INFORMATION FOR THE PROTECTION OF PERSONAL DATA

Informative notice in accordance with articles 13 and 14 of GDPR 2016/679

Identity and contact details of the data processing Controller: the data processing Controller is the company ADLM S.r.l. a socio unico (hereinafter ADLM) – Registered office in Via Montenapoleone 5, 20121 Milano – Tax code 09387011001 – privacy@accademiadellusso.com

1. Contact details of the data protection officer (DPO). The data protection officer can be contacted at the following email address: dpo@accademiadellusso.com

1. Purpose of the processing (art. 6 par. 1 GDPR).

b1. In order to fulfil legal requirements: to comply with obligations prescribed by the law, by a regulation, by EU law, or by instructions given through the authorities or supervisory bodies; for the purpose of consulting this domain; for the management of the contractual and/or pre-contractual relationship with ADLM: specifically, for the purpose of planning and running personalised assistance services within the field of school and university exam preparation and of professional training; purposes strictly linked to and instrumental to the management of the aforementioned relationship (i.e. for the purchasing of pre-contractual information and to implement services and operations, as contractually agreed); for the pursuit of a legitimate interest of ADLM: for the completion of the preliminary checks connected to the fulfilment of the contract, to implement a request made by a client and/or potential client; for quality control, research, and development aimed at improving products and services; to communicate commercial information and to send advertising/informative material related to products and services that are similar to those which form the subject of the contract, including through the use of automated and conventional means, by email and through connected web applications;

b2. To communicate commercial information and to send advertising/informative material relating to products and services, including those belonging to companies that are controlled by, controlling of, linked to, or co-owners, and which are deemed of interest to you, including with automated and conventional means, by email, and through connected web applications, upon gaining express consent;

b3. For profiling: ADLM will be able to process, upon receiving your consent, personal data that is provided of your own accord and data which has been acquired during your use of the service/s offered, for the purpose of analysis (both through automated and conventional means) in order to detect your chosen preferences and commercial habits, to improve services provided and to suggest the commercial offers which are deemed of greater interest to you.

1. Categories of the personal data. The data you provided upon filling in the forms at the collection points on the domain, directly or indirectly attributable to your relationship with ADLM and necessary to fulfil legal and contractual requirements, will be subject to processing. Providing the data is not compulsory. Not providing the data, which is essential for registration, will result in the impossibility for the Controller, Processing Officers, and appointees to effectuate the processing and execute the related services. Also subject to processing are the IP address and browser type you used to connect to this domain (non-identifying data), which are automatically recorded by logical devices for control and protection and used exclusively to control network traffic.

Cookies

Cookies are text files containing minimal information sent to the browser and archived on the user's computer each time that a website is visited. Upon each connection, cookies resend that information to the reference site.

User profiling cookies are not used.

The site uses technical and "third party" cookies.

1. Technical cookies

Based on their characteristics and use, these cookies are divided into two categories:

a1. Strictly necessary cookies (session). These are essential for the correct functioning of the site. Deactivating these could compromise the use of the site.

a2. Analysis and performance cookies (analytics). These cookies are used to collect and analyse, anonymously, the traffic and use of the site, allowing, for example, the detection of whether the same user connects to the site at different times. They also allow the monitoring of the system and the improvement of its performance and use. Deactivating these cookies can be done without losing any functionality.

1. Third party cookies

Visiting a website can result in receiving cookies that are managed by different subjects ("third parties") other than the owner of the website visited. The management of information collected by "third parties" is disciplined by the relative informative notices.

Third party cookies allow the third parties who use them to obtain more complete surveys and statistics on the navigating habits of users. Deactivating these cookies can be done without losing any functionality.

Users can choose to enable or disable cookies by changing their browser settings, following the instructions given by the relative providers.

1. Recipients of the personal data. Within the scope of the purposes stated above, your data will or may be communicated to:

- banks and/or credit institutions in charge of regulating payments according to the methods agreed;

- insurance institutions for the definition of potential procedures relating to damage claim procedures;

- bodies or organisms authorised to fulfil relative obligations within the limits of the previsions of law;

- companies that are controlled by, controlling of, linked to, co-owners and in charge of the processing as physical or juridical persons who, including by means of a contract with ADLM, provide specific processing services or carry out activities connected with, instrumental to, or in support of those carried out by ADLM.

The identities of any potential external processing Officers and Co-owners are available from the Controller or can be requested through a formal means of communication which should be sent to the contact details listed at paragraph a) above.

The informative notice relates to the ADLM domains and does not relate to other websites which may have been consulted by the user through a link. The presence of the informative notice reassures users of being within a domain owned by ADLM or by the appointed Officers.

1. Transfer of data outside the European Union. According to art. 45 GDPR, the transferring of personal data may occur towards a third country or an international organisation if the Commission decides that the third country or international organisation in question guarantees a suitable level of protection or other suitable guarantees as stated in the GDPR.

1. Processing methods. In relation to the purposes stated above, the processing of your personal data will occur with the support of hardcopy, computerised or telematic means that are appropriate for memorising, transmitting, and sharing the data. ADLM informs you that the data you provide is subject to processing by appointed subjects, through manual, hardcopy, and computerised means, by being included in archives and databases. The processing Controller and Officers implement technical and organisational measures to guarantee a level of security which is suitable for the risk, conforming to current legislation, in order to guarantee the safety and privacy of your data.

1. Time period for the conservation of personal data. Within the scope of the purposes indicated above, your personal data will be conserved for the duration of the contract and for the ten years following this period, in which the Owner is subject to obligations regarding conservation for tax or contractual purposes, or for other regulations prescribed by law, directives, or for the purposes already stated. Once this period has ended, if not expressly confirmed by the interested party, the data will be deleted.

By way of example, but not limited to the following:

For commercial aims, considering the legitimate interest of the Controller to conserve personal data collected in order to offer products and services deemed of interest to you, your personal data will be conserved in a way that allows for the identification of the person(s) concerned for a certain period of time that is necessary to fulfil said interest, and more precisely, until the conclusion of the contract. This includes data collected by third parties as stated above at paragraph b3;

To fulfil legal or contractual requirements up until ten years after the expiry of the contract, and in any case for the duration imposed by law or deriving from the contract;

In the event of dispute, for the duration necessary for judicial and/or extra-judicial protection and in any case for a successive period of at least ten years from the contract expiry date and/or for the time necessary to complete legal defence.

YOUR RIGHTS

You can exercise at any moment the rights stated in articles 15 to 22 of the GDPR (i.e. ask for a check to be completed relating to the existence of your personal data; access to your personal data, the correction or cancellation of the data or the limitation of the processing which relates to it, the transformation of the data into a format structured in a common way), and request its transfer to another processing Controller, by sending a registered letter to the following address: ADLM S.r.l. a socio unico – Sede Legale Via Montenapoleone 5, 20121 Milano – C.F. e P.Iva 09387011001 – or by sending an email to the following email address: privacy@accademiadellusso.com

In accordance with art. 8 of the GDPR, the processing of personal data of minors aged 16 is lawful. For individuals under the age of 16, processing will occur only if consent has been given or authorised by whoever has parental responsibility. The processing Controller strives, in every reasonable way, to check that in these cases consent has been given by whoever has parental responsibility over the minor, using the technology available.

You can file any complaints (art. 77 GDPR) and/or opposition to the processing (art. 21 GDPR) to the Data Protection Authority.