Privacy Statement and Cookie Policy
Brainy GMBH/SRL, having registered office in Perara Strada Satzl, 4, CAP 39042, Bressanone (BZ), Italy (hereafter Brainy GMBH/SRL) is committed to protecting the online privacy of users. Pursuant to art. 13 of EU Regulation 2016/679 (hereafter: "Regulation"), this statement informs you on our privacy policy and how your personal data is handled when you visit our website (hereafter “Website”), as well as to enable you to give your specific and informed consent to the processing of your Personal Data, where applicable. Parental consent is required for children under 16 years of age. The information and data provided by you, or otherwise acquired through use of our online services (hereafter "Services"), will be processed in compliance with the Regulation and the Data Controller’s obligation to confidentiality.
Pursuant to the Regulation, Brainy GMBH/SRL shall process Personal Data based on the principles of lawfulness, fairness, transparency, limitation of purpose and retention, data minimisation, accuracy, integrity, and confidentiality.
TABLE OF CONTENTS
Data Controller
Personal Data subject to processing
a. Browsing data
b. Special categories of Personal Data
c. Data volunteered by Data Subjects
d. Cookies
Purposes of data processing
Lawful basis and mandatory or optional nature of data processing
Disclosure of Personal Data
Transfer of Personal Data
Retention of Personal Data
Data Protection Officer
Your rights
Changes
1. Data Controller
In relation to the data processing carried out through our website, the Data Controller is Brainy GMBH/SRL (hereafter “Controller” or “Data Controller”).
For any information regarding the processing of Personal Data by the Data Controller, including the list of Data Processors, please write to: privacy@brainy-rms.com
2. Personal Data subject to processing
The Data Controller collects and processes Personal Data resulting from website browsing, including information such as name, identification number, online identifier, email address, phone number, or information about physical, physiological, psychological, financial, cultural, or social characteristics relating to an identifiable person (hereafter “Personal Data”).
a. Browsing data
During normal operation, the computer systems and software used to operate our Website acquire some Personal Data implicitly transmitted by Internet communication protocols. This includes IP addresses, domain names, URI of requested resources, request time, file size, server response codes, and operating system or IT environment parameters.
This data is used solely for obtaining anonymous statistical information, ensuring website functionality, identifying anomalies or abuses, and may be temporarily used to investigate possible computer crimes. Data is removed within a short period of time, except for the above case.
b. Special categories of Personal Data
If you submit applications via email or our website, you may provide Personal Data that falls under special categories as per art. 9 of the Regulation (e.g., racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, sexual orientation). Do not disclose such data unless strictly necessary.
Explicit consent is required for the processing of special categories of Personal Data. Social media profiles made publicly available on professional platforms (e.g., LinkedIn) may also be viewed.
c. Data volunteered by Data Subjects
You may provide Personal Data of third parties (e.g., via request/contact forms). You act as independent Data Controller for such data and release Brainy GMBH/SRL from any liability regarding disputes, claims, or damages from third parties. You warrant that processing of third-party data is lawful.
d. Cookies and other tracking technologies
Cookies are small text files stored on your device to save website information temporarily. Types of cookies include:
Essential cookies (navigation, shopping cart)
Analytics cookies (website visitor statistics)
Functional cookies (user preferences)
Profiling cookies (user preferences for personalized advertising, sometimes via third-party cookies)
Website visitors must consent to non-essential cookies and can revoke consent at any time via our CMP (Consent Management Platform).
Instructions for blocking cookies in various browsers are as follows:
Firefox, Chrome, Internet Explorer, Safari – follow official browser guides to manage cookies.
3. Processing
With your specific consent, we may process Personal Data to:
Provide requested services
Respond to assistance, information, or booking requests
View CVs and contact applicants
Comply with legal and tax obligations
Marketing purposes (promotions, newsletters, surveys) via automated and non-automated tools, with explicit consent
4. Lawful basis and mandatory or optional nature of data processing
Art. 6(1)(b): Performance of a contract (services requested, response to inquiries)
Art. 6(1)(f): Legitimate interest (e.g., reviewing professional profiles)
Art. 6(1)(a): Consent (marketing and promotional communications)
Providing Personal Data for services or inquiries is optional but necessary to activate services.
5. Disclosure of Personal Data
Personal Data may be shared with:
Parties acting as Data Processors (marketing consultants, hosting providers, technical maintenance providers)
Authorities or entities as required by law
Employees or parties authorized to perform activities strictly related to service provision, under confidentiality obligations
6. Transfer of Personal Data
Some data may be transferred outside the EEA. Brainy GMBH/SRL ensures that any transfer complies with EU Regulation, using adequacy decisions, Standard Contractual Clauses, or other legal safeguards. Contact privacy@brainy-rms.com
for details.
7. Retention of Personal Data
Website browsing and service-related data: only as long as necessary, or as required by Italian law (art. 2946 Civil Code)
CVs/applications: until the purpose is achieved; extensions may be requested
Marketing consent: until withdrawn
For more information, contact privacy@brainy-rms.com
8. Data Protection Officer
The Data Protection Officer can be contacted at dpo@brainy-rms.com
for questions regarding Personal Data processing.
9. Your rights
Under Art. 15–20 of the Regulation, you have the right to:
Access, correct, erase, or restrict processing of your Personal Data
Object to processing
Receive data in a structured, machine-readable format
Submit requests to: privacy@brainy-rms.com
You may also lodge a complaint with the Italian Data Protection Authority if you consider your rights violated (Art. 77 Regulation).
10. Changes
Brainy GMBH/SRL may update this Privacy Statement. Updates will be published on the Website with the latest revision date.