✕
Privacy Policy
1. INTRODUCTION
This Privacy Policy explains how ELITE S.p.A., a company of the Euronext Group (as defined below) having its registered office in Piazza degli Affari 6, Milano ("ELITE" or “we”, “us” or “our”), acting in its capacity of data controller collects information from you when you or a company with which you are connected:
• use our products or services;
• download documents from the Website (as defined below) and/or in connection with the services offered by ELITE or subscribe for alerts or newsletters from ELITE;
• by participating to one of our events;
• visit or register to use https://elite-network.com and all its subdomains (the “Website”).
If you provide Personal Data directly to us or via third parties, in the following cases, please refer directly to section 12 that provides the information relating to these specific cases (“Applicant(s)”):
• You participate in a Euronext recruitment initiative
• You voluntarily submit your resume to a representative of ELITE on an ad hoc basis
• You apply for an advertised job
• A recruiter provides your resume or details to ELITE
• ELITE finds your CV / details in online searches e.g. LinkedIn
• You are referred to an open position by an employee as part of the Euronext Referral Program.
This Privacy Policy applies to any and all job applications submitted and recruitment initiatives co-ordinated by ELITE.
IMPORTANT: should you send your resume via a recruiter with whom you have engaged with, we encourage you to read the relevant recruiter's data protection Privacy Policy to understand how your Personal Data is processed by such a recruiter who is a controller of your Personal Data independently of Euronext’s concerned entity.
1.2 As outlined below, the modalities of processing of your Personal Data (as defined below) will change depending on the applicable purpose of processing above.
1.3 Please read this Privacy Policy carefully and re-visit this page from time to time to review any changes that may have been made.
1.4 Your data controller will be ELITE that will process any Personal Data (as defined below) we collect about you in accordance with applicable data protection laws. ELITE is part of the Euronext Group (“Euronext Group”) which consist of Euronext N.V, a Dutch holding company, located at Beursplein 5, 1012 JW, Amsterdam, the Netherlands, and its direct and indirect affiliated companies.
1.5 In the event of any conflict between this Privacy Policy and the terms of a contract you have with us, the relevant provision of that contract shall prevail. Nothing in this Privacy Policy shall apply to the extent that it is incompatible with applicable data protection laws.
1.6 Effective Date: 14 June 2024
2.2. WHAT PERSONAL DATA WE COLLECT AND ON WHICH LEGAL GROUND?
2.1 "Personal Data" refers to information which does or is capable of identifying you as an individual.
The Personal Data we may process, which we may collect either directly from you or a company with which you are connected or from a third party, may include some or all of the following depending on the nature of the processing activity.
This processing shall be legally required depending of the regulated activity of ELITE.
| DEVICE INFORMATION | We collect information about your computer/device browser via cookies used on ELITE websites. Please see section 4 and 10 of this Privacy Policy for further information. |
| CONTACT AND COMPANY INFORMATION | This may include general Personal Data about who you are such as your name, your corporate contact details, your personal contact details, employer’s name, your job title and position in a company. |
| AML INFORMATION | This may include your position as a director, officer or beneficial owner of a company, copy documentation confirming your identity (such as your passport or identity card) and copy documentation showing proof of your address and information collected through AML software and screening tools. |
| CRM INFORMATION | This may include your correspondence and communications with us and details of your connections with our staff and of your visits to our premises.formazioni possono includere la sua corrispondenza e le sue comunicazioni con noi e dettagli dei suoi rapporti con il nostro personale e delle sue visite alle nostre sedi. |
| PUBLICLY AVAILABLE INFORMATION | This may include information available: (i) on the websites or promotional material of companies or organisations with which you are connected; (ii) in news articles; or (iii) from registries such as the companies registration offices. |
| INFORMATION IN CONNECTION WITH ELITE MEETINGS AND/OR EVENTS | We may collect specific information about you so that we may host you at our premises or at any event or seminar which we organise. We may also collect images (such as photographs and video footage) at IPO announcements and other ELITE events and CCTV footage when you visit our premises. |
| OTHER INFORMATION | We may also process any Personal Data which you or the company with which you are connected choose to provide us. |
2.2 In addition, the Website uses a range of cookies and other tracking technologies to improve and tailor your experience. More information about these can be found in the Cookies Policy.
2.3 We will only collect information that is necessary for us to provide you with the product or service that you have requested. The type of information that we may collect will depend upon the nature of that service or product.
3.HOW WILL WE USE ANY PERSONAL DATA WE COLLECT AND ON WHICH LEGAL GROUND?
3.1 The following is an overview of ELITE 's purposes for processing Personal Information. Please remember that additional information may be provided to you in a separate notice, or in our terms and conditions. In addition to 1.5, in the event of any conflict between any separate notice and our terms and conditions, our terms and conditions shall take precedence.
3.2 The following table details the legal basis ("Legal Basis") according to which and the reasons why ("Purposes") we obtain, collect and process your Personal Data.
| LEGAL BASIS | PURPOSE |
CONTRACT It is necessary to process your Personal Data to enter into and perform our contracts with you. If you do not wish to provide us with your Personal Data for these purposes, we will not be able to enter into or perform our contract(s) with you. | We obtain, collect and process your Personal Data: • to process contract or application between ELITE and you; • to review and publish announcements; • provide you with access to ELITE websites and to enable you to use them • test and improve the effectiveness of ELITE websites and to monitor metrics such as numbers of visitors, traffic data and demographic patterns; • to process your application to participate in dedicated programs organized by ELITE; • for invoicing, billing and commercial purposes. |
LEGITIMATE INTERESTS We process certain of your Personal Data on the basis of our legitimate interests, such as in pursuit of our business or security interests or in the framework of the execution of a contract with a company with which you are connected. Where we process your Personal Data in pursuit of our legitimate interests we determine if such processing is necessary and we carefully consider the impact of our processing activities on your fundamental rights and freedoms. We will not process your Personal Data where our legitimate interests are outweighed by the impact on your rights and freedoms (unless otherwise required or permitted by law). | We obtain, collect and process your Personal Data in order to: subscribed by the company with which you are connected ; |
| LEGAL AND REGULATORY OBLIGATIONS | We obtain, collect and process your Personal Data to comply with legal and regulatory obligations applicable to ELITE (ie carry out regulatory reporting when required by the type of service provided by ELITE, carry out background checks and screening checks on current and prospective directors and qualified advisors) |
CONSENT We may send you direct marketing communications. Where these are electronic communications (email or telephone) we will have obtained your prior consent. In limited circumstances, where we have obtained your explicit prior consent, we may send you marketing communications in relation to carefully selected and relevant third party partners, whose products and services may be of interest to you. You may opt out of certain kinds of marketing, or all forms of marketing, by emailing us at the following address: dpo@euronext.com. Alternatively, you can click on the "opt-out" link provided link provided in all our marketing emails. | Where applicable, we obtain, collect and process your Personal Data on the basis of consent for some specific marketing purposes (i.e. proposal of products & services, invitation to events, marketing communications, newsletters, market research surveys…). |
3.3 Your Personal Information may be processed either electronically or in hard copy form, both inside and outside the EU and the EEA, in accordance with Section 6.
4. ANALYTICS
4.1 This paragraph 4 applies only in relation to the processing of Personal Data performed through the Website and/or in connection with products and/or services offered through it.
4.2 We use analytics tools on the Website to provide the service you request, identify service issues to us, improve our services, provide content tailored to your personal preferences, and to monitor the Website's traffic and usage.
4.3 When we send you marketing emails, we may use email tracking technology, such as dynamic links and image files, to monitor engagement and to understand the relevance and effectiveness of our communications to you.
4.4 When you fill in forms or download files from the Website, we may use technologies to distinguish known from unknown Website visitors, and to monitor customer engagement with our services.
4.5 We may use IP lookup technology to determine your general location so that we can customise the Website for you. We may also use IP lookup to determine how our known clients engage with different parts of the Website.
4.7 All of these tools may be provided by third-party service providers and may include the collection and tracking of certain data and information regarding the characteristics and activities of visitors to the Website. We may disclose data, including Personal Information, to certain such third-party services providers in order to obtain such services.
4.8 One of our providers is Google Analytics and more information about the ways in which they collect and process your Personal Information can be found here: https://www.google.com/policies/privacy/partners.
5.DISCLOSURE OF YOUR PERSONAL DATA
5.1 We may share your Personal Data within the Euronext Group, both inside and outside the European Economic Area as mentioned in Section 6, in order to provide you with our services. Access to your Personal Data is limited to those employees, agents and contractors of the Euronext Group who need access to it in order to provide you with our services; to communicate with you (including, with your prior consent, to send you marketing communications); and to carry out legal or regulatory obligations.
5.2 We may also employ the services of third party service providers located both inside and outside the European Economic Area as mentioned in Section 6 to help us in certain areas, such as website hosting, physical security, marketing and market research. Where third party service providers receive your information we will remain responsible for the use of your Personal Data. We take appropriate steps to ensure that such third parties treat your Personal Data with the same consideration that we do.
5.3 We may from time to time be required to disclose your Personal Data to law enforcement bodies, regulators, agencies or third parties under a legal requirement or court order. We act responsibly and take account of your interests when responding to any such requests.
6.CROSS-BORDER TRANSFERS OF YOUR PERSONAL DATA
6.1 We are an international organisation, with businesses both inside and outside of the European Economic Area ("EEA"). Third party service providers who handle data on our behalf may be based in locations around the world, and we may also be subject to scrutiny from courts or regulators in a number of different jurisdictions. For these reasons, your Personal Data may be transferred to other countries both inside and outside of the EU and the EEA. As privacy laws in other countries may not be equivalent to those in your home country, we only make arrangements to transfer data overseas where we are satisfied that adequate levels of protection are in place to protect any information held in that country or that the service provider acts at all times in compliance with applicable privacy laws. Where required under applicable laws we will take measures to ensure that Personal Data handled in other countries will receive at least the same level of protection as it is given in your home country, for instance by entering into contracts incorporating the European Commission approved model contract clauses.
7.MODALITIES OF PROCESSING OF YOUR PERSONAL DATA
7.1 Your Personal Data are processed by electronic and non-electronic means for the time strictly necessary to achieve the objectives for which that information has been collected. ELITE implements appropriate technical and organizational measures so as to prevent losses and illegal or incorrect use of data, or non-authorized access.
8.RETENTION OF YOUR PERSONAL DATA
8.1 We will retain your Personal Data for as long as is reasonably necessary for the purposes listed in Section 3 above. In particular:
• Personal Data collected for the Mandatory Purposes are retained for the period necessary to the provision of the required product or service, plus a maximum of 10 years from the termination of the account or the termination of the services;
• Personal Data collected for the Marketing Purposes are retained for the period necessary to the provision of the required product or service and for the following 2 years;
At the end of the retention period your Personal Data will be either deleted or anonymized and aggregated.
8.2 However, in some circumstances we may retain Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, tax or accounting obligations. In specific circumstances also we may also retain your Personal Data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges.
9.PROTECTION OF YOUR PERSONAL INFORMATION
Your Personal Data are dealt with in confidence and ELITE has taken appropriate technical and organizational security measures to protect your Personal Data against loss, misuse, alteration and/or destruction. These include, but are not limited to:
• Access control and network protection mechanism to prevent unauthorized access to our systems;
• SSL/TLS Encryption, hardening, backup and secure configuration of systems;
• Physical security controls on premises where Personal Data are stored
Please be aware that the security measures mentioned above apply to systems under the control of ELITE, but that ELITE cannot ensure the security nor confidentiality of any information during its transmission when transmitted via means not under its control, notably the Internet, and that you are aware that data transmitted via such means may be intercepted by third parties.
If ELITE becomes aware of any security breach which results in unauthorized access of your Personal Data, ELITE will endeavor to inform you.
ELITE websites may provide hyperlinks to websites from other companies or persons. This policy does not apply to the use of such websites and we are not responsible or liable for any processing of your Personal Data via these third party websites.
In addition, if you share content from ELITE websites via social media, your Personal Data will be visible to those visiting your personal pages on these social media websites. Euronext is not responsible or liable for any processing of your Personal Data via such media. This policy does not apply to the use of such social media.
10.OUR USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES
10.1 The Website uses cookies and other technologies to improve and tailor your browsing experience as set forth in this Policy and in our Cookie Policy. Please visit our Cookies Policy for more information.
11. YOUR RIGHTS
11.1 The table below sets out the rights which you have to address any concerns or queries with us about our processing of your Personal Data. Please note that these rights are not absolute and are subject to certain exemptions under applicable data protection law.
| RIGHT | FURTHER INFORMATION |
| RIGHT TO BE INFORMED | You have the right to know your Personal Data is being processed by us, how we use your Personal Data and your rights in relation to your Personal Data. |
| RIGHT OF ACCESS | You have the right to ascertain what type of Personal Data Euronext holds about you and to a copy of this Personal Data. |
| RIGHT TO RECTIFICATION | You have the right to have any inaccurate Personal Data which we hold about you updated or corrected. |
| RIGHT TO ERASURE | In certain circumstances you may request that we delete the Personal Data that we hold on you. You have also the right to give post-mortem instructions regarding your Personal Data. |
| RIGHT TO RESTRICTION OF PROCESSING | You have the right to request that we stop using your Personal Data in certain circumstances including if you believe that the Personal Data we hold about you is inaccurate or that our use of your Personal Data is unlawful. If you validly exercise this right, we will store your Personal Data and will not carry out any other processing until the issue is resolved. |
| RIGHT TO OBJECT | Where we rely on our legitimate interests to process your Personal Data, you have a right to object to this use. We will desist from processing your personal information unless we can demonstrate an overriding legitimate interest in the continued processing. |
| RIGHT TO DATA PROTABILITY | In case the processing is based on your consent or a contract conclude with you, you may request us to provide you with certain Personal Data which you have given us in a structured, commonly used and machine-readable format and you may request us to transmit your Personal Data directly to another controller where this is technically feasible. |
You can exercise the rights mentioned above in accordance with the “Data Subject Rights Request Information Procedure ” through the modalities set out in Section 13 below or by submitting a request through the following form.
12. APPLICANTS
This section only applies to Personal Data which you may provide directly to us or via third parties, in the following cases :
• You participate in an ELITE recruitment initiative
• You voluntarily submit your resume to a representative of ELITE SIM on an ad hoc basis
• You apply for an advertised job
• A recruiter provides your resume or details to ELITE
• ELITE finds your CV / details in online searches e.g. LinkedIn
• You are referred to an open position by an employee as part of the Euronext Referral Program.
This section applies:
• to any and all job applications submitted and recruitment initiatives co-ordinated by ELITE,
• up to the point at which we decide not to continue the recruitment process with you or when you start working for us (if applicable). On this latter case, the way we process your Personal Data will no longer be dealt with under this Privacy Policy, but will instead be governed by our Data Privacy Notice.
IMPORTANT: sections 4, 5, 6, 9, 10, 11, 13, 14 and 15 of this Privacy Policy apply to Applicants
12.1 THE PERSONAL DATA WE PROCESS
As part of the recruitment and job application process, we collect the Personal Data that you / your agency / your referrer submit to us, which may include:
| PERSONAL DETAILS | This may include general Personal Data such as your name, gender, residential address, email address, contact telephone numbers, nationality, marital status, etc. |
| DETAILS ABOUT YOUR PREVIOUS EMPLOYMENT |
|
| QUALIFICATIONS | Such as your skills, education, the languages you speak (including your level of proficiency), your eligibility to work in a particular country (e.g. minimum legal age to work, citizenship or visa details), your experience in the job you apply for and other industries, etc. |
| PREFERENCES | Such as positions you may be interested in, information about when you may be available to interview and/or start date for ELITE or work on ongoing basis (e.g. full or part time or on weekends), whether you are open to relocation or working remotely, whether you are willing to travel for work and whether you have your own transport. |
| PUBLICLY AVAILABLE INFORMATION | Details about you which we gather from publicly available sources over the internet and your social media accounts where such searches are relevant to the job you have applied for within ELITE.mazioni su di Lei che raccogliamo da fonti accessibili al pubblico su internet o sui Suoi profili sui social media, quando tali ricerche sono rilevanti per la posizione per cui lei si è candidato. |
| MEDICAL RESULTS | Where legally applicable (Italy, Portugal, United Kingdom and Ireland), results on aptitude and/or pre-employment medical tests which we may ask you to undergo after accepting our offer of employment.ando rilevante, in conformità a disposizioni di legge applicabili (Italia, Portogallo, Regno Unito e Irlanda), I resultati di test attitudinali e / o di esami medici pre-assunzione cui possiamo richiederLe di sottoporsi in seguito all’accettazione di una nostra proposta di impiego. |
| OTHER INFORMATION | Details you may provide us in response to our queries or questions at interview stage (including information about you which we generate throughout the interview and/or recruitment process), at reference check stage, to complete psychometrics tests (where applicable) or details required where mandatory in the respect of local requirements laws. |
If you apply for a position through the “Apply with LinkedIn” option, we may use the information you have previously provided to LinkedIn to populate your application. You are free to remove some details.
The main mandatory information we need to proceed with your recruitment is your resume. You may remove Personal Data from your resume.
It is necessary for us to process your Personal Data in order to assess your job application and/or include you in a recruitment initiative. Ultimately, it may also be necessary for us to process your Personal Data in order to take steps to offer and enter into a contract of employment with you. In the event that you do not wish to provide us with your Personal Data for the purposes outlined in this Privacy Policy, we will not be able to assess your job application and/or include you in a recruitment initiative and/or offer you a contract of employment.
Please note that should you include information you think is relevant to your job application or the recruitment initiative, including cover letters, references from your previous employers and other documents you see fit. For information containing Personal Data, we will hold and process any such Personal Data in accordance with the terms of this Privacy Policy.
12.2 HOW AND WHY WE PROCESS YOUR PERSONAL DATA
The following table details the key context for which ("Legal Basis") and why ("Purposes") we collect, obtain and process your Personal Data within ELITE. The third parties and those within Euronext with whom we may share your Personal Data ("Recipients") are detailed in section 5 and 6 of this Privacy Policy.
| LEGAL BASIS | PURPOSE |
LEGITIMATE INTERESTS It is necessary to process your Personal Data where it is necessary for the purpose of initiate and facilitating the recruitment process. | We obtain, collect and process your Personal Data: • to process your job application, including to contact you in relation to interviews and/or offer you a job after the interview stage ; • to assess your Personal Data against vacancies which we think may be suitable for you ; • to request information from third parties such as qualifications and references ; • to carry out background checks which aim to verify details you have provided to us, potentially using third party sources in UK & US. You will be notified in advance of the use of third parties for the background check. • to retain your information in order to contact you in relation to future vacancies within ELITE may be of interest to you; • to collect feedback on and evaluate the recruitment process ; • to promote internal and external recruitment events such as job fairs, campus events… ; • where legally applicable (Italy, Portugal, United Kingdom and Ireland), to assess if you are fit to work or not fit to work (e.g. where you suffer from a health condition which may affect your work capacity). |
COMPLIANCE WITH A LEGAL OBLIGATION It is necessary to process your Personal Data in order to comply with legal obligations imposed on us as an employer under applicable Irish and European Union law. | We obtain, collect and process your Personal Data in order to comply with legal obligations, which may include: • conformarsi al diritto dell’Unione Europea in materia di impiego, pari opportunità, salute e sicurezza; |
IMPORTANT:
When we process your Personal Data based on our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. We will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law).
We will only use your Personal Data for the purposes for which we collect it (as outlined in this section), unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you in accordance with section 11 of this Privacy Policy and we will explain the legal basis which allows us to do so.
12.3 DISCLOSURE OF YOUR PERSONAL DATA
We may disclose some or all of your Personal Data to the following parties :
• Internal business units such as Human Resources, IT, Finance/Payroll, Managers, system administrators, our trusted third party service providers and our IT service providers;
• Your previous employers when you have provided them as a reference third parties that may be contacted to provide additional information related to your previous work experiences;
• Recruitment agencies;
• Regulatory authorities;
• Outsourced service providers who assist ELITE with recruitment initiatives and campaigns such as recruitment agencies, technical test assessment, background check and health assessment companies (where applicable);etc.
• Professional advisors such as legal advisors, consultants and accountants.
12.4 RETENTION OF YOUR PERSONAL DATA
Where you are a successful job applicant, the Personal Data generated by us and provided by you over the course of the job application/recruitment process will be retained by us for the purpose of your contract of employment. Such Personal Data will be retained in accordance with our Staff Data Protection Policy and Retention Policy (which will be available to you when you commence employment).
Where you are an unsuccessful job applicant, we will retain your Personal Data for a period of up to 12 months after it is determined that your application has been unsuccessful for the purposes of both contacting you in relation to future vacancies within Euronext which we think may be of interest to you and, for the purpose of defending any potential employment equality claims.
Please note that in certain circumstances, we may hold your data for a longer period, for example, if we are processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your Personal Data.
13.CHANGES TO THIS PRIVACY POLICY
13.1 Any changes we make to this Privacy Policy will be notified in advance and detailed on this page in order to ensure that you are fully aware of what Personal Information is collected, how it is used and under what circumstances it will be disclosed.
14.LINKS
14.1 The Website may contain links to other websites. Please be aware that we are not responsible for the privacy policies of such other sites and we would advise you to read the privacy statements of those sites.
15. INFORMATION ABOUT THE DATA CONTROLLER AND CONTACT DETAILS
15.1 Your data controller will be ELITE S.p.A. .In all cases, if you have any complaints or queries relating to the processing of your Personal Information by ELITE, or to exercise any rights in respect of your Personal Information, you should contact us in one of the following ways:
• by sending a request to us at dpo@euronext.com
• by sending a letter to the following address:
Euronext
Compliance Department
Data Protection Officer
14, place des Reflets – CS30064
92054 Paris la Défense.
• By submitting a request through the following form.
15.2 In relation to the Website, you can update, correct or delete your Personal Information by referring to the "My Account" section of the Website. You can also use this area of the Website to prevent us from sending you direct marketing communications.