Privacy Policy
under art. 13 of the General Data Protection Regulation (EU) 2016/679 (GDPR)

This Privacy Policy contains essential information on the methods and purposes by which KeyPartners Italy S.r.l. (the “Data Controller” or “KeyPartners”), owner of this website (the “Website”) and Data Controller of the personal data it collects through the Website, processes such personal data, as well as on your rights as data subject. 

Each user of the Website is strongly encouraged to read this document when first using the Website, and to periodically check any changes that may have been made by KeyPartners. 

This Privacy Policy is provided solely for this Website, KeyPartners is not responsible for any other Website to which you may be redirected via hyperlinks. 

It is KeyPartners’ policy to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you.

 

1. Data controller

KeyPartners is the controller of the personal data collected through and in connection with the use of this Website:  

Name: KeyPartners Italy S.r.l.

Registered office: P.le Biancamano, 8 – 20121 – Milan – Italy

VAT and Fiscal Code: IT12115590965

Email: italy@key-partners.com

KeyPartners Data Protection Officer’s email: dpo@key-partners.com 

 

2. Data We Collect

Data we collect includes both information you knowingly and actively provide us when using or participating in any of our services and promotions, and any information automatically sent by your devices in the course of accessing our products and services. 

2.1 Navigation and Log Data 

Through this Website, the Controller may collect, in the course of its normal operation, navigation data whose communication is implicit in the use of Internet communication protocols.  

When you visit our Website, our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, other details about your visit, and technical details that occur in conjunction with any errors you may encounter. 

This data is used for the sole purpose of obtaining anonymous statistical information on the use of the Website and to check its correct operation and is deleted immediately after processing. 

Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons. 

The data could be used to ascertain responsibility in the event of hypothetical computer crimes to the detriment of the Website. 

  • Personal Information provided voluntarily by the user 

Through the “Contact” page of this Website, KeyPartners may ask for personal information which may include one or more of the following: (i) Name, (ii) Email, (iii) Phone/mobile number, (iv) Work position, (v) Company, (vi) Location (city/country).

Other personal information may be freely and voluntarily provided by the user. 

3. Purposes and legal bases of the processing 

Data described in the section 2.1 above are processed by the Data Controller to allow users technical and functional access to the Website, the analysis of aggregate traffic data and IT security. The legal bases for such processing are the fulfilment of legal obligations and the legitimate interest of the Controller in the proper functioning and security of the Website. 

In this instance, we only collect personal information that is reasonably necessary to allow the functioning and your surfing of this Website. 

Data described in section 2.2 above are collected by the Data Controller to allow users to interact with the Website’s functionalities and to benefit from the services specifically related to it (e.g. data communicated through contact forms). The legal basis for such processing is the execution of requests made to the Controller by the data subjects. Further and more complete information regarding the processing of personal data provided by you for their use by in the context of the Controller’s activity of research and selection of personnel for job positions is available in the privacy policy you are invited to read here: Privacy policy for candidates.

4. Security of Your Personal Information

When we collect and process personal information, and while we retain this information, we will protect it to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification. Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security. We will comply with laws applicable to us in respect of any data breach. 

5. How Long We Keep Your Personal Information

Without prejudice to any retention obligation under the law, KeyPartners will only store personal data you voluntarily provided to us for the time necessary to fulfil the purpose of the processing.  

This time period depends on the object and nature of the request you made through the Contact page of the Website.  

If the data are processed for an continuing purpose, they will be retained for a reasonable period of time from the last action that shows your interest in KeyPartners. In particular, information on data retention periods for data disclosed for recruitment and selection purposes can be found here: Privacy policy for candidates.

Retention for longer periods could apply to data necessary (i) to ascertain, exercise or defend the rights of the Controller, extrajudicially and/or judicial proceedings, exclusively for the protection of the Data Controller’s rights, and (ii) to fulfill legal obligations. 

6. Rights of the data subject

We inform you that, in accordance with current legislation, you have the following rights expressly recognized by the GDPR: 

the right to ask the data controller for access to personal data (Art. 15); 

the right to have one’s personal data corrected or deleted (Art. 16 and 17); 

the limitation of processing in the cases identified by Article 18 GDPR (Art. 18); 

the right to data portability (Art. 20); 

the right to object to their processing (Art. 21),  

the right not to be subject to a decision based solely on automated processing, including profiling (Article 22),

the right to lodge a complaint with the Garante per la protezione dei dati personali (the Italian Data Protection Authority) to complain about a violation of data protection rules. 

Such requests, as well as any request for clarification or further information, may be addressed to the Data Controller by writing to the Data Controller using the addresses indicated under sections 1.

7. Disclosure of Personal Information to Third Parties

Personal data may be communicated to third parties operating in their capacity as autonomous data controllers (including Controller’s clients companies, professionals, public bodies, auditing or supervisory bodies, in the case of data spontaneously provided the user), also in the performance of legal obligations, or processed, on behalf of the Company, by parties designated as data processors to whom appropriate operating instructions are given (including, for example, service providers, consultants and external collaborators).

8. International Transfers of Personal Information

The personal information we collect may be stored, retained and/or processed where we or our partners, affiliates and third-party providers have facilities for this purpose (e.g., in the case of cloud-based storage, at the location of the relevant servers). These locations may be different from the country where you initially provided your data and may include countries that are not members of the European Union (such as the United States or Switzerland). Any transfer of your data to other countries is carried out in compliance with the requirements of the GDPR and, in particular, takes place on the basis of an adequacy decision of the European Commission or through the use of standard contractual clauses drawn up by the latter.

Last updated: 26 february 2025.