個人情報保護方針

PRIVACY INFORMATION NOTICE FOR CANDIDATES

By means of this document, we wish to provide you with information regarding the processing of personal data of candidates who submit their curriculum vitae to one of the Companies (as defined below) or otherwise participate in selection procedures aimed at establishing employment or collaboration relationships with them (the “Candidate” or the “Data Subject“), in accordance with the provisions of Legislative Decree no. 196/2003, as subsequently amended and supplemented (the “Privacy Code“), and EU Regulation 2016/679 (hereinafter, the “Privacy Regulation“).

  1. Data Controller and Data Protection Officer (DPO)

Depending on the search and selection procedure activated from time to time, the autonomous data controller of your personal data is:

  • FENDI S.r.l., with registered office at Palazzo della Civiltà, Quadrato della Concordia n.3, 00144, Rome (RM), Italy, phone 06334501 email privacy@fendi.com; or
  • FENDI Italia S.r.l., with registered office at Palazzo della Civiltà, Quadrato della Concordia n.3, 00144, Rome (RM), Italy, phone 06334501 email privacy@fendi.com

(hereinafter, collectively, “FENDI” or the “Companies“).

FENDI S.r.l. has also appointed a Data Protection Officer (“DPO“), who can be contacted via the dedicated email dpo@fendi.com.

  1. Categories of personal data subject to processing and data collection methods

The Companies will proceed with the collection and processing of the following categories of common personal data and, if applicable, special categories (together, the “Personal Data“), in accordance with the provisions of this information and the documents referred to therein and, in any case, within the limits and to the extent provided by the applicable legislation or collective agreement:

Common Personal Data

  • Candidate’s personal data, such as name, surname, age, residence;
  • Candidate’s contact details, such as phone number and email address;
  • Data contained in the curriculum vitae, including information regarding educational background (degree and related subjects) and information regarding professional experience (position held and years of experience in the role);
  • Other data provided by the Candidate when submitting an online application or during selective interviews to which they have been summoned;

Special Categories of Data

  • Health-related data, revealing information about physical and mental suitability for certain jobs, relating to disabilities or disabling conditions, or belonging to certain protected categories, if necessary;
  • Membership and any roles held in trade unions and associations, including philanthropic ones, any institutional positions held, both elective and non-elective, if required by law.

Such Personal Data will be collected, as the case may be, following:

  • Spontaneous submission of the CV, through (i) traditional communication channels (e.g., hard copy CV left by you at FENDI stores, during FENDI events or at the so-called Career Days you may have attended, or sent via regular mail according to any indications and/or procedures of the Companies) or other electronic communication channels made available by the Companies, including dedicated sections of websites, electronic platforms, or apps of the LVMH Group to which the Companies belong; or (ii) the “Apply with LinkedIn” function, through which the Companies will have access to the data contained in the Candidate’s LinkedIn profile;
  • Submission of the CV following a specific request from one or more of the Companies, with “request” meaning the opening of formal personnel search and selection procedures for particular job positions (also through third parties, such as headhunters, recruitment or employment agencies, to which the Companies may entrust such procedures, which in turn use electronic platforms such as LinkedIn, Monster, Fashion Jobs), as advertised by the Companies, also online (e.g., Careers section or similar on the Companies’ websites).

Please include in the curriculum vitae or otherwise provide us only with the data necessary to evaluate your professional profile and do not provide data that is not necessary for the purposes of this personal data processing notice. In particular, FENDI, in the selection process, does not in any way process the so-called “Judicial Data” of Candidates and, therefore, we ask you not to share such information in any way.

If you provide us with personal data of third parties (e.g., references, family members and/or cohabitants), it will be your responsibility to provide them with this information and ensure that the communication to the Companies and the related data processing by the Companies are lawful and necessary, and you declare to assume all legal obligations and responsibilities, indemnifying FENDI from any dispute, claim, request for compensation in this regard.

  1. Purposes of processing

The Personal Data will be processed for:

  1. Contractual Purposes, namely to select and evaluate the Candidate’s professional profile, with the related management of all phases related to the selection of candidates for the possible establishment of the employment relationship, such as, by way of example, the evaluation of professional profiles of interest, as well as the performance of administrative-accounting tasks in the preliminary phase to the possible signing of the employment or collaboration contract;
  2. Legal Purposes, namely to comply with a legal or regulatory obligation, including, for example, regulations regarding social security and welfare, including supplementary ones, or concerning hygiene and safety at work;
  3. Legitimate Interest Purposes, namely to:
    • retain the Candidate’s curriculum vitae, in case the application is unsuccessful, to possibly evaluate suitability for positions other than the one for which the Candidate had applied, in view of the opening of new job positions;
    • enforce or defend a right, towards you or third parties; as well as
    • carry out activities functional to corporate operations, including transfers of business and business units, acquisitions, mergers, spin-offs or other transformations and for the execution of such operations.

  1. Legal basis of the processing

The legal basis for the processing of Personal Data for Contractual Purposes is Article 6(1)(b) of the Privacy Regulation, as also referred to in Article 111-bis of the Privacy Code, since personnel search and selection procedures involve processing necessary for the performance of a contract of which the data subject is a party or for the performance of pre-contractual measures taken at the request of the data subject.

The legal basis for the processing of Personal Data for Legal Purposes is Article 6(1)(c) of the Privacy Regulation, i.e., to comply with a legal obligation to which the Company is subject.

The processing of Special Categories of Data, both for Contractual Purposes and for Legal Purposes, is permitted exclusively to the extent provided for by specific laws governing access to the labor market for individuals entitled to certain health or other conditions, which consequently make it obligatory for the Companies to process such data of special nature. In these cases, the processing will take place in accordance with Article 9(2)(b) of the Privacy Regulation, which legitimizes the processing of special category data necessary to fulfill specific obligations and exercise specific rights of the data controller or the data subject in the field of employment law and social security and social protection.

All the aforementioned processing is mandatory, as the refusal to provide Personal Data for the aforementioned purposes will make it impossible for the Company to evaluate your profile or the outcome of the application may be compromised.

The legal basis for the processing of Personal Data for Legitimate Interest Purposes is Article 6(1)(f) of the Privacy Regulation, based on FENDI’s legitimate interest which has been adequately balanced with the interests of the data subjects, as the processing of Personal Data must take place strictly necessary for the pursuit of such purposes. The Data Subject may object to such processing in accordance with paragraph 9 “Rights of the Data Subject” of this notice. If you object to such processing, the Personal Data cannot be used for the indicated purpose unless FENDI demonstrates overriding legitimate grounds.

  1. Processing methods

With regard to the above-mentioned purposes, the processing of Personal Data will take place both through computerized and/or telematic means, and on paper, and in any case, by means suitable to guarantee their security, protection, and confidentiality through the adoption of adequate technical, physical, and organizational security measures aimed at preventing unauthorized access, loss, dissemination, and theft of Personal Data.

We inform you that the current methods of collection and management of applications, CVs, and related personal data in electronic mode provide that, once the candidate has submitted the CV through one of the official electronic communication channels made available by the Companies, it will be redirected to the centralized platform of the LVMH Group which provides for the centralized storage (with servers in the EU territory) of personal data collected within the scope of personnel selection and search procedures at the Group level.

  1. Communication and dissemination of personal data

Within the Company structure, the Personal Data of the Data Subject may be disclosed to managers, executives, and employees designated by the Companies for personnel selection activities, as data processors appointed by the Company for the processing of Personal Data and whose access to data is authorized under specific instructions pursuant to Articles 29 and 32 of the Privacy Regulation.

The Candidate’s Personal Data may then be communicated, as external data processors or autonomous data controllers, to the following categories of subjects:

  • providers of instrumental or support services to those provided by FENDI and therefore, by way of example, experts, lawyers, auditing companies, providers of technological services, consultants, including consultants or external companies that carry out personnel search, evaluation, and selection activities on behalf of the Companies;
  • FENDI companies, also foreign ones, the parent company, and the Holding of the LVMH Group, and other companies of the LVMH Group, which receive data from the Companies as a result of services and other activities provided at the intercompany level, for administrative, managerial, organizational purposes, including centralized storage on the electronic platform of the LVMH Group and on other dedicated infrastructures or apps. Furthermore, with your prior consent, Personal Data may be communicated to other companies of the LVMH Group also to evaluate your professional profile for the purpose of establishing an employment or collaboration relationship with said companies, in case an offer corresponding to your profile arises;
  • to subjects indicated by you in the CV, with such indication being considered as authorization for communication that the Companies will consider legitimate;
  • public entities and/or judicial and/or control authorities whose right of access to Personal Data is expressly recognized by laws, regulations, or provisions issued by the competent authorities, upon their request;
  • assignees of the business or business unit, companies resulting from possible mergers, spin-offs, or other transformations of the Company.

Some of the subjects listed above may be located in countries outside the European Union (EU) or the European Economic Area (EEA). In such cases, the communication of Personal Data will take place in accordance with what is indicated in the following paragraph.

In any case, your Personal Data will not be disseminated.

  1. Transfer of data outside the European Economic Area

Personal Data may be transferred outside the national territory also to countries located outside the European Economic Area (EEA), where subsidiaries or affiliates of the Company are based and/or, if you have given consent to the transfer of your data to other companies of the LVMH group, where these latter are based, as well as to third-party service providers indicated in the preceding paragraph 6.

Any transfer of the Candidate’s Personal Data to countries located outside the European Union will, in any case, take place in compliance with appropriate and suitable guarantees for the transfer itself pursuant to the applicable regulations referred to in Articles 45 and ss. of the Privacy Regulation, such as, depending on the case, the adoption of standard contractual clauses approved by the EU Commission. The Candidate may receive further information on this by making an express request to the address indicated in paragraph 9 of this notice.

  1. Period of retention and deletion of personal data and CVs

If the candidate’s profile is deemed of interest, we will contact you within three weeks of receiving the CV. If you do not receive a response within this period, it means that the application has not been successful in accessing the next stage of the selection process and the CV and your data will be deleted, unless the profile and professional qualifications are still considered of interest, also for the future. In these cases, the general policy of retention and deletion of CVs adopted by the Companies, regardless of the establishment or not of contractual relationships, provides that Personal Data are retained for a maximum of 24 months from the submission of the application or from the last modification upload to the LVMH Group Platform. At the expiration of this period, the data will be deleted, unless you indicate otherwise. During this period, you may also request the Company to supplement or update the Personal Data contained in the CV concerning you. Also considering the periodic verification of the data by you, the 24-month retention period for the CV is deemed appropriate – even if your professional profile is not selected – as it allows you to keep your application active for any positions that may arise, possibly even at the Group level, or because the eventual update of the CV that you are entitled to request during the 24 months (for example, by integrating it with new titles or experiences or qualifications acquired in the meantime) could increase your chances of professional insertion. In any case, cases where retention for a subsequent period is required for any disputes, requests from competent authorities or for the period provided for by specific legal obligations or applicable regulations are reserved.

  1. Rights of the Data Subject

In accordance with the provisions of the Privacy Regulation, you have the right to:

  1. obtain from FENDI confirmation of whether or not Personal Data concerning you is being processed, know its content and origin, verify its accuracy or request its integration or updating, or correction;
  2. request erasure without undue delay as well as transformation into anonymous form or blocking of Personal Data processed unlawfully;
  3. object, for legitimate reasons, to the processing of Personal Data;
  4. request from FENDI the restriction of processing of Personal Data where (i) you contest the accuracy of the Personal Data, for the period necessary for FENDI to verify the accuracy of such Personal Data; (ii) the processing is unlawful and you oppose the erasure of the Personal Data, instead requesting that its use be restricted; (iii) although FENDI no longer needs it for processing purposes, the Personal Data is necessary for the establishment, exercise or defense of FENDI’s rights in legal proceedings; (iv) you have objected to processing under Article 21(1) of the Privacy Regulation, pending verification as to whether FENDI’s legitimate grounds override yours;
  5. obtain the portability of your Personal Data; and
  6. withdraw, at any time, the consent you have given to the processing of Personal Data, without this affecting the lawfulness of the processing based on consent before its withdrawal.

You may exercise the aforementioned rights by sending an email to privacy@fendi.com.

The exercise of rights is not subject to any formal constraints and is free of charge. A response will be provided without undue delay and, in any case, no later than one month from receipt of the request.

You also have the right to lodge a complaint with the Garante per la protezione dei dati personali (Italian Data Protection Authority) at the contacts available on the website www.garanteprivacy.it, or with the supervisory authority of the country where you habitually reside, work, or where the alleged violation occurred, if the conditions are met.

  1. Changes and updates

The notice may be subject to changes and additions, also as a result of any changes and/or legislative updates. Changes will be notified in advance and Data Subjects may view the constantly updated text of the notice on the FENDI website, in the Careers section.