This Application collects some Personal Data from its Users.

Owner and Data Controller

Wakala S.r.l. – Viale Bartolomeo Cavaceppi, 113 – 00127 Rome (Italia)
Owner contact email: info@wakala.it

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Usage Data; Trackers; first name; last name; email address; username; phone number; payment info; billing address; profession; company name; order ID; Data communicated while using the service; contact info; physical address; purchase history; device information; VAT Number; ZIP/Postal code; city; country; date of birth; gender; geographic position; language; password; interview-related data; job position; profile picture; social media accounts; user content; work history; Tax ID; county; picture; prefix ; workplace; User ID; number of employees; field of activity; house number; various types of Data; state; IP address; browser information; operating systems; latitude (of city); longitude (of city); metro area; geography/region; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; app information; time zone; number of sessions; session duration; session statistics; page views.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application. Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Displaying content from external platforms, Handling payments, Hosting and backend infrastructure, Analytics, Contacting the User, Building and running this Application, Handling activities related to productivity, Interaction with external social networks and platforms, Registration and authentication, Registration and authentication provided directly by this Application, Platform services and hosting, Traffic optimisation and distribution, Access to third-party accounts and Spam and bots protection.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Access to third-party accounts

This type of service allows this Application to access Data from your account on a third-party service and perform actions with it. These services are not activated automatically, but require explicit authorisation by the User.

LinkedIn account access (LinkedIn Corporation)

This service allows this Application to connect with the User’s account on LinkedIn, provided by LinkedIn Corporation. 

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy

Analytics

The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.

Google Analytics (Universal Analytics)

Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilises the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualise and personalise the ads of its own advertising network.

In order to understand Google’s use of Data, consult their partner policy and their Business Data page.

Personal Data processed: Trackers; Usage Data. Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out

Matomo Cloud (InnoCraft)

Matomo Cloud is an analytics service provided by InnoCraft.

Personal Data processed: app information; browser information; clicks; device information; geography/region; language; number of sessions; operating systems; page views; session duration; session statistics; state; time zone; Usage Data.

Place of processing: New Zealand – Privacy Policy.

Building and running this Application

Key components of this Application are built and run directly by the Owner by making use of the software listed below.

WordPress (self-hosted) (this Application)

This Application is built and run by the Owner via a CMS software (Content Management System) called WordPress.

Personal Data processed: billing address; city; company name; contact info; country; Data communicated while using the service; date of birth; device information; email address; first name; gender; geographic position; language; last name; password; payment info; phone number; physical address; profession; purchase history; Usage Data; username; VAT Number; ZIP/Postal code.

Contacting the User

Phone contact (this Application)

Users that provided their phone number might be contacted for commercial or promotional purposes related to this Application, as well as for fulfilling support requests.

Personal Data processed: phone number.

Mailing list or newsletter (this Application)

By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.

Personal Data processed: email address; first name; last name.

Contact form (this Application)

By filling in the contact form with their Data, the User authorises this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data processed: email address; first name; last name.

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them. Such services are often referred to as widgets, which are small elements placed on a website or app. They provide specific information or perform a particular function and often allow for user interaction. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Google Fonts

Google Fonts is a typeface visualisation service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Application to incorporate content of this kind on its pages.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Font Awesome (Fonticons, Inc. )

Font Awesome is a typeface visualisation service provided by Fonticons, Inc. that allows this Application to incorporate content of this kind on its pages.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy.

Handling activities related to productivity

This type of service helps the Owner to manage tasks, collaboration and, in general, activities related to productivity. In using this type of service, Data of Users will be processed and may be retained, depending on the purpose of the activity in question. These services may be integrated with a wide range of third-party services disclosed within this privacy policy to enable the Owner to import or export Data needed for the relative activity.

Human resources managed internally (this Application)

This Application uses an internal human resources system that does not involve third parties.

Personal Data processed: city; email address; first name; interview-related data; job position; last name; phone number; profile picture; social media accounts; user content; work history.

Handling payments

Unless otherwise specified, this Application processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Application isn’t involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

PayPal (PayPal Inc.)

PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

Personal Data processed: billing address; company name; email address; first name; last name; order ID; payment info; phone number; profession; username; various types of Data as specified in the privacy policy of the service.

Place of processing: See the PayPal privacy policy – Privacy Policy.

Stripe ( Stripe Technology Europe Ltd)

Stripe is a payment service provided by Stripe Technology Europe Ltd.

Personal Data processed: billing address; email address; first name; last name; payment info; various types of Data as specified in the privacy policy of the service.

Place of processing: European Union – Privacy Policy

Hosting and backend infrastructure

This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application.

Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

OpenAI API (OpenAI, L.L.C.)

The OpenAI API provided by OpenAI, L.L.C. is a service that helps the Owner to automate tasks through its AI engine.

Personal Data processed: Data communicated while using the service; Usage Data.

Place of processing: United States – Privacy Policy.

Amazon S3 (Amazon Web Services, Inc.)

Amazon S3 is a cloud storage service provided by Amazon Web Services, Inc.

Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy.

Amazon Web Services (AWS) (Amazon Web Services, Inc.)

Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Italy – Privacy Policy.

ArubaCloud (Aruba S.p.A.)

ArubaCloud is a hosting service provided by Aruba S.p.A.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Italy – Privacy Policy.

Interaction with external social networks and platforms

This type of service allows interaction with social networks or other external platforms directly from the pages of this Application. The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network. This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it. It is recommended to log out from the respective services in order to make sure that the processed data on this Application isn’t being connected back to the User’s profile.

PayPal button and widgets (PayPal Inc.)

The PayPal button and widgets are services allowing interaction with the PayPal platform provided by PayPal Inc.

Personal Data processed: Trackers; Usage Data.

Place of processing: See the PayPal privacy policy – Privacy Policy.

Platform services and hosting

These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Aruba Hosting (Aruba S.p.A.)

Aruba Hosting is a hosting service provided by Aruba S.p.A.

Personal Data processed: billing address; city; country; Data communicated while using the service; device information; email address; first name; gender; language; last name; physical address; prefix ; state; Usage Data; User ID; username; ZIP/Postal code.

Place of processing: Italy – Privacy Policy.

WordPress.com

WordPress.com is a platform provided by Automattic Inc. or by Aut O’Mattic A8C Ireland Ltd., depending on how the Owner manages the Data processing, that allows the Owner to build, run and host this Application.

Personal Data processed: billing address; Data communicated while using the service; device information; email address; first name; last name; payment info; phone number; Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Registration and authentication

By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services. Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third-party services, for registration or identification purposes. Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.

Google OAuth

Google OAuth is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, and is connected to the Google network.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

LinkedIn OAuth (LinkedIn Corporation)

LinkedIn Oauth is a registration and authentication service provided by LinkedIn Corporation and is connected to the LinkedIn social network.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Registration and authentication provided directly by this Application

By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.

Direct registration (this Application)

The User registers by filling out the registration form and providing the Personal Data directly to this Application.

Personal Data processed: billing address; city; company name; country; county; date of birth; email address; field of activity; first name; gender; house number; language; last name; number of employees; password; phone number; physical address; picture; prefix ; profession; profile picture; Tax ID; Usage Data; User ID; username; various types of Data; VAT Number; workplace; ZIP/Postal code.

Spam and bots protection

This type of service analyses the traffic of this Application, potentially containing Users’ Personal Data, with the purpose of filtering it from unwanted parts of traffic, messages and content that are recognised as spam or protecting it from malicious bots activities.

Google reCAPTCHA (Google Ireland Limited)

Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited. The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

In order to understand Google’s use of Data, consult their partner policy and their Business Data page.

Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Trackers; Usage Data.

Place of processing: Ireland – Privacy Policy.

Traffic optimisation and distribution

This type of service allows this Application to distribute their content using servers located across different countries and to optimise their performance. Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Application and the User’s browser. Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

Amazon CloudFront (Amazon Web Services, Inc.)

Amazon CloudFront is a traffic optimisation and distribution service provided by Amazon Web Services, Inc.

Personal Data processed: browser information; city; country; county; device information; geography/region; IP address; latitude (of city); longitude (of city); metro area; operating systems; state; Usage Data; ZIP/Postal code.

Place of processing: Italy – Privacy Policy.

Further information about the processing of Personal Data

Preference Cookies

Preference Cookies store the User preferences detected on this Application in the local domain such as, for example, their timezone and region.

Selling goods and services online

The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery. The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by this Application depends on the payment system used.

Cookie Policy

This Application uses Trackers. To learn more, Users may consult the Cookie Policy.

Further Information for Users

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes.
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Further information about retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The rights of Users based on the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following, to the extent permitted by law:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given theirconsent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing iscarried out on a legal basis other than consent.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regardingcertain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated orcorrected.
• Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Ownerwill not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from theOwner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in astructured, commonly used and machine readable format and, if technically feasible, to have it transmitted to anothercontroller without any hindrance.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governedby public international law or set up by two or more countries, such as the UN, and about the security measures taken by theOwner to safeguard their Data.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or forthe purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a groundrelated to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object tothat processing at any time, free of charge and without providing any justification. Where the User objects to processingfor direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether theOwner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of thisdocument.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Suchrequests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Userswith the information required by law. Any rectification or erasure of Personal Data or restriction of processing will becommunicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this provesimpossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal actionarising from improper use of this Application or the related Services.The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional andcontextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interactionwith this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please seethe contact information at the beginning of this document.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possiblywithin this Application and/or – as far as technically and legally feasible – sending a notice to Users via any contact informationavailable to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed atthe bottom.Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consentfrom the User, where required.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number —allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through this Application (or third-party services employed in this Application), which caninclude: the IP addresses or domain names of the computers utilised by the Users who use this Application, the URI addresses(Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the filereceived in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the countryof origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g., the timespent on each page within the Application) and the details about the path followed within the Application with special referenceto the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User

The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, asdescribed in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposesand means of the processing of Personal Data, including the security measures concerning the operation and use of thisApplication. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Application as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states tothe European Union and the European Economic Area.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User’s browser.

Tracker

Tracker indicates any technology – e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting -that enables the tracking of Users, for example by accessing or storing information on the User’s device.

work history

Provides access to work history.

Legal information

This privacy policy relates solely to this Application, if not stated otherwise within this document.

Latest update: 4 September 2024