Privacy Disclaimer

The FMTS Group, a corporate group consisting of companies subject to management and coordination pursuant to article 2359 of the Italian Civil Code. of the parent company Formamentis srl (hereinafter the “FMTS Group”), has for years considered the protection of the personal data of its own and/or potential customers and users to be of fundamental importance, guaranteeing that the processing of personal data, carried out using any method, whether automated or manual, is carried out in full compliance with the protections and rights recognised by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter the “Regulation”) and other applicable rules on the protection of personal data.

In particular, the FMTS Group, in the pursuit of all its purposes, may become aware of or request Personal Data from you, such as, for example, your name and surname, your e-mail address, your telephone and postal numbers, your tax code or VAT number, your date of birth and other data that could make you identifiable.

The Regulation provides that, before processing Personal Data, the person to whom the Personal Data belong must be informed of the purposes of the Processing, the manner in which it will be carried out and other information required by law.

This information notice, therefore, has been prepared on the basis of the principle of transparency in order to contain all the elements required by Articles 13 and 14 of the Regulation and is divided into individual sections, each of which deals with a specific topic in order to make it quicker, easier and more intuitive to read (for the sake of simplicity, the contents of this website will be referred to jointly as the “Information Notice”).

1) DATA CONTROLLERS AND JOINT DATA

The companies of the FMTS Group that will process your Personal Data autonomously or jointly, for one or more purposes as set out in a specific information notice provided to you during the collection of Personal Data and, by way of example and without limitation, are the following:

• Formamentis S.r.l. with registered office in Rome, Via Barberini 67, 00187, VAT No. 04009110653, in the person of its legal representative, Dr Giuseppe Melara,
• FMTS Experience S.r.l. with registered office at Via L. da Vinci 17/A, 84098 Pontecagnano Faiano (SA), VAT No. 04044560656, in the person of its legal representative, Mr Silvano Del Duca,
• FMTS Formazione S.r.l. with registered office in Pontecagnano Faiano (SA) at Via L. da Vinci 17/A, 84098, VAT No. 04927890659 in the person of its legal representative, Dr Mariagiovanna Sansone,
• FMTS Lavoro S.r.l. with registered office in Pontecagnano Faiano (SA) at Via L. da Vinci 17/A, 84098, with VAT No. 05731800651 in the person of its legal representative, Dr Giuseppe Melara,
• Consorzio Plus with registered office in Pontecagnano Faiano (SA) at Via L. da Vinci 17/A, 84098, with VAT No. 05373250652 in the person of its legal representative, Dr Gianni Greco,
• Farimpresa S.r.l. with registered office in Locri (RC) at Via Oliverio SNC 89044 with VAT no. 02749300808 in the person of its legal representative, Dr Pasquale Calabrese,
• Euformed s.r.l. with registered office in Tito (PZ) Contrada Serra SNC 85050 with VAT no. 01904740766 in the person of its legal representative Dr Mariagiovanna Sansone,
• Copi s.r.l. with registered office in Naples via Giovanni Porzio 4 Centro Direzionale Isola E7 80143 with VAT no. 01306850593 in the person of its legal representative Dr. Mariniello Christian,
• Literalia Formazione s.r.l. with registered office in Formia (LT) at Via O. Spaventola Snc 04025 with VAT No 02568220590 in the person of its legal representative Dr Mariniello Christian,
• Consorzio More Plus with registered office in Pontecagnano Faiano (SA) at Via L. da Vinci 17/A and VAT no. 05908800658, in the person of its legal representative, Dr Mariniello Christian,
• Mobility Hub Ltd with its registered office at 54 Parnell Square West – Dublin 1, D01H0X9 with National Registration Number 618106 in the person of its legal representative Dr Rosalia Esposito,
• T.E.E.P. LIMITED – Training Education and European Project having its registered office at 10 Philpot Lane – EC3M8AA London with National Registration Number 10036734 in the person of its legal representative Dr Silvano Del Duca,
• F.E.M. – Formation, Emploi, Mobilitè sarl with registered office at 11 Avenue Andrè Roussin – 13016 Marseille, with National Registration Number 881121313, in the person of its legal representative Dr Silvano Del Duca,
• ForMalta ltd established at 121, G. Agius Muscat Street – 3400 ZBR, Zabbar, with national registration number C79224, in the person of its legal representative Dr Giuseppe Melara,
• Motum European Project Sl having its registered office at Calle Reina Doña Germana, Num. 29, Puerta Baja – 46005 VALÈNCIA, with National Registration No. 3/18/M58TH70Z5, in the person of its legal representative Dr Blanca Gadea Fitera Crespi,
• Euroglocal Belgio with registered office at Cours Saint Michel 30 – 1040 Etterbeek with National Registration Number 0749441301 in the person of its legal representative Dr. Keivan Hadji Hossein,

The aforementioned companies may act independently as data controllers according to the definition contained in Article 4, point 7) of the Regulation, or, in some specific cases, act as joint data controllers as provided for by Article 26 of the Regulation. In this perspective, for the purposes of this Information Notice each of the above mentioned companies shall be individually referred to as “Data Controller” or jointly as “Joint Data Controllers”.

The Data Controller and/or the Joint Data Controllers may be contacted through the following channels:

• by writing to the FMTS Group Privacy Office at the parent company Formamentis s.r.l., Via L. Da Vinci 17/A, Pontecagnano Faiano (SA) 84098;
• by sending an e-mail to the e-mail address privacy@formamentisweb.it to the kind attention of the FMTS Group Privacy Office;
• by calling +39 0828 370305 and asking for the FMTS Group Privacy Office.

2) PROCESSED DATA

The companies of the FMTS Group will process the following data in order to provide the requested services:

• identification and contact details provided during registration on the site, simply identification such as: name, surname, date of birth, tax code, email address and telephone number;
• particulars provided in the course of applying for jobs or for the purposes referred to in Article 3(a), (f), (i), (k) below, such as curriculum vitae or schooling skills or work experience, professional certificates, information on gender, nationality, copy of identity document, proof of residence and copy of documents proving the right to work in Italy, if foreign (visas, work permits, etc.) data concerning dependent family members and close relatives (family allowances, family assistance permits, etc.);
• health for the purposes referred to in Article 3, letters i), j), k) below, which reveal a state of health such as, for example, membership of protected categories, certification of allergies and/or food intolerances;
• bank account for the purposes referred to in Article 3 (h), (j), (k) relating, for example, to the current account;
• any data that reveal membership of a trade union (for the purposes of taking office and/or requesting deductions for trade union membership dues), membership of a political party or holding elected public office (for the purposes of leave of absence or leave of absence), religious beliefs (for the purposes of religious holidays provided for by law) for the purposes referred to in Article 3(i), (j) below;
• where appropriate, any judicial data revealing measures relating to the judicial record, the register of administrative sanctions, dependent on crime and the relevant pending charges for the purposes referred to in Article 3(i), (j) below.

3) THE PURPOSES OF THE PROCESSING AND THE LEGAL BASIS THEREOF

Each Data Controller, except for specific cases of joint ownership as set out below, may process your Personal Data for the Processing purposes set out below:

A) registration to Internet sites: in order to process your request to register on one or more of its websites, the Data Controller needs to collect some of your Personal Data, as requested in the specific collection form. The Processing of your Personal Data will be carried out by the Data Controller in order to allow you to access your profile, to participate in the initiatives promoted through the website, to receive the website newsletters and to take advantage of all the other services offered by the website from time to time.

Legal basis and lawfulness of processing: contractual legal basis ex article 6 letter b) of the Regulation – the Processing of your Personal Data will be legally based on the contractual relationship that will be created between you and the Data Controller following your acceptance of the terms and conditions of participation of the specific website;

Data controller: all companies.

B) request for information: in order to process your request for information received through one of the methods available on its websites, the Data Controller needs to process some of your Personal Data as requested in the collection form and/or as spontaneously provided by you.

Legal basis and lawfulness of processing: pre-contractual legal basis ex Article 6 letter b) of the Regulation – the Processing of your Personal Data will be carried out by the Data Controller to respond to your request for information and will be legally based on the pre-contractual relationship that will be created between you and the latter.

Data controller: all companies.

C) purchase of products and/or services: the Data Controller, in order to allow your subscription to purchase its products and/or services, needs to collect some of your Personal Data, as requested in the subscription or purchase form.

Legal basis and lawfulness of processing: contractual legal basis ex article 6 letter b) of the Regulation – the Processing of your Personal Data will be conducted by the Data Controller in order to allow you to receive what you have requested and purchased and will therefore be legally based on the contractual relationship that will be created between you and the latter;

Data controller: all companies.

D) participation in events: In order to allow you to participate in the events it organises, the Data Controller needs to collect some of your Personal Data, as requested in the event registration form.

Legal basis and lawfulness of processing: contractual legal basis ex Article 6 letter b) of the Regulation – the Processing of your Personal Data will be conducted by the Data Controller to register you for the event and ensure your participation and will therefore be legally based on the contractual relationship that will be created between you and the latter;

Data controller: all companies.

E) participation in prize competitions, prize events or contests: the Data Controller, in order to allow you to participate in a prize competition or contest organised by the Data Controller, needs to collect some of your Personal Data, as requested in the participation form..

Legal basis and lawfulness of processing: contractual legal basis ex Article 6 letter b) of the Regulation – the Processing of your Personal Data will be conducted by the Data Controller to enable your participation in the contest or prize event or contest and will therefore be legally based on the contractual relationship that will be created between you and the latter following your acceptance of the rules of the initiative;

Data controller: all companies.

F) enrolment and delivery of training courses: the Data Controller, in order to allow your subscription to its training courses and the subsequent use of the same, needs to collect some of your Personal Data, as requested in the registration form.

Legal basis and lawfulness of processing: contractual purpose ex article 6 letter b) of the Regulation – the Processing of your Personal Data will be carried out by the Data Controller to enable your participation in the training courses provided by the Data Controller and will therefore be legally based on the contractual relationship that will be created between you and the latter;

Data controller: Formamentis srl, Fmts Formazione srl, Consorzio Plus, Euformed s.r.l., Consorzio More Plus, Farimpresa s.r.l, Copi S.r.l and Literalia Formazione s.r.l..

G) access to company premises: the Data Controller, in order to allow you access to the FMTS Group’s corporate offices, needs to collect some of your Personal Data, as required by the visitor identification officers;

Legal basis and lawfulness of processing: Legitimate interest under Article 6(f) of the Regulation – The Processing of your Personal Data will be carried out by the Data Controller and will be legally based on its legitimate interest to safeguard and protect its premises and assets and its employees and contractors;

Data controller: all companies.

H) execution of contractual documentation: the Data Controller, in order to carry out the contractual relationship between you and the Data Controller as well as the related fulfilments, needs to collect and process some of your Personal Data as requested in the individual contractual document;

Legal basis and lawfulness of processing: contractual legal basis ex article 6 letter b) of the Regulation – The Processing of your Personal Data will be conducted by the Data Controller to follow up the signing of the individual contractual document and will be legally based on the contractual relationship that will be created between you and the latter;

Data controller: all companies.

I) Personnel selection activities/candidacy for employment positions: The Data Controller, in order to carry out personnel selection processes and correctly assess whether your application is for a specific search activity or voluntary, needs to process your Personal Data contained in your Curriculum Vitae and/or requested in the collection form provided by the Data Controller.

Legal basis and lawfulness of processing: pre-contractual legal basis ex Article 6 letter b) of the Regulation – the Processing of your Personal Data will be carried out by the Data Controller for the purpose of evaluating your application and will be legally based on the pre-contractual relationship that will be created between you and the latter.

Data controller: Fmts Lavoro srl, Formamentis.

J) establishment and management of employment or collaboration relationships: the Data Controller, in order to establish and manage an employment or collaboration relationship, needs to collect some of your Personal Data, as required by the employment or collaboration contract. The Processing of your Personal Data will be conducted by the Controller and will be legally based on the contractual relationship of employment or collaboration between you and the Controller.

Legal basis and lawfulness of processing: contractual purpose ex article 6 letter b) of the Regulation – The Processing of your Personal Data will be carried out by the Data Controller for the purpose of establishing and managing your employment or collaboration relationship with the Data Controller and will be legally based on the employment or collaboration contractual relationship between you and the Data Controller;

Data controller: all companies.

K) application and subsequent management of work experience, job shadowing and training abroad: the Data Controller, in order to enable your participation in the Erasmus+ programmes, needs to collect some of your Personal Data, as requested in the application form.

Legal basis and lawfulness of processing: contractual purpose ex article 6 letter b) of the Regulation – the Processing of your Personal Data will be carried out by the Data Controller to enable your participation in the training courses provided by the Data Controller and will therefore be legally based on the contractual relationship that will be created between you and the latter;

Data controller: Fmts Experience s.r.l., Mobility Hub Ltd, Teep Ltd, Fem s.a.r.l., ForMalta ltd, Motum s.l., Euroglocal Belgio.

L) direct marketing activities: the performance by the Data Controller of promotional and/or marketing activities directed at you. This category includes all activities carried out to promote products, services sold and/or provided by the Data Controller;

Legal basis and lawfulness of processing: Legitimate interest under Article 6(f) of the Regulation – The Processing of your Personal Data will be carried out by the Data Controller and will be legally based on the Data Controller’s legitimate interest to promote its products and services, irrespective of the request for your consent and in any case until you object to such Processing as further explained in Recital 47 of the Regulation where “processing of personal data for direct marketing purposes is considered a legitimate interest”. This will be possible as a result of the assessments made by the Controller regarding the possible and possible prevalence of your interests, rights and fundamental freedoms that require the protection of Personal Data over its own legitimate interest to send direct marketing communications, the main reason being your interest shown towards the Controller by coming into contact with it;

Data controller: all companies.

M) profiling activities: the performance by the Data Controller of profiling activities, i.e. evaluating your tastes, preferences and consumption habits, also in connection with market surveys and statistical analyses. This category includes any form of automated processing of Personal Data in order to evaluate certain personal aspects such as those concerning, by way of example but not limited to, professional performance, economic situation, personal preferences, interests, reliability, behaviour, location or movements;

Legal basis and lawfulness of processing: ata subject’s consent under Article 6(a) of the Regulation – The Processing of your Personal Data will be conducted by the Data Controller and will be legally based on your free, express and unambiguous consent;

Data controller: all companies.

N) communication activities to third parties for marketing purposes: the right of the Data Controller to communicate to third parties specifically identified and indicated in the notice provided, where necessary and required, so that they may process your Personal Data for their own commercial and marketing purposes;

Legal basis and lawfulness of processing: consent of the data subject under Article 6(a) of the Regulation – the Processing of your Personal Data will be conducted by the Data Controller and will be legally based on your free, express and unambiguous consent;

Data controller: all companies.

The contact methods used for direct and indirect marketing and profiling activities may be automated (email) or traditional (telephone calls with an operator). In any case, and as better specified below, you may object to the processing and/or revoke your consent, even in part, for example by consenting only to traditional contact methods.

With regard to contact methods that involve the use of your telephone contacts, we remind you that marketing activities by the companies involved in the processing will be carried out subject to verification that you have been entered in the Register of Objections as established pursuant to and for the purposes of Presidential Decree no. 178 of 7 September 2010 and subsequent amendments.

4) PROCESSING CARRIED OUT BY JOINT CONTROLLERS

With a view to making specific processing activities more functional both to the interests of its customers/users and to its own objectives, on 13/05/2021 all the companies of the FMTS Group entered into a co-ownership agreement pursuant to Article 26 of the Regulations, whereby they undertook to jointly carry out the following purposes J) establishment and management of employment or collaboration relationships L) direct marketing activities, M) profiling activities. For these purposes, the Data Processors have also jointly determined the methods of Processing and have defined, in a clear and transparent manner, the procedures for providing you with timely feedback should you wish to exercise your rights, as provided for by Articles 15, 16, 17, 18 and 21 of the Regulation, as well as in cases of portability of Personal Data as provided for by Article 20 of the Regulation, as better described in Section I of this Information Notice.

With regard to the management of the common database present on the CRM (Customer Relationship Management) platform of the FMTS Group, each company of the FMTS Group has appointed the parent company Formamentis srl as Data Processor which, for the common purposes of direct marketing and profiling, is called upon to manage the phases of registration, organisation, storage, processing, selection, extraction of the personal data of the customers/prospects.

The Joint Data Controllers, in order to ensure the correct management and execution of the joint-ownership agreements, have identified the parent company Formamentis srl as the entity to which to assign specific processing activities, appointing it as the data controller in accordance with the provisions of article 28 of the Regulations, by signing a separate written agreement.

Your Personal Data may be disclosed to specific entities that are considered recipients of such Personal Data, including natural or legal persons, public authorities, departments or other bodies that receive Personal Data, whether or not they are third parties.

5) SUBJECTS TO WHOM YOUR DATA MAY BE DISCLOSED

In this perspective, in order to correctly carry out all the Processing activities necessary to pursue the purposes set out in this Information Notice, the following Recipients may be in the position to process your Personal Data:

– third parties who carry out part of the Processing activities and/or activities connected and instrumental to the same on behalf of the Data Controller or the Joint Data Controllers. These subjects have been appointed as data controllers, i.e. natural or legal persons, public authority, service or other body that processes Personal Data on behalf of the Data Controller;

– individuals, employees and/or contractors of the Data Controller or of the Data Processors, who have been entrusted with specific and/or multiple Processing activities on your Personal Data. Such individuals have been given specific instructions on the security and proper use of Personal Data and are defined as the persons authorised to process Personal Data under the direct authority of the Data Controller or Processor

– third parties who carry out Processing activities and/or activities connected with and instrumental to the same in their capacity as independent data controllers, including but not limited to consulting firms, independent professionals, credit institutions, insurance companies, third party companies and/or companies belonging to the Group;

– companies with which the Data Controller or the Joint Data Controllers have established collaborations by virtue of a contractual relationship;

– where required by law or to prevent or suppress the commission of an offence, your Personal Data may be disclosed to public bodies or judicial authorities without them being defined, however, as recipients. The Regulation provides that public authorities that receive Personal Data as part of a specific investigation carried out in accordance with the laws of the European Union or of the Member States are not Recipients.

6) TIMING

The FMTS Group keeps and uses your personal data for no more than 10 years from the end of the service for service purposes and in any case for the period of prescription provided for by law, for no more than 3 years from the end of the relationship for marketing purposes; for the time of your consent and in any case for no more than 5 years from collection, for profiling purposes. Thereafter, your data will be deleted or made anonymous and processed for aggregate and anonymous statistical analysis.

7) RIGHTS OF THE DATA SUBJECT

As provided for in the Regulation, you may exercise, at any time, against the Data Controller and/or the Joint Data Controllers the following rights:

– RIGHT OF ACCESS, or you can have confirmation of the existence or otherwise of your personal data, even if not yet recorded, and request that such data be made available to you in a clear and comprehensible manner; as part of this right, it is your right to request information and, where appropriate, a copy:

(a) the origin and category of your personal data;

b) the logic of use, if your information is processed by electronic means;

c) the purposes and methods of processing

d) the identification details of the data controller and data processors;

e) of the entities or categories of entity to whom or which your personal data may be communicated or who or which may get to know them;

f) the period for which your data is stored or the criteria used to determine this period, when possible;

g) the existence of an automated decision-making process, including profiling. In this case you may request the logic used, the importance and the consequences foreseen for you;

(h) the existence of adequate safeguards in case of transfer of your data to a non-EU country or an international organisation;

– RIGHT OF RECTIFICATION you may obtain, without justifiable delay, the updating, amendment, rectification of your incorrect data or the integration of your incomplete data, should you have an interest in doing so;

– RIGHT OF CANCELLATION it is your right to obtain the cancellation, blocking of your data or, where possible, their transformation into anonymous form:

(a) if unlawfully processed;

b) if no longer necessary in relation to the purposes for which they were collected or subsequently processed;

c) in case of revocation of the consent on which the processing is based and in case there is no other legal basis;

d) if you have objected to the processing and there are no further legitimate grounds for continuing to use your data;

(e) if we are required to do so by law;

f) if it relates to minors.

The Controller may refuse to delete your data in the event of:

(a) exercise of the right to freedom of expression and information;

(b) compliance with a legal obligation, performance of a task carried out in the public interest or exercise of public authority;

(c) reasons of public health interest

(d) archiving in the public interest, scientific or historical research or for statistical purposes;

(e) establishment, exercise or defence of legal claims;

– RIGHT TO LIMITATION you can obtain the restriction of processing in the event of:

(a) contestation of the accuracy of your personal data, if you have not preferred to request the amendment, updating, modification or rectification of your data;

b) unlawful processing by the Controller to prevent its deletion;

c) exercise of one of your rights in court;

d) verification of whether the Data Controller’s legitimate reasons prevail over those of the data subject;

– RIGHT TO PORTABILITY you have the right to receive, where the processing is carried out by automatic means, without hindrance and in a structured, commonly used and readable format, the personal data concerning you that you have provided to us with your consent or by contract in order to transmit them to another Controller or – if technically feasible – to obtain the direct transmission by the Controller to another Controller;

– RIGHT OF OBJECTION you have the right to object at any time to the processing of your personal data in whole or in part:

(a) for legitimate and overriding reasons relating to your particular situation, to the processing of personal data concerning you;

b) to the processing of personal data concerning you for marketing and/or profiling purposes, where carried out (e.g. you can object to the sending of advertising or direct sales material or to the carrying out of market research or commercial communications, through the use of automated calling systems without the intervention of an operator, by email and through traditional marketing methods, by telephone and paper mail).

For all the cases mentioned above, if necessary, FMTS Group, as data controller, will inform the third parties to whom your personal data are communicated of the possible exercise of your rights, except in specific cases (e.g. when such fulfilment proves to be impossible or involves the use of means that are clearly disproportionate to the protected right). For all of the above cases, if necessary, Formamentis, as data controller, will inform the third parties to whom your personal data is disclosed of the possible exercise of rights by you, except in specific cases (e.g. when this proves impossible or involves the use of means manifestly disproportionate to the protected right).

8) DATA TRANSFER

Data may be transferred outside the European Union, in particular to and from the UNITED KINGDOM, for reasons exclusively related to the provision of the service (e.g. work experience and job shadowing etc.), in which case the FMTS Group will adopt appropriate safeguards, including adequacy decisions and standard contractual clauses approved by the European Commission. In particular, transfers to and from the group company TEEP LTD will be made in accordance with the European Commission’s adequacy decision of 28 June 2021.

9) DPO

In order to facilitate relations between you and each Data Controller, the FMTS Group has decided to adopt and appoint a Data Protection Officer (DPO) as provided for in Articles 37-39 of the Regulation. FMTS Group has therefore identified this figure in the person of Dr Gianni Greco and you can contact him at privacy@formamentisweb.it and/or by writing to the Data Protection Officer of FMTS Group at Formamentis srl.

The updated list of our Data Protection Officers is available at the head office at Via Leonardo Da Vinci 17/A, Pontecagnano Faiano (Sa). Finally, you have the right to lodge a complaint with the Garante per la Protezione dei Dati Personali (www.garanteprivacy.it) regarding the processing operations referred to in this information notice.

10) SECURITY MEASURES

The FMTS Group and third parties working for us take appropriate and adequate security measures to prevent unauthorised access, disclosure, modification or destruction of your data, in accordance with applicable national legislation and the GDPR.

In particular, systems are used to control access to the network, servers and programs to prevent the disclosure of data to unauthorised third parties, firewall and antivirus systems are adopted to protect against viruses and malware that could delete, disclose or render unusable the data, data encryption and pseudonymisation techniques are implemented, physical and logistical measures are implemented to protect the IT infrastructure, business continuity and disaster recovery procedures are implemented, as well as Data Brunch in the event of a breach.

The sites and any associated data passing through the cloud servers are managed by ARUBA S.p.A. (https://www.aruba.it), by AMAZON S.p.A. (https://www.amazon.it), FlameNetworks (https://www.flamenetworks.com/), by Register  (https://www.register.it/) and ­­­­­­­­­­­­­­­­Azure Active Directory (https://azure.microsoft.com/it-it/overview/).

11) DATA FROM MINORS

Only persons of 18 years of age or older may provide consent. For minors under this age, the consent of their parents or guardians is required.

Formamentis S.r.l. does not knowingly use the service to process personal data of persons under 18 years of age for profiling purposes.

This information may be subject to change. For any updates, please consult the websites made available by Formamentis.

Last update: 10/05/2022