This Privacy Policy aims to describe the purposes and methods through which Virality Srl, as Data Controller ("Company" or "Data Controller"), collects and processes personal data relating to the user ("User") who interacts with the website ("Site") and the various services offered by the same. The information contained in this Privacy Policy is provided pursuant to Article 13 of the EU Regulation of April 27, 2016 No. 679 ("Regulation"), as well as the Measures issued by the Italian Data Protection Authority and Guidelines of the European authorities. The information about data processing is provided only for the Site and for the processing operated by the Company and does not extend to processing operated by third parties through other sites that may be consulted by the User through links. With respect to such further processing, the Company assumes no responsibility, and the User should refer to the individual Privacy Policies of third party sites. Translated with (free version)

1. Owner and place of treatment

The Data Controller is the Company Virality Srl with head office in Via Isonzo 55/2, Casalecchio di Reno (BO) (Italy). The data is mainly processed at the Data Controller's head office, by the Company's technical staff appointed for the purpose, within the territory of the European Union and, with regard to the services entrusted to or offered by third parties, also outside the Italian State and/or outside the European Union. In case of transfer of data to countries that do not have standards of protection equal to the Italian one, the Company undertakes to adopt the necessary measures for such transfer. Translated with (free version)

2. Modalities of data processing

The Company treats the User's data adopting all the appropriate security measures to prevent unauthorized access, as well as unauthorized disclosure, modification or destruction of data. The treatment is carried out with both manual and computerized and / or telematics, with organizational methods and logic strictly related and limited to the purposes indicated.

3. Purpose of data processing and legal basis for processing

The Company, through the Site, may process the User's data for the following purposes:

  • The Company, through the Site, may process the User's data for the following purposes:
  • Purpose of collecting "Work with Us" applications. The Company offers the User the opportunity to send via email their application to work in the Company through the "Work with us" section of the Site. To this end, the Company will acquire and use the information provided by the User through the spontaneous sending of the CV for the exclusive purpose of selection and management of applications. In any case, Users are kindly requested not to include in their CV any data of a sensitive nature (e.g. relating to health, political opinions, sexual life, etc.), except for those strictly necessary by law for the purposes of selection and evaluation of the CV (e.g. belonging to protected categories). The legal basis of the processing is represented by the execution of a request by the User to evaluate his professional profile in relation to job positions with the Company, and any refusal to provide personal data makes it impossible for the Company to manage and execute the User's requests. Translated with (free version)
  • Contact the Company. The Company offers the User the possibility to send via email communications to the Company, requests, questions and information about its activities, initiatives and services. In this regard, the personal data provided by the User (e.g. email address, possible telephone number and/or other information spontaneously provided by the User) will be processed by the Company in order to take charge of, correctly manage and respond to the User's communication. The legal basis of the treatment is represented by the execution of the service expressly requested by the User, and the eventual refusal to provide personal data involves the impossibility for the Company to manage and respond to the communication or the request for information.
  • Marketing Activities. The User's data may be used for the Company's marketing activities related to the products and/or services offered, such as the sending of informative material and commercial communications on Virality's services, initiatives and/or offers by e-mail. The legal basis of the processing is represented by the consent given by the User.
  • Pursuit of the legitimate interests of the Company and/or third parties. The User's data may also be used to exercise the rights and legitimate interests of the Company and/or third parties, for example, the right to defence in court, the management of complaints and litigation, the possible recovery of credits, the prevention of fraud and/or illegal activities. In these cases, although the provision of the User's personal data is not compulsory, it is in any case necessary because such data is strictly connected and instrumental to the pursuit of such legitimate interests, which do not prevail over the User's fundamental rights and freedoms, and any refusal to provide such data could make it impossible to provide the services requested (e.g. requesting information from the Company).
  • Fulfillment of legal and/or applicable obligations. The Company may also use the personal data provided by the User or otherwise acquired during the User's interaction with the Site for purposes related to the execution of legal obligations, regulations, national and EU legislation as well as arising from provisions issued by authorities empowered by law, which represent the legal basis of the treatment, without the need to obtain the User's prior consent.
  • To perform aggregate statistical analysis on an anonymous basis in order to improve the performance and services offered by the Company through the Site. In this case, no consent of the User will be required, as the indicated treatment will be carried out only on anonymous data.

4. Categories of data subject to processing

The Company receives and collects, through the Site, information about the User who visits the pages of the Site and who uses the web services available on the Site. In particular, the Company acquires and processes the following information.

4.1 Data collected through navigation and cookies

When the User visits the Website, the latter collects certain data such as the pages viewed, the links or buttons clicked by the User, the date and time of access, the User's IP address, the browser used and the operating system used (so-called "navigation data"). Navigation data could, by their very nature, allow to identify the User also through processing and associations with data held by third parties. However, the Company uses this data only to obtain statistical and anonymous information on the use of the Site for purposes strictly related to the operation of the same. Navigation data could also be used to ascertain responsibility in case of possible computer crimes against the Site. Secondly, in relation to the collection of User data through cookies and similar technologies, please visit the Cookie Policy.

4.2 Data provided voluntarily by the User

The Company limits the collection of information voluntarily provided by the User to that which is necessary to pursue the purposes described in paragraph 3 above and the services expressly requested. In addition, the Company may collect and process additional personal data, if the same are voluntarily provided by the User as part of the services offered by the Site, for example, if the User contacts the Company to report problems or malfunctions, exercise their rights on the processing of personal data, etc.. These data will be processed by the Company solely for the purposes strictly related to the User's request. Failure to provide this information may make it impossible to obtain the requested service.

5. Communication of data to third parties

The data provided by the User and those collected by the Site as part of its services (e.g. IP address) will not be disclosed and may be communicated, for the purposes and in the manner described in this Privacy Policy, to the categories of persons listed below:

  • Group companies, for administrative-accounting purposes, for the pursuit of the legitimate interests of the Company and/or third parties, and for the purpose of carrying out the services expressly requested by the User;
  • companies, collaborators, consultants or freelance professionals that the Company uses to carry out tasks of a technical or organizational nature (such as IT service providers), or with which the Company collaborates, for the purposes of the provision and operation of its services, or for any communication activities;
  • persons, companies or professional firms providing assistance and consultancy to the Company, with particular but not exclusive reference to accounting, administrative, legal, tax and financial matters;
  • subjects whose right to access data is recognized by law or by orders of the authorities.

The subjects belonging to the above categories will use the data as autonomous data controllers in accordance with the law or as data processors regularly appointed by the Company. These subjects may be established in EU and non-EU countries. In particular, in the event that these subjects are established in non-EU countries, the Company will adopt the measures provided for by the Regulation to legitimize the transfer of personal data to them. The list of the subjects to whom the data are or may be communicated, as well as the indication of the privacy measures adopted to legitimize extra-EU transfers, may be requested from the Company by contacting the addresses indicated in the section "Users' Rights and Contacts".

6. Data Retention

The data are processed for the time necessary to carry out the activities indicated in paragraph 3 above, and are deleted when the purposes for which they were collected and processed cease to exist. In particular, the Company will delete the personal data of the User who has requested information or sent communications by contacting the Company through the Website after 5 years from the provision of the same. Secondly, the Company will delete the personal data of the User who has applied for a job with the Company 18 months after providing the data, if the candidate does not establish a working relationship with the Company. Finally, in relation to the processing of data for marketing purposes, the data will be kept until the User expresses his opposition to the processing.

7. User rights and contacts

  • to obtain confirmation that your personal data is being processed and, in this case, to request from the data controller access to information relating to such processing (e.g. purposes, categories of data processed, recipients or categories of recipients of the data, storage period, etc.);
  • request the rectification of inaccurate or incomplete data;
  • to ask the data controller to delete the data (e.g. if the personal data are no longer necessary in relation to the purposes for which they were collected, in case of revocation of the consent on which the processing is based, etc.);
  • request the limitation of processing (e.g. if the User disputes the accuracy of the data; if the processing is unlawful and the User objects to the deletion of the personal data; if the data are necessary for the exercise or defence in court of a right of the User, even if the data controller no longer needs them; in case of exercise of the right to object, for the time necessary to verify the existence of legitimate reasons);
  • to receive in a commonly used and machine-readable format (e.g. pdf) the personal data concerning him and to transmit them to another owner, or to obtain the direct transmission from one owner to another, if technically feasible (so-called data portability).

The User also has the right to oppose in whole or in part, for legitimate reasons, the processing of personal data concerning him. These rights can be exercised directly by sending a communication to the following email address: Finally, if the User believes that the processing of the data provided violates the legislation on the protection of personal data, he has the right to complain to the Authority for the protection of personal data (

8. Data Protection Officer ("DPO")

The Company has identified and appointed a Data Protection Officer, so-called "DPO", who can be reached at

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