UE General Data Protection Regulation 2016/679 - “GDPR”

Privacy Policy "Study Opportunities" Service

WHO ARE WE?

Ladybird s.r.l. - Via Leonardo da Vinci 16, 10126, Turin, Italy - Tax code and VAT number 10816460017 (hereinafter also "Company" or "Data Controller")

WHAT CATEGORIES OF DATA DO WE PROCESS?

The common personal data collected in the form to which this notice refers.

WHICH IS THE SOURCE OF DATA?

The data are provided directly by you by filling in the form.

WHY DO WE PROCESS PERSONAL DATA (PURPOSE) AND WHAT IS THE BASIS FOR THE PROCESSING (LEGAL BASIS) OF EACH CATEGORY OF DATA?

We process personal data for the following purposes:

1.

• “generalist”, also of a commercial nature, on market research and for the administration of approval questionnaires concerning education-related topics (Master's degrees, webinars and other training and/or work opportunities), also by means of the Newsletter;
  

• organisational (e.g. reminders for participation in events and webinars);

• “personalised”,  also of a commercial nature, based on the collection of information about you (e.g. geographical, country of origin) or indicated by you (e.g. master's degree of interest) on topics of interest in the context of training and/or work opportunities (e.g. Courses, Master's degrees, Webinars, etc.)
  

On the basis of the need to execute the Terms and Conditions of Service (Art. 6 § 1.b GDPR), sending, by any means (e.g. e-mail or instant messaging services), different kind of communication:

2.

Allow our partner Universities and/or Higher Education institution(s) (or those offering courses similar to the one to which this Privacy Policy refers) to contact you again, sharing your personal data with them, on the basis of your consent, which is free and withdrawable at any time (art. 6 § 1.a GDPR).

TO WHOM DO WE COMMUNICATE THE DATA (CATEGORIES OF RECIPIENTS)?

To the minimum extent necessary to achieve each of the Purposes, on one of the legitimacy prerequisites described above and on the basis of the applicable legislation and/or a contractual agreement with the Controller, we will or may communicate the data to:

1. parties necessary for the performance of activities connected with and consequent to the provision of the site and the services requested (e.g. IT service providers), who act as Data Processors;
2. internal staff authorised by us, committed to confidentiality or subject to a legal obligation to confidentiality.
3. University(s) and/or Higher Education institution(s) our partner(s), sharing (subject to your consent) your personal data with them in order to be contacted for the above-mentioned purpose n. 2.
   

DO WE TRANSFER PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA?

Yes, we use the services of companies established outside the European Economic Area (e.g. United States; in this case the transfer is made on the basis of standard contractual clauses and additional measures to ensure data protection) for the management of the landing page where your personal data is collected, and for the storage of your personal data. In any case, we ensure that data transfers are only made to countries that guarantee an adequate level of protection, for which there is an adequacy decision by the European Commission, or on the basis of one of the other guarantees provided for in Chapter V of the GDPR. Further information on transfers of personal data outside the European Economic Area is available by writing to the Data Controller.

HOW LONG DO WE RETAIN THE DATA?

Data provided will be retained for the time strictly necessary to perform the Service, and in any case no longer than one year after collection; in relation to the Newsletter, the data will be retained until you object to processing. For purpose no. 2, retention times are defined by the recipient of the data (e.g. the University or Higher Education partner institution to which we have, with your consent, shared your data).

ARE YOU OBLIGED TO PROVIDE US WITH PERSONAL DATA?

The data provided by you is necessary for the execution of the contract, but you are of course not obliged to use the Service. You are not obliged to consent to the processing for purpose no. 2. You are not obliged to fill in the form (and thus allow us to process the data for purpose no. 1), but you can object to the processing, as indicated in 'rights' (see below). You are not obliged to consent to processing for purposes 2 and 3. 

WHAT HAPPENS IF YOU REFUSE TO COMMUNICATE YOUR DATA?

If you do not complete the form and do not accept the T&Cs you will not be able to use the Service. If you do not consent to the processing for purpose no. 2, your contact details will not be shared with third party universities/training organisations.  Failure to provide your data will not result in any negative consequences.

WHAT RIGHTS DO YOU HAVE AS A "DATA SUBJECT"?

You have the right to:

1. access your data in our possession, and to request a copy of it, except where the exercise of the right infringes the rights and freedoms of other natural persons;
2. request the rectification of any incomplete or inaccurate data;
   
3. request the deletion of the data, subject to the exclusions or limitations established by the applicable legislation (e.g. Article 17 § 3 GDPR);
4. request the restriction of processing, where the conditions are met and subject to the exclusions set out in Article 18 § 2 GDPR;
5. request data portability (i.e. to receive the data in a structured, commonly used and machine-readable format, so that it can be transmitted to another Data Controller without hindrance), to the extent that the Processing is based on consent or on the need to perform a contract, where technically possible and except where the exercise of the right would infringe the rights and freedoms of other natural persons;
6. lodge a complaint with the Garante per la Protezione dei Dati Personali (in Italy, www.garanteprivacy.it), or with the Data Protection Authority of the EU State where you habitually reside or work, or of the place where the alleged infringement has occurred.

Right to withdraw consent: you may object to processing based on consent for the activity of receiving personalised communications (no. 2), by not giving it initially or by withdrawing it subsequently; you may object to processing based on consent to share personal data for the purpose no. 3 by not giving it initially or by withdrawing it subsequently directly to the recipient of the data (e.g. Partner University). In any event, please note that any subsequent withdrawal of consent shall not affect the lawfulness of the data processing carried out in the period prior to such withdrawal. The exercise of the above rights may also be delayed, limited or excluded in the cases provided for in Article 2-undecies of Italian Legislative Decree No. 196/2003.

WHO CAN YOU CONTACT FOR QUESTIONS OR TO EXERCISE YOUR RIGHTS?

You can contact us at the following e-mail address:

Privacy Policy "Study Opportunities" Service | UE General Data Protection Regulation 2016/679 - “GDPR”

WHO ARE WE?

Ladybird s.r.l. - Via Leonardo da Vinci 16, 10126, Turin, Italy - Tax code and VAT number 10816460017 (hereinafter also "Company" or "Data Controller")

WHAT CATEGORIES OF DATA DO WE PROCESS?

The common personal data collected in the form to which this notice refers.

WHICH IS THE SOURCE OF DATA?

I dati sono forniti direttamente da te con la compilazione del form.

WHY DO WE PROCESS PERSONAL DATA AND WHAT IS THE BASIS FOR THE PROCESSING OF EACH CATEGORY OF DATA?

We process personal data for the following purposes:

1.

On the basis of the need to execute the Terms and Conditions of Service (Art. 6 § 1.b GDPR), sending, by any means (e.g. e-mail or instant messaging services), different kind of communication:

• “generalist”, also of a commercial nature, on market research and for the administration of approval questionnaires concerning education-related topics (Master's degrees, webinars and other training and/or work opportunities), also by means of the Newsletter; 

• organisational (e.g. reminders for participation in events and webinars); 

• “personalised”,  also of a commercial nature, based on the collection of information about you (e.g. geographical, country of origin) or indicated by you (e.g. master's degree of interest) on topics of interest in the context of training and/or work opportunities (e.g. Courses, Master's degrees, Webinars, etc.)

2.

Allow our partner Universities and/or Higher Education institution(s) (or those offering courses similar to the one to which this Privacy Policy refers) to contact you again, sharing your personal data with them, on the basis of your consent, which is free and withdrawable at any time (art. 6 § 1.a GDPR).

TO WHOM DO WE COMMUNICATE THE DATA?

CON CHI CONDIVIDIAMO I DATI?

To the minimum extent necessary to achieve each of the Purposes, on one of the legitimacy prerequisites described above and on the basis of the applicable legislation and/or a contractual agreement with the Controller, we will or may communicate the data to:

1. parties necessary for the performance of activities connected with and consequent to the provision of the site and the services requested (e.g. IT service providers), who act as Data Processors;
2. internal staff authorised by us, committed to confidentiality or subject to a legal obligation to confidentiality.
3. University(s) and/or Higher Education institution(s) our partner(s), sharing (subject to your consent) your personal data with them in order to be contacted for the above-mentioned purpose n. 2.

DO WE TRANSFER PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA?

Yes, we use the services of companies established outside the European Economic Area (e.g. United States; in this case the transfer is made on the basis of standard contractual clauses and additional measures to ensure data protection) for the management of the landing page where your personal data is collected, and for the storage of your personal data. In any case, we ensure that data transfers are only made to countries that guarantee an adequate level of protection, for which there is an adequacy decision by the European Commission, or on the basis of one of the other guarantees provided for in Chapter V of the GDPR. Further information on transfers of personal data outside the European Economic Area is available by writing to the Data Controller.

HOW LONG DO WE RETAIN THE DATA?

Data provided will be retained for the time strictly necessary to perform the Service, and in any case no longer than one year after collection; in relation to the Newsletter, the data will be retained until you object to processing. For purpose no. 2, retention times are defined by the recipient of the data (e.g. the University or Higher Education partner institution to which we have, with your consent, shared your data).

ARE YOU OBLIGED TO PROVIDE US WITH PERSONAL DATA?

The data provided by you is necessary for the execution of the contract, but you are of course not obliged to use the Service. You are not obliged to consent to the processing for purpose no. 2. You are not obliged to fill in the form (and thus allow us to process the data for purpose no. 1), but you can object to the processing, as indicated in 'rights' (see below). You are not obliged to consent to processing for purposes 2 and 3. 

WHAT HAPPENS IF YOU REFUSE TO COMMUNICATE YOUR DATA?

If you do not complete the form and do not accept the T&Cs you will not be able to use the Service. If you do not consent to the processing for purpose no. 2, your contact details will not be shared with third party universities/training organisations.  Failure to provide your data will not result in any negative consequences.

WHAT RIGHTS DO YOU HAVE?

You have the right to:

1. access your data in our possession, and to request a copy of it, except where the exercise of the right infringes the rights and freedoms of other natural persons;
2. request the rectification of any incomplete or inaccurate data;
   
3. request the deletion of the data, subject to the exclusions or limitations established by the applicable legislation (e.g. Article 17 § 3 GDPR);
4. request the restriction of processing, where the conditions are met and subject to the exclusions set out in Article 18 § 2 GDPR;
5. request data portability (i.e. to receive the data in a structured, commonly used and machine-readable format, so that it can be transmitted to another Data Controller without hindrance), to the extent that the Processing is based on consent or on the need to perform a contract, where technically possible and except where the exercise of the right would infringe the rights and freedoms of other natural persons;
6. lodge a complaint with the Garante per la Protezione dei Dati Personali (in Italy, www.garanteprivacy.it), or with the Data Protection Authority of the EU State where you habitually reside or work, or of the place where the alleged infringement has occurred.

Right to withdraw consent: you may object to processing based on consent for the activity of receiving personalised communications (no. 2), by not giving it initially or by withdrawing it subsequently; you may object to processing based on consent to share personal data for the purpose no. 3 by not giving it initially or by withdrawing it subsequently directly to the recipient of the data (e.g. Partner University). In any event, please note that any subsequent withdrawal of consent shall not affect the lawfulness of the data processing carried out in the period prior to such withdrawal. The exercise of the above rights may also be delayed, limited or excluded in the cases provided for in Article 2-undecies of Italian Legislative Decree No. 196/2003.

WHO CAN YOU CONTACT FOR QUESTIONS OR TO EXERCISE YOUR RIGHTS?

You can contact us at the following e-mail address: