Privacy policy
This privacy notice (the “Notice”) is provided pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (“GDPR”) to those who access and browse the website indicated below:
cosulich.com (the “Website”)
The Notice describes how the Website is managed with reference to the processing of personal data relating to users who access it and the use of cookies. It is also specified that this Notice exclusively concerns the Website; therefore, any website to which you may be redirected from the Website is excluded.
1. Who is the data controller?
Fratelli Cosulich S.p.A., with registered office in Trieste, Via Dante Alighieri 5, is the controller of your personal data (“FC” or the “Company” or “We”).
The Company is available for any information regarding the processing of personal data carried out by the Company. The Company may be contacted at: gdpr@cosulich.it
2. What personal data do we process?
“Personal Data” means any information capable of identifying, directly or indirectly, a natural person, in this case, you as a user browsing the Website (“Data”).
In particular, the Company processes the following categories of Data:
a) Browsing data
The IT systems and software procedures used to operate the Website acquire, during their normal operation, certain Data whose transmission is implicit in the use of Internet communication protocols. This information is not collected in order to be associated with identified individuals, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of the computers used by users connecting to the Website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the technical/IT method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the server’s response (successful, error, etc.) and other parameters relating to the user’s operating system and IT environment.
These Data are used solely for the purpose of obtaining anonymous statistical information on the use of the Website and to check its proper functioning, to identify anomalies and/or abuses, and are deleted immediately after processing.
In limited cases, these data may be used to ascertain liability in the event of hypothetical cybercrimes against the Website or third parties.
b) Name and contact details
In certain sections of the Website, you may enter certain Data (such as, for example, your first name, surname, email address, the company you work for) in order to use certain services such as, by way of example only, contacting us through the “Contact Us” section, applying for open positions with us, sending a spontaneous application or requesting subscription to our newsletter.
c) Data voluntarily provided by the data subject
In some cases, you may transmit third-party Data to us. With regard to such cases, you will act as an independent data controller and, therefore, you will assume all legal obligations and responsibilities.
Consequently, in these limited cases you agree to indemnify us to the fullest extent possible against any dispute, claim, demand for damages arising from data processing, etc. that may be brought against the Company by such third parties in relation to their Data transmitted by you in the event of a breach of applicable personal data protection laws.
In any event, where in using the Website you provide us with or otherwise process Data of such third parties, you agree to guarantee to us from now on—assuming all related responsibility—that such specific processing is based on an appropriate legal basis (for example, the data subject’s consent) pursuant to Article 6 GDPR, which legitimises the processing of the information in question.
3. For what purposes do we process your data, on what legal basis and for how long?
This section describes the Data processing activities carried out by the Company through the Website, the purposes of each processing activity, the related legal basis and the relevant data retention period or, where it is not possible to determine it precisely, the criteria used to determine such period. If you would like to obtain more information regarding retention periods, please contact the Company at: gdpr@cosulich.it
a) Management of your contact request
Your Data will be processed to manage contact requests submitted by you through the Website.
The legal basis for this processing is the performance of a contract to which the data subject is party or the implementation of pre-contractual measures taken at the data subject’s request (pursuant to Article 6(1)(b) GDPR), as the processing is necessary in order to respond to your request. Providing your Data for this purpose is optional, but failure to provide it would make it impossible for the Company to respond to your request.
The Data processed for this purpose will be stored for the time strictly necessary to follow up on your request and, subsequently, for 12 months.
b) Management of your application
If you apply for one of the positions open within the Company or submit a spontaneous application, we will process your Data (including those contained in your CV, if provided) to manage your application.
Further information on the processing activities carried out for the management of your application, the related legal basis and retention periods is available in the specific information notice for candidates, which will be provided to you at the time of your application through the dedicated “Career” platform: https://career.cosulich.com/
c) Sending newsletters
Subject to your consent, your Data (in particular, your email address) may be processed for the sending of newsletters by the Company.
The legal basis for this processing is your consent (pursuant to Article 6(1)(a) GDPR). Please note that, as this processing has a marketing purpose, you may withdraw your consent at any time by clicking on the unsubscribe link at the bottom of each newsletter received or by contacting the Company at: gdpr@cosulich.it. Withdrawal of consent does not entail any consequence for the use of the Website.
Providing Data for this purpose is optional and failure to provide it will not entail any consequence for you, except the impossibility of receiving our newsletter.
The Data processed for this purpose will be stored until you withdraw your consent and, in any event, for a maximum of 12 months from collection.
d) Legal obligations
Your Data may be processed in order to comply with any legal obligations to which the Company is subject (pursuant to Article 6(1)(c) GDPR).
Providing Data for this purpose is optional, but failure to provide it would make it impossible to use one or more services (such as applying for open positions with us, submitting a spontaneous application or contacting us to request information).
The Data processed for this purpose will be stored for the period provided for by law.
e) Website security
Your Data may be processed in order to detect, respond to and prevent fraudulent and unlawful behaviour or activities that may compromise the security of the Website. Providing Data for this purpose is optional, but failure to provide it would make it impossible to browse the Website.
The legal basis for this processing is the Company’s legitimate interest in safeguarding its interests and protecting Website users.
The Data processed for this purpose will be stored for the period provided for by the applicable legislation for the protection of the Company’s interests.
f) Whistleblowing reports
Your Data may be processed in the event of submission of reports using the whistleblowing platform made available by the Company.
Further information on the processing activities carried out for the management of whistleblowing reports, the related legal basis and retention periods is available on the dedicated platform: https://globaleaks.cosulich.com/#/
4. Cookies
Below is the list of cookies used on the Website, generated and kept up to date by our cookie management tool.
5. With whom do we share your data?
Your Data may be shared, for the purposes referred to in paragraph 3 above, with the following parties (collectively, “Recipients”):
- entities acting as suppliers on behalf of the Company, such as: i) persons, companies or professional firms, typically acting as data processors, providing assistance and consultancy to the Company in accounting, administrative, legal, tax and financial matters; ii) entities delegated to carry out technical maintenance activities on the Website, typically acting as data processors; iii) newsletter delivery service providers;
- entities, bodies or authorities to whom it is mandatory to disclose your Data pursuant to legal provisions or orders of the authorities;
- natural persons authorised by the Company to process Data necessary to carry out activities strictly related to the management of the Website and the services available therein (such as managing your applications), who have committed themselves to confidentiality or are under an appropriate legal obligation of confidentiality, such as the Company’s employees or collaborators;
- other Group companies located within the European Union, whether subsidiaries or affiliates.
6. Where do we transfer your data?
The server on which the Website is hosted is located in Ireland.
Your Data may be transferred to Recipients located outside the European Economic Area who provide outsourced technology services to the Company; should such transfer become necessary, the Company ensures that the processing of your Data by such Recipients is carried out in compliance with the GDPR. Therefore, such transfers may be based on an adequacy decision or on the Standard Contractual Clauses approved by the European Commission, with the prior adoption of appropriate security measures to ensure the protection of the transferred Data.
7. What are your rights as a data subject?
You, as a data subject, have the right to:
- access your Data and request a copy thereof;
- request rectification or updating of your Data, where inaccurate or incomplete;
- request, in certain circumstances, the erasure of Data relating to you or the restriction of the processing of your Data;
- request, in certain circumstances, to receive your Data in a structured, commonly used and machine-readable format (right to data portability).
Finally, you may at any time object to the processing (in the cases provided for by law) and lodge a complaint with the Data Protection Authority if you believe that the processing of your Data is contrary to the legislation in force.
In the case of processing based on consent, you have the right to withdraw the consent previously given at any time, with future effect.
You may exercise your rights by writing to: gdpr@cosulich.it or to the Company’s physical address indicated above.
8. Changes
This Notice is effective as of 1 October 2026. The Company reserves the right to amend or simply update its content, in whole or in part, also due to changes in the applicable legislation. If the amendments to this Notice concern substantial changes in the processing activities or may in any case have a significant impact on data subjects, the Company will take care to properly inform data subjects. In any case, we invite you to regularly visit this section in order to be aware of the most recent and updated version of the Notice, so as to remain always informed about the Data processed and the use made thereof.