Privacy Policy

1. Data Controller and the purposes of the present Privacy Policy

This Privacy Policy describes the modalities and the purposes through which swiftlinux processes, as data controller, the personal data of the users (“User/Users”) of the website www.swiftlinux.com (“ Site”).

By using the Site, in particular, any registered or unregistered User may access job vacancies, including those made available by swiftlinux’s clients through direct feeds on the Site and those collected through a specialized search engine which operates at locations in various Countries of the world.

This allows the User of the Site to access the majority of the job vacancies and job news available on internet by means of a single platform. Moreover, the registered User (“Registered User”), may benefit from a series of specific services, as better illustrated by the detailed information notices linked into the present Privacy Policy.

This Privacy Policy is provided to the Users pursuant to the Italian Legislative Decree no. 196/2003 (“Privacy Code”), to the EU Regulation no. 679/2016 (the “Regulation”), to the EU applicable laws and to the Provisions and Recommendations provided by the Italian Data Protection Authority time by time.

This Privacy Policy may be amended by swiftlinux, also in order to take into account the relevant legislative developments, the technological progress and the changes into the swiftlinux’s activities or the introduction of new services.

In the event in which swiftlinux would decide to amend this Privacy Policy, it will provide for an extensive information notice on the Site. If the amendments are particularly relevant, swiftlinux may communicate them to the Users via a different channels (e.g. by sending an email).

This Privacy Policy refers only to the Site and to the processing of personal data carried out by swiftlinux on it, without covering the data processing operations carried out by other websites/third parties visited by the User through links present on the Site, by the subjects with which swiftlinux collaborates in order to provide the Users with the services requested or by the subjects that access the information related to the Users by means of the Site or swiftlinux’s applications, for which swiftlinux takes no responsibility.

2. Data Processing purposes

The Users’ personal data will be collected and processed by swiftlinux, mainly with electronics, telematics and automatics tools, for the following purposes:

(a) The activation of swiftlinux’s services

Users’ personal data will be processed to allow the unregistered User (“ Unregistered User”) to view and access, through the swiftlinux web portal, the job vacancies provided by swiftlinux’ clients as well as the job advertisements published on other websites and collected and shown by swiftlinux to satisfy the search criteria inserted by the Unregistered User during its researches (so called Keywords). If Unregistered User click on a job vacancy, it could be directly addressed to the websites of the companies that published the above announcements, to the pages of the Site by which swiftlinux collects, on behalf of its clients, the Users’ applications as well as to the others pages of the Site in which the User may understand the job vacancy details before being addressed to the external websites.

In such cases, the Unregistered User has full evidence to be re-directed to a job vacancy published outside the Site. swiftlinux assumes no responsibility for the correctness, truthfulness or updating of third-party job offers to which the Unregistered User might access through the Site. Unregistered User personal data will also be used for administrative purposes.

(b) The activation of swiftlinux’s service provided for Registered User

In addition to the services offered to the Unregistered Users, described in previous par. 2 (a), the personal data of the User will be processed to allow the latter to register on the Site and to the swiftlinux’s services.

The User could register itself on the swiftlinux’s services by providing its e-mail address or also by carrying out a login with its social accounts (e.g. Facebook, Google, Linkedin). The registration allows the User to access to the job vacancies notification service (job vacancies notification). The Registered Users personal data will be also processed for the relevant administrative purposes, including technical assistance activities and also for sending to the Users service messages (such as, welcome messages, useful suggestions for obtaining better search results on swiftlinux’s Site, service communications about the amendments of the Site, etc.).

Finally, swiftlinux will allow the Registered Users to upload their Curriculm Vitae on the Site, in order to allow them to have it always available and, with their prior consent, to share it with third subjects, including swiftlinux subsidiaries and associate companies as well as swiftlinux’s clients for personnel selection purposes and to facilitate labour matching.

(c) Statistics and analysis

The aggregate data related to the User, not able to directly identify him/her, will be processed for carrying out statistical analysis to improve swiftlinux’s technical assistance and services offered to the Users, for developing the platform and the Site contents, for enhancing the search criteria of the job vacancies, as well as to correct and develop the research and analysis techniques.

(d) swiftlinux’s legitimate interests

The User personal data will be also processed by swiftlinux in order to exercise its and/or third subjects’ rights and legitimate interests, such as the legal defense, the management of claims and disputes which will may arise, the prevention of fraud and/or illegal activities, possible credit recovering and the invoicing of the swiftlinux’s clients.

(e) Legal obligation

Moreover, the Users personal data will be processed to fulfill legal obligations provided by regulations, national and European laws as well as to be compliant with the provisions provided by authorized Authorities.

3. Personal data processed

3.1 Web-browsing data

As all the IT systems of every website, also the Site’s IT system automatically records, in the course of its normal operations, certain personal data, the transmission of which is necessary for the communication protocols of the internet. Such data consists of information such as IP addresses of the devices used by Users connecting to the Site, URI (Uniform Resource Identifier) addresses of the resources requested, time of the request, method used to transmit the request to the server, size of the file obtained as an answer, numerical code indicating the status of the answer from the server (successful, error, etc.) and other parameters related to the User’s operating system.
In addition to serving the purposes of the Site’s operation, said data will be used to get statistical information concerning the use of the Site and check it is operating correctly. The access data may also be used for the ascertainment of liabilities in case of IT crimes damaging the Site.
Moreover, when the Users are redirected to the website of the swiftlinux’s clients by clicking on a link contained into a job vacancy, swiftlinux will record such action by collecting the User IP address, the date, the email address (if the User is registered on the Site) and the job vacancy ID: such processing will be carried out by swiftlinux for invoicing purposes and for preventing possible frauds through any possible automatic clicks generation, pursuant to the above paragraph 2, point (d).

3.2 Data processed by using cookie

In order to carry out specific activities, swiftlinux collects User and Registered Users personal data (e.g. IP addresses) by using cookie and similar technologies. For a detailed illustration on the type of cookie installed on the Site and on their functions and purposes, the Users can read the swiftlinux’s Cookie Policy at the following paragraph 8.

3.3 Data voluntarily provided by the Registered Users

swiftlinux collects the Registered Users personal data, as voluntary provided by the latters and collected by swiftlinux in order to register to the service referred as “job vacancies notification ”, as indicated into the registration form.

4. Legal basis of the processing

The legal basis of the processing carried out by swiftlinux for the purposes of activation of swiftlinux’s services, is the execution of the services requested by the Users; therefore, the collection of the User personal data is necessary, as any refusal to provide such data does not allow swiftlinux to manage and provide the services requested.

With particular reference to the purposes of carrying out aggregated analysis and pursuing swiftlinux’s interests, instead, the legal basis of the processing is the “legitimate interest” of swiftlinux and its clients: in this cases, although the collection of the personal data is not mandatorily required by the law or essential for providing the service to the Users, it is in any case necessary as such data are strictly connected with the above legitimate interests, which does not override interests or fundamental rights and freedoms of the Users. Any refusal to provide such data, therefore, could entail the impossibility for swiftlinux to provide the services requested.

Finally, in relation to the purpose of legal obligations, the User prior consent is not needed as such processing will be carried out for the fulfilling of a legal obligation; therefore, any refusal to provide such data entail the impossibility to obtain the service requested from swiftlinux.

5. Communication of the data and access to the data

The personal data provided by the Users as well those data collected by the Site in the context of the relevant services provided (e.g. IP addresses) will not be disseminated but may be communicated, also outside EU, only for purposes and with the modalities illustrated above, to the following categories of parties:

• swiftlinux’s clients (e.g. third subjects and companies), for the purpose of providing the services requested by the Users and for facilitating the labor matching (e.g. access to the job vacancies, sending of an application, etc.), as well as, with the Users prior consent, for carrying out marketing purposes;

• collaborators, consultants or self-employed professionals to which swiftlinux collaborates for carrying out technical or organizational activities (such as the IT providers) or with which swiftlinux works for the purpose of providing its services or carrying out marketing activities;

• individuals, companies, or professional firms providing assistance and advice to swiftlinux, in relation, without limitation to, accounting, administrative, legal, tax and financial matters;

• parties authorized to access the data by law or authorities’ orders.

The persons and entities indicated above will process the data in their capacity as independent data controllers pursuant to the applicable laws or as Data Processors. The list of the names of the subjects to which the data are or may be communicated is available at swiftlinux.

For the purposes indicated at the present Privacy Policy, the personal data will also be transferred abroad to EU and not-EU countries, included to the companies which belongs to swiftlinux group of companies: in particular, for the cases in which such data will be transferred outside EU, swiftlinux states to adopt the specific measures provided by for the Privacy Code for the legitimation of such processing, such as specific agreements which include the Standard Contractual Clauses provided by the EU Commission or the subscription of the EU-US Privacy Shield for the data transfer to the USA. The Users may request for obtaining the indication of the countries to which their personal data are transferred as well as the privacy measures adopted by swiftlinux to make such processing legitimate by contacting the persons indicated below.

Finally, the personal data will be processed by employees and/or collaborators entrusted by swiftlinux and duly appointed as persons in charge of the processing under the direct supervision and liability of swiftlinux.

6. Data retention

swiftlinux adopts adequate security measures able to prevent unauthorized accesses, dissemination, alteration or destruction of the data. Such data are mainly processed and stored at swiftlinux legal office or at different data centres located into the EU territory and, with particular reference to the services provided by third partied, also outside EU.

The personal data are processed mainly by electronic, computerized and automated tools, for the period of time which is strictly necessary to carry out the purposes for which they were collected. Such data are stored by swiftlinux for the time necessary to provide the service requested by the Users and, after the provision of such services, the will be stored only for the provision of the execution of swiftlinux’s services and for carrying out the activities of aggregated analysis, fulfilment of legitimate interests, legal obligations set out above.

7. User’s rights

The Users, as data subjects, retain specific rights. For example, they have the right to obtain:

(i) the confirmation as to the existence of data concerning them, even if not recorded yet, and the communication of the same data in an intelligible form;

(ii) the indication of the origin of the data, purposes and modalities of the processing, subjects and categories of subjects to which the data may be communicated or which may get to know the data in their capacity as representatives in the State’s territory, as data processors, or persons in charge of the processing;

(iii) the updating, rectification or, where interested therein, integration of the data;

(iv) the erasure, transformation into anonymous form, or blocking of data that have been processed unlawfully.

The data subjects, moreover, shall have the right to object, in whole or in part, on legitimate grounds, to the processing of their personal data.

Finally, if applicable, the Users retain the right to rectification, right to erasure, right to restriction of processing, right to data portability as well as the right to lodge a complaint with the Italian Data Protection Authority in relation to the processing described into the present Privacy Policy.

The rights listed above may be exercised directly by means of the specific functions available on the Site, or of the links inserted in the emails, or by sending an email to the following address:
[email protected]

8. Cookies

A cookie is a small size file which a website sends to the browser and saves on your computer when you visit a website. Cookies are used in order to allow or enhance the websites operation, but also to provide swiftlinux with information on the Site.

The Site uses different kinds of cookies and similar technologies, each one with a specific function, as indicated below.

8.1 Technical Cookies
These cookies are essential to allow the User to browse the Site and use its functions, such as accessing the website’s reserved areas (authentication cookies). Without these kind of cookies the services requested, such as access to the reserved area of the Registered Users, cannot be provided. These cookies which are strictly necessary, are used to record one single identifier in order to manage and identify the User with respect to other Users visiting the Site at the same time, providing the User with a consistent and precise service. These cookies are necessary for the Site to work properly therefore they does not need the Users prior consent.

8.2 Performance and analytics cookies set by swiftlinux and similar technologies
These cookies may be used by swiftlinux for the purposes of performance and improving the Site. These cookies gather information about how users use the Site, which pages are visited for example, and allows swiftlinux to recognize Users, trace their online behaviors and identify which features of the website are of most interest to Users.

Moreover, in the cases in which the User is readdressed to the websites of the companies that have published a job vacancy, swiftlinux uses analytics cookie (which lasts 12 hours, so-called “tracking pixel”) for collecting information on how the Users browse such third companies’ websites (e.g. the pages browsed, the application procedure, etc.) in order to carry out the activities of aggregated analysis and pursuing of legitimate interests under the above paragraph 2 – in particular, to verify the quality of its services -, to transfer to such third companies anonymous feedbacks on the correct functioning and effectiveness of the services provided and for carrying out internal analysis.

Finally, swiftlinux may use tracking scripts which have with similar functionalities to the cookie ones in order to carry out sample tests on both Unregistered and Registered Users (e.g. mouse movements, the positioning on the Site and on its contents, etc.). The information collected are processed only for aggregate analysis which are not based on the personal data of the Users (e.g. IP, MAC address, etc.).

8.3 Third party analytics cookies
These cookies are used by Google Analytics for example, Google Adwords, Google Doubleclick, Criteo, Facebook, Connexity, Jetpack, in order to carry out statistical analysis of how users browse the Site, the number of pages visited or the clicks carried out on a page during the navigation sessions. The data obtained by swiftlinux from this analysis is used exclusively only if the service provider uses cookies in connection with the web browser installed on your computer or on other devices used by the Users for accessing the Site.

For further information about the use of third party cookies and instructions on how to manage them, as well as how to opt-out of them, please visit the relevant third party websites for further information at the following links:
Google Analytics, Google Adwords, Google Doubleclick: http://www.google.com/policies/technologies/cookies/
Criteo: http://www.criteo.com/privacy/
Facebook: https://www.facebook.com/help/cookies/update
Connexity: http://connexity.com/privacy-policy/
Jetpack: https://automattic.com/cookies/ .

8.4 First Party Profiling Cookies

These cookies are installed in relation to the contents visualized by the User and their utilization of the Website. These cookies allow the Website to record the preferences expressed by the User in their browsing, to analyse their behaviour, and customize specific Website contents to each single User, for the purpose of developing content and sending promotional messages in line with the preferences expressed by the User as they navigate the Website. This type of cookies may also be used to restrict the number of visualizations of specific content and to analyse the results acquired through specific actions on the Website.

The Owner may also add web beacons (GIFT or web bugs) in web pages or e-mails for the purpose of tracking clicks on the links or images featured, and the Users’ opening of e-mails containing job adverts and business newsletters. This information is collected to monitor the number of Users that visit the Website pages or click on the e-mails containig job adverts and the newsletters, allowing the Owner to obtain statistical information and identify the characteristics and contents preferred by Users, in order to send them customized information. These cookies are: JE , JE_GLOBAL

8.5 Third-Party Profiling Cookies

swiftlinux uses business partners to display advertisement communications on the Website and its services on third-party websites, and to enable its advertisement network partners to display advertisment content connected with the preferences shown by the Users who registered with the Website or browsed through it. These cookies are used by Google and other third parties (such as Appnexus, Rubicon Project, Pubmatic, Criteo, Index Exchange and others, as listed here: Advertising Partners List ) for the purpose of displaying advertisement banners to Users in their browsing. These cookies are also used to show Users products or services they are interested in, or similar to those visualized, based on their browsing history.

These cookies connect to the User’s browser or other device used by Users to browse the Internet. For further information on how to manage this type of cookies and on how to refuse their utilization, please see Google’s privacy policy ( https://policies.google.com/technologies/ads ; https://policies.google.com/technologies/partner-sites ; https://adssettings.google.com/ ) and the policies used by the third-parties mentioned above, and apply the available options at the following link: http://www.youronlinechoices.com/

8.6 How to disable cookies
Please note that, also after having provided the consent by overcoming the banner cookie on the landing page of the Site, if you wish, you may set your browser to limit the number of cookies accepted or disable all cookies, by changing the browser’s settings with the following procedures:

Microsoft Internet Explorer 7/8 / Microsoft Internet Explorer 9/10/11
Click “Tools” in the top right hand corner and select “Internet settings”. In the pop-up window select “Privacy”: the User may change the cookie settings here.

• Google Chrome
Click the “wrench” icon in the top right hand corner and select “Settings”. Then select “Show advanced settings” and change the “Privacy” settings.

• Mozilla Firefox
In the top left hand menu select “Settings”. In the pop-up window select “Privacy”: the User may change the cookie settings here.

• Safari
In the top right hand menu select “Preferences”. Then click “Security” and change the cookies settings.
In order to carry out this operation on your mobile phone, please consult your device handbook.
Please be aware that by disabling the cookies – web browsing cookies, technical or performance cookies – certain functions of the Site may not be available.