Privacy Policy

Information notice pursuant to EU Regulation 2016/679 (GDPR) and Italian Legislative Decree 196/2003

Last updated: April 2026

K-EN S.r.l. (“K-EN”, “we”, “us” or “our”) is committed to protecting the privacy and personal data of visitors to this Website, prospective clients, candidates, and business contacts.

Particular care is taken in relation to personal data processed in the context of executive search and strategic advisory activities, given the sensitivity and professional nature of such interactions.

This Privacy Policy explains how personal data is collected, used, stored, and otherwise processed in accordance with Regulation (EU) 2016/679 (“GDPR”), Italian Legislative Decree No. 196/2003 (as amended by D.Lgs. 101/2018), and applicable data protection laws.

Data controller

The data controller is:

K-EN S.r.l.

  • Registered office: Via Fiori Oscuri 9, 20121 Milan (MI), Italy

  • VAT / Tax code: 14629300964

  • Email: info@k-en.it

  • PEC: kensrl@pec.it

Data Protection contact

K-EN has appointed an internal contact for data protection matters. A formal Data Protection Officer (DPO) under Art. 37 GDPR has not been appointed, as the assessment of its mandatory nature is ongoing; should a DPO be appointed, this Privacy Policy will be updated accordingly.

For any question or request relating to the processing of personal data, users may contact the data protection contact at info@k-en.it.

Personal data collected

K-EN may process different categories of personal data depending on the interaction with the Website or business activities, including:

  • Contact details: name, surname, email address, telephone number

  • Professional information: CV, work experience, qualifications, professional references

  • Business-related data: role, company, nature of professional interactions

  • Technical and navigation data: IP address, browser type and version, device information, operating system, pages visited, time of visit, referring URL, and interaction data

K-EN may also collect data from publicly available professional sources (such as LinkedIn) or from third parties acting lawfully and with an appropriate legal basis.

Purposes and legal bases of processing

Personal data is processed for the following purposes, each linked to its respective legal basis:

  • Website management, technical functioning, and security — Legal basis: legitimate interest of the controller (Art. 6(1)(f) GDPR)

  • Responding to enquiries and contact form submissions — Legal basis: pre-contractual measures at the request of the data subject (Art. 6(1)(b) GDPR)

  • Conducting executive search and recruitment activities, including evaluating candidacies — Legal basis: pre-contractual measures (Art. 6(1)(b)) and, where applicable, consent (Art. 6(1)(a))

  • Providing strategic advisory services to client organisations — Legal basis: contractual necessity (Art. 6(1)(b) GDPR)

  • Managing business relationships and professional contacts — Legal basis: legitimate interest (Art. 6(1)(f) GDPR)

  • Compliance with legal and regulatory obligations — Legal basis: legal obligation (Art. 6(1)(c) GDPR)

  • Protection of legal rights, prevention of fraud, and enforcement of agreements — Legal basis: legitimate interest (Art. 6(1)(f) GDPR)

In advisory contexts, K-EN may process information relating to organisational structures, governance, leadership, or strategic matters, always applying strict confidentiality standards.

Nature of data provision and consequences of refusal

The provision of personal data for the purposes of responding to enquiries or conducting executive search activities is voluntary. However, failure to provide necessary data may result in the inability to process enquiries, evaluate candidacies, or establish a professional relationship.

The provision of technical data (cookies, IP address) is automatic upon access to the Website and is necessary for its functioning.

Automated decision-making

K-EN does not use automated decision-making processes, including profiling, that produce legal effects or similarly significantly affect data subjects.

Data sharing

Personal data may be shared with the following categories of recipients, to the extent necessary:

  • Authorised personnel within K-EN, bound by confidentiality obligations

  • External service providers acting as data processors pursuant to Art. 28 GDPR, including in particular Squarespace Inc. as hosting and website platform provider, as well as IT, legal and accounting advisors

  • Client companies, where necessary for the performance of recruitment or advisory services and with appropriate confidentiality safeguards

  • Public authorities, courts, or regulators, where required by law or to protect legal rights

K-EN does not sell, rent, or otherwise make available personal data to third parties for marketing purposes.

International transfers

Some of the data processors used by K-EN — in particular Squarespace Inc., which hosts this Website — are established in the United States. Personal data may therefore be transferred outside the European Economic Area (EEA). In such cases, K-EN ensures that appropriate safeguards are in place, including:

  • Transfers to countries benefiting from an adequacy decision by the European Commission (Art. 45 GDPR), including the EU–US Data Privacy Framework where applicable

  • Standard Contractual Clauses (SCCs) approved by the European Commission (Art. 46(2)(c) GDPR)

  • Other appropriate safeguards as permitted under Chapter V of the GDPR

Users may request information about the specific safeguards applied by contacting K-EN at the address above.

Data retention

Personal data is retained for the following periods:

  • Contact form enquiries: 12 months from the last interaction, unless a professional relationship is established

  • Candidate data (CVs, professional profiles): 36 months from submission or last update, unless consent is renewed or a different retention period is agreed

  • Client and business contact data: for the duration of the contractual relationship and for 10 years thereafter (as required by Italian civil and tax law)

  • Technical and navigation data: maximum 6 months, unless otherwise required for security purposes

  • Data required for legal compliance: as required by applicable law (e.g., 10 years for tax records pursuant to Art. 2220 of the Italian Civil Code)

Data subject rights

Under the GDPR, data subjects have the following rights:

  • Right of access (Art. 15): to obtain confirmation of processing and a copy of personal data

  • Right to rectification (Art. 16): to request correction of inaccurate data

  • Right to erasure (Art. 17): to request deletion of data, subject to legal retention obligations

  • Right to restriction (Art. 18): to request limitation of processing in specific circumstances

  • Right to object (Art. 21): to object to processing based on legitimate interest

  • Right to data portability (Art. 20): to receive data in a structured, machine-readable format

  • Right to withdraw consent (Art. 7(3)): at any time, without affecting the lawfulness of prior processing

Requests may be submitted to: info@k-en.it

K-EN shall respond to data subject requests without undue delay and in any event within 30 days of receipt, which may be extended by a further 60 days for complex requests.

Users also have the right to lodge a complaint with the Garante per la Protezione dei Dati Personali (www.garanteprivacy.it), the Italian supervisory authority for data protection.

Security

K-EN implements appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction, in accordance with Art. 32 GDPR.

Professional confidentiality

K-EN operates in contexts involving sensitive and strategic information. All such information is treated with a high level of professional discretion and confidentiality. Content on this Website does not constitute professional advice and should not be relied upon for decision-making.

Updates

K-EN reserves the right to update this Privacy Policy at any time. The date of the last update is indicated at the top of this page. Material changes will be communicated through the Website.

Contact

For any questions regarding this Privacy Policy or the processing of personal data:

K-EN S.r.l.