Privacy Policy

WHY ARE YOU RECEIVING THIS NOTICE

In compliance with the provisions of Article 13 of the EU Regulation 2016/679 (hereinafter, the “EU Regulation”) on the protection of individuals with regard to the processing of personal data and on the free movement of such data, this information is provided to users of the website https://www.naba.it/ (hereinafter, the “WebSite”).

It is understood that the Controller makes further detailed information available for specific situations.

IDENTITY OF THE DATA CONTROLLER AND DATA PROTECTION OFFICER

Pursuant to Article 4 no. 7 of the EU Regulation, Nuova Accademia S.r.l. based in Via Carlo Darwin, 20,

20143, Milan (MI), Telephone: 02 973721, is the Data Controller (hereinafter also referred to as the "Controller") who can be contacted at privacy@naba.it. Nuova Accademia S.r.l. has appointed a Data Protection Officer (DPO), who can be contacted at dpo@naba-da.com.

TYPES OF DATA PROCESSED

For the pursuit of the purposes set out below, the Controller will, as appropriate and where necessary, process personal data belonging to the following categories:

• Common personal data such as personal details, contact data relating to initiatives, courses, events offered by the Data Controller;
• Browsing data (common personal data) data belonging to this category is collected via cookies. For detailed information on the cookies used, please refer to the specific cookie policy.

COOKIE

For more information on the use of cookies within the Website, see the Cookie Policy

PURPOSE OF PROCESSING AND RETENTION PERIOD

The purposes of the processing are as follows:

1. Purposes on the basis of the data subject's consent (Art. 6 paragraph 1 letter a of GDPR)

1. Send communications regarding Campus initiatives, Scholarships, courses and events that might interest you;
2. Aggregate and analyse the information collected to provide you with customised content to improve the educational offer.

Data processed for the above purposes will be stored for 3 years; however, the data subject is given the opportunity to withdraw consent at any time (Art. 7 paragraph 3 GDPR)

2. Purposes for the protection of a legitimate interest of the data controller (Art. 6 paragraph 1 letter f GDPR)

1. Management of the Data Controller's website;
2. Contacting and sending you information about our courses via e-mail, telephone and WhatsApp/SMS/Chat channels as a result of your request received by filling in the forms on our website;
3. Accreditation at events promoted by our Campus such as the Domus Academy Open Day;

Data processed for the purpose c) will be stored in accordance with the provisions of cookie policy .

Data processed for purposes d) and e) will be stored for 5 years.

LEGAL BASES OF PROCESSING

The processing of the above-mentioned personal data is based on the following legal basis:

• Consent of the data subject (Art. 6 paragraph 1 letter a GDPR).
• Legitimate interest of the data controller (Art. 6 paragraph 1 letter f GDPR);

CATEGORIES OF RECIPIENTS

The data acquired by the Data Controller, within the scope of the above-mentioned purposes, may be communicated to one or more of the categories of subjects set out below, such as, for example:

• Group companies;
• Third parties (by way of example, external collaborators and companies providing specific instrumental services) who perform outsourcing activities on behalf of the Controller, in their capacity as external data controllers;
• Hosting service providers;
• People carrying out management activities on the data controller's computer system;
• Judicial authorities as well as to those subjects to whom communication is mandatory by law. These subjects will process the data in their capacity as autonomous data controllers.

The complete and up-to-date list of Autonomous Data Controllers, Data Processors in charge of processing and Data Recipients in any capacity (pursuant to Article 4 no. 9 of the EU Regulation) may be requested at the offices of the Data Controller or at the e-mail address: privacy@naba.it .

EXTRA-EEA TRANSFER OF PERSONAL DATA

The management and storage of personal data will take place on servers located within the European Union of the Data Controller and/or third party companies appointed and duly appointed as Data Processors. Transfers may take place to countries that do not provide the same level of protection as envisaged by the GDPR or applicable legislation. Nuova Accademia S.r.l. will ensure that each of these recipients undertakes specific contractual obligations in accordance with applicable data protection regulations (including the signing of Standard Contractual Clauses - Standard Contractual Clauses - approved by the European Commission), unless the Data Controller may refer to any other legal basis for the transfer of such information. In any case, the data subject may always request further information, including the countries to which the personal data will be transferred, by writing to the e-mail address privacy@naba.it .

Details of cookie transfers can be found at cookie policy .

METHODS OF TREATMENT

Personal data will be processed both in paper and electronic and/or automated form. It is possible to carry out operations of collection, recording, organisation, storage, consultation, processing, modification, extraction, comparison, use, interconnection, communication, deletion, destruction and any other appropriate operation, also automated, in compliance with the provisions of the law necessary to guarantee, among other things, the confidentiality and security of the data as well as their accuracy, updating and relevance to the stated purposes.

RIGHTS OF THE DATA SUBJECT

The data subject, in relation to the personal data provided, has the right to exercise at any time and in accordance with the provisions of the EU Regulation the rights set out in the latter and set out below:

• Right to withdraw consent (Art. 7 paragraph 3 of the EU Regulation): right to withdraw consent given. Withdrawal of consent does not affect the lawfulness of the processing based on the consent before withdrawal;
• Data subject's right of access (Art. 15 of the EU Regulation): the right to obtain confirmation as to whether or not personal data relating to him/her exist and a copy of such data in intelligible form;
• Right of rectification (Art. 16 of the EU Regulation): right to rectification of inaccurate personal data concerning him/her;
• Right to erasure “right to be forgotten” (Art. 17 of the EU Regulation): right to erasure of one's own data;
• Right to restriction of processing (Art. 18 of the EU Regulation): right to obtain the restriction of processing, e.g. if the accuracy of the data is contested or in case of unlawful processing;
• Right to data portability (Art. 20 of the EU Regulation): the right to receive in a structured, commonly used and machine-readable format the personal data concerning him/her that has been provided to the Data Controller and the right to transmit such data to another Data Controller without hindrance where the processing is carried out on the basis of consent or a contract and is carried out by automated means;
• Right to object (Art. 21 of the EU Regulation): the right to object to the processing of one's own personal data;
• Right not to be subject to automated decision-making (Art. 22 of the EU Regulation): right not to be subject to a decision based solely on automated processing.

We inform you that the Company undertakes to reply to your request within one month, except in the case of particularly complex requests, for which it may take up to three months. In any case, the Company shall explain to you the reason for the wait within one month of your request.

The outcome of the request will be provided in writing (at the request of the interested party) or in electronic format (and, in this case, free of charge). The Owner specifies that the interested party may be asked to make a possible contribution in the event that his/her requests are manifestly unfounded, excessive or repetitive: in this regard, Nuova Accademia S.r.l. will keep track of the requests. Nuova Accademia S.r.l. in accordance with Art. 19 of the EU Regulation, undertakes to inform the recipients to whom the personal data of the interested party has been communicated of any rectification, cancellation or limitation of processing requested by the interested party, where possible. Please note that revocation of consent does not affect the lawfulness of the processing based on consent before revocation.

RIGHT TO LODGE A COMPLAINT (ART. 77 OF THE EU REGULATION)

If the data subject considers that his or her rights have been compromised or infringed, or that the processing of his or her data is contrary to the legislation in force, he or she has the right to lodge a complaint with the Personal Data Protection Authority in accordance with the procedures indicated by it at the following link.

NATURE OF DATA PROVISION

For the purposes of d) and e), the provision of data by the data subject is necessary; failure to provide such data will not permit proper handling of requests received from the data subject.

For the purposes of points a) and b), the provision of data by the data subject is optional: failure to provide data on the part of the data subject will result in the impossibility of receiving communications relating to Campus initiatives, scholarships, courses and events of interest; as well as the impossibility for the Data Controller to aggregate and analyse the information collected through the website in order to improve the educational offer.

For the purpose c) the provision of data by the person concerned is necessary; failure to provide such data will not allow proper navigation on this website.

CHANGES AND UPDATES

Nuova Accademia S.r.l. may also make changes and/or additions to this information notice as a consequence of possible subsequent regulatory changes and/or additions. In such cases, the new version of this information notice will be communicated as soon as possible to reach whoever it might concerned as quickly as possible.