Notice pursuant to art. 13 Reg. UE 2016/679 (GDPR)

Pursuant to Reg. UE 2016/679 (General Data Protection Regulation) we provide you the deserved information concerning processing of collected personal data. The notice is not valid for external links; Data Controller is not to be considered responsible for third parties’ web pages.

The notice is drawn up pursuant to art. 13 Reg. UE 2016/679 (General Data Protection Regulation) and inspired to DIRECTIVE 2009/136/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 25 November 2009 and to Simplified Arrangements to Provide Information and Obtain Consent Regarding Cookies – 8 may 2014 by Italian Data Protection Authority.

Personal data

Any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can directly or indirectly be identified, in particular by reference to an identifier such as a name, an identification number, a location data, an online identifier or to one or more specific factors to the physical, physiological, genetic, mental, economic, cultural or social identity (C26, C27, C30).

Navigation data

Computer systems and procedures software preceded to the operation of this site, acquire, during their normal exercise, some personal data whose transmission is implicit using Internet communication protocols. This category includes: IP addresses, URI/URL (Uniform Resource Identifier/Locator), time of request, type of request, outgoing packet size, server status of response (received, error, etc…) and other parameters related to the operating system.

Data provided by data subject

The optional, explicit and voluntary dispatching of messages to contact-addresses, as well as compilation and forwarding of  forms , involves the acquisition of sender’s personal data necessary to reply, as well as all the personal data included in messages themselves.

Detailed Notices

Detailed notices related to specific services or processing are available on specific pages of the site.


Click here for more information about the cookie policy.

Who is the data controller? How to contact him?

Pursuant to art. 4 ad 24 Reg UE the Data Controller is StartApp SA with registered office in ia Penate 4, 6850 Mendrisio (CH).

Contacts: Tel. +41 (0) 91641 3030; E-Mail:

Has the Data Protection Officer been nominated? How to contact him?

The company has arranged to appoint a Data protection officer pursuant to artt. 37 – 39 Reg. UE 2016/679. Contacts: Tel. +41 (0) 91641 3030; E-Mail:; address: StartApp SA Via Penate 4, 6850 Mendrisio (CH)

Purposes, legal basis & data retention

Purpose A)

  1. Website browsing
  2. Contact form


  • Website browsing: Legitimate interest – art. 6 lett. f) and recital 47: processing is necessary for pursuing data controller’s (or third party) legitimate interest, provided that the interests or the fundamental rights and freedoms of the data subject are not overriding, taking into consideration his reasonable expectations based on the relationship with controller. Activities strictly necessary for site operation and platform browsing services.
  • Contact form: Execution of pre-contractual measures also adopted on data subject’s request;


  •  Website browsing: Single session. See cookie policy
  • Contact form: 1 year

NATURE OF CONFERRAL Apart from what specified on navigation data, the subject is free to furnish personal data. The provision of personal data is mandatory or optional depending on the purpose for which the data is processed. Whether data marked with an * or with the wording “requested” are not provided, the data processor won’t be able to supply his service. Data conferral for purpose B) is optional and, where lacking, personal data won’t be processed for such purpose; the denial of conferral will not undermine benefit from purpose A). 

Purpose B)

Direct marketing Whether the data subject fills any forms ment to collect data related to Direct Marketing purposesprior consent and until opposition for direct marketing, market research, direct sales, surveys on satisfaction degree, newsletters and promotionals, commercial and advertising material or regarding events and initiatives, through automated means of E-Mail, telefax, messages, SMS, MMS or other types, as well as operator-phone calls, paper mail or other information pack. The Data Controller uses newsletters and promotional communication reports to compare and possibly improve results. Thanks to reports, the Data Controller will be able to discover, for example: the number of readers, single openings, unique “clickers” and clicks; devices and operating systems employed to read the communication; user’s detailed activity; details of sent, delivered and forwarded emails; All these data are employed with the purpose of comparing, and possibly improving, the result of communication.

LEGAL BASIS Consent Art. 6.1 a) GDPR: the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
DATA RETENTION Until opposition (opt-out)
NATURE OF CONFERRAL Data conferral for purpose B) is optional and, where lacking, personal data won’t be processed for such purpose; the denial of conferral will not undermine benefit from purpose A).

Who the collected data will be communicated to?

Provided data will be shared with recipients who will treat them as data processors (art. 28 Reg. UE 2016/679) and/or as natural person acting under the controller’s or processor’s authority (art. 29 Reg. UE 2016/679) for former purposes.Namely, data will be shared with:

  • Subjects providing services for information system management and communication networks (including E-mail boxes, newsletter services, among which HubSpot Inc, freelancers, Offices or companies in the context of assistance and consultancy;
  • Competent authorities for compliance with legal obligations and / or provisions of public bodies, upon request;

The list of data processors is constantly updated and available at the headquarter of Labor Project S.r.l. or writing to:

Does Labor Project transfer data to a third country and/or to international organisations?

StartApp SA won’t transfer personal data to a third country and /or to international organizations

Are personal data processed by an automated mean?

Automated profiling systems such as “lead scoring” may be implemented to identify the propensity to purchase.

Which rights am I entitled to? How can I exercise them?

You may freely exercise your rights, at any time, under Reg. EU 2016/679 – GDPR pursuant to artt. 15, 16, 17, 18, 19, 20, 21 addressing Data Protection Officer, sending an E-Mail to You have the right, at any time, to obtain from the Data Controller the access to your personal data, request their rectification, erasure or processing restriction. Furthermore you have the right to object anytime to your personal data processing as well as to data portability.You have the right to oppose to the processing based upon consent and/or legitimate interest.To unsubscribe from traditional direct marketing updates (eg. operator phone calls), please write to (subject: “cancellazione da tradizionale”).To unsubscribe from direct marketing updates (eg. E-Mail or sms), please write to (subject: “cancellazione da automatizzato”) or use our automated unsubscribing tools.Without prejudice to any other administrative or judicial remedy, in case you consider the processing conflicting with Reg. UE 2016/679, pursuant to article 15 lett. f) you have the right to lodge a complaint with a supervisory authority (

More information

Data controller retains the right to modify, update, add or remove parts of this statement at his own discretion, in any moment.

Date of review: 26/10/20