Privacy Policy

1. Data Controller

The data controller for the processing of personal data collected through this website is:

This Privacy Policy describes how we collect, use, store, and protect personal data when you visit our website or interact with our services. We are committed to complying with Regulation (EU) 2016/679 (General Data Protection Regulation, "GDPR"), Italian Legislative Decree No. 196/2003 (as amended by Legislative Decree No. 101/2018), and all other applicable data protection legislation.

2. Types of Personal Data Collected

We may collect and process the following categories of personal data:

2.1 Data Provided Voluntarily by the User

When you complete a contact form, request information about our programs, or communicate with us via email, you may provide us with:

• Full name
• Email address
• Phone number
• Information about your preferred program or learning format
• Any additional information included in the message or comment field

2.2 Data Collected Automatically (Browsing Data)

Our website's technical systems may automatically collect certain data during normal operation, including:

• IP address
• Browser type and version
• Operating system
• Referring website URL
• Pages visited on our website
• Date and time of access
• Device information

This data is collected for the purpose of ensuring the proper functioning of the website and may be used in anonymized, aggregate form for statistical analysis.

2.3 Cookies and Similar Technologies

Our website uses cookies and similar tracking technologies. For detailed information about the types of cookies used, their purposes, and your options for managing them, please refer to our Cookie Policy.

3. Purposes and Legal Basis for Processing

We process your personal data for the following purposes and on the following legal bases:

4. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Specifically:

• Contact form submissions and inquiries: retained for up to 24 months from the date of the last communication, unless a longer retention period is required for legal or contractual reasons.
• Program enrollment data: retained for the duration of the educational program and for up to 10 years thereafter, as required by Italian tax and civil law.
• Browsing data and cookies: retained as described in our Cookie Policy.

After the applicable retention period, personal data will be securely deleted or anonymized.

5. Data Sharing and Recipients

We do not sell, trade, or rent your personal data to third parties. Your personal data may be shared with the following categories of recipients only when necessary:

• Service providers: third-party companies that provide technical services essential to the operation of our website (such as hosting providers, email service providers, and IT support), acting as data processors under written agreements compliant with Art. 28 GDPR.
• Legal and regulatory authorities: where disclosure is required by applicable law, regulation, or legal process.
• Professional advisors: accountants, lawyers, or auditors, where necessary for legal compliance or the protection of our legitimate interests.

We ensure that all third-party recipients provide adequate guarantees for the protection of personal data, in accordance with applicable data protection law.

6. International Data Transfers

As our company is registered in Italy and serves participants in Canada, personal data may be transferred between the European Economic Area (EEA) and Canada. The European Commission has recognized Canada (for organizations subject to the Personal Information Protection and Electronic Documents Act) as providing an adequate level of data protection under Art. 45 GDPR.

Where personal data is transferred to any country that has not received an adequacy decision, we will ensure that appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by the European Commission, or other legally recognized transfer mechanisms under Chapter V of the GDPR.

7. Your Rights as a Data Subject

Under the GDPR and applicable Italian data protection law, you have the following rights regarding your personal data:

• Right of Access (Art. 15 GDPR): You have the right to obtain confirmation as to whether your personal data is being processed and, if so, to receive a copy of such data along with information about the processing.
• Right to Rectification (Art. 16 GDPR): You have the right to request the correction of inaccurate personal data or the completion of incomplete data.
• Right to Erasure (Art. 17 GDPR): You have the right to request the deletion of your personal data, subject to applicable legal exceptions.
• Right to Restriction of Processing (Art. 18 GDPR): You have the right to request the restriction of processing of your personal data under certain circumstances.
• Right to Data Portability (Art. 20 GDPR): You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller.
• Right to Object (Art. 21 GDPR): You have the right to object to the processing of your personal data based on legitimate interests, including processing for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before the withdrawal.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days, as required by the GDPR.

8. Right to Lodge a Complaint

If you believe that the processing of your personal data infringes applicable data protection law, you have the right to lodge a complaint with the competent supervisory authority. In Italy, the supervisory authority is:

9. Data Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction. These measures include, but are not limited to:

• Encryption of data in transit using HTTPS/SSL protocols
• Secure server environments with access controls
• Regular review and updating of security practices
• Limiting access to personal data to authorized personnel only

While we strive to protect your personal data, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee absolute security of your data.

10. Data Processing of Minors

Our website and educational programs are designed for adults. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that personal data has been collected from a minor without appropriate parental consent, we will take steps to delete such data promptly.

11. Third-Party Links

Our website may contain links to third-party websites or services that are not operated by us. We are not responsible for the privacy practices of such third-party websites. We encourage you to review the privacy policies of any third-party websites you visit.

12. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time. Any changes will be posted on this page with an updated "Last updated" date. We encourage you to review this Privacy Policy periodically. Continued use of the website after any modifications to the Privacy Policy constitutes acceptance of the updated terms.

13. Governing Law and Jurisdiction

This Privacy Policy is governed by and construed in accordance with the laws of Italy and the European Union, including the GDPR and Italian Legislative Decree No. 196/2003 (as amended). Any disputes arising from or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Milano, Italy.

14. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact us: