Privacy Policy

Privacy Policy – BitBang S.r.l

For the Italian version, click here.

BitBang S.r.l., with registered offices in Bologna, Via Enrico Mattei no. 102, VAT number 02329121202 (hereinafter, “BitBang” or “Data Controller”), is committed to protecting the online privacy of the users of the www.bitbang.com website (hereinafter, “Website”). As such, this document (hereinafter, “Privacy Policy”) has been written according to Article 13 of EU Regulation 2016/679 (hereinafter, the “Regulation” or “GDPR”), in order to allow you to understand our policy regarding your privacy, and how your personal data will be handled when using our Website. This Privacy Policy contains important information regarding the protection of your personal data so that you are able to consent to the processing of your personal data in an explicit and informed manner, where appropriate.

The information and data which you may provide, or which may otherwise be collected through the Website, in the context of your use of BitBang’s services (hereinafter, the “Services“), as better defined in  Section 3, will be used in compliance with the principles of lawfulness, fairness, transparency, purpose limitation, storage limitation, data minimization, accuracy, integrity and confidentiality.

TABLE OF CONTENTS

1. Data Controller and Data Protection Officer
2. Personal Data processed
   a. Personal Data provided voluntarily by the data subject
   b. Candidature. Special Categories of Personal Data
   c. Third party Personal Data provided voluntarily by the user of the Website
   d. Browsing data
   e. Cookies
   f. Personal data not obtained from the data subject

3. Purpose of the processing

4. Legal bases and mandatory/discretionary nature of the conferment

5. Recipients of Personal Data

6. Transfers of Personal Data

7. Retention of Personal Data

8. Data subjects’ rights. Contact details of the Data Controller

9. Amendments

1. Data Controller and Data Protection Officer

BitBang, as identified at the beginning of this Privacy Policy, is the Data Controller regarding all personal data processed through the Website.

It is possible to contact BitBang’s Data Protection Officer (“DPO”) at any time by writing to: dpo@bitbang.com. 

2. Personal Data processed

As you use the Website, we inform you that the Data Controller may collect and process your personal data, which may consist of – also depending on your decisions regarding use of the Services – an identifier such as your name, an identification number, an online identifier (“Personal Data“).

Your Personal Data may be collected either because you voluntarily provided it (for example, when filling out an online form) or simply by analysing your behaviour on the Website.

Personal Data which may be processed through the Website are as follows:

a. Personal Data provided voluntarily by the data subject

 In some sections of the Website, e.g. on the ‘Contacts’ page, you are offered the opportunity to enter information and Personal Data such as your name, surname, telephone number, e-mail address, etc., which will be processed for the purposes set out in Section 3.

b. Job applications. Special Categories of Personal Data

 By submitting your resume through the ”Careers” section of the Website, you may provide further Personal Data and information to the Data Controller, which will be used as better indicated in Paragraph 3.b. below.

With respect to such Personal Data, we kindly ask you not to provide those falling under the special categories referred to in art. 9 of the Regulation (i.e. ‘[…] data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, as well as […] data concerning health or sex life or sexual orientation’) unless strictly necessary. Otherwise, should you decide to provide this information as well, such Personal Data shall be processed if and to the extent that it is effectively and strictly necessary by BitBang as provided for in the general authorization pro tempore in force issued by the Authority for the protection of personal data; should the processing of such special categories be not necessary for evaluating your application and establishing the employment relationship, BitBang will refrain from processing them.

c. Third party Personal Data provided voluntarily by the user of the Website.

 In some sections of the Website (e.g. in the ‘Contact Us’ form or through the ‘Careers” section), you may enter text messages or information, visible to the Controller, that may contain personal data of other persons. With respect to these cases, you act as autonomous Data Controller, assuming all the obligations and responsibilities provided for by law. In this regard, you hereby grant the broadest indemnity with respect to any dispute, claim, or request for damages arising from the processing of data, etc. that may be brought against the Controller by third parties whose Personal Data have been processed through your use of the Website functions in violation of the applicable data protection laws. In any case, should you provide or otherwise process third-party Personal Data while using the Website, you hereby guarantee – assuming full responsibility – that such processing is based on the consent of the relevant third party or on another appropriate legal basis legitimizes the processing of the information in question.

d. Browsing Data

The Website’s operation, as is standard with any website on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation. While BitBang does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information is also considered Personal Data.

This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on. These data are used exclusively to compile anonymous, statistical information on the use of the Website, as well as to ensure its correct operation and identify any anomalies and/or abuses of the Website – this data is deleted immediately after processing. Such data could be used to ascertain responsibility in the event of computer crimes carried out against the Website or against third parties.

e. Cookie

For details of the cookies served by the Website and how to manage your preferences, please consult to our Cookie Policy 

e. Personal data not obtained from the data subject

The Data Controller may have collected some of your Personal Data from public or freely accessible sources such as Linkedin, company websites, registers, etc. It should be noted that such data will be used exclusively for the purpose of ‘light profiling with personalised effects’ as set out in Paragraph 3 below.

In other cases, BitBang may receive your Personal Data from third parties and, more specifically, from our business partners if you have given your specific consent to disclose your data to third parties (BitBang, in this case) for their own direct marketing purposes. In this case, this document will be made available to you by BitBang, pursuant to article 14 of the Regulations, before your Personal Data are processed for the Marketing purpose, as described in Section 3.c. of this Privacy Policy, only through the use of automated contact channels; the communication you will receive from BitBang will also indicate the business partner to which you have given your consent for the communication of your Personal Data to BitBang and you will be given the immediate possibility to manage your consent.

3. Purpose of the processing

The purposes of the processing of your Personal Data collected through the Website are the following:

a. provide the Services such as: downloading the material on the Site, requesting a demo, subscribing to events, requesting documentation, subscribing to BitBang’s newsletter, replying to your requests sent to the addresses and contact details published on the Site or through the ‘Contact Us’ form (‘Provision of a Service’);

b. To analyse CVs and to contact the candidates who submit their applications through the “Work with us” section of the Website (“Recruitment”). The Data Controller also intends to retain your CV in order to improve its personnel selection processes, to ensure its organizational efficiency and the optimization of the activities of BitBang personnel employed in such activities, including with respect to candidates who have not yet been interviewed or for candidates who have had an interview that was not followed by an employment engagement, so that we can contact you at a later time or evaluate your CV in the future (“Selection Process Optimization”).

c. To carry out marketing activities, conduct studies, research, market statistics and send you advertising and information material via e-mail or SMS, and/or over the telephone through operators and/or through the official pages of the Data Controller on social media related to the activities, products and services of the Data Controller (“Marketing”). You can, at any time, withdraw the consent that you have previously granted to traditional or automated marketing methods by giving notice to the Data Controller without any formality, simply by writing to the addresses indicated in Section 8 of the Privacy Policy or by using the functionality at the bottom of our marketing e-mails, without prejudice to the lawfulness of the processing based on your previous consent.

d. subject to your consent, to assess your interests, habits, choices with respect to the Controller’s Services and the use of the Site, with the help of electronic tools, by analysing the Personal Data you provide through online forms (for example, your company role, the events you attend, etc.), as well as the behaviour relating to the consultation of commercial communications that we send you by e-mail (such as whether or not you open an e-mail, the links you click, the actions you take on the linked pages, etc.) in order to create a database of your personal data. ), as well as the behaviours related to the consultation of the commercial communications that we send you by e-mail (such as, for example, the opening or not of an e-mail, the links you clicked on, the actions performed on the linked pages) in order to create a profile of you either with the Personal Data provided to BitBang directly by you or otherwise acquired by the Data Controller from partners to which you have given your consent or from public sources or through the use of profiling cookies in order to develop targeted and personalised marketing campaigns, such as, for example, to invite you to events that we believe may be of interest to you or offers and discounts, as well as to optimise the Owner’s strategic and business choices (‘Integrated Profiling’). Any consent given for this processing may be revoked at any time by sending an e-mail to privacy@bitbang.com and via the ‘Cookie Settings’ page or the cookie banner on the Site with respect to cookies;

e. classify you into broad categories and/or groups on the basis of a small number of your objective characteristics or behaviour (for example, on the basis of your company role, courses/webinars/events you have enrolled in or attended), in order to allow you to use BitBang products and/or services in line with the customer segment to which you belong or which you represent as well as to send you, subject to your consent for the purpose of Marketing, communications or commercial proposals that are not incompatible with your target and to avoid sending you communications or proposals that you might perceive as totally useless or inappropriate to your position (purpose of ‘Light Profiling with personalised effects’); it should be noted, in any case, that through the profiling in question, the Data Controller will not create an analytical and granular profile for the purpose of actively customising the communications and commercial proposals that will be addressed to it, but will merely divide the clientele into broad target classes with a view to carrying out more functional marketing activities and in order to exclude from marketing campaigns certain groups of customers who are incompatible with the advertised product/service;

f. To fulfil the obligations provided for by law which required the Data Controller to collect and / or further process certain types of Personal Data (“Compliance”).

g. To prevent or detect any fraudulent conduct or abuse of the Website in order to allow the Data Controller to defend itself in court (“Abuse/Fraud”).

h. for statistical purposes, without it being possible to trace your identity (‘Statistics’) by analysing in a general and aggregate manner the information of the users of the Site and the related Services offered in order to improve the products and services offered as well as the functionalities of the Site, without identifying the data subjects and without personalising the data leading to evaluations of data subjects;

i. To disclose your Personal Data (e.g., name, surname and e-mail address) to companies which have sponsorship or partnership relationships with BitBang and which operate within the Digital Marketing field, for their autonomous marketing purposes. The identity of these companies is indicated from time to time on the webpage of the event you register to attend (“Disclosure to Third Parties for marketing purposes”).

4. Legal basis and mandatory / discretionary nature of the conferment

The legal basis of the processing of Personal Data for the purposes referred to in Section 3 are the following:

a. Provision of the Service: the processing for this purpose is necessary to provide the Service and for the performance of the contract. The provision of your Personal Data for this purpose is optional, however, failure to provide them would imply the inability to provide the requested Services or to respond to your requests.

b. Recruitment: the processing for this purpose is necessary to allow the Data Controller to schedule interviews and manage the recruitment procedure. The provision of your Personal Data is optional, but any failure to provide it would make it impossible for BitBang to evaluate your profile and your application. The processing of your Personal Data does not require your consent as it is a spontaneous application, in accordance with the applicable Italian data protection law (see section 111-a of the Italian Data Protection Code, as amended by the legislative Decree no. 101/2018: “If an uninvited CV is received with a view to possible recruitment, the information referred to in Article 13 of the Regulation shall be provided when the respective data subject is first contacted thereafter. Within the framework of the purposes referred to in Article 6(1), letter b), of the Regulation, no consent shall be required to process the personal data contained in the CV”). In this regard, we remind you to not provide special categories of Personal Data (such as data concerning your health, your religious beliefs, your political opinions, etc.) if not strictly necessary; in this case, the processing of such Personal Data will take place in compliance with and within the limits of the general pro tempore authorization of the Garante per la protezione dei dati personali. The storage of CVs for the purpose of the Selection Process Optimisation is based on the legitimate interest of the Data Controller (art. 6(1)(f) GDPR reads: “[…] processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child”) to consider your profile for further open job positions compatible with your CV even after your application, due to the two-year CV retention period, unless you object, considering that such activity is not detrimental to your rights and interests.

c. Marketing: the processing for this purpose is based on your prior consent (art. 6(1)(a) GDPR reads: “[…] the data subject has given consent to the processing of his or her personal data for one or more specific purposes”). It is not mandatory for you to give your consent to the Data Controller for this purpose and you can withdraw your consent at any time without any consequences (except for the fact that you will no longer receive marketing communications from the Data Controller).  You may revoke your previously given consent by writing to privacy@bitbang.com or via the functionality at the bottom of our commercial e-mails;

d.Integrated Profiling: processing for this purpose requires his prior consent (see Article 6(1)(a) of the Regulation: ‘[…] the data subject has given consent to the processing of his personal data for one or more specific purposes’). You are not obliged to give your consent to the Controller for this purpose and you are free to withdraw it at any time without any consequences. You may revoke your previously given consent by writing to privacy@bitbang.com.

e. Light profiling with personalised effects: processing for this purpose is based on the interest of the data controller (see Article 6(1)(f) of the Regulation ‘[…] processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child) in ensuring the functionality of direct marketing communications and to avoid the sending of unnecessary or inappropriate promotional communications and commercial offers with respect to the target of costumers;

f. Compliance: the processing for this purpose is necessary for BitBang in order to fulfil any legal obligations to which it is subject (art. 6(1)(c) GDPR reads: “[…] processing is necessary for compliance with a legal obligation to which the controller is subject”). When providing Personal Data to the Data Controller, such data must be processed according to the applicable regulations, which could entail their retention and disclosure to the Authorities for accounting, tax or other obligations.

g. Abuse/Fraud: the information collected for this purpose will be used exclusively to prevent and / or identify any fraudulent activity or abuse in the use of the Website and therefore allows the Data Controller to protect itself in court.

h. Statistics: it is specified that such processing is not performed on Personal Data and therefore can be freely carried out by the Data Controller.

i. Disclosure to Third Parties for marketing purposes: the processing of your Personal Data for this purpose is based on your consent (art. 6(1)(a) GDPR reads: “[…] the data subject has given consent to the processing of his or her personal data for one or more specific purposes”). The provision of your Personal Data for this purpose is entirely optional and does not affect the use of the Services. If, in any case, you wish to object to the processing of your Personal Data for this purpose you may do so at any time by writing to the Data Controller, without prejudice to the lawfulness of the processing based on your consent given prior to the withdrawal.

5. Recipients of Personal Data

Your Personal Data may be shared with the subjects mentioned below (collectively “Recipients”):

a. Subjects typically acting as data processors, namely: persons, companies or professional firms which provide the Data Controller with advice and consulting in accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services.

b.  Subjects with whom it is necessary to interact for the Provision of the Service or the purposes set out above (e.g. hosting providers or platform providers for sending e-mails, or for collecting your job application);c. Persons authorised to perform technical maintenance of the Website (including the maintenance of network equipment and electronic communications networks).

d. Persons authorized by the Data Controller to process the Personal Data required for carrying out activities strictly related to the provision of the Services, who have committed themselves to confidentiality or have an appropriate legal obligation of confidentiality (for example, the employees of BitBang).

e. Subjects, bodies or authorities to whom it is mandatory to disclose your Personal Data to in accordance with Compliance, Abuse/Fraud purposes or under the orders of the authorities.

f. Third parties active in the field of Digital Marketing for their own autonomous and separate marketing purposes, only if you have given your specific consent.

6. Transfers of Personal Data

e. Subjects, bodies or authorities to whom it is mandatory to disclose your Personal DYour personal data may be shared with Recipients outside the European Economic Area. The Data Controller ensures that the processing of your Personal Data by these Recipients will take place in compliance with the applicable legislation. Transfers will be made through appropriate guarantees, such as adequacy decisions, Standard Contractual Clauses approved by the European Commission or others. For further information on the transfers of personal data, you may contact BitBang by writing to: dpo@bitbang.com or privacy@bitbang.com.

7. Retention of Personal Data

The Personal Data processed for the purpose ofthe Provision of the Service will be kept by the Data Controller for the time strictly necessary for said purpose. However, as such Personal Data are processed to provide you with the Services, the Data Controller may keep them for a longer period, in particular to the extent necessary to protect BitBang’s interests from possible claims related to the Services (art. 2946 of the Italian Civil Code).The Personal Data processed for the purpose of Recruitment will be processed for the entire duration of the selection process, while for the purpose of Selection Process Optimization, your Personal Data will be kept by the Controller, unless you object, for 2 years after the receipt of your resume.The Personal Data processed for Marketing purposes will be retained by the Controller for 24 months (starting from the their date of registration). In any case, once consent has been withdrawn, the Controller will no longer use your Personal Data for this purpose, but may still retain it, in particular to the extent necessary to protect the Controller’s interests from possible claims related to such processing.

The Personal Data processed for the purposes of Integrated Profiling will be retained by the Controller for 12 months (starting from their date of registration). In any case, once the consent is withdrawn, the Controller will no longer use your Personal Data for that purpose, but may still retain it, in particular to the extent necessary to protect the Controller’s interests from possible claims related to such processing. The Personal Data processed for the purpose of light Profiling with personalised effects shall be retained by the Controller for a period of 12 months, starting from the registration of the Personal Data, unless you object to the processing.

Personal Data processed for the Compliance purpose will be retained by the Data Controller for the period provided for by specific legal obligations or applicable legislation.

Personal Data processed to prevent Abuse/Fraud will be retained by the Data Controller for the time strictly necessary for the aforesaid purpose and therefore until the Data Controller is bound to keep them to protect itself in court to disclose such data to the competent Authorities.  On the other hand, Personal Data processed for Disclosure to Third Parties for marketing purposes will, as a general rule, be processed, until you withdraw your consent. Further information about the data retention period and the criteria used to determine this period can be requested by writing to the Data Controller at the addresses provided in Paragraph 8 of the Privacy Policy.

8. Data subject rights. Contact details of the Data Controller

Pursuant to article 15 et seq. of the Regulation, you, as the data subject, are entitled to request BitBang, at any time, to access, rectify or delete your Personal Data or to object to its processing in the cases provided for by article 21 of the Regulation, you are entitled to request the restriction of processing in the cases provided for by article 18 of the Regulation, and you are entitled to obtain in a structured, commonly used and machine-readable format the Personal Data concerning you, in the cases provided for by article 20 of the Regulations. You also have the right to object at any time and without justification to the sending of direct marketing communications via automated means (such as, specifically, e-mail, SMS, the Controller’s official social media pages) and non-automated means (such as, specifically, operator calls), as well as to the performance of profiling activities insofar as they are related to Marketing. With regard to the objection to direct marketing communications, this is without prejudice to the possibility of exercising this right also in part, i.e., for example, by objecting only to the sending of communications by automated means.

Finally, with regard to telemarketing initiatives through the use of a landline or mobile phone, we further specify that, pursuant to current sector regulations, you may object to the use of your Personal Data, including your telephone number, for sales or commercial promotions via telephone also by registering with the Public Register of Oppositions at https://www. registrodelleopposizioni.it/ or, if you have an existing contractual relationship with BitBang or one that ended less than 30 days ago, by withdrawing your consent to commercial communications (see Marketing purposes) provided at the time of entering into the aforementioned relationship.

Any consent given for the purpose of Integrated Profiling and Disclosure to Third Parties for marketing purposes may be withdrawn at any time by writing to privacy@bitbang.com.

Consent to analysis by means of cookies can be withdrawn by clicking on ‘Cookie settings’ in the footer of each page of the Website and as further indicated in the Cookie Policy.

You may exercise your rights by writing to BitBang at the following address: privacy@bitbang.com or at the physical address of the Controller indicated above.

In any case, you always have the right to lodge a complaint with the competent Supervisory Authority (the “Authority for the protection of personal data”) according to Article 77 of the Regulation if you consider that the processing of your Personal Data is in breach of the applicable legislation, and to bring an action before the competent judicial authorities (Article 79 of the Regulation).