Privacy Policy

Privacy Policy

Version No. 2 dated June 16, 2025

1. INTRODUCTION – WHO ARE WE?

INTRODUCTION – WHO ARE WE?
Next14 S.p.A., with registered office at Via Tortona 37, 20144 – Milan, P. IVA 02701840346 and Different S.p.a., with registered office
in Via Tortona 37, 20144 – Milan P.IVA 13198000153(hereinafter, respectively, “Next14” and “Different”; and,
jointly, the “Co-Owners”), owners of the website https://nextdifferent.com/ (hereinafter, the “Site”), as
co-owners of the processing of personal data of users browsing the Site (hereinafter, “Users”) provide herewith
below the privacy policy pursuant to Article 13 of the EU Regulation 2016/679 of April 27, 2016 (hereinafter,
“Regulation” or “Applicable Legislation”).

HOW TO CONTACT US?
The Co-Holders hold in the highest regard the right to privacy and protection of personal data of their
Users. For any information in relation to this privacy policy, Users may contact each of the
Co-Titleholders at any time, using the following methods:
 By sending a registered letter with return receipt to the registered office of each of the Co-Titleholders: Via Tortona 37, 20144 – Milan;
 By sending an e-mail message to the following e-mail addresses:
Next14: info@next14.com;
Different: contact@differentglobal.com.
Users may also contact Next14’s Data Protection Officer (DPO or DPO) of each of the
Co-Owners, whose contact details are as follows: the company Shibumi S.r.l., in the designated person of Lawyer Lapo
Curini Galletti, who can be contacted at the email address: dpo@nextdifferent.com

WHAT WE DO. – PURPOSE OF THE PROCESSING
By browsing the Site, the User can stay up-to-date regarding the services and activities developed and/or
promoted by the Co-Holders, request information from the Co-Holders or send job applications to the Co-Holders.
In connection with the activities that may be carried out through the Site, the Co-Holders collect personal data relating to Users.
This Site and any services offered through the Site are reserved for individuals who have reached the age of eighteen years
. Co-Holders therefore do not collect personal data relating to individuals under the age of 18. Upon request from Users, Co-
Holders will promptly delete all personal data unintentionally collected relating to individuals under the age of 18.
In particular, personal data of Users will be lawfully processed by the Co-Holders for the following purposes of processing:
a) contractual obligations and provision of the requested service, i.e. to enable navigation of the Site and to give
execution to specific requests of the User, including generic, commercial, press or
related to job applications/collaboration received by the Co-Holders.
User data collected by the Co-Holders for these purposes include:

• Site navigation: all personal data whose transmission is implicit in the use of the protocols of
  Internet communication, that the computer systems and software procedures responsible for the operation of the Site
  acquire in the course of their normal operation: the IP addresses or domain names of the computers used
  by Users, the addresses in URI (Uniform Resource Identifier) notation of the resources requested, the time of the
  request, the method used in submitting the request to the server, the size of the file obtained in response, the
  numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters
  relating to the User’s operating system and computer environment. These data are used for the sole purpose of
  obtaining anonymous statistical information on the use of the Site and to allow it to function properly;
• “Let’s Talk” section on the Site: the User’s first name, last name, e-mail address, as well as all information and data
  voluntarily entered by the User within the curriculum vitae and/or in the message attached to the
  request. The data provided by the User will be processed in order to ascertain the identity of the User (including through
  validation of the e-mail address), thus avoiding possible fraud or abuse and to process the request
  of the User regarding the possibility of establishing a work/collaboration activity with Co-Titleholders e,
  in particular, to (i) send the User any information related to the business sector of the Co-Holders
  (target market, logistical information such as location of the interview, mode of the interview, etc.),
  necessary or even just useful for the User in view of the possible cognitive interview to which the User may be
  invited by the Co-Titleholders; and ii) communicate with the User for reasons related only to the selection process
  (communication of the dates of the possible cognitive interviews, communication regarding the outcome of the selection,
  etc.).

b) administrative-accounting purposes, i.e., to carry out activities of an organizational, administrative, financial
and accounting nature, such as internal organizational activities and activities functional to the fulfillment of contractual and
pre-contractual obligations;
c) legal obligations, i.e., to fulfill obligations required by law, an authority, a regulation or
European legislation.
The provision of personal data for the above-mentioned processing purposes is optional but necessary, as failure to
provide such data will result in the inability of the User to contact the Co-Titleholders for the purposes indicated on the Site
through the appropriate sections provided by the Co-Titleholders on the Site.
The personal data that are necessary for the pursuit of the processing purposes described in this paragraph 3 are
indicated with an asterisk within the various forms provided by the Co-Owners on the Site.

4. LEGAL BASIS
   Contractual obligations and provision of service (as described by paragraph 3, lett. a) above): the legal basis
   consists in art. 6, paragraph 1, lett. b) of the Regulation, i.e. the processing is necessary for the performance of a contract
   to which the User is party or the execution of pre-contractual measures taken at the User’s request.
   Administrative-accounting purposes (as described by paragraph 3, lett. b)): the legal basis consists
   in art. 6, paragraph 1, lett. b) of the Regulation, as the processing is necessary for the execution of a contract and/or
   the execution of pre-contractual measures adopted at the request of the User.
   Legal obligations (as described by the previous paragraph 3, lett. c)): the legal basis consists in art. 6, paragraph 1,
   lett. c) of the Regulation, as the processing is necessary to fulfill a legal obligation to which the Co-
   Holders are subject.
5. PROCESSING METHODS AND DATA STORAGE TIME
   The Co-Owners will process Users’ personal data by means of manual and computerized tools, with logic strictly
   related to the purposes themselves and, in any case, in such a way as to ensure the security and confidentiality of the data.
   Users’ personal data will be retained for the time strictly necessary to fulfill the primary purposes (as
   described in paragraph 3 above), or otherwise as necessary for the protection in civil law of the interests of
   Co-Owners and Users.
   Notwithstanding the above, Users’ personal data collected through the “Let’s Talk” section of the Site will be
   retained for 12 months.
6. SCOPE OF COMMUNICATION AND DIFFUSION OF DATA
   The User’s personal data may be transferred outside the European Union and, in such case, each of the Co-Titleholders will
   ensure that the transfer takes place in accordance with the Applicable Legislation and, in particular, in accordance with Articles 45
   (Transfer on the basis of an adequacy decision) and 46 (Transfer subject to adequate safeguards) of the
   Regulations.
   The personal data of the Users may come to the knowledge of the employees and/or collaborators of the Co-Owners in charge of
   managing the Site and the Users “requests. These individuals, who have been instructed to do so by each of the Co-Holders pursuant to
   Article 29 of the Regulations, will process Users” data exclusively for the purposes set forth in this notice and
   in compliance with the provisions of the Applicable Regulations.
   Users’ personal data may also come to the attention of third parties who may process personal data on
   behalf of the Co-Holders as Data Processors, such as, but not limited to, providers of IT services
   and logistics functional to the operation of the Site, providers of outsourced or cloud computing services, professionals and consultants.
   Users have the right to obtain a list of any data processors appointed by each of the Co-
   Owners by making a request to the latter in the manner indicated in paragraph 8 below.
7. CO-OWNERSHIP ACTIVITIES BETWEEN NEXT14 AND DIFFERENT – ESSENTIAL CONTENT
   OF THE CO-OWNERSHIP AGREEMENT IN COMPLIANCE WITH THE PROVISIONS
   OF ARTICLE 26 OF THE REGULATIONS.

Next14 and Different have established, by means of an internal agreement, their respective responsibilities with regard to compliance with
obligations arising from the applicable legislation, with particular regard to the possible exercise of the User’s rights and the
respective functions of communication of the information referred to in Articles 13 and 14 of the Regulations.
In compliance with the provisions of Article 26 of the Regulations, the essential content of the agreement between the two Co-
Data Controllers is set out below:
i. the Co-Holders are Next14 and Different;
ii. the Data Protection Officer (DPO or DPO) of Next14 and Different can be contacted at the following
e-mail address: dpo@nextdifferent.com.
iii. the personal data collected by the Co-Holders is for the purpose of the activities carried out in co-ownership as referred to in paragraph 3,
lett. a) of the Privacy Policy, in particular navigation of the Site and management of the “let’s talk” section;
iv. for the creation and collection of such personal data, the Co-Holders may use third party providers, for example,
providers of servers within which the personal data collected and processed are managed, which have been
duly appointed by the Co-Holders as data controllers pursuant to Article 28 of the Regulations;
v. the processing of the personal data in question will take place within a member state of the European Union or in
another country that is part of the European Economic Area and, if transfers are necessary
outside these territories, it will be the responsibility of the Co-Holders making such transfers to ensure that such transfers occur
in full compliance with applicable law;
vi. where they are required to do so, both Co-Holders will cooperate in ensuring that the data subject is able to exercise the rights of
set out in Articles 15-22 of the Regulation;
vii. the main point of contact for data subjects for all processing carried out in co-ownership by Next14 and
Different is Next14, which can be contacted via the references in the disclosure.

8. RIGHTS OF INTERESTED PARTIES
   Users may exercise the rights guaranteed to them by the Applicable Regulations by contacting each of the Co-Titleholders by the following means:
   
    By sending a registered letter with return receipt to the registered office of one of the Co-Titleholders: Via Tortona 37, 20144 – Milan;
    By sending an e-mail message to one of the following addresses:
   Next14: info@next14.com;
   Different: contact@differentglobal.com.
   Users may also contact the Data Protection Officer (DPO or DPO) of each of the Co-Holders,
   at the following e-mail address: dpo@nextdifferent.com.
   Pursuant to the Applicable Legislation, Users have:
   a. the right to withdraw consent at any time, if the processing is based on their consent;
   b. The right of access to personal data;
   c. (where applicable) the right to data portability (the right to receive all personal data relating to them in
   a structured, commonly used and machine-readable format), the right to limitation of
   processing of personal data, the right to rectification and the right to erasure (“right to be forgotten”);
   d. the right to object:
   i. in whole or in part, on legitimate grounds to the processing of personal data concerning them, even if pertinent
   to the purpose of collection;
   ii. in whole or in part, to the processing of personal data concerning them for the purpose of sending advertising material or
   direct sales or for carrying out market research or commercial communication;
   e. if they believe that the processing concerning them violates the Regulation, the right to lodge a complaint with
   a Supervisory Authority (in the Member State in which they habitually reside, in the Member State in which they work, or in
   the Member State in which the alleged violation occurred). The Italian Supervisory Authority is the Guarantor for the Protection of
   Personal Data, with headquarters at Piazza Venezia, No. 11, 00186 – Rome (RM) (www.garanteprivacy.it).

The Co-Titles are not responsible for updating all links displayed in this policy; therefore, whenever
a link is not working and/or updated, the User acknowledges and agrees that he or she should always refer to
document and/or section of the websites referred to by that link.ternet websites referred to by that link.