Privacy Notice


Pursuant to Art. 13 of the EU Reg. 2016/679 (General Data Protection Regulation, “GDPR”), the following Privacy Notice provides all the relevant information regarding the processing of personal data provided during the candidates’ recruiting process.


The data controllers are the following companies of the Symphonie Prime Group (collectively the “Controllers”): 

  • Symphonie Prime S.r.l.,established in Rome (ITA);

  • Hoverture Europe AG, established in Munich (GER);

  • Rapsodoo italia Srl, established in Rome (ITA);

  • Hoverture Italia Srl, established in Rome (ITA);

  • Ydea Studio Srl, established in Rome (ITA);

  • Endocode  Deutschland AG, established in Berlin (GER);

  • Rapsodoo Iberia S.L.,established in Madrid (ESP);

  • Seedble Srl, established in Rome (ITA);

  • Bit2win S.r.l., established in Rome (ITA);

  • Diapason Prime S.r.l., established in Rome (ITA).


The Controllers may collect and process the following data categories: 

  • Identification data (e.g. first name, last name, age, home address, ID cards).

  • Contact data (e.g. phone number, e-mail address).

  • Other types of personal data such as: professional and employment data, participation in non-profit organisations. 

  • Performance data, related to the results of the job application.

  • (If applicable) Special categories of personal data that, for instance, may be contained in the Curriculum Vitae (e.g. health related data, religious beliefs, trade union memberships).

  • Occasionally, images and/or pictures may be processed in the forms and within the limits described in the following paragraphs.

Personal data may be collected:

  • During recruiting days and/or events; 

  • Through the Controllers’ website (e.g in case of spontaneous job applications).

  • During the course and in accordance with the activities carried out by the Controllers (e.g. events or projects scheduled during the hiring  process).


Personal data will be processed for the following purposes:

Recruiting and screening 

Personal data collected and stored by the Controllers may be processed for:

  • participating in job interviews and for screening activities;

  • preparing documents for the hiring process (e.g hiring contract and other agreements);

  • any other activity strictly necessary for the hiring process.

The legal basis for the processing is the performance of the contract - art. 6(1)(b) GDPR.

If applicable, special categories of personal data are processed for the performance of the contract - Art. 6(1)(b) GDPR and in order to carry out the obligations and exercise specific rights of the controllers or of the data subject in the field of employment and social security - Art 9(2)(b) GDPR.

Complying with legal and regulatory obligations;

Personal data may be also processed to fulfil legal and/or regulatory obligations set out by State law, European regulations, or government authorities. The legal basis for the processing is the compliance with a legal obligation - Art. 6(1)(c)GDPR.


  • In order to fulfil the purposes described above, access to the personal data shall be allowed only to authorised personnel or to external service providers, acting as authorised Data Processors in accordance with Art. 28 GDPR. Personal  data will not be disseminated under any circumstances.. Specifically, personal data may be disclosed to the following categories of recipients:

  • subjects that provide services for the management of the data processing IT system and communication networks of the Data Controllers 

  • firms or companies or sole professionals in the context of assistance and consultancy relationships in favour of the Data Controllers 

  • Competent authorities in order to comply with legal obligations and/or provisions of public bodies, upon request.


Personal data will not be transferred outside the EU/EEA or to third countries without an Adequacy Decision by the European Commission.


Personal data will be subject to the processing activities listed in Art. 4(2) GDPR, namely: collection, recording, storage, consultation, modification, extraction, comparison, use, interconnection, blocking, communication, deletion. 

Personal data will be processed manually and automatically. In case of automatic processing, personal data will be carried out in full compliance with the requirements of confidentiality and the most appropriate security measures, as provided for by the provisions in force and in accordance with technological progress, and with the prior consent of the data subject, where necessary.


In accordance with the data minimisation principle personal data collected will be stored for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.


The provision of personal data for the purposes set out in section 3 of this Notice is necessary in order to carry out recruiting activities. Failure to provide personal data may make it impossible to complete the job application. As far as marketing and content creation purposes are concerned, the provision of personal data is completely optional.


The data subject may exercise their rights as described in Chapter III GDPR and specifically: 

  • The right to obtain confirmation as to whether or not personal data is being processed and if so, to obtain access to the personal data and to receive the information contained in this Notice.

  • The right to obtain, without undue delay, the rectification of inaccurate or incomplete personal data.

  • The right to obtain the deletion, without undue delay, of personal data under certain conditions.

  • The right to object, under certain circumstances, to the processing of personal data, for reasons relating to specific situations of the data subjects.

  • The right to request that any of the above changes be communicated to other parties to whom personal data has been disclosed.

  • The right not to be subject to automated decision-making processes, including profiling.

  • The right to withdraw your consent at any time.

  • The right to receive the personal data in a common readable format should the data subject wish to transfer it to another data controller (data portability).

  • The right to lodge a complaint at any time with the supervisory Data Protection Authority if any data protection rights have been violated.

  • The right to obtain the restriction of processing in the cases provided for by the GDPR.

Data subjects may exercise their rights by contacting the Data Controllers via the following email address


The Controllers may amend, supplement or update this Notice from time to time in accordance with applicable law. The Controllers will notify the aforementioned changes as most appropriate.