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PRIVACY POLICY


PRIVACY INFORMATION


INTRODUCTION

This privacy policy explains who we are, how we collect, share and use your
Personal Information (or “Personal Data”), and how you can exercise your privacy
rights.

We are committed to ensuring that your privacy is protected. Should we ask you
to provide certain information by which you can be identified, you can be
assured that it will only be used in accordance with this Privacy Policy.

We may change this policy from time-to-time by updating this page. You should
check this page from time to time to ensure that you are happy with any changes.

If you do not agree with the content of this Policy, then please remember it is
your choice whether you want to use our services. Your continued use of the
resources made available on our Services following the posting of any changes to
this policy constitutes acceptance of those changes.

If you have any questions or concerns about our use of your personal
information, then please contact us using the contacts provided below.


DATA CONTROLLER

The data controller is CoreView s.r.l. with registered office in via Palestrina,
33 20124 Milan (Italy). Our VAT number is 10146510960.

The requests relating to the exercise of the rights provided by the 2016/679
General Data Protection Regulation (“GDPR” or “Regulation”) can be sent, in
writing also by e-mail message, to privacy@coreview.com.

‍Requests relating to the identity of the Data Processors designated by CoreView
S.r.l. can be requested by e-mail sent to privacy@coreview.com.


CONTACT DATA OF THE DATA PROTECTION OFFICER

The Company has appointed a “data protection officer” (so-called “Data
Protection Officer” or “DPO”) provided for by the Regulation, who can be
contacted at the following e-mail address: privacy@coreview.com.


WHAT TYPE OF DATA WE COLLECT

Personal Data processed by us has been voluntarily provided by you or may also
be acquired by us in the exercise of our business or from third parties.

You are responsible for any personal and /or third party’s information that you
share with us and warrant that you have the right to disclose it, discharging us
of any liability toward third parties.

The data processed by us, either on its own or through third parties, could be:

 * First and last name, the data relating to your education and job; company
   name, the Personal Data of the legal representative / attorney; address and
   other elements of personal identification (date of birth, place of birth);
   demographic information such as postcode; fiscal Code; contact information
   including e-mail, phone number. If you purchase our Services, Billing and
   communications information (your credit card details and billing address,
   identification details of banking relationships (such as IBAN) preferences
   and business interests.
 * Personal Data we process on your behalf: If you purchase our Services, you
   need to provide us information about Services’ users, such as their names and
   email addresses, their devices and usage of the Services. We use and process
   this information to provide the Services in accordance with your
   instructions.
 * Personal Data we collect from other sources: We may obtain information about
   you from third-party sources, such as public databases, social media
   platforms, third-party data providers and our joint marketing partners. We
   take steps to ensure that such third parties are legally or contractually
   permitted to disclose such information to us. Examples of the information we
   receive from other sources include demographic information, device
   information, location (such as city and state), and online behavioural data.

We do not collect, access or scan any of your organisation’s content including,
but not limited to:

 * Email messages
 * Calendar entries
 * Contact lists or Address books
 * SharePoint documents or content

We do not process neither do we process any “particular” Personal Data, such as,
for example, the Personal Data suitable to reveal the state of health, political
opinions, religious beliefs, etc…


LEGAL BASIS FOR PROCESSING

We process Personal Information about you as a data controller as described in
this section, where such processing has a legal basis or is in our legitimate
interests and not overridden by your data protection interests or fundamental
rights and freedoms. Our legitimate interests typically include: improving,
maintaining, providing, and enhancing our technology, products and services; and
ensuring the security of the Services.


ADDITIONAL DATA-PROCESSING PURPOSES

If additional data-processing purposes are added to the above we will let you
know prior to process whether the provision of Personal Information we are
collecting is compulsory or if it may be provided on a voluntary basis and the
consequences, if any, of not providing the information.


PROCESSING ARRANGEMENTS

Your Personal Data could be processed by a third party acting as separate
controller or, if necessary, as Data processor, on our behalf, in a
predominantly automated and computerized manner, in order to guarantee security
and confidentiality and to prevent unauthorized access to the data themselves.
We do not perform automated decision-making, including profiling.

We may need to communicate your Personal Data to third parties belonging to the
following categories:

 * People involved in technical and organizational activity on our behalf
   (including payroll activity);
 * Subsidiaries, parent companies and affiliates of the CoreView Group, of which
   CoreView s.r.l. is a part;
 * Business/marketing partner;
 * Authorities and in general, subjects, public or private, with functions of
   public importance;
 * External companies and / or professionals that assistance us;
 * Third-party companies for processing aimed for promotional initiatives, if
   you have expressed your consent.
   

The list of possible subjects to which your Personal Data can be communicated is
available at CoreView or by contacting us at: privacy@coreview.com

‍Your Personal Data could be processed also by our personnel, acting as
authorized or System administrator, according to their role in our company.

We will not sell, distribute or lease your Personal Information to third parties
unless we have your permission or are required by law to do so. Your Personal
Data will not be disseminated.

We also operate in the United States with CoreView USA Inc., a US-registered
company belonging to our group, member of the EU-US Privacy Shield
(Authorization to transfer data abroad by the agreement called “EU-US Privacy
Shield of 27 October 2016”, Published in the Official Gazette No. 273 of 22
November 2016). Therefore, with your consent, your data could be transferred to
the United States, in which case we guarantee all necessary precautions required
by law for non-EU transfers will be taken.


YOUR RIGHTS


The European Economic Area (EEA) provides certain rights to data subjects
(including access, rectification, erasure, restriction of processing, data
portability, and the right to object and to complain). We undertake to provide
you the same rights no matter where you choose to live.

As available and except as limited under applicable law, the rights afforded to
individuals are:


 1.  Right of Access (the right to be informed of and request access to the
     Personal Data we process about you);
 2.  Right to Rectification (the right to request that we amend or update your
     Personal Data where it is inaccurate or incomplete);
 3.  Right to Erasure (the right to request that we delete your Personal Data);
 4.  Right to Restrict (the right to request that we temporarily or permanently
     stop processing all or some of your Personal Data);
 5.  Right to Data Portability (the right to request a copy of your Personal
     Data in electronic format and the right to transmit that Personal Data for
     use in another party’s service);
 6.  Right to Object (the right, at any time, to object to us processing your
     Personal Data on grounds relating to your particular situation);
     
 7.  Right to object to your Personal Data being processed for direct marketing
     purposes;
     
 8.  Right not to be subject to Automated Decision-making (the right to not be
     subject to a decision based solely on automated decision-making, including
     profiling, where the decision would have a legal effect on you or produce a
     similarly significant effect);
     
 9.  Right to lodge a complaint with the Guarantor in the event of a breach in
     the processing of data pursuant to art. 77 of Regulation 2016/679;
     
 10. Right to appeal to the courts in the event of unlawful processing of the
     data, even against the acts undertaken by the Guarantor pursuant to art. 78
     of Regulation 2016/679.
     

If you have previously opted in to our marketing emails, you can opt out at any
time by clicking the “unsubscribe” link at the bottom of our marketing messages.
Also, all opt-out requests can be made by emailing us using the contact details
privacy@coreview.com

If you decide to withdraw your consent, we may continue to send you
non-promotional communications, unless you decide to unsubscribe from the
contact list. Please note that some communications (such as service messages,
account notifications, billing information) are considered transactional and
necessary for account management, and you cannot opt out of these messages
unless you cancel your account.

If you have any questions or concerns about your rights regarding the use of
your Personal Information, please contact us at: privacy@coreview.com. We will
reply as soon as possible after verifying your identity.



RETENTION OF DATA


Your Personal Data will be stored for a period of time not exceeding that
necessary to achieve the purposes for which it was collected and in any case for
the maximum time required by applicable law (for example, a ten-year
prescription for civil and administrative/accounting data).

Our retention periods will vary depending on the type of data involved, but,
generally, we’ll refer to these criteria in order to determine retention period:


 * Whether we have a legal or contractual need to retain the data
 * Whether the data is necessary to provide our Services
 * Whether our Customers have the ability to access and delete the data within
   their accounts
   
 * Whether our Customers would reasonably expect that we would retain the data
   until they remove it or until their accounts are closed or terminated

When we have no ongoing legitimate need to process your Personal Data, we will
either delete or anonymize it or, if this is not possible (for example, because
your Personal Data has been stored in backup archives), then we will securely
store your Personal Data and isolate it from any further processing until
deletion is possible.

Regarding the processing for marketing purposes, your data will be processed and
stored for a reasonable period of time in relation to the interest you have
shown towards our initiatives, which we will periodically check, except for your
opposition or request for revocation of the authorization to receive commercial
communications.



OUR SECURITY


We take appropriate and reasonable technical and organizational measures to
protect your Personal Data from loss, misuse, unauthorized access, disclosure,
alteration, and destruction, taking into account the risks involved in the
processing and the nature of the Personal Data.



DISCLAIMER


Our Services are intended for use by our Customers. As a result, for much of the
Personal Information we collect and process about Users through the Services, we
act as a processor on behalf of our Customers. We are not responsible for the
privacy or security practices of our Customers, which may differ from those set
forth in this privacy policy.



PRIVACY POLICY FOR CUSTOMERS


INTRODUCTION

This privacy policy explains who we are, how we collect, share and use Personal
Information, when you are our Customer, and how you can exercise your privacy
rights.

We are committed to ensuring that your privacy is protected. Should we ask you
to provide certain information by which you can be identified, you can be
assured that it will only be used in accordance with this Privacy Policy.

We may change this policy from time to time by updating this page. You should
check this page from time to time to ensure that you are happy with any changes.

If you do not agree with the content of this Policy, then please remember it is
your choice whether you want to use our Services. Your continued use of the
resources made available on our Services following the posting of any changes to
this policy constitutes acceptance of those changes.

If you have any questions or concerns about our use of your Personal
Information, then please contact us using the contacts provided below.


DATA CONTROLLER

The data controller is CoreView s.r.l. with registered office in via Palestrina,
33 20124 Milan (Italy). Our VAT number is 10146510960.

The requests relating to the exercise of the rights provided by the 2016/679
General Data Protection Regulation (“GDPR” or “Regulation”) can be sent, in
writing also by e-mail message, to privacy@coreview.com.

‍Requests relating to the identity of the Data Processors designated by CoreView
S.r.l. can be requested by e-mail sent to privacy@coreview.com.


CONTACT DATA OF THE DATA PROTECTION OFFICER

The Company has appointed a “data protection officer” (so-called “Data
Protection Officer” or “DPO”) provided for by the Regulation, who can be
contacted at the following e-mail address: privacy@coreview.com.


WHAT TYPE OF DATA WE COLLECT

Personal Data processed by us has been voluntarily provided by you or may also
be acquired by us in the exercise of our business or form third parties.

You are responsible for any personal and /or third party’s information that you
share with us and warrant that you have the right to disclose it, discharging us
of any liability toward third parties.

The data processed by us, either on its own or through third parties, could be:

 * First and last name, the data relating to your education and job; company
   name, the Personal Data of the legal representative / attorney; address and
   other elements of personal identification (date of birth, place of birth);
   demographic information such as postcode; Fiscal Code; contact information
   including e-mail, phone number, if you purchase our Services, billing and
   communications information (your credit card details and billing address,
   identification details of banking relationships as IBAN) preferences and
   business interests.
 * Personal Data we process on your behalf: If you purchase our Services, you
   need to provide us information about Services’ users, such as their names and
   email addresses, their devices and usage of the Services. We use and process
   this information to provide the Services in accordance with your
   instructions.
 * Personal Data we collect from other sources: We may obtain information about
   you from third-party sources, such as public databases, social media
   platforms, third-party data providers and our joint marketing partners. We
   take steps to ensure that such third parties are legally or contractually
   permitted to disclose such information to us. Examples of the information we
   receive from other sources include demographic information, device
   information, location (such as city and state), and online behavioural data.

We do not collect, access or scan any of your organisation’s content including,
but not limited to:

 * Email messages
 * Calendar entries
 * Contact lists or Address books
 * SharePoint documents or content

We do not process neither do we process any “particular” Personal Data, such as,
for example, the Personal Data suitable to reveal the state of health, political
opinions, religious beliefs, etc…


WHAT WE DO WITH PERSONAL DATA WE GATHER

We use your personal data for a variety of purposes including:

 * Management of relations with you deriving from the signed contract;
 * Compliance with legal obligations;
 * Improve our activity and our Services (eg. Detection of the degree of
   customer satisfaction on the quality of services rendered and on the activity
   carried out by us, the preparation of studies and market research);
 * Inform you with marketing communications about our products and / or services
   that we think you may be interested in through letters, telephone,
   advertising material, automated communication systems and in particular,
   newsletters (subject to your specific, express consent).The provision of
   personal data by you necessary for the purposes referred to in point a), is
   not mandatory, but the refusal to supply them may make it impossible for us
   to provide the Services. Their processing does not require your consent.

The provision of personal data necessary for the purposes referred to in point
b) is mandatory and the relative processing does not require your consent. The
provision of personal data necessary for the purposes referred to in point c) is
not mandatory and the relative processing requires your consent. The provision
of data necessary for the purposes referred to in the previous letter d) is not
mandatory and their processing requires your consent, freely expressible and
modifiable at any time as better described below (“Your rights”).


LEGAL BASIS FOR PROCESSING

We process Personal Information about you as a data controller as described in
this section, where such processing has a legal basis or is in our legitimate
interests, and not overridden by your data protection interests or fundamental
rights and freedoms. Our legitimate interests typically include: improving,
maintaining, providing, and enhancing our technology, products and services; and
ensuring the security of the Services.


ADDITIONAL DATA-PROCESSING PURPOSES

If additional data-processing purposes are added to the above we will let you
know prior to process whether the provision of Personal Information we are
collecting is compulsory or if it may be provided on a voluntary basis and the
consequences, if any, of not providing the information. By giving us this
information, you agree to this information being collected, used and disclosed
as described in our Terms of use and in this Privacy Policy.


PROCESSING ARRANGEMENTS

Your Personal Data could be processed by a third party acting as separate
controller or, if necessary, as Data processor, on our behalf, in a
predominantly automated and computerized manner, in order to guarantee security
and confidentiality and to prevent unauthorized access to the data themselves.
We do not perform automated decision-making, including profiling.

We may need to communicate your Personal Data to third parties belonging to the
following categories:

 * People involved in technical and organizational activity on our behalf
   (including payroll activity);
 * Subsidiaries, parent companies and affiliates of the CoreView Group, of which
   CoreView s.r.l. is a part;
 * Business/marketing partner;
 * Authorities and in general, subjects, public or private, with functions of
   public importance;
 * External companies and / or professionals that assistance us;
 * Third-party companies for processing aimed for promotional initiatives, if
   you have expressed your consent.
   

The list of possible subjects to which your Personal Data can be communicated is
available at CoreView s.r.l. or contacting us at: privacy@coreview.com

‍Your Personal data could be processed also by our personnel, acting as
authorized or System administrator, according to their role in our company.

We will not sell, distribute or lease your personal information to third parties
unless we have your permission or are required by law to do so. Your personal
data will not be disseminated.

We also operate in the United States with CoreView USA Inc., a US-registered
company belonging to our group, member of the EU-US Privacy Shield
(Authorization to transfer data abroad by the agreement called “EU-US Privacy
Shield of 27 October 2016”, Published in the Official Gazette No. 273 of 22
November 2016); therefore, with your consent, your data could be transferred to
the United States, in which case we guarantee all necessary precautions required
by law for non-EU transfers will be taken.


YOUR RIGHTS


The European Economic Area (EEA) provides certain rights to data subjects
(including access, rectification, erasure, restriction of processing, data
portability, and the right to object and to complain). We undertake to provide
you the same rights no matter where you choose to live.

As available and except as limited under applicable law, the rights afforded to
individuals are:


 1.  Right of Access (the right to be informed of and request access to the
     Personal Data we process about you);
 2.  Right to Rectification (the right to request that we amend or update your
     Personal Data where it is inaccurate or incomplete);
 3.  Right to Erasure (the right to request that we delete your Personal Data);
 4.  Right to Restrict (the right to request that we temporarily or permanently
     stop processing all or some of your Personal Data);
 5.  Right to Data Portability (the right to request a copy of your Personal
     Data in electronic format and the right to transmit that Personal Data for
     use in another party’s service);
 6.  Right to Object (the right, at any time, to object to us processing your
     Personal Data on grounds relating to your particular situation);
     
 7.  Right to object to your Personal Data being processed for direct marketing
     purposes;
     
 8.  Right not to be subject to Automated Decision-making (the right to not be
     subject to a decision based solely on automated decision-making, including
     profiling, where the decision would have a legal effect on you or produce a
     similarly significant effect);
     
 9.  Right to lodge a complaint with the Guarantor in the event of a breach in
     the processing of data pursuant to art 77 of Regulation 2016/679;
     
 10. Right to appeal to the courts in the event of unlawful processing of the
     data, even against the acts undertaken by the Guarantor pursuant to art 78
     of Regulation 2016/679.
     

If you have previously opted in to our marketing emails, you can opt out at any
time by clicking the “unsubscribe” link at the bottom of our marketing messages.
Also, all opt-out requests can be made by emailing us using the contact details
privacy@coreview.com

If you decide to withdraw your consent, we may continue to send you
non-promotional communications, unless you decide to unsubscribe from the
contact list. Please note that some communications (such as service messages,
account notifications, billing information) are considered transactional and
necessary for account management, and you cannot opt out of these messages
unless you cancel your account.

If you have any questions or concerns about your rights regarding the use of
your Personal Information, please contact us at: privacy@coreview.com. We will
reply as soon as possible after verifying your identity.



RETENTION OF DATA


Your Personal Data will be stored for a period of time not exceeding that
necessary to achieve the purposes for which it was collected and in any case for
the maximum time required by applicable law (for example, a ten-year
prescription for civil and administrative/accounting data).

Our retention periods will vary depending on the type of data involved, but,
generally, we’ll refer to these criteria in order to determine retention period:


 * Whether we have a legal or contractual need to retain the data
 * Whether the data is necessary to provide our Services
 * Whether our Customers have the ability to access and delete the data within
   their accounts
   
 * Whether our Customers would reasonably expect that we would retain the data
   until they remove it or until their accounts are closed or terminated

When we have no ongoing legitimate need to process your Personal Data, we will
either delete or anonymize it or, if this is not possible (for example, because
your Personal Data has been stored in backup archives), then we will securely
store your Personal Data and isolate it from any further processing until
deletion is possible.

Regarding the processing for marketing purposes, your data will be processed and
stored for a reasonable period of time in relation to the interest you have
shown towards our initiatives, which we will periodically check, except for your
opposition or request for revocation of the authorization to receive commercial
communications.



OUR SECURITY


We take appropriate and reasonable technical and organizational measures to
protect your Personal Data from loss, misuse, unauthorized access, disclosure,
alteration, and destruction, taking into account the risks involved in the
processing and the nature of the Personal Data.



DISCLAIMER


Our Services are intended for use by our Customers. As a result, for much of the
Personal Information we collect and process about Users through the Services, we
act as a processor on behalf of our Customers. We are not responsible for the
privacy or security practices of our Customers, which may differ from those set
forth in this privacy policy.



PRIVACY POLICY FOR SUPPLIERS


INTRODUCTION

This privacy policy explains who we are, how we collect, share and use Personal
Information, when you are our Customer, and how you can exercise your privacy
rights.

We are committed to ensuring that your privacy is protected. Should we ask you
to provide certain information by which you can be identified, you can be
assured that it will only be used in accordance with this Privacy Policy.

We may change this policy from time to time by updating this page. You should
check this page from time to time to ensure that you are happy with any changes.

If you do not agree with the content of this Policy, then please remember it is
your choice whether you want to use our Services. Your continued use of the
resources made available on our Services following the posting of any changes to
this policy constitutes acceptance of those changes.

If you have any questions or concerns about our use of your Personal
Information, then please contact us using the contacts provided below.


DATA CONTROLLER

The data controller is CoreView s.r.l. with registered office in via Palestrina,
33 20124 Milan (Italy). Our VAT number is 10146510960.

The requests relating to the exercise of the rights provided by the 2016/679
General Data Protection Regulation (“GDPR” or “Regulation”) can be sent, in
writing also by e-mail message, to privacy@coreview.com.

‍Requests relating to the identity of the Data Processors designated by CoreView
S.r.l. can be requested by e-mail sent to privacy@coreview.com.


CONTACT DATA OF THE DATA PROTECTION OFFICER

The Company has appointed a “data protection officer” (so-called “Data
Protection Officer” or “DPO”) provided for by the Regulation, who can be
contacted at the following e-mail address: privacy@coreview.com.


WHAT TYPE OF DATA WE COLLECT

Personal Data processed by us have been voluntarily provided by you.

The data processed by us, either on its own or through third parties, could be:

 * First and last name, company name, for the companies, the personal data of
   the legal representative / attorney; address and other elements of personal
   identification (date of birth, place of birth, tax code of the legal
   representative); fiscal Code; contact information including e-mail, phone
   number; Billing and communications information (billing address,
   identification details of banking relationships as IBAN).

We do not process any “particular” personal data such as, for example, the
personal data suitable to reveal the state of health, political opinions,
religious beliefs, etc…


WHAT WE DO WITH PERSONAL DATA WE GATHER

We use your personal data for a variety of purposes including:

 * Management of relations with you deriving from the signed contract;
 * Compliance with legal obligations;
 * Litigation management

The provision of personal data by you necessary for the purposes referred to in
point a), is not mandatory, but the refusal to supply them may make it
impossible for us to sign a contract with you. Their processing does not require
your consent.

The provision of personal data necessary for the purposes referred to in point
b) c) is mandatory and the relative processing does not require your consent.


ADDITIONAL DATA-PROCESSING PURPOSES

If additional data-processing purposes are added to the above we will let you
know prior to process whether the provision of Personal Information we are
collecting is compulsory or if it may be provided on a voluntary basis and the
consequences, if any, of not providing the information. By giving us this
information, you agree to this information being collected, used and disclosed
as described in our Terms of use and in this Privacy Policy.


PROCESSING ARRANGEMENTS

Your Personal Data could be processed by a third party acting as separate
controller or, if necessary, as Data processor, on our behalf, in a
predominantly automated and computerized manner, in order to guarantee security
and confidentiality and to prevent unauthorized access to the data themselves.
We do not perform automated decision-making, including profiling.

We may need to communicate your Personal Data to third parties belonging to the
following categories:

 * People involved in technical and organizational activity on our behalf
   (including payroll activity);
 * Subsidiaries, parent companies and affiliates of the Corview Group, of which
   CoreView s.r.l. is a part;
 * Business/marketing partner;
 * Authorities and in general, subjects, public or private, with functions of
   public importance;
 * External companies and / or professionals that assistance us;
 * Third-party companies for processing aimed for promotional initiatives, if
   you have expressed your consent.
   

The list of possible subjects to which your Personal Data can be communicated is
available at CoreView s.r.l. or contacting us at: privacy@coreview.com

‍Your Personal data could be processed also by our personnel, acting as
authorized or System administrator, according to their role in our company.

We will not sell, distribute or lease your personal information to third parties
unless we have your permission or are required by law to do so. Your personal
data will not be disseminated.

We also operate in the United States with CoreView USA Inc., a US-registered
company belonging to our group, member of the EU-US Privacy Shield
(Authorization to transfer data abroad by the agreement called “EU-US Privacy
Shield of 27 October 2016”, Published in the Official Gazette No. 273 of 22
November 2016); therefore, with your consent, your data could be transferred to
the United States, in which case we guarantee all necessary precautions required
by law for non-EU transfers will be taken.


YOUR RIGHTS


The European Economic Area (EEA) provides certain rights to data subjects
(including access, rectification, erasure, restriction of processing, data
portability, and the right to object and to complain). We undertake to provide
you the same rights no matter where you choose to live.

As available and except as limited under applicable law, the rights afforded to
individuals are:


 1.  Right of Access (the right to be informed of and request access to the
     Personal Data we process about you);
 2.  Right to Rectification (the right to request that we amend or update your
     Personal Data where it is inaccurate or incomplete);
 3.  Right to Erasure (the right to request that we delete your Personal Data);
 4.  Right to Restrict (the right to request that we temporarily or permanently
     stop processing all or some of your Personal Data);
 5.  Right to Data Portability (the right to request a copy of your Personal
     Data in electronic format and the right to transmit that Personal Data for
     use in another party’s service);
 6.  Right to Object (the right, at any time, to object to us processing your
     Personal Data on grounds relating to your particular situation);
     
 7.  Right to object to your Personal Data being processed for direct marketing
     purposes;
     
 8.  Right not to be subject to Automated Decision-making (the right to not be
     subject to a decision based solely on automated decision-making, including
     profiling, where the decision would have a legal effect on you or produce a
     similarly significant effect);
     
 9.  Right to lodge a complaint with the Guarantor in the event of a breach in
     the processing of data pursuant to art 77 of Regulation 2016/679;
     
 10. Right to appeal to the courts in the event of unlawful processing of the
     data, even against the acts undertaken by the Guarantor pursuant to art 78
     of Regulation 2016/679.
     

If you have previously opted in to our marketing emails, you can opt out at any
time by clicking the “unsubscribe” link at the bottom of our marketing messages.
Also, all opt-out requests can be made by emailing us using the contact details
privacy@coreview.com

If you decide to withdraw your consent, we may continue to send you
non-promotional communications, unless you decide to unsubscribe from the
contact list. Please note that some communications (such as service messages,
account notifications, billing information) are considered transactional and
necessary for account management, and you cannot opt out of these messages
unless you cancel your account.

If you have any questions or concerns about your rights regarding the use of
your Personal Information, please contact us at: privacy@coreview.com. We will
reply as soon as possible after verifying your identity.



RETENTION OF DATA


Your Personal Data will be stored for a period of time not exceeding that
necessary to achieve the purposes for which it was collected and in any case for
the maximum time required by applicable law (for example, a ten-year
prescription for civil and administrative/accounting data).

Our retention periods will vary depending on the type of data involved, but,
generally, we’ll refer to these criteria in order to determine retention period:


 * Whether we have a legal or contractual need to retain the data
 * Whether the data is necessary to provide our Services
 * Whether our Customers have the ability to access and delete the data within
   their accounts
   
 * Whether our Customers would reasonably expect that we would retain the data
   until they remove it or until their accounts are closed or terminated

When we have no ongoing legitimate need to process your Personal Data, we will
either delete or anonymize it or, if this is not possible (for example, because
your Personal Data has been stored in backup archives), then we will securely
store your Personal Data and isolate it from any further processing until
deletion is possible.

Regarding the processing for marketing purposes, your data will be processed and
stored for a reasonable period of time in relation to the interest you have
shown towards our initiatives, which we will periodically check, except for your
opposition or request for revocation of the authorization to receive commercial
communications.



OUR SECURITY


We take appropriate and reasonable technical and organizational measures to
protect your Personal Data from loss, misuse, unauthorized access, disclosure,
alteration, and destruction, taking into account the risks involved in the
processing and the nature of the Personal Data.



PRIVACY POLICY FOR CANDIDATES


INTRODUCTION

This privacy policy explains who we are, how we process your personal
information (or personal data) we collect for the purpose of evaluating a
possible employment or collaboration relationship with you and how you can
exercise your privacy rights.

We are committed to ensuring that your privacy is protected. Should we ask you
to provide certain information by which you can be identified, you can be
assured that it will only be used in accordance with this Privacy Policy.

We may change this policy from time to time by updating this page. You should
check this page from time to time to ensure that you are happy with any changes.

If you have any questions or concerns about our use of your Personal
Information, then please contact us using privacy@coreview.com


DATA CONTROLLER

The data controller is CoreView s.r.l. with registered office in via Palestrina,
33 20124 Milan (Italy). Our VAT number is 10146510960.

The requests relating to the exercise of the rights provided by the 2016/679
General Data Protection Regulation (“GDPR” or “Regulation”) can be sent, in
writing also by e-mail message, to privacy@coreview.com.

‍Requests relating to the identity of the Data Processors designated by CoreView
S.r.l. can be requested by e-mail sent to privacy@coreview.com.


CONTACT DATA OF THE DATA PROTECTION OFFICER

The Company has appointed a “data protection officer” (so-called “Data
Protection Officer” or “DPO”) provided for by the Regulation, who can be
contacted at the following e-mail address: privacy@coreview.com.


WHAT TYPE OF DATA WE COLLECT

Personal data processed by us have been voluntarily provided by you or may also
be acquired by us in the exercise of our business or by third parties.

The data processed by us, either on its own or through third parties, could be:

 * First and last name, the data relating to your education and job; address and
   other elements of personal identification (date of birth, place of birth);
   Fiscal code; contact information including e-mail, phone number.
 * We do not process any personal data “particular” such as, for example, the
   personal data suitable to reveal the state of health, political opinions,
   religious beliefs, etc.. Please do not publish such data unless absolutely
   necessary.


WHAT WE DO WITH YOUR PERSONAL DATA

We use your personal data exclusively for personnel research activities carried
out for our own business needs; the provision of personal data by you is not
mandatory, but the refusal to supply them may make it impossible for us to
evaluate your professional profile for the establishment of a working
relationship and / or collaboration with us. Their processing require your
consent.


ADDITIONAL DATA-PROCESSING PURPOSES

If additional data-processing purposes are added to the above we will let you
know prior to process whether the provision of Personal Information we are
collecting is compulsory or if it may be provided on a voluntary basis and the
consequences, if any, of not providing the information. By giving us this
information, you agree to this information being collected, used and disclosed
as described in our Terms of use and in this Privacy Policy.


PROCESSING ARRANGEMENTS

Your Personal Data could be processed by a third party acting as separate
controller or, if necessary, as Data processor, on our behalf, in a
predominantly automated and computerized manner, in order to guarantee security
and confidentiality and to prevent unauthorized access to the data themselves.
We do not perform automated decision-making, including profiling.

We may need to communicate your Personal Data to third parties belonging to the
following categories:

 * People involved in technical and organizational activity on our behalf;
   
 * Subsidiaries, parent companies and affiliates of the CoreView Group, of which
   CoreView s.r.l. is a part;
   
 * Business/marketing partner

The list of possible subjects to which your Personal Data can be communicated is
available at CoreView s.r.l. or contacting us at: privacy@coreview.com

‍Your Personal data could be processed also by our personnel, acting as
authorized or System administrator, according to their role in our company.

We will not sell, distribute or lease your personal information to third parties
unless we have your permission or are required by law to do so. Your personal
data will not be disseminated.

We also operate in the United States with CoreView USA Inc., a US-registered
company belonging to our group, member of the EU-US Privacy Shield
(Authorization to transfer data abroad by the agreement called “EU-US Privacy
Shield of 27 October 2016”, Published in the Official Gazette No. 273 of 22
November 2016); therefore, with your consent, your data could be transferred to
the United States, in which case we guarantee all necessary precautions required
by law for non-EU transfers will be taken.


YOUR RIGHTS


The European Economic Area (EEA) provides certain rights to data subjects
(including access, rectification, erasure, restriction of processing, data
portability, and the right to object and to complain). We undertake to provide
you the same rights no matter where you choose to live.

As available and except as limited under applicable law, the rights afforded to
individuals are:


 1.  Right of Access (the right to be informed of and request access to the
     Personal Data we process about you);
 2.  Right to Rectification (the right to request that we amend or update your
     Personal Data where it is inaccurate or incomplete);
 3.  Right to Erasure (the right to request that we delete your Personal Data);
 4.  Right to Restrict (the right to request that we temporarily or permanently
     stop processing all or some of your Personal Data);
 5.  Right to Data Portability (the right to request a copy of your Personal
     Data in electronic format and the right to transmit that Personal Data for
     use in another party’s service);
 6.  Right to Object (the right, at any time, to object to us processing your
     Personal Data on grounds relating to your particular situation);
     
 7.  Right to object to your Personal Data being processed for direct marketing
     purposes;
     
 8.  Right not to be subject to Automated Decision-making (the right to not be
     subject to a decision based solely on automated decision-making, including
     profiling, where the decision would have a legal effect on you or produce a
     similarly significant effect);
     
 9.  Right to lodge a complaint with the Guarantor in the event of a breach in
     the processing of data pursuant to art 77 of Regulation 2016/679;
     
 10. Right to appeal to the courts in the event of unlawful processing of the
     data, even against the acts undertaken by the Guarantor pursuant to art 78
     of Regulation 2016/679.
     

If you have previously opted in to our marketing emails, you can opt out at any
time by clicking the “unsubscribe” link at the bottom of our marketing messages.
Also, all opt-out requests can be made by emailing us using the contact details
privacy@coreview.com

If you decide to withdraw your consent, we may continue to send you
non-promotional communications, unless you decide to unsubscribe from the
contact list. Please note that some communications (such as service messages,
account notifications, billing information) are considered transactional and
necessary for account management, and you cannot opt out of these messages
unless you cancel your account.

If you have any questions or concerns about your rights regarding the use of
your Personal Information, please contact us at: privacy@coreview.com. We will
reply as soon as possible after verifying your identity.



PRIVACY POLICY FOR CONTACTS


INTRODUCTION

This privacy policy explains who we are, how we collect, share and use your
Personal Information we collect when you visit our website or you contact us via
forms through the site www.coreview.com (“Contact”, “Request a trial”, “Sign up
for news and updates”) or we receive from our business partner, and how you can
exercise your privacy rights.

We are committed to ensuring that your privacy is protected. Should we ask you
to provide certain information by which you can be identified, you can be
assured that it will only be used in accordance with this Privacy Policy.

We may change this policy from time to time by updating this page. You should
check this page from time to time to ensure that you are happy with any changes.

If you have any questions or concerns about our use of your Personal
Information, then please contact us using the contact provided below.


DATA CONTROLLER

The data controller is CoreView s.r.l. with registered office in via Palestrina,
33 20124 Milan (Italy). Our VAT number is 10146510960.

The requests relating to the exercise of the rights provided by the 2016/679
General Data Protection Regulation (“GDPR” or “Regulation”) can be sent, in
writing also by e-mail message, to privacy@coreview.com.

‍Requests relating to the identity of the Data Processors designated by CoreView
S.r.l. can be requested by e-mail sent to privacy@coreview.com.


CONTACT DATA OF THE DATA PROTECTION OFFICER

The Company has appointed a “data protection officer” (so-called “Data
Protection Officer” or “DPO”) provided for by the Regulation, who can be
contacted at the following e-mail address: privacy@coreview.com.


WHAT TYPE OF DATA WE COLLECT

Personal Data processed by us has been voluntarily provided by you or may also
be acquired by us automatically through cookies or by our business partners.

Your data processed by us, either on its own or through third parties, could be:

 * First and Last Name, Address and personal identification data (date of birth,
   place of birth), contact information including e-mail, phone number; the data
   relating to your education and job title; preferences and business interests,
   company name, the personal data of the legal representative / attorney;
   demographic information such as postcode.
 * For more info about your personal data we collect thought cookies, please
   visit our cookie policy.
 * We do not process any “particular” personal data mentioned such as, for
   example, the personal data suitable to reveal the state of health, political
   opinions, religious beliefs, etc…


WHAT WE DO WITH PERSONAL DATA WE GATHER

We use your personal data for a variety of purposes including:

 * Management of your request;
   
 * Compliance with legal obligations;
   
 * Inform you with marketing communications about our products and / or services
   that we think you may be interested in through letters, telephone,
   advertising material, automated communication systems and in particular,
   newsletters.

The provision by you of personal data necessary for the purposes referred to in
point a.) is not mandatory, but the refusal to supply them may make it
impossible for us to manage your request. Their processing require your consent.

The provision of personal data necessary for the purposes referred to in point
b) is mandatory and the relative processing does not require your consent.

The provision of personal data necessary for the purposes referred to in point
c) is not mandatory and the relative processing require your consent freely
expressible and modifiable at any time as better described below (“Your
rights”).


LEGAL BASIS FOR PROCESSING

We process Personal Information about you as a data controller as described in
this section, where such processing has a legal basis or is in our legitimate
interests and not overridden by your data protection interests or fundamental
rights and freedoms. Our legitimate interests typically include: improving,
maintaining, providing, and enhancing our technology, products and services; and
ensuring the security of the Services.


ADDITIONAL DATA-PROCESSING PURPOSES

If additional data-processing purposes are added to the above we will let you
know prior to process whether the provision of Personal Information we are
collecting is compulsory or if it may be provided on a voluntary basis and the
consequences, if any, of not providing the information. By giving us this
information, you agree to this information being collected, used and disclosed
as described in our Terms of use and in this Privacy Policy.


PROCESSING ARRANGEMENTS

Your Personal Data could be processed by a third party acting as separate
controller or, if necessary, as Data processor, on our behalf, in a
predominantly automated and computerized manner, in order to guarantee security
and confidentiality and to prevent unauthorized access to the data themselves.
We do not perform automated decision-making, including profiling.

We may need to communicate your Personal Data to third parties belonging to the
following categories:

 * People involved in technical and organizational activity on our behalf;
   
 * Subsidiaries, parent companies and affiliates of the CoreView Group, of which
   CoreView s.r.l. is a part;
   
 * Third-party companies for processing aimed for promotional initiatives, if
   you have expressed your consent.

The list of possible subjects to which your Personal Data can be communicated is
available at CoreView s.r.l. or contacting us at: privacy@coreview.com

‍Your Personal data could be processed also by our personnel, acting as
authorized or System administrator, according to their role in our company.

We will not sell, distribute or lease your personal information to third parties
unless we have your permission or are required by law to do so. Your personal
data will not be disseminated.

We also operate in the United States with CoreView USA Inc., a US-registered
company belonging to our group, member of the EU-US Privacy Shield
(Authorization to transfer data abroad by the agreement called “EU-US Privacy
Shield of 27 October 2016”, Published in the Official Gazette No. 273 of 22
November 2016); therefore, with your consent, your data could be transferred to
the United States, in which case we guarantee all necessary precautions required
by law for non-EU transfers will be taken.


YOUR RIGHTS


The European Economic Area (EEA) provides certain rights to data subjects
(including access, rectification, erasure, restriction of processing, data
portability, and the right to object and to complain). We undertake to provide
you the same rights no matter where you choose to live.

As available and except as limited under applicable law, the rights afforded to
individuals are:


 1.  Right of Access (the right to be informed of and request access to the
     Personal Data we process about you);
 2.  Right to Rectification (the right to request that we amend or update your
     Personal Data where it is inaccurate or incomplete);
 3.  Right to Erasure (the right to request that we delete your Personal Data);
 4.  Right to Restrict (the right to request that we temporarily or permanently
     stop processing all or some of your Personal Data);
 5.  Right to Data Portability (the right to request a copy of your Personal
     Data in electronic format and the right to transmit that Personal Data for
     use in another party’s service);
 6.  Right to Object (the right, at any time, to object to us processing your
     Personal Data on grounds relating to your particular situation);
     
 7.  Right to object to your Personal Data being processed for direct marketing
     purposes;
     
 8.  Right not to be subject to Automated Decision-making (the right to not be
     subject to a decision based solely on automated decision-making, including
     profiling, where the decision would have a legal effect on you or produce a
     similarly significant effect);
     
 9.  Right to lodge a complaint with the Guarantor in the event of a breach in
     the processing of data pursuant to art 77 of Regulation 2016/679;
     
 10. Right to appeal to the courts in the event of unlawful processing of the
     data, even against the acts undertaken by the Guarantor pursuant to art 78
     of Regulation 2016/679.
     

If you have previously opted in to our marketing emails, you can opt out at any
time by clicking the “unsubscribe” link at the bottom of our marketing messages.
Also, all opt-out requests can be made by emailing us using the contact details
privacy@coreview.com

If you decide to withdraw your consent, we may continue to send you
non-promotional communications, unless you decide to unsubscribe from the
contact list. If you have any questions or concerns about your rights regarding
the use of your personal information, please contact us at: privacy@coreview.com

We will reply as soon as possible after verifying your identity.



RETENTION OF DATA


Your personal data will be stored for a period of time not exceeding that
necessary to achieve the purposes for which it was collected and in any case for
the maximum time of two years required by the applicable law, if in the meantime
the right of opposition is not exercised by you or you have not withdrawn your
consent or a contractual relations is not established among us.

When we have no ongoing legitimate need to process your Personal data, we will
either delete or anonymize it or, if this is not possible (for example, because
your Personal data has been stored in backup archives), then we will securely
store your Personal data and isolate it from any further processing until
deletion is possible.



OUR SECURITY


We take appropriate and reasonable technical and organizational measures to
protect your Personal data from loss, misuse, unauthorized access, disclosure,
alteration, and destruction, taking into account the risks involved in the
processing and the nature of the Personal data.



COOKIES POLICY


INTRODUCTION

This privacy policy explains how we use cookie to collect your Personal
information when you visit our website www.coreview.com and how you can exercise
your privacy rights.

We are committed to ensuring that your privacy is protected. Should we ask you
to provide certain information by which you can be identified, you can be
assured that it will only be used in accordance with this Privacy Policy.

We may change this policy from time to time by updating this page. You should
check this page from time to time to ensure that you are happy with any changes.
If you do not agree with the content of this Policy, then please remember it is
your choice whether to use our website.

If you have any questions or concerns about our use of your Personal
Information, then please visit our Privacy Policy (General or for Contacts) and
contact us using privacy@coreview.com.


DATA CONTROLLER

The data controller is CoreView s.r.l. with registered office in via Palestrina,
33 20124 Milan (Italy). Our VAT number is 10146510960.

The requests relating to the exercise of the rights provided by the 2016/679
General Data Protection Regulation (“GDPR” or “Regulation”) can be sent, in
writing also by e-mail message, to privacy@coreview.com.

‍Requests relating to the identity of the Data Processors designated by CoreView
S.r.l. can be requested by e-mail sent to privacy@coreview.com.


CONTACT DATA OF THE DATA PROTECTION OFFICER

The Company has appointed a “data protection officer” (so-called “Data
Protection Officer” or “DPO”) provided for by the Regulation, who can be
contacted at the following e-mail address: privacy@coreview.com.


WHAT ARE COOKIES?

We may use cookies and other tracking technologies described in this Cookie
policy to collect Personal Information, or to collect information that becomes
Personal Information if we combine it with other information we have collected.
For more information about how we process your Personal Information, please
consult our Privacy policy on our website. A cookie is a small file which asks
permission to be placed on your computer’s hard drive. Once you agree, the file
is added and the cookie helps analyze web traffic or lets us know when you visit
a particular site. Cookies allow web applications to respond to you as an
individual. The web application can tailor its operations to your needs, likes
and dislikes by gathering and remembering information about your preferences.


WHY DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

TECHNICAL COOKIES

We use third party analytics service to identify which pages are being used.
This helps us to analyze data about web page traffic and improve our website in
order to tailor it to customer needs. We only use this information for
statistical analysis purposes and then the data is removed from the system.
Cookies help us provide you with a better website, by enabling us to monitor
which pages you find useful and which you do not. A cookie in no way gives us
access to your computer or any information about you, other than the data you
choose to share with us.

You can find third party documentation here below:

 * Google Analytics: Is a web analytics service provided by Google, Inc.
   (“Google”). The information generated by the cookie on the website’s use
   (including IP address) is collected by Google and filed with Google servers
   in the United States. Google will use this information to track and review
   website usage, compile website activity reports, and provide other website
   activity services: https://policies.google.com/privacy
   https://tools.google.com/dlpage/gaoptout‍
   

PROFILING COOKIES

With your consent, which is free and optional, we may use third-party profiling
cookies, that are cookies designed to create user profiles for remarketing
purposes, to promote advertising based on preferences expressed by you in
navigation within the website. These data are collected and processed using the
following services:

 * AdWords Remarketing (Google Inc.): AdWords Remarketing is a marketing service
   provided by Google Inc. It connects the activity of www.example.com with the
   Adwords advertising network and the Doubleclick Cookie. You can opt out of
   the cookie tracking here: https://support.google.com/ads/answer/2662922?hl=en
   
 * Personal Data collected: Cookie and Usage Data. Place of processing: Itay –
   Find the Privacy Policy
   


HOW TO MANAGE COOKIES

You can choose to accept or decline cookies.

Most web browsers automatically accept cookies, but you can usually modify your
browser setting to decline cookies if you prefer.

You can delete all cookies that are already on your computer and you can set
most browsers to prevent them from being placed. You can find information about
how to manage cookies in every browser at the following addresses: Google
Chrome, Mozilla Firefox, Apple Safari, Microsoft Windows Explorer.

In the case of cookies provided by third parties, you can also exercise his
right to oppose the tracking inquiring through the privacy policy of the third
party, via the opt out link if explicitly provided or by contacting it directly.
Notwithstanding the foregoing, the Data Controller informs that you can use Your
Online Choices. Through this service it is possible to manage the tracking
preferences of most advertising tools.

You can delete or block these cookies, but this may prevent you from taking full
advantage of the website.


YOUR RIGHTS


The European Economic Area (EEA) provides certain rights to data subjects
(including access, rectification, erasure, restriction of processing, data
portability, and the right to object and to complain). We undertake to provide
you the same rights no matter where you choose to live.

As available and except as limited under applicable law, the rights afforded to
individuals are:


 1.  Right of Access (the right to be informed of and request access to the
     Personal Data we process about you);
 2.  Right to Rectification (the right to request that we amend or update your
     Personal Data where it is inaccurate or incomplete);
 3.  Right to Erasure (the right to request that we delete your Personal Data);
 4.  Right to Restrict (the right to request that we temporarily or permanently
     stop processing all or some of your Personal Data);
 5.  Right to Data Portability (the right to request a copy of your Personal
     Data in electronic format and the right to transmit that Personal Data for
     use in another party’s service);
 6.  Right to Object (the right, at any time, to object to us processing your
     Personal Data on grounds relating to your particular situation);
     
 7.  Right to object to your Personal Data being processed for direct marketing
     purposes;
     
 8.  Right not to be subject to Automated Decision-making (the right to not be
     subject to a decision based solely on automated decision-making, including
     profiling, where the decision would have a legal effect on you or produce a
     similarly significant effect);
     
 9.  Right to lodge a complaint with the Guarantor in the event of a breach in
     the processing of data pursuant to art 77 of Regulation 2016/679;
     
 10. Right to appeal to the courts in the event of unlawful processing of the
     data, even against the acts undertaken by the Guarantor pursuant to art 78
     of Regulation 2016/679.
     

If you have previously opted in to our marketing emails, you can opt out at any
time by clicking the “unsubscribe” link at the bottom of our marketing messages.
Also, all opt-out requests can be made by emailing us using the contact details
privacy@coreview.com

‍If you have any questions or concerns about your rights regarding the use of
your personal information, please contact us at: privacy@coreview.com. We will
reply as soon as possible after verifying your identity.



RETENTION OF DATA


Personal data will be processed up to the request of the interested party.



LINKS TO OTHER WEBSITES


Our website may contain links to other websites of interest. However, once you
have used these links to leave our site, you should note that we do not have any
control over that other website. Therefore, we cannot be responsible for the
protection and privacy of any information which you provide whilst visiting such
sites and such sites are not governed by this privacy statement. You should
exercise caution and look at the privacy statement applicable to the website in
question.


 * Privacy Information
 * Privacy Policy For Customers
 * Privacy Policy For Suppliers
 * Privacy Policy For Candidates
 * Privacy Policy For Contacts
 * Cookies Policy

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