Disclosure for aligneracademyitalia.co.uk.
Articles 13-14 of EU Reg. 2016/679
The information notice is a general obligation that must be fulfilled before or at the latest when initiating the direct collection of personal data. In the case of personal data not collected directly from the data subject, the notice must be provided within a reasonable period of time, or at the time of disclosure (not registration) of the data (to a third party or the data subject). Pursuant to the General Regulation for the Protection of Personal Data of Natural Persons(GDPR – Reg.(EU)2016/679), the undersigned organization, the data controller, informs of the following:
SOURCES AND CATEGORIES OF PERSONAL DATA
Personal data held by this organization are collected directly from data subjects. This site does not collect sensitive data, by which is meant those that are likely to reveal racial or ethnic origin, religious philosophical or other beliefs, political opinions, membership in trade unions, associations or organizations of a religious, philosophical, political or trade union nature, state of health and sexual life.
Navigation data
Computer systems and software procedures used to operate the website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified interested parties, 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 the IP addresses or domain names of the computers used by users connecting to the site, the URI (Uniform Resource Identifier) notation addresses 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 check its correct operation and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site.
Profiling data
No profiling data is directly acquired regarding the data subject’s consumption habits or choices. However, it is possible that through links or by incorporating third-party elements, such information may be acquired by autonomous or separate parties. See in this regard the section on Third Party Cookies.
Cookies
Like others, this website saves cookies on the browser used by the affected user for the purpose of transmitting personally identifiable information and enhancing the user experience. In fact, cookies are small text strings that sites visited by the user send to his terminal (usually to the browser), where they are stored, sometimes even with characteristics of wide temporal persistence, to be then re-transmitted to the same sites on the next visit.
As explained below, you can choose whether and which cookies to accept, bearing in mind that refusing their use may affect the ability to perform certain transactions on the site or the accuracy and adequacy of some customizable content proposed or the ability to recognize the user from one visit to the next. In case you make no choice in this regard, the default settings will be applied and all cookies will be activated: however, at any time, you may communicate or change your decisions in this regard.
Technical cookies
In particular, so-called session cookies are used, which are not stored persistently on the user’s computer and vanish when the browser is closed, and whose use is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to enable the safe and efficient exploration of the site and that avoid the use of other computer techniques potentially prejudicial to the confidentiality of users’ browsing and do not allow the acquisition of personal identification data of the user. Then analytics cookies are used, which help to understand how visitors interact with site content by collecting information (geographic and web origin, technology used, language, entry pages, visited pages, exit pages, dwell times, etc.) and generating website usage statistics without personal identification of individual visitors. All of these are to be considered technical cookies for which, since it is not necessary to give consent, the opt-out mechanism applies. Technical cookies are not disclosed to third parties as they are necessary or useful for the operation of the site; therefore, they are processed only by individuals qualified as data processors, data controllers or system administrators.
Third-party cookies
Finally, the site incorporates cookies and other elements (tags, pixels, etc.) of third parties (autonomous and on which the Owner has no responsibility) that also carry out profiling activities and for which please refer to their respective sites:
– there are no third-party cookies
Data voluntarily provided by the user
The optional, explicit and voluntary sending of electronic mail to the addresses indicated on the site involves the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data included in the email. The explicit and voluntary sending of the forms that can be filled out on the site containing data of the interested party also entails processing in order to follow up on pre-contractual obligations or the execution of the services provided with the sending of the forms. Such information in the forms may concern personal data, contact information, contact details, telephone numbers, email addresses of the interested parties and identified and identifiable third parties having cause with the user of the site. However, specific summary disclosures will be progressively reported or displayed on the pages of the site set up for particular on-demand services.
PURPOSE AND LEGAL BASIS FOR PROCESSING
Personal data are used (ref. art.6(b) of GDPR):
(a) to enable navigation on the site and
(b) possibly to perform the requested service or performance as part of the normal activity carried out by this organization (ateco code 85.59.2 Training and professional development courses).
In addition, all personal data may be processed:
c) for purposes related to obligations under laws, as well as provisions issued by authorities empowered to do so by law (ref. Articles 6(c) and 9(b,g,h) of the GDPR);
d) for the establishment, exercise or defense of a right in and out of court (legitimate interest) of this organization (ref. Articles 6(f) and 9(f) of the GDPR);
e) for direct marketing purposes according to the legitimate interest of the Data Controller in particular; for cookies, advertising ids used to show advertisements and ads; for e-mail addresses for sending the newsletter; for navigation and usage logs to protect the site and the service from cyber-attacks; in these cases the data subject can always deny consent so that the Data Controller will abstain from processing (ref. Art. 6(f) of the GDPR);
(f) for purposes functional to the activity for which the data subject has the right to express consent or not, such as, for example, subscribing to the newsletter to receive informational messages and promotion and sale of products and services, satisfaction survey, communication of data to third parties for receiving information and promotional and marketing communications (GDPR art.6(a))
CONSEQUENCES OF REFUSAL TO PROVIDE DATA
The provision of data collected from the data subject is optional but essential in order to process them for the purposes in ( a) and ( b).
In the event that the interested parties do not communicate their indispensable data and do not allow the processing, it will not be possible to proceed with the fulfillment and implementation of the proposed services and follow up on the contractual obligations undertaken, with consequent prejudice to the proper fulfillment of regulatory obligations, such as accounting, tax and administrative obligations, etc.
Apart from what is specified for navigation data, the user is free to provide personal data for cookies and specific requests through forms e.g. on products and/or services. Failure to provide them may make it impossible to obtain what has been requested .
For all non-essential data, including sensitive data, the provision is optional. In the absence of consent or incomplete or erroneous provision of certain data, including sensitive data, the required fulfilments could be so incomplete as to cause prejudice or in terms of sanctions or loss of benefits, either because of the impossibility of guaranteeing the congruity of the processing itself to the obligations for which it is carried out, or because of the possible mismatch of the results of the processing itself with the obligations imposed by the legal regulations to which it is addressed, intending to exonerate the undersigned organization from any and all responsibility for any sanctions or afflictive measures.
MODE OF DATA PROCESSING
Processing related to the web services of the site are processed by automated tools for the time strictly necessary to achieve the purposes for which they were collected; they take place at the server in Italy or EU and are handled only by technical personnel in charge of processing, or by any persons in charge of maintenance and administration operations. Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access and loss of confidentiality. The facility is equipped with anti-intrusion, firewall, log and disaster recovery devices. Specific data encryption and segregation mechanisms and user authentication and authorization are used.
Data processing means the collection, recording, organization, storage, processing, modification, deletion and destruction of data or the combination of two or more of these operations. In relation to the aforementioned purposes, the processing of personal data is carried out by means of manual, computerized and telematic tools, with logic strictly related to the purposes themselves and, in any case, in such a way as to ensure the security and confidentiality personal data will therefore be processed in accordance with the methods indicated in Art. 5 Reg.to EU 2016/679, which provides, among other things, that the data be processed lawfully and fairly, collected and recorded for specific, explicit and legitimate purposes, accurate, and if necessary updated, relevant, complete and not excessive in relation to the purposes of processing, respecting the fundamental rights and freedoms, as well as the dignity of the person concerned with particular reference to confidentiality and personal identity, by means of protection and security measures. The undersigned organization has set up and will further refine the data access and storage security system.
No automated decision-making (e.g., profiling) is carried out.
EXTRA EU TRANSFERS
Processing takes place in non-EU and non-EEA countries when connections to the site come from those countries (at the request of the data subject located there).
RETENTION PERIOD
Personal data will be kept, in general, as long as the purposes of processing persist according to the category of data processed.
CATEGORIES OF RECIPIENTS
Data (only those that are indispensable) are disclosed
– to appointees and processors, both internal to the organization of the writer, as well as external, who perform specific tasks and operations (administration of the site, analysis of navigation data, traffic data, profiling, management of emails and forms sent voluntarily by the user, fulfillment of e-commerce requests and orders, etc.).
– In the cases and to the persons prescribed by law
Data will not be disclosed unless otherwise provided by law or after anonymization. Except as specified for cookies and third-party elements, without the prior general consent of the data subject to communications to third parties, it will only be possible to implement services that do not provide for such communications. In case of necessity, specific and punctual consents will be requested and the subjects who receive the data will use them as autonomous holders.
In some cases (not subject to the ordinary management of this site) the Authority may request news and information, for the purpose of controlling the processing of personal data. In these cases, the response is mandatory under penalty of administrative sanction.
RIGHTS OF THE DATA SUBJECT
You may at any time: exercise your rights (access, rectification, cancellation, restriction, portability, opposition, no automated decision-making processes) when provided against the data controller, pursuant to Articles 15 to 22 of the GDPR (link to the standard); file a complaint with the Garante(www.garanteprivacy.it); where the processing is based on consent, revoke such consent given, taking into account that revocation of consent does not affect the lawfulness of the processing based on the consent before revocation.
Disabling cookies
Almost all browsers offer the ability to manage and disable cookies, so that user preferences are respected. In some browsers, rules can be set to manage cookies on a site-by-site basis, an option that provides more precise control over user privacy; another feature available on some browsers is incognito browsing mode, so that all cookies created in this mode are deleted after closing.
Please refer to the following instructions for cookie management in relevant browsers:
Chrome
Firefox
Internet Explorer
Safari
RETENTION PERIOD
The data controller is ClearApp Ltd. in the person of its legal representative pro tempore.
The registered office is at Via A. Lamarmora 31, 10128 Turin
e-mail italia@eumaa.com
The full list of data processors is available upon request.