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Privacy Policy Applications – CV

(Article 13 of the EU General Regulation on the protection of personal data no. 679/2016

Art. 111-bis of the legislative decree 30 June 2003, n. 196 – Privacy Code)

Dear Sir / Madame,

The societies

FENDI S.r.l., with registered office in Palazzo della Civiltà, Quadrato della Concordia n.3, 00144, Rome (RM), Italy, Tax Code and Business Register of Rome n. 000466430584, VAT number 00900421009, telephone 06334501 e-mail privacy@fendi.com

FENDI Italia S.r.l., with registered office in Palazzo della Civiltà, Quadrato della Concordia n.3, 00144, Rome (RM), Italy, Tax Code and Business Register of Rome n. 000466430584, VAT number 00900421009, telephone 06334501 e-mail privacy@fendi.com

FENDI Private Suites S.r.l., with registered office in Palazzo della Civiltà, Quadrato della Concordia n.3, 00144, Rome (RM), Italy, Tax Code and Business Register of Rome n. 000466430584, VAT number 00900421009, telephone 06334501 e-mail privacy@fendi.com

hereafter defined collectively as the “Companies” in their activity – even individually carried out – of research and selection of personnel, they communicate that for the management of the aforementioned recruiting procedures in view of the possible establishment of an employment relationship with one of the Companies (independently from the contractual type of the legal relationship) are each autonomously – from time to time and on the basis of the search and selection procedure activated by one of the Companies – a Data Controller of the personal data of candidates for any job positions, pursuant to articles 4, n. 7) and 24 of EU Regulation 2016/679 of 27 April 2016 concerning the protection of individuals with regard to the processing of personal data (hereinafter, the “Regulation”).

The Companies inform you pursuant to art. 13 of the Regulations that will process your personal data for the purposes and with the methods indicated below.

By processing of personal data – common and of a particular nature – we mean any operation or set of operations, carried out with or without the aid of automated processes and applied to personal data or sets of personal data, even if not registered in a database , such as the collection, registration, organization, structuring, storage, processing, selection, blocking, adaptation or modification, extraction, consultation, use, communication by transmission , dissemination or any other form of making available, comparison or interconnection, limitation, cancellation or destruction.

We therefore inform you that such data will be processed with the support of paper, computer or telematic means for the pursuit of the following purposes.

Pursuant to art. 111-bis of the Privacy Code (Legislative Decree 30 June 2003, n.196 as coordinated with the Regulations) the information on the treatment in case of receipt of curricula not requested or requested by the Companies but spontaneously transmitted by the candidates concerned for the purposes of Any establishment of an employment relationship must be made at the first contact following the sending of the curriculum sent by the interested party. The Company therefore provides the following information which fulfills the obligations set out in art. 13 of the Regulation and 111-bis of the Privacy Code. Furthermore, this information on the processing of personal data is also issued for the various cases of CVs whose sending has instead been requested by the Company on the basis of the internal personnel selection procedures envisaged and applicable.

Identification details and contact details of the Data Controller.

As required by the Guidelines on transparency WP 260/2017, the identification details of each of the autonomous data controllers are provided, together with the contact details.

FENDI S.r.l., with registered office in Palazzo della Civiltà, Quadrato della Concordia n.3, 00144, Rome (RM), Italy, Tax Code and Business Register of Rome n. 000466430584, VAT number 00900421009, telephone 06334501 e-mail privacy@fendi.com

FENDI Italia S.r.l., with registered office in Palazzo della Civiltà, Quadrato della Concordia n.3, 00144, Rome (RM), Italy, Tax Code and Business Register of Rome n. 000466430584, VAT number 00900421009, telephone 06334501 e-mail privacy@fendi.com

FENDI Private Suites S.r.l., with registered office in Palazzo della Civiltà, Quadrato della Concordia n.3, 00144, Rome (RM), Italy, Tax Code and Business Register of Rome n. 000466430584, VAT number 00900421009, telephone 06334501 e-mail privacy@fendi.com

Contact details of the Italian Data Protection Officer (RDP – DPO) and of the LVMH Group.

As required by the Guidelines on the Personal Data Protection Officer (RDP / DPO) WP243 / 2016, the contact details of the Data Protection Officer (RPD – DPO) of the Companies are provided.

Geographical address: Palazzo della Civiltà, Quadrato della Concordia n.3, 00144, Rome

DPO’s dedicated telephone number: ……………… ..

DPO’s dedicated email: dpo@fendi.com

As for the contact details of the Personal Data Protection Officer (RDP / DPO) of the LVMH Group to which the companies belong, the contact details are also provided:

• the contact form available at the link can be used: https://www.lvmh.com/contact/

• the following postal communication channel can be used: LVMH Data Protection Officer, 24-32 rue Jean Goujon, 75008 Paris,

Purpose of the processing

Generally manage the personnel search and selection procedures, receive requests for professional placement, evaluate the professional profiles of interest that emerge from the CVs sent, manage all the phases related to the selection of candidates (communications with interested parties, call for interviews , conducting interviews and evaluative interviews – including through questionnaires – with the managers of the Companies, etc) evaluate the results of the interviews, manage every phase connected to the procedures for receiving candidatures sent spontaneously or requested by the Company, keep in compliance with the limitation principle retention times for all information and documents relating to personnel research and selection activities, regardless of whether or not you are subsequently included in the organization charts of one of the companies.

Methods of processing

The data contained in the CVs sent will be processed with the support of electronic or electronic paper means (including the transformation of any paper CVs into electronic files by scanning).

More specifically, the methods of collecting and processing personal data from CVs are represented, as appropriate, by websites, electronic platforms, official Company apps, electronic platforms or external apps such as Linkedin; direct contacts with the Companies (eg: paper CV left by you at FENDI stores managed by the Companies or during FENDI events in which you have participated or sent by ordinary mail according to any indications and / or procedures of the Companies), organization of the cc. dd Career Day, entrusting the search and selection of personnel to external recruitment companies.

The collection of data and CVs takes place as a result of:

(a) spontaneous sending of the CV by you, through the traditional or 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;

(b) sending your CV following a specific request from one or more of the Companies, meaning by “request” or “solicited sending” the opening of formal procedures for the search and selection of personnel for particular job positions (also through third parties, such as recruitment companies to which the Companies may possibly entrust these 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 of Company websites.

We inform you that the current methods of collecting and managing applications, CVs and related personal data electronically provide that once the candidate has sent the CV through one of the official electronic communication channels made available by the Companies, they are redirected to the LinkedIn platform and from there to the centralized platform of the LVMH Group called LVMHCareers which provides for the centralized storage (with use in the EU) of personal data collected as part of the selection and recruitment procedures for personnel at Group level.

Categories of personal data being processed.

The Companies will proceed with the collection and processing of the following categories of personal data as typically relating to personnel search and selection procedures:

  • personal and contact details of the candidate
  • data contained in the curriculum vitae
  • other data provided by the candidate when submitting an online application or during selective interviews to which he has been called
  • possible processing of data of a particular nature if required by law (eg: quotas reserved for protected categories);
  • photo of the CV if inserted.

Communication and dissemination of personal data

The candidate’s personal data will be disclosed:

  • to the parent company and Holding of the LVMH Group with registered office in 24-32 rue Jean Goujon, 75008 Paris France, which receives the data from the companies for centralized storage on the electronic platform called LVMHCareers and on other infrastructures or apps dedicated to this as Inmind By Djigg and Talent Link. The Companies have appointed LVMH as the external data processor pursuant to Article 28 of the Regulation (through the DPA – Data Controller to Data Processor contract), prescribing all the appropriate technical and organizational measures for the storage and management of the data subject to communication;
  • LVMH has in turn appointed as authorized sub-processors – bound by the same compliance with the identical technical and organizational measures on the data covered by the DPA data Controller to Data Processor contract – the Lumesse sub-suppliers…. and MH SAS, which have been bound to use infrastructures located exclusively in the territory of the European Union;
  • to executives, middle managers and employees designated by the Companies for personnel selection activities, and whose access to data is authorized by virtue of specific instructions pursuant to articles 29 and 32 of the Regulations;
  • to consultants or external companies that carry out research, evaluation and possible selection of personnel on behalf of the Companies: the list of names and contact details of these external companies can be obtained by you by making a request to the email privacy@fendi.com;
  • to all the other companies of the LVMH Group or subsidiaries or associates for the purpose of verifying any needs of said various companies to include professional figures of their own interest in the workforce; in these cases, the legitimacy basis of the processing of the communication of your data is represented by the legitimate interest of the third party (i.e. the candidate) to expand the options and possibilities available to him to be hired; it is also specified that access to the LVMH Careers platform by companies of the LVMH Group located outside the European Union or the sending of your data to these companies represent cases of international transfer of personal data for which the Companies have proceeded to put in place the appropriate guarantee measures provided for by articles 45 and 46 of the Regulation, with particular reference to: transfer of data to non-EU countries deemed adequate on the basis of specific Decisions of the EU Commission; stipulates specific agreements for the transfer of data with the companies of the LVMH Group located in non-EU countries, also based on the standard contractual clauses referred to in Decisions 2021/914 and 2021/915 of the EU Commission of June 4, 2021;
  • to subjects indicated by you in the CV, this indication being valid as communication authorization that the Companies will consider covered by the specific consent of the interested party.

Personal data will not be disclosed.

Optional or mandatory consent. Conferment of data of a particular nature in the Curricula vitae

We inform you that – in the case of a curriculum vitae not requested by the Companies and sent spontaneously by the interested party – the provision of data is necessary for the purposes indicated and for the purpose of evaluating and selecting applications. In this perspective, it is not mandatory to acquire any consent from the interested party, within the limits set out in Article 6, paragraph 1, letter (b) of the Regulation, as referred to in art. 111-bis of the Privacy Code, as the personnel search and selection procedures imply a treatment necessary for the execution of a contract of which the interested party is a party or for the execution of pre-contractual measures adopted at the request of the interested party or for the pursuit of the legitimate interest of the third party (i.e. the candidate himself).

Please insert in your curriculum vitae or provide us with only the data necessary to evaluate your professional profile and not to indicate – where not strictly necessary in relation to legal constraints (eg: quotas reserved for particular categories of workers) – particular data nature pursuant to art. 9 of the Regulation (“data of a particular nature” are: data suitable for revealing racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organizations religious, philosophical, political or trade union nature, as well as personal data suitable for revealing the state of health and sexual life). The indication of data of a particular nature in the CV is allowed only as provided for by the specific laws that regulate access to the labor market for those entitled to particular health or other conditions which consequently make it mandatory for the Companies to proceed with the processing. of data of a particular nature. In such cases, we inform you that pursuant to article 9, paragraph 2 of the Regulation, the inapplicability condition of the prohibition to processing is that provided for in letter (b) which legitimizes – notwithstanding the prohibition – the processing of data of a particular nature necessary to fulfill the obligations and exercise the specific rights of the data controller or the data subject in the field of labor law and social security and social protection. In this perspective, it is not necessary to acquire any specific consent to the processing.

In the case of a curriculum vitae whose sending has been requested by the Company (and not spontaneously transmitted by the interested party) any data of a particular nature indicated (relating, in particular, to health, religious beliefs and political opinions) will be immediately deleted in the absence of the above cited fair need for treatment.

The processing of data suitable for revealing the state of health of the relatives or cohabitants of the candidates is allowed if it is aimed at the recognition of a specific benefit in favor of the candidates, in particular for the purposes of a mandatory recruitment or the recognition of a resulting qualification from disability or infirmity, from war events or from reasons of service as required by specific regulations that regulate access to the labor market. We inform you that pursuant to article 9, paragraph 2 of the Regulation, the inapplicability condition of the prohibition to treatment is in such cases that provided for in letter (b) which legitimizes – notwithstanding the prohibition – the processing of data of a particular nature of family members o of the cohabitants of the candidates necessary for the latter to exercise their specific rights in the field of labor law and social security and social protection. In this perspective, it is not necessary to acquire any specific consent to the processing. In cases where it is not possible to base the processing of the data of the relatives or cohabitants of the candidates on the basis of labor law and social security and social protection, we ask you to acquire the specific consent of the interested parties (to be documented in the documentation sending the candidacy) before sending the curriculum vitae, the Company having to – if not – delete the related information.

Retention and cancellation period of personal data and CVs

Regardless of whether or not contractual relationships are established with the Companies, we inform you that your personal data will be kept for a maximum of 12 months starting from the submission of the application or from the upload of the latest modification to the LVMHCareers Platform and will subsequently be deleted, except Your different report. During this period, you may also request the Company to integrate or update the personal data contained in the CV concerning you.

The address for the exercise of rights as recognized by Articles 15 to 23 of the Regulation (also with reference to requests addressed to third parties to whom the data has been communicated with the specific consent of the interested party) is the email privacy@fendi.com

Candidate’s statements

By submitting your curriculum vitae, you implicitly certify:

  1. that all the information indicated is true;
  2. that you have communicated all relevant information that could relate to your candidacy for the requested position;
  3. to be aware that if you have communicated false or misleading information that led to the establishment of an employment relationship, the latter could be terminated for this reason;
  4. to have provided the information exclusively for the purposes of evaluations aimed at a possible use;
  5. to be aware that by offering the application, obtaining employment will be subject to the satisfaction of the requirements and results required by the employer relating to any checks that may be required regarding the training previously acquired.

Exercise of rights by the interested party.

Pursuant to articles 13, paragraph 2, letters (b) and (d), from 15 to 22 of the Regulation, the interested party is informed that:

a) he has the right to ask the Companies in their autonomous position each of the Data Controllers to access personal data, to rectify or cancel them or limit their processing or to oppose their processing or not be subjected to decisions based on fully automated processing, including profiling;

b) he has the right to lodge a complaint with the Guarantor for the protection of personal data, or with the competent authority which is that of the place of habitual residence or domicile of those who dispute a violation of their rights, following the procedures and indications published on the official website of the Authority at www.garanteprivacy.it;

c) any corrections or cancellations or limitations of processing carried out at the request of the interested party – unless this proves impossible or involves a disproportionate effort – will be communicated to each of the recipients to whom the personal data have been transmitted

The exercise of rights is not subject to any formal constraints and is free. Only in the event of a request for further copies of the data requested by the interested party, the Company may charge a reasonable fee based on administrative costs. If the interested party submits the request by electronic means, and unless otherwise indicated by the interested party, the information is provided in a commonly used electronic format.The specific address for transmitting requests for the exercise of rights as recognized by the Regulation is the following: privacy @ fendi.com. No other formalities are required. The reply will be given within the terms provided for in article 12, paragraph 3 of the Regulation (“The data controller provides the data subject with information relating to the action taken regarding a request pursuant to articles 15 to 22 without undue delay and, in any case, at the latest within one month of receipt of the request. This deadline can be extended by two months, if necessary, taking into account the complexity and number of requests. The data controller informs the interested party of this extension, and of the reasons for the delay, within one month of receipt of the request. If the interested party submits the request by electronic means, the information is provided, where possible, by electronic means, unless otherwise indicated by the interested party “)

For usefulness, the links to articles 15 to 23 of the Regulation on the rights of the interested party are given below.