Privacy Notice on the processing of personal data of candidates
This Privacy Policy is drafted in accordance with the Federal Data Protection Act (FADP) of 25 September 2020 and with the Regulation (EU) 2016/679 (GDPR) and informs about how the Group process candidates’ personal data. It applies to personal data collected during your job application. Please, read this Privacy Policy carefully in order to understand our views and practices regarding your personal data.
1. DEFINITIONS
The personal data provided by you or otherwise acquired in compliance with the legislative and contractual provisions in force – inherent to, connected with and/or instrumental to the evaluation of your candidacy for the purposes of personnel selection, will form the object of processing, in compliance with the provisions of the FADP, GDPR and the obligations of confidentiality.
Personal data: any information concerning an identified or identifiable natural person. For example, personal data contained in a CV (e.g., first name, last name, previous professional experience, image).
Data subject: the private person whose personal data are processed.
Processing: any operation concerning data, regardless of the means and procedures used, namely the collection, storage, use, modification, communication, archiving or destruction of data.
Communication: making data accessible, such as authorizing consultation, transmission, or dissemination.
2. IDENTITY AND CONTACT DETAILS OF THE DATA CONTROLLER
The company that determines the purpose and means of the processing of personal data, in accordance with Art. 5 (J) FADP and Art. 4 (7) GDPR, is Pagani Pens SA, a company under Swiss law with its registered office at Via Ponteggia 19, 6814 Cadempino – Switzerland, represented by the persons with signatory rights. The contact details of the data controller are as follows: privacy@paganipens.com
3. PURPOSE OF PROCESSING AND DATA RETENTION
PURPOSE OF PROCESSING | LEGAL BASIS | DATA RETENTION |
|---|---|---|
a) Personnel selection: conducting personnel search and selection activities for the purpose of the possible establishment of an employment relationship. Analysis of spontaneous applications and applications in response to job vacancies posted through the website. Conducting interviews including video interviews (candidate image) and/or telephone interviews. Processing is carried out for the execution of pre-contractual measures. | Data are processed for the purpose of the execution of pre-contractual measures, possible establishment of an employment relationship. | The data will be kept for 12 months after the conclusion of the selection process should Pagani Pens SA decide not to proceed with its application. The CVs of candidates who proceed in the selection process, joining Pagani Pens SA as employees, will be kept in the company, along with the employee’s records, for 10 years after the end of the employment relationship. |
b) Viewing the candidate’s publicly accessible “social profile” on social media/networks. The Data Controller may collect and process the candidate’s personal data to the extent that such collection is necessary and relevant for selection and related to social network business. The data processing is necessary for the pursuit of the overriding interest of the Data Controller. | Data are processed for the purpose of the execution of pre-contractual measures, possible establishment of an employment relationship. | Data will be kept for the duration of the selection process and then deleted. |
c) Verification of curriculum vitae: request for copies of documentation related to work certificates, documents related to educational courses (e.g., continuing education) to complete the application dossier and proceed with the evaluation. The data processing is necessary for the pursuit of the overriding interest of the Data Controller. | Data are processed for the purpose of the execution of pre-contractual measures, possible establishment of an employment relationship. | The data will be kept for 12 months after the conclusion of the selection process should Pagani Pens SA decide not to proceed with its application. The CVs of candidates who proceed in the selection process, joining Pagani Pens SA as employees, will be kept in the company, along with the employee’s records, for 10 years after the end of the employment relationship. |
4. RECIPIENTS OF PERSONAL DATA
The data of a personal nature provided will be communicated to recipients, who will process the data acting as data processors for the purposes listed above or data controllers. Precisely, data will be communicated to: – collaborators operating in various company functions and who will process the data in the performance of their duties according to the directives issued by the company. In particular, internal subjects dealing with selection and function managers who have requested the opening of the job position for which you have applied; – subjects who provide services for the management of the information system used by Pagani Pens SA and telecommunications networks (including e-mail); – firms or companies as part of assistance and consulting relationships;- Group Companies for which you have applied; – competent authorities for fulfillment of legal obligations and/or provisions of public bodies, upon request.
5. DATA COMMUNICATION ABROAD
Data are collected in a first step centrally by the Group company Pagani Pens SA, a company based in Switzerland, and are, in a second step, shared with the Group company for which you have applied, if you are a candidate for a branch located in the European Union. The data is therefore located both in Switzerland and in the country where the Group company you have applied for is located (i.e. Germany). Data are processed in accordance with data protection regulations. They are therefore transmitted to countries that guarantee a high level of data protection or on the basis of agreements between Group companies after verification of the security measures applied to protect the data.
6. DATA SUBJECTS RIGHTS
Under the conditions set forth in the FADP and the GDPR, the Data Controller specifically recognizes the following rights (non-exhaustive list):
- to obtain rectification of inaccurate or outdated personal data;
- to be informed in writing and free of charge if personal data concerning you are being processed;
- revoke consent to the processing of data that you have previously given;
- prevent the disclosure to third parties of personal data worthy of special protection;
- express your opinion on an automated individual decision or request that it be reviewed by a natural person.
- to obtain delivery of personal data or to demand its transmission to a third party.
- demand that data processing be stopped, that its disclosure to third parties be prevented, or that personal data be rectified or destroyed.
- right to demand that a certain processing of personal data be prohibited, that a certain communication of personal data to third parties be prohibited, or that personal data be deleted or destroyed.
- if neither the accuracy nor the inaccuracy of the personal data can be proven, request that a mention be added to the data noting its disputed character.
- request that the rectification, destruction, blocking, notably that of communication to third parties, as well as the mention of the disputed character or the judgment be communicated to third parties or published.
- have the illegality of a processing of personal data established.
You may exercise your rights as expressed by the FADP and the GDPR by contacting the Data Controller through the address privacy@paganipens.com.
7. ADDITIONAL INFORMATION: MODIFICATION │ ENTRY INTO FORCE
The Data Controller reserves the right to change, update, add or remove portions of this privacy policy at its discretion and at any time. In order to facilitate such review, the policy will contain the date of update.
Date of update: October 3, 2024