivers: navigations products and services, fishing, tourism and spare time, water sports
● Hobbies such as horoscopes, astrology, magic, card games, betting on sports and gambling
● Lottery and prize draws

Coregistration means that alongside the data provided to Triboo Direct srl for the purposes described above, data will also be specifically and separately collected and autonomously processed by the coregistration partner which shall act as an autonomous data controller.

If users grant their specific consent, there are certain areas on the website where they may access useful and interesting services from third party Triboo Direct srl partners, setting up a direct relationship with them. Partners offering Coregistration, who are autonomous data controllers, after receiving the data must then provide a relevant privacy statement and obtain the necessary consent from users, who will be entitled to the rights provided for by article 7 of Legislative Decree 196/2003 directly with said partners. In terms of collecting and processing data relating to Coregistration, Triboo Direct srl has a merely technical role. The activation of Coregistration is optional and not necessary to receive Triboo Direct srl services.

Transfer of data
Users’ personal data shall not be transferred under any circumstance.

Processing terms
Data will be processed either manually or automatically using procedures that safeguard compliance with applicable laws and regulations. Specific security measures are adopted to prevent the loss of data, unlawful or improper use and unauthorised access to data.

Type of data provided
In addition to the information provided below concerning navigation data and the contractual services rendered via the website, users are free to provide the personal data specified in the forms available on this website and to grant their optional consent or not. Not granting consent or the subsequent withdrawal of consent might make it impossible to provide the free services being requested.

Scope of communication of data
Categories of possible recipients of personal data or who may acquire access to data in their capacity as Persons in Charge of Processing or Data Processor. Without prejudice to the information set out above concerning optional data processing by third parties for marketing purposes, users’ personal data shall never be communicated to unauthorised third parties. Unless specifically requested by a user who has granted their express consent or activated Coregistration, external subjects shall not have access to the databases that contain registered users’ data.

Recruitment companies are usually provided with statistics that do not reveal the identity of users. Likewise, all communications from recruitment companies shall be sent by the Data Processor only, who may opt to do so using technological partners, however in no event will personal data be disseminated to recruitment companies (including via e-mail) or any other recipient not explained in this privacy statement.

Duration of data processing
The personal data processed by Triboo Direct srl is retained mainly for legal, tax and contractual requirements. The data retention period in this case is the maximum retention period applicable for the stated purpose of the data processing.
For the time being, we deem that the retention period established by tax rules of 10 years is reasonable for the planned purposes of the data processing. The only exception to this principle arises in the event of dispute or in general, whenever it is necessary to safeguard the rights and interests of the company and in the event of data processing for optional marketing purposes.
In relation to the first exception, the data must be retained adopting the necessary security measures, only for the time needed to pursue said purpose. In relation to data that is processed with the authorisation of the data subject for marketing purposes, the data relating to said user should be retained for marketing purposes for up to 3 years since the last active use by the data subject of Triboo Direct srl services. The term active use means any express, voluntary action by the data subject such as sending a request to Triboo Direct srl, opening a link in an e-mail, signing up for a new service, granting optional consent, etc.
In terms of safeguarding the company’s rights and needs, note that the data of users who have opted to withhold their consent are retained only for defence purposes and for the purpose of retrieving information in the event of a dispute, and in any case only for the length of time required to achieve said purpose.

The website uses several types of cookies, which are memorised in each user’s computer and then deleted after 30 days. Please click this LINK for more information regarding the use of cookies.

Web navigation data
Whilst navigating the website as well as all the websites that can be accessed from adverts, anonymous data may be collected. Said data, which is processed to develop statistics on the use of the websites and check the correct functioning of the underlying IT systems.

An updated list of the Processor is available at our offices in viale Sarca 336 Ed.16 - 20126 Milan Italy. The following has been appointed as Processor for the purpose of the exercise of the rights provided for by article 7 of Legislative Decree 196/2003: Triboo Direct srl – in viale Sarca 336 Ed.16 - 20126 Milan Italy - e-mail:

Data Subject Rights
Pursuant to article 7 of Legislative Decree 196/2003 (as amended), users whose personal data is processed are entitled to obtain confirmation at any time of the existence or nor of such data and to know the content and the source thereof, also in order to check its accuracy or request its integration, rectification, updating, deletion and/or to communicate the withdrawal of consent. According to said article, users also have the right to request the deletion or anonymization of their data or to block unlawful processing or otherwise to object for legitimate reasons to its processing.

Such right may be exercised using the user nickname and password via the main webpage The right to access data and all other requests (anonymization of data, objection to processing or requests to block processing) may be addressed to the Data Processor specified above.

TITLE II – Data Subject’s Rights Section 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); and 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 following rights: a) to obtain updating, rectification or, where interested therein, integration of the data; b) to obtain erasure, 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) to obtain 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 disseminated, 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 surveys. Section 8. Exercise of Rights. 1. The rights referred to in Section 7 may be exercised by making a request to the data controller or processor without formalities, also by the agency of a person in charge of the processing. A suitable response shall be provided to said request without delay. 2. The rights referred to in Section 7 may not be exercised by making a request to the data controller or processor, or else by lodging a complaint in pursuance of Section 145, if the personal data are processed: a) pursuant to the provisions of decree-law no. 143 of 3 May 1991, as converted, with amendments, into Act no. 197 of 5 July 1991 and subsequently amended, concerning money laundering; b) pursuant to the provisions of decree-law no. 419 of 31 December 1991, as converted, with amendments, into Act no. 172 of 18 February 1992 and subsequently amended, concerning support for victims of extortion; c) by parliamentary Inquiry Committees set up as per Article 82 of the Constitution; d) by a public body other than a profit-seeking public body, where this is expressly required by a law for purposes exclusively related to currency and financial policy, the system of payments, control of brokers and credit and financial markets and protection of their stability; e) in pursuance of Section 24(1), letter f), as regards the period during which performance of the investigations by defence counsel or establishment of the legal claim might be actually and concretely prejudiced; f) by providers of publicly available electronic communications services in respect of incoming phone calls, unless this may be actually and concretely prejudicial to performance of the investigations by defence counsel as per Act no. 397 of 7 December 2000; g) for reasons of justice by judicial authorities at all levels and of all instances as well as by the Higher Council of the Judiciary or other self-regulatory bodies, or else by the Ministry of Justice; or h) in pursuance of Section 53, without prejudice to Act no. 121 of 1 April 1981. 3. In the cases referred to in paragraph 2, letters a), b), d), e) and f), the Data Protection Authority, also following a report submitted by the data subject, shall act as per Sections 157, 158 and 159; in the cases referred to in letters c), g) and h) of said paragraph, the Data Protection Authority shall act as per Section 160. 4. Exercise of the rights referred to in Section 7 may be permitted with regard to data of non-objective character on condition that it does not concern rectification of or additions to personal evaluation data in connection with judgments, opinions and other types of subjective assessment, or else the specification of policies to be implemented or decision-making activities by the data controller. Section 9. Mechanisms to Exercise Rights. 1. The request addressed to the data controller or processor may also be conveyed by means of a registered letter, facsimile or e-mail. The Data Protection Authority may specify other suitable arrangements with regard to new technological solutions. If the request is related to exercise of the rights referred to in Section 7(1) and (2), it may also be made verbally; in this case, it will be written down in summary fashion by either a person in charge of the processing or the data processor. 2. The data subject may grant, in writing, power of attorney or representation to natural persons, bodies, associations or organisations in connection with exercise of the rights as per Section 7. The data subject may also be assisted by a person of his/her choice. 3. The rights as per Section 7, where related to the personal data concerning a deceased, may be exercised by any entity that is interested therein or else acts to protect a data subject or for family-related reasons deserving protection. 4. The data subject’s identity shall be verified on the basis of suitable information, also by means of available records or documents or by producing or attaching a copy of an identity document. The person acting on instructions from the data subject must produce or attach a copy of either the proxy or the letter of attorney, which shall have been undersigned by the data subject in the presence of a person in charge thereof or else shall bear the data subject's signature and be produced jointly with a copy of an ID document from the data subject, which shall not have to be certified true pursuant to law.(1) 5. The request referred to in Section 7(1) and (2) may be worded freely without any constraints and may be renewed at intervals of not less than ninety days, unless there are well-grounded reasons. (1) As amended by Section 40(2)d. of decree no. 201 dated 6 December 2011 subsequently converted, with amendments, into Act no. 214 dated 22 December 2011; the amendment repealed the final period in this paragraph, which read as follows: “If the data subject is a legal person, a body or association, the relevant request shall be made by the natural person that is legally authorized thereto based on the relevant regulations or articles of association.” Section 10 Response to Data Subjects 1. With a view to enabling effective exercise of the rights referred to in Section 7, data controllers shall take suitable measures in order to, in particular, a) facilitate access to personal data by the data subjects, even by means of ad hoc software allowing accurate retrieval of the data concerning individual identified or identifiable data subjects; b) simplify the arrangements and reduce the delay for the responses, also with regard to public relations departments or offices. 2. The data processor or the person(s) in charge of the processing shall be responsible for retrieval of the data, which may be communicated to the requesting party also verbally, or else displayed by electronic means - on condition that the data are easily intelligible in such cases also in the light of the nature and amount of the information. The data shall be reproduced on paper or magnetic media, or else transmitted via electronic networks, whenever this is requested. 3. The response provided to the data subject shall include all the personal data concerning him/her that are processed by the data controller, unless the request concerns either a specific processing operation or specific personal data or categories of personal data. If the request is made to a health care professional or health care body, Section 84(1) shall apply. 4. If data retrieval is especially difficult, the response to the data subject’s request may also consist in producing or delivering copy of records and documents containing the personal data at stake. 5. The right to obtain communication of the data in intelligible form does not apply to personal data concerning third parties, unless breaking down the processed data or eliminating certain items from the latter prevents the data subject’s personal data from being understandable. 6. Data are communicated in intelligible form also by using legible handwriting. If codes or abbreviations are communicated, the criteria for understanding the relevant meanings shall be made available also by the agency of the persons in charge of the processing. 7. Where it is not confirmed that personal data concerning the data subject exist, further to a request as per Section 7(1) and (2), letters a), b) and c), the data subject may be charged a fee which shall not be in excess of the costs actually incurred for the inquiries made in the specific case. 8. The fee referred to in paragraph 7 may not be in excess of the amount specified by the Data Protection Authority in a generally applicable provision, which may also refer to a lump sum to be paid in case the data are processed by electronic means and the response is provided verbally. Through said instrument the Data Protection Authority may also provide that the fee may be charged if the personal data are contained on special media whose reproduction is specifically requested, or else if a considerable effort is required by one or more data controllers on account of the complexity and/or amount of the requests and existence of data concerning the data subject can be confirmed. 9. The fee referred to in paragraphs 7 and 8 may also be paid by bank or postal draft, or else by debit or credit card, if possible upon receiving the relevant response and anyhow within fifteen days of said response.

This privacy statement can be consulted online using recent browsers. All efforts will be made to make the functions of this website interoperable using automatic privacy checks that are available for certain products used by users. Given that the development of said automatic privacy checks has not yet been completed and they are not free from bugs, the document that can be accessed via currently constitutes the privacy policy for this website, which shall be subject to revision.

Below the list of partners with information about privacy, to which, prior explicit consent, notify the data: