Notice on the processing of personal data
Courtesy translation — version 5. This text is a faithful translation of the Italian original, which is the only binding version. In the event of any discrepancy, the Italian text prevails. The version number is the same as the Italian one: a translation is not a new version, it is the same version in another language.
W.F.B. Srl — Via Romolo Gessi 13, 20146 Milan (MI), Italy — VAT no. 04724770237
This notice concerns two categories of people. Read the part that applies to you: they are separate because the data processed and the reasons why we process them are different.
- Part A — if you are an employee or collaborator of W.F.B. and use the app for your shifts, your documents and communications with the office.
- Part B — if you are a contact person of a client company and use the portal to request services and consult statements.
PART A — Employees and collaborators
In brief (first level)
Who: W.F.B. Srl, your employer, is the data controller. What: the data needed to manage the employment relationship: personal details, documents, shifts and hours, communications with the office. Why: to perform the employment contract and comply with legal obligations — we do not ask you for consent for these activities, because they are required. Where: all data remain on servers within the European Union. Your rights: access, rectification, erasure and the other rights provided by the GDPR; you can exercise them by writing to the contacts indicated below and you will receive a reply within 30 days.
The full text below explains every point.
1. Who processes your data?
The data controller is W.F.B. Srl, Via Romolo Gessi 13, 20146 Milan (MI), Italy, VAT no. IT04724770237, contact email: privacy@wfbservice.it.
W.F.B. Srl uses the MUNUS+ software platform to manage staff, shifts and documents. The platform is the tool; the decisions about which data to process and why are taken by W.F.B. Srl as your employer.
W.F.B. Srl has not appointed a Data Protection Officer (DPO): for a company of this size and with these processing activities the appointment is not mandatory. For any matter concerning your data you can write to the address indicated above.
2. What data do we process, why, and what happens if you do not provide it?
| Data category | What it is for | Provision | Legal basis |
|---|---|---|---|
| Personal details: first and last name, sex, date and place of birth, tax code, staff number | To identify you uniquely and to comply with tax, social security and insurance obligations | Required: without this data the employment relationship cannot be managed | Contract (art. 6.1.b) and legal obligations (art. 6.1.c) |
| Contact details: mobile phone, email, residence and domicile | Work communications (shifts, expiring documents) and administrative fulfilments | Required for mandatory communications; the email also serves as the app username | Contract (art. 6.1.b) |
| Documents: copy of the identity document and professional certificates (e.g. food hygiene, fire safety) with expiry dates | To verify identity and eligibility for job roles: an expired mandatory certificate makes the shifts of that role unassignable, for your protection and that of others | Required for the roles that call for them; the platform warns you before expiry | Legal obligations on employment and safety (art. 6.1.c); contract (art. 6.1.b) |
| Photograph of the face | The identification badge and your recognisability at workplaces where it is required (e.g. site regulations) | Required where the work context imposes visual identification. The photo is never shown to W.F.B. Srl's clients | Safety obligations (art. 6.1.c) and contract (art. 6.1.b). Any further use of the photo, if ever proposed, will require your separate and revocable consent |
| Shifts and hours: assigned and confirmed shifts, planned and actual hours, absences (leave, time off, sickness, injury) | To organise work, count hours for pay purposes and for invoicing services to clients | Derives from the employment relationship | Contract (art. 6.1.b); legitimate organisational interest (art. 6.1.f) |
| Messages: the chat between you and the office inside the app | Operational coordination and the ability to reconstruct the arrangements made (who said what, when) | Use of the chat is the working tool for operational communications | Legitimate interest (art. 6.1.f). We do not use the chat to assess your performance |
| Account data: login email, password (stored only in non-reversible encrypted form), any second authentication factor, date of last login, notification subscriptions | To let you log in securely and protect your account | Necessary to use the app | Contract (art. 6.1.b); legitimate interest in security (art. 6.1.f) |
| Operations log: who created or modified data and when, with the reason for significant operations | Security, data correctness and the ability to reconstruct events in the event of disputes or incidents | Generated automatically by the system | Legitimate interest (art. 6.1.f). It is not a tool for monitoring work performance |
Data not necessary to managing the relationship is not requested from you. If in future the platform were to collect optional data (e.g. bank details for new services), you will receive an update to this notice before activation.
3. Who sees your data inside the platform?
Access is profiled by role: only authorised W.F.B. Srl staff (administration and operators) see your data, and operators only for the sites within their remit.
W.F.B. Srl's clients where you work, as a rule, do not see your name: they see that a shift is covered, not by whom. The name appears only to clients expressly enabled by W.F.B. Srl and only for confirmed shifts. They never see your photo, your contact details, your documents or your overall hours; the summaries they receive never contain names.
4. To whom is the data disclosed? (technical suppliers)
To run the platform, W.F.B. Srl relies on suppliers that process data on its behalf, on the basis of contracts compliant with art. 28 GDPR:
| Company | Function | Data involved | Country |
|---|---|---|---|
| Hetzner Online GmbH | servers, database and document storage | all platform data | Germany (EU) |
| Backblaze Inc. | external backup copy | backup copies encrypted before sending: the supplier cannot read them | Netherlands (EU) |
| Brevo (Sendinblue SAS) | email sending (invitations, password recovery, alerts) | email address and content of the communications | France (EU) |
All suppliers process the data within the European Union.
Push notifications: if you enable notifications on your device, delivery goes through the service of your operating system or browser (Apple, Google or Mozilla, depending on the device you choose). These services receive an identification code of the device and an encrypted message they cannot read (Web Push standard). For Google, the transmission is covered by the EU-US adequacy decision (Data Privacy Framework). You can disable notifications at any time without consequences for the employment relationship.
The data may also be disclosed, where the law so provides, to labour consultants, social security and insurance bodies and public authorities, which act as independent controllers. No data is transferred to third parties for marketing, profiling or the training of artificial intelligence systems.
5. How long do we keep the data?
| Data | Retention |
|---|---|
| Personal details and employment relationship data (shifts, hours, absences) | duration of the relationship + 10 years (civil and accounting time limits) |
| Copy of the identity document | duration of the relationship + 5 years |
| Professional certificates | duration of the relationship + 5 years (the renewal history documents eligibility over time) |
| Photograph | removed on termination of the relationship within 30 days, save for specific obligations |
| Chat messages | for the entire duration of the employment relationship. ⚠️ The chat is append-only by design: messages cannot be edited or deleted — not even by their author, the office included — because they serve to reconstruct the arrangements made about a shift. On termination of the relationship they are removed together with the other data not subject to retention obligations |
| Operations log | 5 years, for security and accountability |
| Deactivated account | the minimum identifying data remain associated with the historical operations for the integrity of the log; the rest is removed or anonymised after 10 years |
| Closed shifts | 10 years: closed hours become the basis for pay and for invoicing the client, so they follow accounting time limits and cannot be erased on request |
| Backup copies | automatic rotation: copies expire within 30 days |
On expiry, the data is deleted or anonymised. Deletion propagates to the backup copies with their natural rotation (maximum 30 days).
6. What are your rights?
You have the right to obtain access to your data, the rectification of inaccurate data (many you can correct directly from your record in the app), erasure in the cases provided by art. 17 GDPR, the restriction of processing, the portability of the data you have provided, and to object to processing based on legitimate interest.
To exercise them write to privacy@wfbservice.it: you will receive a reply within 30 days. Exercising your rights cannot entail any negative consequence for the employment relationship.
If you believe that a processing operation infringes the law, you may lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).
Transparency note: some data cannot be erased as long as the law requires it to be kept (e.g. data needed for tax and social security fulfilments). In that case you will receive a reasoned reply indicating what has been erased and what has not, and why.
7. How do we protect your data?
We adopt technical and organisational measures appropriate to the risk, as required by art. 32 GDPR: always encrypted connections; passwords stored only in non-reversible encrypted form and mandatory two-factor authentication for W.F.B. Srl staff; access profiled by role and by site; each company's data isolated from the others; automatic block after a few failed login attempts; daily backups, verified and also kept at an external supplier in encrypted form; logging of significant operations; continuous system monitoring.
The complete and up-to-date list of measures is collected in a technical document that you can request at any time by writing to privacy@wfbservice.it.
No IT system can be said to be 100% secure, and the law does not demand it: the obligation is to adopt measures appropriate to the risk and to be able to demonstrate them, not to guarantee an absolute result. If, despite the measures, a breach of your data were to occur:
- we notify the Italian Data Protection Authority within 72 hours of becoming aware of it, in the cases provided by art. 33 GDPR;
- we inform you directly and without undue delay if the breach entails a high risk to your rights (art. 34 GDPR), telling you what happened, which data is involved, what consequences are possible and what we are doing;
- we record what happened, even where notification is not due.
8. Updates to this notice
This notice is versioned: every change produces a new version, with a date, and the platform asks you to take note of it at the first subsequent login. Previous versions remain recorded: you can always know which text you saw and when, from the "Consents" section of your profile.
PART B — Contact persons of client companies
In brief (first level)
Who: W.F.B. Srl is the controller of the data of contact persons and portal users. What: professional contact details and portal account data. Why: to manage the service relationship between W.F.B. Srl and the company you work for. Where: all data remain on servers within the European Union. Rights: access, rectification, erasure and the other GDPR rights, with a reply within 30 days.
1. Who processes your data?
The controller is W.F.B. Srl, Via Romolo Gessi 13, 20146 Milan (MI), Italy, VAT no. IT04724770237, contact email: privacy@wfbservice.it.
W.F.B. Srl uses the MUNUS+ platform to manage service requests, shifts and reporting towards its clients. You access the portal as the contact person of the client company you work for.
2. What data do we process and why?
| Category | What it is for | Legal basis |
|---|---|---|
| Professional contact details: first name, last name, company role, email, telephone | To maintain operational and commercial relations with the company you represent (service requests, statements, communications) | Performance of the contract with the client company (art. 6.1.b) and legitimate interest in ordinary commercial relations (art. 6.1.f) |
| Portal account data: login email, password (stored only in non-reversible encrypted form), any second factor, date of last login | To let you access the portal securely | Contract (art. 6.1.b); legitimate interest in security (art. 6.1.f) |
| Portal activity: service requests created, statement confirmations (recording who confirms and when), acknowledgements of legal documents | To deliver the service and document approvals with evidential value | Contract (art. 6.1.b) |
Providing contact details is necessary in order to operate on the portal: without them, the company you represent can still receive the services through traditional channels.
We do not process your data for marketing or profiling.
3. What you see, and what we see
The portal shows only the data of the company you work for: its requests, its sites, its statements. Out of confidentiality towards the staff, as a rule the names of the personnel employed on the shifts are not visible and the summaries never contain names.
4. To whom is the data disclosed?
The same technical suppliers of the platform, bound by contracts under art. 28 GDPR:
| Company | Function | Country |
|---|---|---|
| Hetzner Online GmbH | servers, database, storage | Germany (EU) |
| Backblaze Inc. | backup copies encrypted before sending | Netherlands (EU) |
| Brevo (Sendinblue SAS) | email sending (portal invitations, statements, alerts) | France (EU) |
All suppliers process the data within the European Union. For push notifications, what is described in the general notice applies: delivery through your device's service (Apple/Google/Mozilla) with encrypted content that the service cannot read.
5. How long do we keep the data?
| Data | Retention |
|---|---|
| Contact details | duration of the relationship with the client company + 2 years |
| Portal account | until access is revoked by W.F.B. Srl or by the company + 2 years |
| Confirmed statements and records of approvals | 10 years (accounting and tax relevance) |
| Backup copies | automatic rotation within 30 days |
6. What are your rights?
Access, rectification, erasure, restriction, portability, objection to processing based on legitimate interest. Write to privacy@wfbservice.it: reply within 30 days. You may lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).
If you are no longer the contact person of the client company, let us know: we will deactivate the account and keep only what is necessary to document the operations already carried out.
7. Security and updates
The same measures described in Part A apply: encrypted connections, profiled access, mandatory two-factor authentication for W.F.B. Srl staff, isolation of data by company, encrypted backups at an external supplier, logging of operations. The complete list is collected in a technical document that you can request by writing to privacy@wfbservice.it.
No IT system can be said to be 100% secure: the law imposes measures appropriate to the risk and the ability to demonstrate them, not an absolute result. In the event of a data breach we notify the Authority within 72 hours in the cases provided (art. 33 GDPR) and we communicate it directly to the data subjects when it entails a high risk to their rights (art. 34 GDPR).
This notice is versioned: every change produces a new version and the portal asks you to take note of it at the first subsequent login.
Document updated on 30 August 2026.