Privacy Policy
This Application collects some Personal Data from its Users.
This document can be printed using the print command present in the settings of any browser.
Data Controller
Future of Work Group – Registered office: Viale Emilio Caldara 11/13, 20122 Milan (MI) – Tax Code and VAT No. 04452400163
Data Controller's email address: info@radicalhr.it
Types of Data Collected
Among the Personal Data collected by this Application, independently or through third parties, there are: email; Trackers; Usage Data; various types of Data; unique device identifiers for advertising; first name; last name; VAT number; device information; phone number; profession; City; company name; social media accounts; education; work history; job position; profile picture; user content; city; number of sessions; session duration; browsing history; session statistics; data relating to interviews; email open and interaction data; IP address; device and email client information.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or through specific explanatory texts displayed prior to the collection of the Data itself.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this Application.
Unless otherwise specified, all Data requested by this Application is mandatory. If the User refuses to communicate it, it may be impossible for this Application to provide the Service. In cases where this Application specifically states that some Data is optional, Users are free not to communicate such Data without any consequences for the availability of the Service or its operation.
Users who have doubts about which Data is mandatory are encouraged to contact the Data Controller.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service requested by the User, in addition to the other purposes described in this document and in the Cookie Policy. The use of tracking tools within emails sent by the Data Controller is described in the section “Email tracking (pixels and tracked links)”.
The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through this Application.
Mode and Place of Processing the Collected Data
Processing methods
The Data Controller adopts appropriate security measures aimed at preventing unauthorized access, disclosure, modification, or unauthorized destruction of the Personal Data.
The processing is carried out using computers and/or IT-enabled tools, following organizational procedures and practices strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other parties involved in the organization of this Application or external parties appointed, if necessary, as Data Processors by the Data Controller may have access to the Data. The updated list of Processors may always be requested from the Data Controller.
Place
The Data is processed at the Data Controller's operating offices and in any other places where the parties involved in the processing are located. For further information, contact the Data Controller.
The User's Personal Data may be transferred to a country other than their own. To obtain further information on the place of processing, the User can refer to the section containing details about the processing of Personal Data.
Retention period
Unless otherwise stated in this document, Personal Data is processed and stored for as long as required by the purpose for which it was collected and may be retained for a longer period due to legal obligations or based on the Users' consent.
Purposes of Processing the Collected Data
The User's Data is collected to allow the Data Controller to provide the Service, comply with legal obligations, respond to requests or enforcement actions, protect its rights and interests, detect any malicious or fraudulent activities, as well as for the following purposes: User database management, Advertising, Remarketing and behavioral targeting, Analytics, Displaying content from external platforms, Contacting the User, Tag management, Managing data collection and online surveys, Registration and authentication, Heat mapping and session recording, Interaction with online survey platforms, Interaction with data collection platforms and other third parties, Data connection, Content and functionality performance testing, Contact management and sending messages, Commercial communications and newsletters, Email tracking and profiling, and Productivity management.
To obtain detailed information on the purposes of the processing and the Personal Data processed for each purpose, the User can refer to the section “Details on the processing of Personal Data”.
Details on the Processing of Personal Data
Personal Data is collected for the following purposes and using the following services.
Data Connection
This type of services allows the Data Controller to share Data with the third-party services mentioned within this privacy policy. This causes Data to flow through these services and potentially be retained.
Zapier (Zapier, Inc.)
Zapier is a workflow automation service provided by Zapier, Inc. that automates the flow of data between third-party services.
Personal Data processed: last name; email; first name; VAT number.
Place of processing: United States – Privacy Policy.
Contacting the User
Contact form
By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes, or any other kind of request as indicated by the form’s header.
Personal Data processed: email.
Contact management and sending messages
This type of services allows managing a database of email contacts, phone contacts, or any other contact information used to communicate with the User. Emails sent by the Data Controller through these services contain tools that record the opening of messages and clicks on links contained within them. This tracking takes place only with the User's consent.
HubSpot Email (HubSpot, Inc.)
HubSpot Email is an address management and email messaging service provided by HubSpot, Inc. The Data Controller uses it to send newsletters and commercial communications, service communications, and emails from its sales team. HubSpot, Inc. acts as a Data Processor. Personal Data processed: Usage Data; email; email open and interaction data; IP address; device and email client information.
Place of processing: European Union (Germany) – Privacy Policy.
Commercial communications and newsletters
With the User's consent, the Data Controller uses the provided email address to send newsletters, updates on its services, event invitations, and other commercial communications. Legal basis: consent.
Personal Data processed: email; first name; last name; company name; job position.
The User can unsubscribe at any time via the link at the bottom of each email or by writing to info@radicalhr.it.
Email tracking (pixels and tracked links)
What it is. The emails that the Data Controller sends via HubSpot may contain a tracking pixel, i.e., an invisible 1x1 pixel image, and tracked links. When the User opens an email or clicks on a link, the opening and clicks are recorded, associated with their email address, along with date and time, IP address, and device and email client information. Tracking applies to newsletters, commercial communications, and emails sent by the Data Controller's sales team.
Consent to communications and tracking, with separate withdrawal. Tracking is a different processing activity from receiving communications and occurs only with specific consent. In the registration forms, the two consents are requested via a single optional checkbox, which expressly describes both: “I agree to receive newsletters and commercial communications from Radical HR, with tracking of opens and clicks also for profiling purposes”. The Data Controller records the two consents separately, and the User can withdraw tracking alone while continuing to receive communications.
Purposes. Open and click data are used to:
measure the effectiveness of communications per individual recipient, for example to improve subject lines, content, and sending times;
profiling: combine open and click data with other data provided by the User, such as role and company, to estimate their level of interest in the Data Controller's services (lead scoring), divide contacts into segments, and adapt content and frequency of messages. This activity does not involve automated decisions that produce legal effects or similarly significantly affect the User.
Legal basis. User's consent, pursuant to Art. 122 of the Italian Personal Data Protection Code and Art. 6, para. 1, letter a) of the GDPR.
How to withdraw tracking alone. The User can withdraw consent to tracking at any time, while continuing to receive emails:
via the link for managing preferences at the bottom of each newsletter and commercial communication, by unchecking the box relating to email tracking;
for emails sent by the sales team, by replying directly to the email or by writing to info@radicalhr.it.
Withdrawal does not affect the lawfulness of tracking carried out prior to the withdrawal itself.
What happens to data already collected after withdrawal. Withdrawal immediately stops the collection of new open and click data. The data already collected is no longer used for measurement, profiling, or automation and remains stored in the contact record, with limited access, because the platform used does not provide a procedure to delete it separately from the record. It is deleted together with the record according to the criteria indicated in the “Retention” paragraph. The User can request the deletion of this history by writing to info@radicalhr.it. Since tracking data cannot be deleted separately, deletion concerns the entire contact record, including the other data contained therein, and is completed within 30 days of processing the request.
Retention. Open and click data is retained according to the following criteria:
as long as the User is subscribed to at least one of the Data Controller's communications and maintains consent to tracking, as it is needed to measure the effectiveness of sendings over time and update the profile;
if the User withdraws consent to tracking only, no new data is collected; the data already collected is no longer used and is managed as described in the paragraph “What happens to data already collected after withdrawal”;
if the User unsubscribes from all communications and has no ongoing business relationship with the Data Controller, their contact record, including tracking data, is deleted within 24 months of unsubscription, as part of a periodic database review. The Data Controller retains only what is necessary to avoid sending them further communications;
for clients, suppliers, and partners, the contact record is retained for the business purposes provided for by the contract, for its duration, and for the subsequent period required by legal obligations. This retention does not extend to the use of tracking data: if the contact unsubscribes or withdraws consent to tracking, the data already collected is no longer used, is managed as described in the paragraph “What happens to data already collected after withdrawal”, and is deleted at the latest together with the record.
In any case, the User can request the deletion of their data at any time by writing to info@radicalhr.it.
Recipients and place of processing. HubSpot, Inc., as Data Processor. Place of processing: European Union (Germany).
User database management
This type of services allows the Data Controller to build user profiles starting from an email address, name, or any other information that the User provides to this Application, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social network profiles) and used to build private profiles that the Data Controller can display and use to improve this Application.
Some of these services may also enable scheduled messaging to the User, such as emails based on specific actions performed on this Application.
ActiveCampaign (ActiveCampaign, Inc.)
ActiveCampaign is a User database management service provided by ActiveCampaign, Inc.
Personal Data processed: email; Trackers; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
HubSpot CRM (HubSpot, Inc.)
HubSpot CRM is a User database management service provided by HubSpot, Inc.
Email open and click data is recorded in the contact record and used for profiling only if the User has given consent to tracking, as described in the section “Email tracking (pixels and tracked links)”.
Personal Data processed: City; last name; Usage Data; email; first name; phone number; profession; company name; email open and interaction data.
Place of processing: European Union (Germany) – Privacy Policy.
Tag management
This type of service allows the Data Controller to manage the tags or scripts needed on this Application in a centralized manner. Consequently, the User's Data may be processed by these services, potentially resulting in its retention.
Google Tag Manager (Google Ireland Limited)
Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data processed: Usage Data.
Place of processing: Ireland – Privacy Policy.
Productivity management
This type of services helps the Data Controller manage tasks, work projects, and general productivity-related activities. When using this type of service, Users' Data will be processed and may be retained, depending on the purposes of the activity in question.
These services may be integrated with a wide range of third-party services mentioned within this privacy policy to allow the Data Controller to import or export the Data necessary for the corresponding activity.
Teamtailor (Teamtailor AB)
Teamtailor is a service provided by Teamtailor AB that allows the Data Controller to manage human resources processes. In particular, it enables communication with candidates and tracking of the selection process.
Personal Data processed: social media accounts; city; last name; user content; browsing history; interview-related data; session duration; education; email; profile picture; job position; first name; number of sessions; phone number; session statistics; work history; Trackers.
Place of processing: Sweden – Privacy Policy.
Managing data collection and online surveys
This type of service allows this Application to manage the creation, deployment, administration, distribution, and analysis of online forms and surveys in order to collect, save, and reuse Data from responding Users.
The Personal Data collected depends on the information requested and provided by Users in the corresponding online form.
These services may be integrated with a wide range of third-party services to enable the Data Controller to take subsequent actions with the processed Data – for example, contact management, sending messages, analytics, advertising, and payment processing.
Hotjar surveys (Hotjar Ltd.)
Hotjar surveys is a survey generator and data collection platform provided by Hotjar Ltd. Hotjar surveys may use cookies to track User behavior. Users can opt out of Hotjar surveys cookie tracking by visiting this opt-out page. Hotjar surveys respects the “Do Not Track” option available in most modern browsers which, if activated, sends a special signal to stop monitoring the User's activity. Users can find more information here on how to enable the “Do Not Track” option for each supported browser.
Personal Data processed: Usage Data.
Place of processing: Malta – Privacy Policy – Opt Out.
Facebook Lead Ads (Meta Platforms Ireland Limited)
Facebook Lead Ads is an advertising and data collection service provided by Meta Platforms Ireland Limited that allows showing Users ads in the form of forms pre-populated with Personal Data from their Facebook profiles, such as names and email addresses. Depending on the type of ad, Users may be asked to provide further information. Submitting the form entails the collection and processing of this Data by the Data Controller in accordance with this privacy policy and solely for the specific purpose indicated on the form and/or within this privacy policy, where applicable. The User may exercise their rights at any time, including the right to withdraw consent to the processing of their Data, as specified in the section containing information on User rights in this privacy policy.
Personal Data processed: Trackers.
Place of processing: Ireland – Privacy Policy – Opt out.
Heat mapping and session recording
Heat mapping services are used to identify the areas of this Application that Users interact with most frequently, in order to identify which of them attract the most interest. These services allow monitoring and analyzing traffic data and serve to keep track of User behavior. Some of these services may record sessions and make them available for later playback.
Hotjar Heat Maps & Recordings (Hotjar Ltd.)
Hotjar is a heat mapping and session recording service provided by Hotjar Ltd. Hotjar respects generic “Do Not Track” headers. This means that the browser can instruct the script not to collect any User data. This setting is available in all major browsers. More information on opting out of Hotjar is available here.
Personal Data processed: Usage Data; Trackers; various types of Data as specified in the privacy policy of the service.
Place of processing: Malta – Privacy Policy – Opt Out.
Interaction with online survey platforms
This type of services allows interacting with third-party online survey platforms directly from the pages of this Application. In the event that one of these services is installed, it may collect Usage Data for the pages where it is installed, even if Users do not use the service.
Hotjar Poll & Survey widgets (Hotjar Ltd.)
Hotjar Poll & Survey widgets are services that allow interaction with the Hotjar platform provided by Hotjar Ltd. Hotjar respects generic “Do Not Track” headers. This means that the browser can instruct the script not to collect any User data. This setting is available in all major browsers. More information on opting out of Hotjar is available here.
Personal Data processed: Usage Data; Trackers; various types of Data.
Place of processing: Malta – Privacy Policy – Opt Out.
Interaction with data collection platforms and other third parties
This type of services allows Users to interact with data collection platforms or other services directly from the pages of this Application for the purpose of saving and reusing data. In the event that one of these services is installed, it may collect Usage Data for the pages where it is installed, even if Users do not use the service.
Hotjar Recruit User Testers (Hotjar Ltd.)
The Hotjar Recruit User Testers widget is a service that allows interaction with the Hotjar data collection platform operated by Hotjar Ltd. Hotjar respects generic “Do Not Track” headers. This means that the browser can instruct the script not to collect any User data. This setting is available in all major browsers. More information on opting out of Hotjar is available here.
Personal Data processed: Usage Data; Trackers; various types of Data.
Place of processing: Malta – Privacy Policy – Opt Out.
Advertising
This type of services allows User Data to be used for commercial communication purposes. These communications are displayed on this Application in the form of banners and other advertising forms, also in relation to User interests. This does not mean that all Personal Data is used for this purpose. Data and conditions of use are indicated below.
Some of the services listed below may use Trackers to identify the User, or use the technique of behavioral retargeting, i.e., displaying ads personalized according to the User's interests and behavior, or measuring ad performance. For more information, we suggest checking the privacy policies of the respective services.
Services of this type usually allow Users to opt out of such tracking. Users can learn how to opt out of interest-based advertising by visiting the relevant opt-out section in this document.
Facebook Lookalike Audience (Meta Platforms Ireland Limited)
Facebook Lookalike Audience is an advertising and behavioral targeting service provided by Meta Platforms Ireland Limited that uses Data collected through the Facebook Custom Audience service to display ads to Users with similar behaviors to Users who are already in a Custom Audience list based on their prior use of this Application or their interaction with relevant content across Facebook applications and services. Based on this Data, personalized ads will be displayed to Users suggested by Facebook Lookalike Audience. Users can choose not to use Facebook cookies for ad personalization by visiting this opt-out page.
Personal Data processed: Usage Data; Trackers.
Place of processing: Ireland – Privacy Policy – Opt out.
Meta ads conversion tracking (Meta pixel) (Meta Platforms Ireland Limited)
Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms Ireland Limited that connects data from the Meta ad network with actions performed within this Application. The Meta pixel tracks conversions that can be attributed to Facebook, Instagram, and Audience Network ads.
Personal Data processed: Usage Data; Trackers.
Place of processing: Ireland – Privacy Policy – Opt out.
jsDelivr (jsdelivr.com)
jsDelivr is a traffic optimization and distribution service provided by jsdelivr.com.
Personal Data processed: Usage Data; Trackers.
Place of processing: Poland – Privacy Policy.
LinkedIn Conversion Tracking (LinkedIn Insight Tag) (LinkedIn Corporation)
LinkedIn Conversion Tracking (LinkedIn Insight Tag) is an analytics and behavioral targeting service provided by LinkedIn Corporation that connects data from the LinkedIn ad network with actions performed within this Application. The LinkedIn Insight Tag tracks conversions that can be attributed to LinkedIn ads and enables targeting groups of Users based on their past use of this Application. Users can opt out of behavioral advertising features through their device settings, their LinkedIn account settings, or by visiting the AdChoices opt-out page.
Personal Data processed: Usage Data; device information; Trackers.
Place of processing: United States – Privacy Policy – Opt out.
Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)
Hotjar is an analytics service provided by Hotjar Ltd. Hotjar respects generic “Do Not Track” headers. This means that the browser can instruct the script not to collect any User data. This setting is available in all major browsers. More information on opting out of Hotjar is available here.
Personal Data processed: Usage Data; Trackers.
Place of processing: Malta – Privacy Policy – Opt Out.
Query Click (Query Click Limited)
Query Click is an advertising service provided by Query Click Limited.
Personal Data processed: Usage Data; Trackers.
Place of processing: United Kingdom – Privacy Policy.
Registration and authentication
By registering or authenticating, the User allows this Application to identify them and give them access to dedicated services. Depending on what is indicated below, registration and authentication services may be provided with the assistance of third parties. If this occurs, this Application may access some Data stored by the third-party service used for registration or identification. Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to learn more, please refer to the description of each service.
Facebook Oauth (Meta Platforms Ireland Limited)
Facebook Oauth is a registration and authentication service provided by Meta Platforms Ireland Limited and connected to the Facebook network.
Personal Data processed: Trackers; various types of Data.
Place of processing: Ireland – Privacy Policy – Opt out.
Remarketing and behavioral targeting
This type of services allows this Application and its partners to communicate, optimize, and serve advertising based on past use of this Application by the User. This activity is facilitated by tracking Usage Data and using Trackers to collect information which is then transferred to partners that manage remarketing and behavioral targeting activities. Some services offer a remarketing option based on email address lists.
Services of this type usually allow Users to opt out of such tracking. Users can learn how to opt out of interest-based advertising by visiting the relevant opt-out section in this document.
Facebook Remarketing (Meta Platforms Ireland Limited)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms Ireland Limited that connects the activity of this Application with the Facebook advertising network.
Personal Data processed: Usage Data; Trackers.
Place of processing: Ireland – Privacy Policy – Opt out.
LinkedIn Website Retargeting (LinkedIn Corporation)
LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of this Application with the LinkedIn advertising network.
Personal Data processed: Usage Data; Trackers.
Place of processing: United States – Privacy Policy – Opt out.
Facebook Custom Audience (Meta Platforms Ireland Limited)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Meta Platforms Ireland Limited that connects the activity of this Application with the Facebook advertising network. Users can choose not to use Facebook Trackers for ad personalization by visiting this opt-out page.
Personal Data processed: email; Trackers.
Place of processing: Ireland – Privacy Policy – Opt out.
Analytics
The services contained in this section enable the Data Controller to monitor and analyze traffic data and are used to keep track of User behavior.
Google Analytics (Universal Analytics) (Google Ireland Limited)
Google Analytics (Universal Analytics) is a web analytics service provided by Google Ireland Limited (“Google”). Google uses the Personal Data collected to track and examine the use of this Application, compile reports, and share them with other services developed by Google. Google may use the Personal Data to contextualize and personalize the ads of its own advertising network. For an understanding of Google's data use, please consult Google's partner policy.
Personal Data processed: Usage Data; Trackers.
Place of processing: Ireland – Privacy Policy – Opt Out.
Google Analytics (Universal Analytics) with anonymized IP (Google Ireland Limited)
Google Analytics (Universal Analytics) is a web analytics service provided by Google Ireland Limited (“Google”). Google uses the Personal Data collected to track and examine the use of this Application, compile reports, and share them with other services developed by Google. Google may use the Personal Data to contextualize and personalize the ads of its own advertising network. This integration of Google Analytics anonymizes your IP address. Anonymization works by shortening Users' IP addresses within the member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the IP address be sent to Google servers and shortened within the United States. For an understanding of Google's data use, please consult Google's partner policy.
Personal Data processed: Usage Data; Trackers.
Place of processing: Ireland – Privacy Policy – Opt Out.
Google Analytics Demographics and Interests reports (Google Ireland Limited)
Google Analytics Demographics and Interests reports is an advertising reporting feature that makes demographic and interest Data available within Google Analytics for this Application (demographic Data refers to age and gender Data). Users can opt out of Google cookies by visiting Google's Ad Settings.
Personal Data processed: unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example); Trackers.
Place of processing: Ireland – Privacy Policy – Opt Out.
Advertising reporting features in Google Analytics (Google Ireland Limited)
Google Analytics on this Application has advertising reporting features activated, which collect additional information from Google advertising cookies (web activity) and device advertising IDs (app activity). This allows the Data Controller to analyze specific behavioral and interest Data (traffic Data and Data on Users' interaction with ads) and, if enabled, demographic Data (information on age and gender). Users can manage their advertising preferences and disable advertising Cookies via Google's Ad Settings. Please note that this may not prevent Users' devices from being identified based on automatically transmitted information, such as their IP address. To understand how Google uses Data, it is recommended to review their partner policy and their page on Business Data.
Personal Data processed: unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example); Trackers; various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy – Opt Out.
Content and functionality performance testing (A/B testing)
The services contained in this section allow the Data Controller to track and analyze the User's response, in terms of traffic or behavior, regarding changes to the structure, text, or any other component of this Application.
Google Optimize (Google Ireland Limited)
Google Optimize is an A/B testing service provided by Google Ireland Limited (“Google”). Google may use Personal Data to contextualize and personalize the ads of its advertising network.
Personal Data processed: Usage Data; Trackers.
Place of processing: Ireland – Privacy Policy.
Google Optimize 360 (Google Ireland Limited)
Google Optimize 360 is an A/B testing service provided by Google Ireland Limited (“Google”). This service allows the Data Controller to target groups of Users based on their past use of this Application. Users who disable tracking by Google Analytics will not be included in experiments created within Google Optimize 360. Google may use Personal Data to contextualize and personalize the ads of its advertising network.
Personal Data processed: Usage Data; Trackers.
Place of processing: Ireland – Privacy Policy.
Displaying content from external platforms
This type of services allows viewing content hosted on external platforms directly from the pages of this Application and interacting with it. Such services are often called widgets, which are small elements embedded in a website or application. They provide specific information or perform a particular function and often allow user interaction. This type of service may still collect web traffic data for the pages where the service is installed, even when users do not use it.
Google Fonts (Google Ireland Limited)
Google Fonts is a typeface visualization service provided by Google Ireland Limited that allows this Application to incorporate such content within its pages.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
Wistia widget (Wistia, Inc.)
Wistia is a video content visualization service provided by Wistia, Inc. that allows this Application to incorporate such content within its pages.
Personal Data processed: Usage Data; Trackers.
Place of processing: United States – Privacy Policy.
Information on how to opt out of interest-based advertising
In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more about how to disable interest-based advertising in the appropriate section of the Cookie Policy.
Cookie Policy
This Application uses Trackers. To learn more, Users may consult the Cookie Policy.
Further Information for Users
Legal basis of processing
The Data Controller processes Personal Data relating to the User if one of the following conditions applies:
the User has given consent for one or more specific purposes;
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Data Controller is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Data Controller;
processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party.
In particular, sending commercial communications and newsletters and email tracking (opens and clicks), including related profiling, are based exclusively on the User's consent, pursuant to Art. 6, para. 1, letter a) of the GDPR and Arts. 122 and 130 of the Italian Personal Data Protection Code.
In any case, it is always possible to ask the Data Controller to help clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless otherwise stated in this document, Personal Data is processed and stored for as long as required by the purpose for which it was collected and may be retained for a longer period due to legal obligations or based on the Users' consent.
Therefore:
Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Data Controller’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Data Controller within the relevant sections of this document or by contacting the Data Controller.
When processing is based on the User’s consent, the Data Controller may retain Personal Data longer until such consent is withdrawn. Furthermore, the Data Controller may be obliged to retain Personal Data for a longer period whenever required to fulfill a legal obligation or upon order of an authority.
Email open and click data is retained according to the criteria indicated in the section “Email tracking (pixels and tracked links)”, to which reference is also made for its management after the withdrawal of consent.
Once the retention period expires, Personal Data shall be deleted.
User Rights based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Data Controller. In particular, within the limits provided by law, the User has the right to:
withdraw consent at any time. The User has the right to withdraw consent where they have previously given their consent to the processing of their Personal Data. For email communications, withdrawal can also be partial: the User can withdraw only consent to email tracking and continue receiving communications, or unsubscribe completely. Both options are available via the link for managing preferences present at the bottom of each newsletter and commercial communication, or by writing to info@radicalhr.it. Withdrawal does not result in any limitation of the Data Controller's services.
object to processing of their Data. The User has the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
access their Data. The User has the right to learn if Data is being processed by the Data Controller, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the Data undergoing processing.
verify and seek rectification. The User has the right to verify the accuracy of their Data and ask for it to be updated or corrected.
restrict the processing of their Data. The User has the right to restrict the processing of their Data. In this case, the Data Controller will not process their Data for any purpose other than storing it.
have their Personal Data deleted or otherwise removed. The User has the right to obtain the erasure of their Data from the Data Controller.
receive their Data and have it transferred to another controller. The User has the right to receive their Data in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
lodge a complaint. The User has the right to bring a claim before their competent data protection supervisory authority or take legal action.
Users are entitled to learn about the legal basis for Data transfers abroad, including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Data Controller to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Data Controller, or for the purposes of the legitimate interests pursued by the Data Controller, Users may object to such processing by providing a ground related to their particular situation.
Users must know that, however, should their Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where Users object to processing for direct marketing purposes, Personal Data will no longer be processed for such purposes. To learn whether the Data Controller is processing Data for direct marketing purposes, Users may refer to the respective sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Data Controller through the contact details provided in this document. These requests are free of charge and will be answered by the Data Controller as early as possible and always within one month, providing the User with all information required by law. Any rectification, erasure, or restriction of processing will be communicated by the Data Controller to each recipient, if any, to whom the Personal Data has been disclosed, unless this proves impossible or involves disproportionate effort. At the User's request, the Data Controller will inform the User about those recipients.
Additional information about Data processing
Legal action
The User's Personal Data may be used for legal purposes by the Data Controller in court or in the stages leading to possible legal action arising from improper use of this Application or the related Services by the User. The User declares to be aware that the Data Controller may be required to reveal Data upon order of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services, or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (system logs) or use other Personal Data (such as the User's IP Address) for this purpose.
Information not contained in this policy
More details concerning the processing of Personal Data may be requested from the Data Controller at any time using the contact information.
Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Data Controller. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Data Controller shall collect new consent from the User, where required.
Last modified: October 28, 2026
Last modified: October 28, 2026
