CANDIDATE PRIVACY NOTICE
As part of its recruitment process relevant to employment or other individual engagements, Bulgari S.p.A. and its affiliates*1 all acting as “Joint Controllers” for the specific purposes identified in this Privacy Notice (collectively referred to as “Bulgari”) receive, use, and store candidates’ personal data. Bulgari may also share the information with others in some specific situations (see below).
By registering and submitting your application for a role with Bulgari, either directly or via an authorised third party, Bulgari will collect and process your personal data. This Candidate Privacy Notice contains details of Bulgari’s policies and practices regarding the collection and processing of your personal data and the rights and choices you have.
In the event that you have any questions or concerns about the information provided, please contact Bulgari using the information at the end of this Privacy Notice.
Bulgari will process candidate data in accordance with this Privacy Notice, unless in conflict with requirements set by the applicable law, in which case the applicable law will prevail.
To ensure all personal data is processed in accordance with its data protection policies, Bulgari can only accept applications or expressions of interest in a role at Bulgari through its careers portal, which can be accessed at: http://careers.Bulgari.com/.
What personal data does Bulgari collect
Except as otherwise set forth in the addendum to this Privacy Notice, Bulgari may collect, use, share, and store your personal data during the recruitment process, which includes but is not limited to:
1) General Personal Dataa. Application data: Your CV, name, registered home address, email address, phone number, academic and professional qualifications, diversity profile (age, gender etc.), citizenship, compensation details, and any other information you choose to include in your CV and cover letter;
b. Assessment data: Pre-employment assessments (such as technical, behavioural or psychometric tests), interviews and any other information collected to evaluate your candidacy; the outcome of processing your OPQ test will involve a form of automatically processing your personal data to evaluate certain personal aspects relating to you, in particular, to analyse or predict aspects concerning your preferences in the workplace. The outcome of the test will be always subject to human review to make the final decision concerning your candidacy.
c. Pre-employment screening data: date of birth, personal identification, bank account information, tax status, online presence, medical data and declarations, criminal record, credit rating, employment, and regulatory references and status, personal location information, and the dependent's details
2) Sensitive Dataa. Diversity profile: Bulgari might process your health data (e.g. belonging to protected categories, disabilities) to promote diversity and inclusion and ensure equal opportunities and employment.
Sources of Data Collection
Bulgari may collect personal data that you directly provide on the website or directly to the Bulgari personnel. In addition, Bulgari may collect your personal data from other legitimate sources such as other LVMH groups, publicly available sources (including the Internet, only where considered relevant in relation to the position for which you are applying for), search engines, and information from third parties that you have chosen and consented to disclosing information about you. Examples of such third parties may include recruiters, online professional networks or vendors in connection with pre-employment screening data.
Why Does Bulgari Collect and Use Your Personal Data
Bulgari has a legitimate interest in processing your personal data during the recruitment process. Processing personal data from job applicants allows Bulgari to manage the recruitment process, assess and confirm a candidate’s suitability for employment or other engagements, and decide when an offer of employment or engagement should be extended. Bulgari will only process data relating to criminal convictions if such is required, by law, for your specific position with Bulgari. In addition and to the extent any data as such is processed by Bulgari, Bulgari will process any health data in compliance with the guidelines issued by the relevant Data Protection Authority.
In some cases, Bulgari needs to process your personal data to ensure that Bulgari is complying with its legal, regulatory, and corporate governance obligations. Bulgari will process your health data for the purpose of ensuring equal opportunities and employment. Processing your personal data for this purpose is necessary to carry out the obligations and exercise the specific rights in the field of employment, social security and social protection law.
Some of the information Bulgari may obtain from or about you might be sensitive. Except as otherwise set forth hereinafter Bulgari generally only keeps sensitive information if you expressly consent to it, and/or if it is necessary to carry out its obligations or exercise its legal rights (or to enable you to exercise your legal rights). Moreover, upon your consent Bulgari may share your personal data with LVMH Hennessy Moet Louis Vuitton SE and its subsidiaries worldwide (“LVMH”), including those outside of the European Economic Area, in order to, if applicable, be contacted in case of an offer corresponding to the relevant profile. If you decide not to give permission for your personal data to be transferred to LVMH, this will exclude you from being contacted for potential offers corresponding to your profile and will not affect the current selection process.
How does Bulgari Share Your Personal Data
Bulgari may disclose your personal data if required to do so by law, court of law, or as requested by a governmental or law enforcement authority.
Aside from this, Bulgari generally only shares your personal data with others for important components of the recruitment process. For example, Bulgari may share your personal data with other members of the Bulgari group, of companies relevant to your application or to LVMH Hennessy Moet Louis Vuitton SE and its subsidiaries worldwide (“LVMH”).
Bulgari may also share your personal data with a select group of third-party service providers that carry out certain recruitment-related activities on its behalf, such as background checking agencies and companies that help Bulgari with storing data.
Bulgari expects entities with which Bulgari shares your personal data (both corporate groups and non-affiliated third parties) to protect the confidentiality and security of your data and to use it only for its intended purposes.
Transferring Your Personal Data to Other Countries
The organisations with which Bulgari may share your personal data may be located in countries outside of the European Economic Area (“EEA”); in this respect, if the data is transferred outside of the European Economic Area, in countries not deemed adequate by the European Commission, LVMH has adopted binding corporate rules (BCR) validated by the French Data Protection Authority (CNIL), after having assessed the possible provision of "supplementary measures" to ensure a level of protection essentially equivalent to that guaranteed within the European Union.
A copy of said BCR can be obtained by sending an email to firstname.lastname@example.org or by sending a written letter to the Data Protection Officer [DPO] at Bulgari S.p.A., Lungotevere Marzio 11, Rome.
How Long Does Bulgari Keep Your Personal Data
If your job application for a specific role is unsuccessful or if you submit a general application for its consideration, then, except as otherwise set forth, Bulgari will generally keep your information for 36 months beyond the recruitment process, unless you authorise us to keep it longer. Bulgari does this in case any other position becomes available that may suit your application and to maintain a record of its recruitment processes for legal reasons.
If your job application is successful, your personal data Bulgari gathered during the recruitment process will be retained during your employment. The period for which your personal data will be held will be provided to you in a separate employee privacy notice.
How Does Bulgari Protect Your Personal Data
Bulgari has implemented technical, administrative, and physical security measures to protect your personal data from unauthorised access and improper use. Bulgari has built security policies and procedures based on Bulgari’s view of best practice frameworks and reviews these procedures in order to consider appropriate new technology and methods on an ongoing basis. Except as otherwise required by law, only those who have proper authorisation will be allowed to view your personal data. In addition, Bulgari trains its employees on the importance of confidentiality and maintaining the privacy and security of your information. Moreover, Bulgari undergoes periodic security risk assessments to ensure the security of information in its possession.
Subject to certain limitations, you have the right to access your personal data stored by Bulgari, to restrict or object to the processing of your personal data, and to rectify, erase, and restrict your personal data. Your rights below are subject to you exercising them in good faith and Bulgari’s legitimate business interests or other valid basis to continue processing your personal data, in accordance with Bulgari’s policies and applicable law; where Bulgari relies upon its legitimate interests to process your personal data as a basis for processing, it shall demonstrate such compelling legitimate grounds on an individual basis. To request further information on the balancing test performed you may contact Bulgari at any time by sending an email to the following address: email@example.com.
To exercise your rights, obtain further information about your rights or ask any questions regarding the processing of your personal data by Bulgari, please email firstname.lastname@example.org or contact the Data Protection Officer (DPO) of Bulgari through the various methods of contact specified at the end of this Privacy Notice.
Questions, Concerns, and Complaints
Should you wish to make a complaint about Bulgari’s use of your personal data, you may contact Bulgari using the methods specified at the end of this Privacy Notice.
You also have the right to lodge a complaint with the appropriate regulatory body/supervisory authority, in particular in the country where you reside, place of work or of an alleged infringement of the law.
Data Controller Name and Contact Details
The data controller responsible for processing data is Bulgari S.p.A. – Via dei Condotti 11 – 00186 Rome (RM) as well as each Bulgari Corporate Group, all of them acting as joint controllers.
How to Contact Bulgari
Bulgari has appointed a Data Protection Officer (hereinafter “DPO”) that you may contact at any time via e-mail to the following address: email@example.com or by sending a letter addressed to: Guido Sandonà, Lungotevere Marzio, n°11 – 00186 – Rome (RM) – Italy, or alternatively by contacting the following number (+39) 06.68810211.
The DPO is always available to provide you with all the information you might need concerning the processing of your personal data by Bulgari under this privacy notice and to exercise the specific rights provided to you by the GDPR.
1 *The term Bulgari Corporate Group refers to: Bulgari S.p.A. (Italy), Bulgari Italia S.p.A. (Italy), Bulgari Accessori S.r.l. (Italy), Bulgari Asia Pacific Ltd (Hong Kong), Bulgari Asia Pacific Ltd (Macao Branch), Bulgari Australia PTY Ltd (Australia), Bulgari Belgium SA (Belgium), Bulgari Canada Ltd (Canada), Bulgari Commercial de Mexico Ltd (Mexico), Bulgari Commercial Shanghai CO Ltd (People’s Republic of China), Bulgari Corporation of America (U.S.A.), Bulgari Denmark ApS (Denmark), Bulgari Deutschland GmbH (Germany), Bulgari do Brazil Lda (Brazil), Bulgari España SA (Spain), Bulgari France SA (France), Bulgari Gioielli S.p.a., Inc., Bulgari Global Operations SA, Bulgari Horlogerie S.A., Bulgari New Zealand Limited, Bulgari Netherlands, Bulgari Ireland Ltd (Ireland), Bulgari Japan Ltd (Japan), Bulgari Korea Ltd (Korea), Bulgari Malaysia SDN BHD (Malaysia), Bulgari Montecarlo SAM (Principality of Monaco), Bulgari Panama Inc. (Panama), Bulgari Philippines Inc., Bulgari Prague (Czech Republic), Bulgari Portugal Lda (Portugal), Bulgari Qatar Llc (State of Qatar), Bulgari Russia Llc (Russian Federation), Bulgari SA (Switzerland), Bulgari St Barth SAS (Saint Barthelemy), Bulgari South Asian Operation PTE Ltd (Republic of Singapore), Bulgari Taiwan Ltd (Taiwan), Bulgari Turkey Luxury and Trade Llc (Republic of Turkey), Bulgari Thailand Ltd (Thailand), Bulgari UK Ltd (United Kingdom), Bulgari Vietnam Ltd, Gulf Luxury Trading Llc (Dubai), Lux Jewels Bahrain Wll (Kingdom of Bahrain), Lux Jewels Kuwait Wll (State of Kuwait), India Luxco Retail Private Ltd (Republic of India), BK for Jewellery and Precious metals and stones co.