Privacy policy

Privacy policy

PRIVACY POLICY EX ART. 13 EU REGULATION 2016/679

GENERAL TERMS AND CONDITIONS FOR THE USE OF HURRAH.eu

By using the website www.hurrah.eu or our services, you accept the following terms and conditions, as well as the rules for the use and participation set forth by Hurrah srl Società Benefit with its registered office in Via Bordighera 4, Milano, 20242, VAT and C.F. 11505870961, ("Hurrah"), owner of the website and holder of all rights thereto.

1. Privacy

Hurrah considers your privacy very important; the use of your data is strictly reserved for the service and for the management of the services on our website including Community services. Information on the processing of personal data can be found below.

2. Availability of site content

Hurrah.eu publishes content under the Creative Commons License according to which all content on the website can be reproduced, communicated and made available to the public under the following conditions:

  1. the content shall not be used for commercial purposes
  2. the content shall not be processed, altered, transformed or used to create other material
  3. the source shall always be cited as well as the link to the site of origin, if available.
3. Exclusion of liability for the content of the website
  1. Accessing and browsing the website is entirely at the users' own risk and responsibility.
  2. Hurrah is not responsible for content posted by users or content republished from other sites on the public domain. Hurrah is under no obligation to control, monitor or approve the above-mentioned content in advance. However, should Hurrah become aware of the presence of content that breaches the law or the rights of others, it will remove it at its sole discretion.
  3. Anyone who comes across content on the Site that he/she considers illegal, inappropriate, offensive or vulgar, is invited to report it promptly to the email address info@hurrah.eu.
  4. Some sections or areas of the site may contain links to other sites owned by third parties, in this case we disclaim any responsibility for the content of such websites.
4. User registration data

Hurrah.eu is accessible to the public, it is always possible to consult it without registering. However, in order to fully use our services, it is necessary to register by filling in the relevant form with the required personal data. Processing of such data is carried out in line with the modalities set out in the privacy policy. The user who registers with Hurrah agrees to the following:

  1. not to provide false personal information on the website, or create an account on behalf of another person without authorization;
  2. not to create more than one personal account;
  3. not to create another account without our permission if the original account is disabled;
  4. ensure that the contact information is always correct and updated;
  5. not to share one’s password or allow others to access the account or take any other action that could jeopardize the account’s security;
  6. not to transfer one’s own account to a third party without prior consent.

Take on personal responsibility for the data declared in the registration form and for the consequences of false declarations. In the event of any misrepresentation in the registration form, we reserve the right not to enable or disable the user’s access, without any obligation to provide notice or reasons and without prejudice to the right of taking appropriate legal action.

In case a fictitious name is used for registration, Hurrah reserves the right to remove it (for example, if the owner of a trademark complains that the username may be brand-infringing).

5. Community

Hurrah makes Community Services available to users only for direct, personal and private use amongst users, provided that it is not for profit or commercial purposes, and that it is done in full compliance with the above-said conditions. In this regard, the user declares and warrants that the content he/she publishes on the website (i.e. video interviews) is content of which the user has full and free availability, that it is not obscene, violent, defamatory or blasphemous, that with its circulation the user is not infringing any rights or legal provisions and that, wherever necessary, he/she has obtained consent and releases.

In addition, to promote civil coexistence among users of the Hurrah Community, we invite you to publish only content related to the topic of the post and to Hurrah’s services, to do it in your name and citing the source, to refrain from publishing content for advertising purposes or content not related to Hurrah’s services and not to denigrate, intimidate or harass other users.

7. Security

We are committed to ensuring data security in accordance with the European GDPR regulation.

It is expressly prohibited to:

  • access the website using automated tools such as collection bots or spiders, without prior authorization from us;
  • engage in unlawful multi-level marketing on the site, such as pyramid schemes;
  • attempt to obtain login information or access other users' accounts;
  • use the site for any illegal, deceptive, malicious purpose;
  • take any action that hampers, overburdens, or impairs the proper functioning or appearance of the Site.
8. Changes to the Terms and Conditions

Hurrah reserves the right to change the Site, policies and these Terms and Conditions at any time to offer new products or services, or to comply with legal or regulatory requirements. You will be subject to the policies and terms in effect at the time of use of the site or of the services offered by Hurrah, unless any changes to such policies and terms are required by the applicable legislation or competent authority.

10. Governing law and dispute resolution

These Terms and Conditions, as well as all relationships governed by, arising out of, resulting from or in any way connected with these Terms and Conditions, shall be governed by Italy’s substantive and procedural laws. Any disputes that may arise between the user and Hurrah shall be subject to the exclusive jurisdiction of the Court of Milan.

USE OF USER DATA
1. Data Controller
  1. The Data Controller referred to in this Privacy Policy is Hurrah srl SB with registered office in Via Bordighera 4, 20142 Milan, Italy, VAT no. 11505870961 ("Hurrah").
  2. Any request from the User concerning the Processing carried out by Hurrah with regard to his/her Personal Data should be addressed to Hurrah by sending an email to: info@hurrah.eu.
2. Purpose and legal basis of the Processing

Hurrah collects and uses the Candidates' Personal Data and navigation data recorded by cookies for the following purposes:

  1. to provide services to candidates, including registration on the site and entering of information of professional interest (Profile), the management of the administrative relationship and all that results from the signing of the General Conditions and the sending of communications when performing the Service.
  2. The collection of Personal Data is necessary for the use of the Services.
  3. Profiling is a necessary procedure for the execution of Services relating to the identification of Candidate Lists. The navigation information recorded by cookies contributes to the profiling of the user and make the service more accurate.
  4. The processing of data is based on the General Conditions of Use that the Candidate signs when registering on the Site, necessary to carry out statistical analyses, market research, improve the presentation of the Service and the use of the Site by Candidates. To this end, Hurrah uses, wherever possible, anonymous Personal Data (Personal Data that do not identify users or make them identifiable).
  5. Processing is based on Hurrah's legitimate interest, i.e. the benefit it can obtain by being able to provide Candidates with a Service that better responds to the preferences expressed by Candidates themselves while browsing the Site and using the services, considering the fact that using a customized Service is in the Candidates’ best interests.
  6. For this reason, Hurrah intends to enhance and implement the Site’s navigation and the use of Services, that includes Newsletters, Mobile Notifications and personalized DEMs in its own and in the users’ legitimate interest while respecting the Candidates' right to confidentiality. Therefore, subject to explicit and separate consent, Hurrah will use the users' data to send Newsletters, Mobile Notifications and DEMs to the Candidate.
  7. Consent to receive Newsletters, notifications and DEMs is optional and refusal to consent will only result in the Candidate not being able to receive Newsletters, Mobile Notifications and/or DEMs.
  8. Withdrawal of consent may be exercised at any time by sending an e-mail to Hurrah or by exercising opt-out from Hurrah’s communications, considering that the revocation does not affect the lawfulness of the Processing carried out prior to revocation.
  9. Opposition to Processing (where it concerns Personal Data and not anonymous data) can be exercised at any time by sending an e-mail to Hurrah or by deleting the account directly on the Site.
3. Data collection methods

Hurrah collects Personal Data in the following ways:

  1. Personal Data entered on the Sites by Candidates: this is Personal Data that Candidates enter on the website including that connected with the Application?
  2. Personal Data automatically collected by the Site: Personal Data that Hurrah automatically collects from the Site through, but not limited to, Cookies (for further information, Hurrah recommends reading the Cookies Policy available on the Site at the following link: https://hurrah.eu/site/cookies
4. Possible categories of recipients of Personal Data

Personal Data are processed by Hurrah and/or by third parties, selected for their reliability and competence, to whom they may be disclosed whenever necessary or appropriate, provided that they are located in Italy or within the European Union. In particular, Hurrah informs Users that Personal Data may be processed by, and/or communicated to:

  1. Customers;
  2. Hurrah’s employees and/or collaborators;
  3. third party service providers necessary to ensure the Site’s functions (by way of example: company providing hosting services);
  4. third party service providers necessary to use the Service (e.g. payment processors);
  5. third parties who provide services for the analysis of navigation data on the Site;
  6. subject to the optional and explicit consent of the Candidate, third parties who provide instant messaging systems (e.g. WhatsApp);
  7. subject to the optional and explicit consent of the Candidate, third parties who provide automatic services for sending newsletters and/or any other type of commercial communication, marketing services, promotion, analysis of habits and consumer choices, profiling.
5. Period of retention of Personal Data and criteria for determining such period

Unless exercising the right to withdraw consent and/or object to the use of the Service and, in the case of additional services such as Newsletters, Mobile Notifications and DEMs, Hurrah retains Candidates' Personal Data for 36 months from collection;

If the Candidate does not take any active initiative (e.g. browsing, searches and/or any other way of using the service on the Site for a continuous period of 36 months from the registration on the Site or from the last access or consultation, the Candidate will be classified as inactive user and the relevant Personal Data will be automatically deleted.

limited to the information necessary to comply with legal obligations and to allow Hurrah to ascertain, exercise and defend its rights in court and/or in the event of a tax audit, Hurrah shall store all or part of the Personal Data for a maximum period of 10 years from collection.

Once this period has expired, Hurrah will automatically delete the Personal Data collected, or will make them irreversibly anonymous.

6. Possible transfer of Personal Data to non-EU countries

Personal Data collected by Hurrah for the purpose of sending Mobile Notifications to the Candidate, in case the Candidate has chosen to receive Mobile Notifications through the instant messaging software of platforms such as Facebook, WhatsApp or Telegram, data is transferred to the relevant companies. In this case, the transfer of such Personal Data to companies based in the United States of America, is made pursuant to art. 45 of the Regulation and provided such companies belong to the so-called Privacy Shield List (i.e., the list of U.S. organizations that provide adequate levels of data protection and comply with European principles on the subject of Processing;

The Privacy Shield List is published and updated on the basis of the adequacy decision of the European Commission no. 2016/1250, which was adopted by virtue of art. 25 of Directive 95/46/EC that will remain in force until revoked, amended or repealed, as provided for by art. 45 of the Regulation.

7. Profiling

The Profiling carried out by Hurrah has the following characteristics:

  1. object: the Profiling is carried out by parameterizing the Candidate's Application, i.e. the Personal Data that the Candidate has entered on the Site (suitable for analyzing aspects concerning qualifications, specializations, professional experiences, educational goals and professional aspirations), with respect to the Job and Training Opportunity;
  2. purpose: to identify as close a link as possible between the Job and Training Opportunity and the Candidate's Application, in order for the Candidate to be included in the Candidate List and to have the possibility to be pre-selected for the Clients' Job and Training Opportunities.
  3. Impact for Candidates: Profiling allows the Candidate to benefit from Hurrah's Services and, subject to the Candidate’s explicit consent, to receive Hurrah's Newsletters, Mobile Notifications and/or DEM. As a result of Profiling, the Candidate will not necessarily be contacted by a Client for a specific Job and Training Opportunity. However, Hurrah warrants that: (i) Profiling does not affect the Candidate's behavior on the Site and his choices in using the Service and/or other additional services such as Newsletters, Mobile Notifications and DEMs; (ii) it does not have a prolonged and permanent impact on Candidates, given that they can modify their Application and Personal Data at any time and independently; (iii) it does not discriminate against Candidates; (iv) Candidates may, at any time, ask Hurrah to review their Application with respect to a specific Job and Training Opportunity, simply by contacting Hurrah at: info@hurrah.eu.
8. User and/or Customer rights

Pursuant to the Regulation, each User is entitled to:

  1. with reference to the Processing, revoke consent at any time
  2. request access to Personal Data and to the information on the relevant Processing and to any copy in electronic format
  3. request the rectification and/or integration of Personal Data, without undue delay
  4. request without undue delay cancellation of Personal Data, for specific reasons (e.g. unlawful processing, withdrawal of consent, absence of the purpose of the Processing)
  5. to request the limitation of the Processing in the event of specific cases (for example, inaccuracy of Personal Data, unlawfulness of the Processing, exercise of a right in a court of law)
  6. to be informed by DG without undue delay of any violation or unauthorized access by third parties to their systems containing Personal Data (so-called data breach).
DEFINITIONS
  1. Client: legal person looking for Candidates for job openings and/or to whom to propose training courses.
  1. Candidate / user: a natural person of age looking for work and/or training opportunities, who registers on the Site in order to use the Service.
  1. Application/Registration: personal information and professional interests’ preferences that the Candidate enters in his/her profile when registering on the Site.
  1. Cookies: cookies are text files (letters and/or numbers) that record information each time the Candidate visits the Site through a browser. On each subsequent visit, the browser sends the cookies back to the website that originated them.
  1. Personal Data: information which is not detrimental to personal freedoms and relating to a natural person, identified by name or number, location data, contact data and registration or application data (see above)
  1. DEM: Direct Email Marketing, i.e. an e-mail communication that Hurrah sends to Candidates to inform them about Job and Training Opportunities or about related news.
  1. Candidate List: list of Candidates whose profile falls within the professional scope that the Customer considers suitable for the Job and Training Opportunities. The Candidate List is identified through Profiling.
  1. Newsletters: weekly informative newsletters containing news and updates published on the Site.
  1. Mobile Notifications: alert or instant messaging service that Hurrah offers to Candidates who want to receive updates about specific job and/or training areas, also on external platforms (WhatsApp, Messenger etc.).
  1. Profiling: automated process of Candidate selection carried out on the basis of the information entered by the Candidate compared with the Job and Training Opportunity. Profiling is necessary in order to use the Service.
  1. Service: Hurrah allows the Candidate or registered user to:
  1. register and create a personal profile;
  1. consult the Job and Training Opportunities published on the Site;
  1. contact a Customer or be referred by Hurrah to a Customer or other users through the Candidate List, for a specific Job and Training Opportunity.
  1. Processing: any operation involving Personal Data, such as, but not limited to, collection, structuring, storage, retrieval, consultation, communication, interconnection, erasure and destruction.

For further information on the terms and conditions for the exercise of the rights granted to the User, the latter may consult the text of the EU Regulation published at the following link https://eur-lex.europa.eu/legal-content/IT/TXT/?uri=CELEX:32016R0679.