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privacy compliance -Privacy Policy – Candidates pursuant Art. 13 EU Regulation 2016/679 (GDPR) and D.lgs. 196/2003 as amended

Rulex S.r.l. (hereinafter also referred to as “Rulex” or the “Company”), as Data Controller, informs You that, in order to start a cognitive process aimed at selecting professional figures to be included within its staff, it offers the possibility to submit Your application on Rulex website and / or through other recruiting channels both in relation to specific open positions and in the form of a spontaneous application.

With this document, drawn up pursuant to art. 13 of the EU Regulation n. 679/2016 (hereinafter also “GDPR”), Rulex informs You of the following.

Data Controller.
The Data Controller of Your personal data is Rulex S.r.l. (VAT 01715910996), with registered office in Via Felice Romani, n. 9/2, Genova, e-mail: [email protected], tel. +39 0108050190.

Purpose and legal basis of the processing
The personal data You provide (i.e., personal details, residence, e-mail address, curriculum vitae, educational qualifications and professional certifications, evidence of previous professional experience), shall be processed in a lawful and correct manner and in full compliance with the regulations in force, with the support of paper and/or electronic means, exclusively for the following purposes and on the following legal basis:

a) purposes related to the carrying out of the selection process by Rulex: carrying out, by way of example, the following processing: (i) use of the personal data provided by You for the purposes of research and selection of professional figures to be included in the organizational structure of Rulex; (ii) use of the personal data provided by You in order to send communications (i.e. telephone, e-mail) as part of the process of research, evaluation of skills and selection of personnel; (iii) use of the personal data provided by You in order to provide for the fulfilments related to the establishment of the employment relationship; (iv) use of the personal data provided by You in order to manage any further requirement related to the selection of the candidature and the eventual hiring. The legal basis for the processing is the execution of pre-contractual measures taken at the request of the data subject;
b) litigation management purposes: the processing is necessary for the management of complaints and/or litigation, for the prevention and suppression of unlawful acts, as well as, in general, for the protection of the rights and legitimate interests of Rulex and/or third parties, including in court. The legal basis of the processing is the legitimate interest (Rulex’s interest corresponds to the right of action and defence enshrined in Art. 24 of the Constitution, socially recognized as prevailing over the interests of the individual concerned).

Please note that Your personal data will be communicated and processed by Rulex personnel duly appointed and instructed by the Company itself.

Recipients of personal data
The personal data You provide may be communicated and made accessible, compatibly with the purposes indicated above, to the following categories of subjects:

  • Group companies;
  • Public administrations;
  • Italian and / or foreign supervisory authorities;
  • Other subjects for which the current legal and / or contractual legislation provides for the obligation to communicate in compliance with the provisions of the law for employers and / or in cases where the communication must take place by virtue of a contractual relationship with Rulex.

Any recipients of Your personal data will be able to process them as “data processors” specifically appointed and instructed by Rulex or as “data controller” authorized to access them under the provisions of law, regulations and / or regulations.

Special categories of personal data
If, among the personal data provided by You, there are data belonging to special categories of data, as indicated by art. 9(1) GDPR (i.e. personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation) the same will be processed during the selection process for the sole purpose of enabling the fulfilment of obligations and the exercise of rights of Rulex or the person concerned in the field of labour law (art. 9(1)(a) and (b) GDPR).

Transfer of personal data
Rulex does not transfer personal data provided by You outside the European Economic Area (EEA). However, should it become necessary to transfer Your personal data outside the EEA, in order to protect Your personal data in international transfers Rulex will adopt appropriate safeguards, i.e. European Commission adequacy decisions pursuant to Art. 45 GDPR, standard contractual clauses approved by the European Commission and contractual instruments offering adequate safeguards (Article 46 GDPR); alternatively, transfers will take place if the exceptions provided for in Article 49 GDPR apply (i.e. consent of the data subject, necessity of the transfer for the purpose of contractual/pre-contractual measures, overriding public interest, right to defence in court, vital interests of the data subject or of other persons, data entered in a public register).

Data retention period
Your personal data will be kept for a maximum of 6 months from the time of receipt or from the last update received by them, unless certain needs exist that justify storage for a further period, such as the onset of disputes. In the latter case, Your personal data will be kept until the deadlines for appealing actions are exhausted.
In the event of your explicit consent, Rulex will retain your personal data until the final deadline of 24 months from the time of receipt or from the last update received, in order to allow the Company to contact you even beyond the ordinary retention period of 6 months.

Rights of the data subject
We inform You that as data subject You may exercise towards Rulex all the rights provided for by article 15 and following of the GDPR. In particular:

  • right of access (Art. 15 GDPR): confirmation as to whether or not personal data concerning You are being processed and, if so, the right to obtain, inter alia, access to Your personal data and information regarding the purposes of the processing, the categories of personal data concerned, the recipients or categories of recipients to whom the personal data have been or will be communicated;
  • right of rectification (Art. 16 GDPR): (i) rectification of inaccurate personal data relating to You without undue delay and (ii) supplementation of Your personal data, if incomplete;
  • right to erasure (“right to be forgotten” art. 17 GDPR): erasure of personal data concerning You without undue delay;
  • right to restriction of processing (art. 18 GDPR): restriction of processing in the cases referred to in Article 18 GDPR;
  • right to data portability (Art. 20 GDPR): receipt in a structured, commonly used and machine-readable format of personal data concerning You and in our possession; right to transmit such data to another data controller without hindrance by the controller to whom You have provided them in the cases referred to in Article 20 GDPR;
  • right to object to processing carried out pursuant to Article 6(1)(e) or (f) (Article 21 GDPR): objection, at any time, on grounds relating to Your particular situation, to the processing of personal data concerning You pursuant to Article 6(1)(e) or (f), including profiling on the basis of those provisions.

Procedures for the exercise of rights and complaints to the authority for the protection of personal data
To exercise the rights described above, You may contact the Data Controller by means of a formal request sent to the e-mail address: [email protected], attaching an identification document.
You also have the right to lodge a complaint with the supervisory authority pursuant to Article 77 GDPR, if You believe that the processing of Your data violates the requirements of the GDPR. In Italy, the function of supervisory authority is exercised by the Garante per la protezione dei dati personali (https://www.garanteprivacy.it).

Nature of the conferment of data and consequences in case of failure to provide them
The provision of Your personal data is optional. However, failure to provide personal data will make it impossible for Rulex to follow up the personnel selection process.
For further information and/or clarification, please contact the Data Controller at the following e-mail address: [email protected].

Consent for the data retention period
Pursuant to Article 6 GDPR as a data subject, having read the above information, I give my consent to the retention of my personal data until the final deadline of 24 months from the time of receipt or the last update received, in order to allow Rulex to contact me even beyond the ordinary retention period of 6 months.

Date October 14, 2025