Tutored is a social platform dedicated to the university world and talent acquisition.
Indeed, within the platform and the App users can share information, notes, books, private lessons, and they can interact with a community of students from the same study path. Moreover, they have the opportunity to create and update their personal profile and to find the companies and the job offers in line with their ambitions.
Tutored (registered office in Rome, via Marsala 29/H, hereinafter “Tutored”) is committed to protecting the privacy of its users.
All the information and data that you will provide or otherwise acquired in the context of the use of Tutored services - such as: access to the Website’s private are, https://www.tutored.me/en/, the use of push notifications to inform users about job offers (hereinafter “Services” -, will be processed in accordance to the provvisions of the Regulation and the duty of confidentiality that inspire Tutored’s activities.
In accordance to the Regulation, the data processing activities performed by Tutored will be based on the principles of lawfulness, fairness, transparency, purpose limitation and conservation, minimization of data, accuracy, integrity and confidentiality.
- Data controller
- Personal data subject to processing
- Browsing data
- Special categories of personal data
- Data provided voluntarily by the user
- Purpose of the data processing
- Legal basis and mandatory or optional nature of the data processing
- Recipients of personal data
- Transfers of personal data
- Storage of personal data
- Rights of the data subject
- Data controller and Data Protection Officer “DPO”
The data controller of all the data processed through the Website is Tutored as defined above, reachable at https://www.tutored.me/en/.
The Data Protection Officer (hereinafter “DPO”) ex article 37 and following of the Regulation: reachable at firstname.lastname@example.org
- Personal Data subject to processing
We inform you that Tutored will process your personal data during your browsing sessions, which may consist of an identifica such as the name, an identificato Number, an online identificato or one or more characeristic elements of your physical, economic, cultural or social identity, suitable of identifying or making identifiable the interested subject (hereinafter “Personal Data”).
The Personal Data processed through the Website are the following:
Personal Identification: name, surname, address, nationality, date of birth, ethnicity or gender
Sensitive Data: any sensitive data relating to Law 12 March 1999, n. 68.
Paths: university or post-university education, CV, cover letters.
Imports: important information imported by Tutored for third parties
All the information listed here is not provided immediately by browsing the Website, but it May be requested for the provisione of some of Tutored Services, as better specified in Point b.
a. Browsing Data:
during their normal operation, the IT Systems and software procedure used to operate the Website acquire some Personal Data whose trasmissione is implicito in the use of Internet Communication Protocols. This information is not collected with the purpose of being associated with identified interested parties, but due to their very nature they could allow for users identification through processing and association with data held by third parties. This category of data includes the IP addresses or Domain names of the computers used by users who browse the Website, the addresses in URI notation (Uniform Resource Identifier) of the requested resources, the time of the request, the metodo used to submit the request to the server, the size of the file obtained in response, the numerica code indicati the status of the response given by the server (succesful, error, etc.) and other parameters relating to the operating System and the user’s IT environment. These data are used for the sole purpose of obtaining Anonymous statistica information on the use of the Website and to check its correct functioning, to identici anomalie and/or abuses, and they are delete immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer Crimea against the Website or third parties: except for this case, at present the data on web contacts are not stored for more that seven days.
b. Special Categories of Personal Data:
through the services dedicated to temporary employment, a transfer of your Personal Data falling within the category of special categories of Personal Data referred to in article 9 of the Regulation may occur, verbatim the “[...] 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 person’s sex life or sexual orientation”.
We inform you that these data are used only when strictly necessary.
We remind you that Tutored cannot ne held responsible for any reason, nor it will be able to receive disputes whatsoever following the transmission of special categories of Personal Data in the absence of specific manifestation of consent to precess such data (possibility which obviously allows for sending a CV). Indeed, in such case the processing of Personal Data would be allowed as it concerns data made manifesto public by the interested party, in accordance with article 9(1)(e) of the Regulation. However, we specify the importance, as stated above, to express the explicit consent to the processing of special categories of Personal Data, should you decide to share this information.
We also inform you that, for the purpose of selection, Tutored may analyze the professional social profiles made available on the internet and may ask you to cross the information present on the Social Networks with the information present on Tutored in order to outline an effective and complete application profile. Therefore, if you choose to access tTutored with the Social Network login, we may import the information requested from your your account and make it part of your profile (e.g. LinkedIn).
c. Data voluntarily provided by the interested party:
during the use of some Webiste’s services, the processing of third parties Personal Data sent by you to tutored may occur. In respect to these hypotheses, you are an independent data controller, assumine all legal obligations and responsibilities. In this case, the widest indemnity operates with respect to any dispute, claim, request for compensation for damage etc. due to the data processing that should be propose against Tutored by third parties whose Personal Data have been processed through your use of the functions of the Website in violation of the applicabile rules for the protection of Personal Data. In any case, should you provide or in any manner process third parties Personal Data when using the Website, you guarente from now - taking all responsibilites - that this particular case of data processing is based on a suitable legal basis pursuant to article 6 of the Regulation which legitimizes the processing of the information Ion quesiton.
- Finalità del trattamento
Purpose of the Data Processing: the data processing that we intendo to Carry out, with your specific consent where necessary, has the following purposes:
a. To allow the provision of the services requested by you, namely:
i) Accessing the private area of the Website;
ii) Sending the newsletter;
iii) Uploading a CV to apply to a job offer;
iv) Helping potential employers to analyze your profile and to contact you;
v) Replying to requests for assisane or information;
vi) Contacting us and replying to your requests;
vii) Visualizing the job offers published sin the Website;
viii) Receiving push notifications via email or Whatsapp;
ix) Sharing notes, hints, and advices about exams or sharing job offers;
b. To fulfill any legal, accounting and tax obligations.
c. To provide personalized, targeted or location-based contents, services and advertising from Tutored and third parties.
d. To keep you updated about job offers and career tips.
e. To make inferences on your career giving you tips about job offers.
f. To Carry out polls and to publish the results.
g. To detect anomalo and illegal behaviour.
- Legal basis and mandatory or optional nature of the data processing:
the legal basis for the processing of Personal Data for the purposes referred to in section 3 (a-b-c-g) is article 6(1)(b) of the Regulation as the processing of personal data is necessary for the provision of the Services or for the response to requests of the interested party. Providing Personal Data for these purposes is optional but any failure to provide tem would make the Services provided by the Website, finding requests or evaluating CV impossible to activate. With specific reference to purpose 3.c and the related Analysis of professional profiles made freely available for Tutored, the legal basis of the processing of Personal Data is article 6(1)(f) of the Regulation, i.e. Tutored’s legittimate interest in verifying any risk on the candidates’ suitability to fill the specific open position.
The purpose referred to in section 3.b represents a legitimate processing of Personal Data pursuant to art. 6 (1) (c) of the Regulation. Once Personal Data has been provided, the processing is indeed necessary to fulfill a legal obligation to which Tutored is subject.
For the processing of Personal Data carried out for the purpose of direct sending of its advertising material or of its direct sale or for carrying out its market research or commercial communications in relation to Tutored products or services similar to those purchased by you, Tutored can use, without your consent, the e-mail and paper mail addresses pursuant to and within the limits permitted by the provision of the Guarantor Authority for the protection of personal data of 19 June 2008; the legal basis for the processing of your data for this purpose is art. 6, paragraph 1, lett. f) of the Regulations.
In any case, pursuant to art. 21 of the Regulation, you have the possibility to oppose this processing of Personal Data at any time, initially or on the occasion of subsequent communications, easily and free of charge also by writing to the Data Controller or the DPO at the addresses indicated above, as well as to obtain an immediate confirmation that confirms the interruption of this processing of Personal Data (art.15 of the Regulations).
- Recipients of Personal Data:
For the purpose referred to in section 3 above, your Personal Data may be shared with:
- a. Subjects who typically act as data processors pursuant to art. 28 of the Regulation, that is: i) persons, companies or professional firms that provide assistance and advice to Tutored in accounting, administrative, legal, tax, financial and credit recovery matters relating to the provision of the Services; ii) subjects with whom it is necessary to interact for the provision of the Services (for example hosting providers) iii) or subjects delegated to carry out technical maintenance activities (including the maintenance of network equipment and electronic communication networks); (collectively "Recipients"); the list of data processors that process data can be requested from the Data Controller or from the DPO by writing to the following addresses:email@example.com .
- b. Subjects, entities or authorities, independent data controllers, to whom it is mandatory to communicate your Personal Data pursuant to legal provisions or orders from the authorities;
- c. Persons authorized by Tutored to process Personal Data pursuant to art. 29 of the Regulation necessary to carry out activities strictly related to the provision of the Services, which are committed to confidentiality or have an adequate legal obligation of confidentiality (e.g. Tutored employees).
- d. The data will be accessible to other companies and temporary agencies that use Tutored to receive curricula and spontaneous applications. By applying to a job offer within Tutored, providing contact information to show interest in a job offer, responding to a message from an employer, you consent to the disclosure of your information to that employer and / or to the temporary agency of reference and to be contacted by this employer and such temporary agency for employment-related purposes.
Tutored reserves the right to publish the privacy policies of websites and temporary employment agencies to which it addresses and connected to Tutored, as far as possible.
Tutored will also process your data for administrative and accounting purposes pursuant to art. 6.1.f) and Recitals 47 and 48 of the Regulation.
By presenting your resume you make it searchable and the information is consequently made available, potentially depending on the service, on a public website.
Recruiters, companies and temporary agencies that have access to the databases containing your resume or profile will have access to your information.
We also share aggregate information about visitors to the Site to post online ads. In addition, we collect data relating to professional qualifications, education, age, experience level or other information relevant to the job search. These aggregated data do not identify users individually and can be made available to employers or shared publicly.
We disclose your information if you are legally obliged to do so to meet legal requirements or comply with legal procedures and protect our rights or property and investigate the commission of crimes or behaviors that endanger the safety of things or people.
6. Transfers of Personal Data
Some of your personal data are shared with recipients who could be found outside the European Economic Area. The owner ensures that the processing of your personal data by these recipients takes place in compliance with the Regulation. Indeed, transfers can be based on an adequacy decision, on the Standard Contractual Clauses approved by the European Commission or on another suitable legal basis. More information is available from the Data Controller or from the Tutored DPO at the following addresses: firstname.lastname@example.org.
- Storage of Personal Data:
Personal Data processed for the purposes referred to in section 3 will be kept for the time strictly necessary to achieve those same purposes in compliance with the principles of minimization and limitation of conservation pursuant to articles 5.1.e) of the Regulation. In any case, the Data Controller will process the Personal Data for the time necessary for contractual and legal obligations. As for the CVs sent, the Personal Data will be kept as long as the position for which the CV was sent is available. This is without prejudice to the possibility for the Data Controller to contact the candidate shortly before the indicated deadline to request an extension of this retention period and to proceed with push, email or Whatsapp notifications to notify of similar positions.
- Diritti degli interessati
Pursuant to articles 15 and following of the Regulation, you have the right to request at any time, access to your Personal Data, their correction or cancellation, the limitation of treatment in the cases provided for by art. 18 of the Regulation, obtain the data concerning you in a structured format, commonly used and readable by an automatic device, in the cases provided for by art. 20 of the Regulation. At any time, you can revoke ex art. 7 of the Regulation the consent given; propose a complaint to the competent supervisory authority pursuant to article 77 of the GDPR (Guarantor for the Protection of Personal Data) pursuant to art. 77 of the Regulation, if you believe that the processing of your data is contrary to the legislation in force.
According to article 21 of the GDPR, you can submit an opposition to the processing of your Personal Data in which you shall give evidence of the reasons that justify the opposition: the Data Controller retains the right to evaluate the application, which would not be accepted in the case of the existence of binding legitimate reasons to proceed with the processing that prevails over your interests, rights and freedoms.
Requests should be sent in writing to the Data Controller or to the DPO at the following addresses:
To delete your account, write to email@example.com