Privacy policy

  1. Cookies
    Cookies are text files (letters and/or numbers) containing packets of information that are stored on the User’s computer or mobile device whenever they visit a website through a browser. Upon subsequent visits, the browser sends the cookies to the website that originated them. Cookies can be stored only for the duration of use of a specific site (i.e., session cookies) or for a longer period independent of the session (i.e., persistent cookies).
  2. CRM
    It is the “Customer Relationship Management” software used by the Company to monitor the activity related to the Services provided to Users and to send personalized commercial communications based on the type and market of the User.
  3. Personal Data
    Any information relating to an identified or identifiable natural person, directly or indirectly, by reference to the name, an identification number, location data, an online identifier, or to factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity.
  4. Forms
    These are the forms on the Website designed, respectively, to allow the User to: i) submit a contact request; ii) request a demo version of the Platform; iii) become a partner of the Company.
  5. Privacy Policy
    This document consists of the privacy policy for the processing of Personal Data and the cookie policy.
  6. Cookie Policy
    It is the cookie policy available on the Website.
  7. Platform
    It is the “nCore HR” software licensed by the Company to its clients and through which it provides the Services.
  8. Profiling
    Processing of Personal Data by evaluating personal aspects of Users using automated procedures in whole or in part.
  9. Regulation
    EU Regulation 2016/679 of 27 April 2016.
  10. Services
    These are the services provided by nCore to customers through the Platform.
  11. Website
    This is the current website.
  12. Processing
    Any operation or set of operations performed on Personal Data, such as collection, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
  13. Users
    These are the users of the Website.

The Data Controller referred to in this Information is nCore S.r.l., with registered office in Milan (MI), 20124, Via Vittor Pisani n.15, Tax Code/VAT Number 10144420964 (“nCore” or “Company”). The Data Protection Officer acting as the reference for the Controller/Processor is Dr. Gianluca Lombardi with the following contact email: ncore@segnalazionidpo.it.
Any requests from Users concerning the Processing carried out by nCore regarding their Personal Data (including the exercise of the rights referred to in the following point 7) should be addressed to nCore by mail at the registered office, or by email at the following address: privacy@ncorehr.com

nCore collects and uses Users’ Personal Data for the following purposes:

  1. Enable browsing on the Website, primarily through the use of Cookies.
    The collection of Personal Data for the purpose referred to in letter a) is governed by the Cookie Policy, available at the following link Cookie Policy, which nCore recommends reading.
  2. Manage contact requests received on the Website through the completion of the Contact Form by Users.
    The collection of Personal Data for the purpose referred to in letter b) is necessary for managing contact requests sent by the User. This Processing is based on the User’s free, specific, informed, and unequivocal consent, expressed by declaration or positive action (e.g., flag) on the Website. The withdrawal of consent can be exercised at any time, following the indications provided in point 7 letter a) of this Information.
  3. Manage requests for receiving the demo version of the Platform received on the Website through the completion of the corresponding Form by Users, and sending the demo version to them.
    The collection of Personal Data for the purpose referred to in letter c) is necessary for managing the request to receive the demo version of the Platform and for sending it to the User. This Processing is based on the User’s free, specific, informed, and unequivocal consent, expressed by declaration or positive action (e.g., flag) on the Website. The withdrawal of consent can be exercised at any time, following the indications provided in point 7 letter a) of this Information.
  4. Manage requests for collaboration as “partners” received on the Website through the completion of the corresponding Form by Users.
    The collection of Personal Data for the purpose referred to in letter d) is necessary for managing requests from Users interested in becoming partners of the Company and receiving any appropriate information from nCore in this regard. This Processing is based on the User’s free, specific, informed, and unequivocal consent, expressed by declaration or positive action (e.g., flag) on the Website. The withdrawal of consent can be exercised at any time, following the indications provided in point 7 letter a) of this Information.
  5. With prior optional consent, perform statistical analysis and market research, send informative and advertising material based on the type and market of reference of the User, monitor the potential use of the Services by Users, and verify the response to requests for sending the demo version of the Platform, also by using a CRM, but without Profiling activities by nCore.
    The collection of Personal Data for the purposes referred to in letter e) is optional, and any refusal by the User prevents them from receiving personalized commercial communications from nCore based on the type and market of reference in which the User operates. This Processing is based on the User’s free, specific, informed, and unequivocal consent, expressed by declaration or positive action (e.g., flag) on the Website. The withdrawal of consent can be exercised at any time, following the indications provided in point 7 letter a) of this Information.
  6. Perform statistical analysis on the use of the Website to improve the Website. Where possible, to achieve this purpose, nCore uses anonymous Personal Data (Personal Data that do not identify or make Users identifiable)
    The Processing referred to in letter f) is based on nCore’s legitimate interest consisting of the benefit that nCore can obtain from improving the Website and offering Services more relevant to the preferences expressed by Users while browsing the Website, which nCore considers to prevail over the right to privacy of Users. Opposition to this Processing (if it does not concern anonymous data) can be exercised at any time following the indications provided in point 7 letter g) of this Information.

nCore collects and uses Users’ Personal Data for the following purposes:

  1. Personal Data collected automatically by the Website: these are Personal Data collected automatically by the Website through, but not limited to, Cookies (for further information, nCore recommends reading the Cookie Policy).
  2. Personal Data voluntarily provided to nCore by Users through online or offline methods: these are Personal Data provided by Users, for example, to send contact requests through the completion of Forms or via email, or directly communicated to employees and collaborators of nCore

Personal Data is processed by nCore and/or third parties, selected for reliability and competence, to whom they may be disclosed as necessary or appropriate, provided that they are within the European Union. In particular, nCore informs Users that Personal Data may be processed by, and/or disclosed to:

  1. employees and/or collaborators of nCore;
  2. third-party service providers necessary to ensure the functioning of the Site (for example: hosting companies, IT technicians);
  3. third parties providing services for the analysis of Site navigation data.
  4. upon optional consent of the User, third parties providing automatic newsletter sending services and/or any other type of commercial communication, marketing services, promotion, analysis of consumption habits and choices.

Personal Data is retained by nCore for the period of time strictly necessary to achieve the purposes for which they were collected, as indicated in point 3 above. In particular, unless the right to withdraw consent as indicated in the subsequent point 7 letter a) and the right to object as indicated in point 7 letter g) are exercised, nCore retains Personal Data for the following durations:

  1. Cookies: for the purpose stated in point 3 letter a), we recommend reading the Cookie Policy;
  2. Personal Data voluntarily submitted to nCore via the “Contact Us” Form: for the purpose stated in point 3 letter b), for a period of 3 months from the receipt of the contact request, in order to verify if the User requires further assistance on the same topic. Notwithstanding this term, in the event of submitting a complaint or grievance via the “Contact Us” Form, the User’s Personal Data will be retained for the period specified in the subsequent letter f);
  3. Personal Data voluntarily submitted to nCore via the “Request Demo” Form: for the purpose stated in point 3 letter c), for a period of 12 months from the receipt of the request to send the demo version of the Platform, in order to allow nCore to customize the demo version for the User and to verify if the User is interested in using the “full” version of the Platform;
  4. Personal Data voluntarily submitted to nCore via the “Become a Partner” Form: for the purpose stated in point 3 letter d), for a period of 12 months from the receipt of the User’s request to become a partner of the Company, in order to allow nCore to provide further information to the User and to evaluate the possibility of cooperating with the User.
  5. Personal Data for commercial communications: for the purpose stated in point 3 letter e), for a period of 24 months following the last interaction with nCore by the User, indicating an interest in receiving communications related to the Company, such as consent collection, service request, or completion of any of the Forms;
  6. In any case, nCore is authorized to retain, in whole or in part, Personal Data for a maximum period of 10 years from collection, limited to information necessary to comply with legal obligations and enable nCore to potentially ascertain, exercise, and defend its own rights in court.

After such terms, nCore will proceed with the automatic deletion of the collected Personal Data, or their irreversible transformation into anonymous form;

According to the Regulation, for the period outlined in section 6 of this Privacy Policy, each User has the right to:

  1. With regard to the processing referred to in section 3, letters b), c), d), and e), revoke consent at any time without affecting the lawfulness of the processing, by sending an email to nCore, exercising the opt-out option (cf. Article 7 of the Regulation);
  2. Request access to Personal Data and information regarding its processing from nCore, including a copy in electronic format, unless otherwise requested by the Users (cf. Article 15 of the Regulation).
  3. Request the rectification and/or integration of Personal Data without undue delay (cf. Article 16 of the Regulation);
  4. Under specific circumstances (e.g., unlawful processing, withdrawal of consent, no longer necessary for the purposes of processing), request the erasure of Personal Data without undue delay (cf. Article 17 of the Regulation);
  5. In certain situations (e.g., inaccurate Personal Data, unlawful processing, exercising a right in court proceedings), request the restriction of processing (Article 18 of the Regulation);
  6. Receive in a structured, commonly used, and machine-readable format the Personal Data concerning them and, consequently, exercise the right to data portability and transmit such data to another controller (Article 19 of the Regulation);
  7. With regard to the processing referred to in section 3, letter f) (if not concerning anonymous data), object at any time to the processing of Personal Data by sending an email to nCore (cf. Article 21 of the Regulation);
  8. Be informed by nCore without undue delay of any breaches or unauthorized access by third parties to their systems containing Personal Data (so-called data breaches – Article 34 of the Regulation);
  9. Lodge a complaint with the supervisory authority of the EU country in which they reside, work, or where they believe the violation of their rights has occurred (cf. Article 77 of the Regulation).

For further information on the terms and conditions for exercising the rights granted to Users, they can consult the text of the EU Regulation published at the following link https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016R0679&from=EN, or contact nCore in the manner provided in section 2 of this Information Notice.