Privacy Policy

Privacy policies

Privacy Policy Courses

Information for those concerned in accordance with Article 13 of the European Regulation on the Protection of Personal Data (GDPR – General Data Protection Regulation) No. 679/2016 and attached provisions issued by the National and European Authorities

Premises

Please note: this information is provided only for the website that you are visiting and not for other websites you may visit using the links; other websites that may be visited through links on this website may contain tracking systems that are nothing to do with Polimoda. Therefore, Polimoda cannot guarantee that these “external” sites have suitable security systems to safeguard the data processed and to prevent any damage (e.g. from computer viruses).

The Data Controller

The Data Controller is the “Ente per le Arti Applicate alla Moda ed al Costume”, also referred to as “Polimoda”, with registered offices in Villa Favard – Via Curtatone, 1 – 50123 Florence (Italy).
E-mail: orientation@polimoda.com – privacy@polimoda.com
Registered email: direzione@pec.polimoda.biz
Website: www.polimoda.com: further information and instructions of a legal and/or other nature also partly connected to this document may be found on the website; this does not affect your right to contact us for further explanation to safeguard and guarantee your rights.

Contact details for the person responsible for protection of personal data (RDP o DPO – Data Protection Officer)

To date, the Association, having carried out the relevant assessments, has not identified a person to be responsible for the protection of personal data, (RPD o DPO – Data Protection Officer); a reservation remains, however, to integrate this policy statement in the event of any different implementation of procedures (ref. Articles 37-38-39 of GDPR no. 679/2016 and Guidelines issued by the Privacy Authority concerning the protection of personal data and by the Article 29 Working Party (WP29).
In any case, Polimoda uses external consultants specialising in the subject of safeguarding the privacy of natural persons and in house, it has persons dedicated to the subject in question, who act as filters in the management of relations with the aforementioned specialists or with data subjects and with the supervisory authorities.
It is in any case possible for the data subject to contact the persons in charge at Polimoda via the contact means made available here.

The Data processor

The persons in charge of processing, as defined and regulated by art. 28 of the GDPR, are named in the specific list available from the offices of Polimoda and which can be requested in writing using the above references.
The data controller has carried out thorough analysis of the role of subjects appointed as data processing and the impacts and risks connected to the operations of said subjects, signing contractual agreements covering the contents envisaged by the regulations as per GDPR no. 679/2016.

Categories of data processed

1. Common data:
– name and surname
– telephone number
– mobile number
– residence/domicile address
– e-mail
– gender
– place and date of birth
– educational qualification
– audio / video recordings of the data subject

2. Special categories of data pursuant to Article 9 of GDPR n. 679/2016 (i.e. data concerning your heath) and / or judicial data, only if required for admission to, enrolment in, attendance on your chosen course, for your request to participate to the selection process for the granting of scholarship and only with your express consent.
The processing of these data may also occur in case of specific problems linked to your person that you may wish to communicate to us or due to the occurrence of specific circumstances such as (accidents, occurrence of diseases that may impact the management of your relationships with us, the existence of significant legal problems, etc.) and/or concerning the management of emergency situations linked to your state of psychological or physical health which may occur in the context of your course attendance and all related activities, the completion of insurance procedures in the case of accidents, and management of absences and/or suspension of attendance for reasons of health. Data which qualify as belonging to special categories pursuant to article 9 of GDPR n. 679/2016 (i.e. the existence of particular pathologies or obvious physical or vocal alterations) may also be identified at the time of audio/video/photographic recordings.

3. Data linked to browsing on this website:
As well as data you provide expressly to Polimoda, other data may be recorded due to your browsing on this website. For all website access, we record the type of browser (e.g. Internet Explorer, Mozilla), the operating system (e.g. Windows, Macintosh) and the host and URL of the visitor, as well as data on the requested page. These data can be used in aggregate, anonymous form for statistical analysis of website use.
Other personal data collected may – in the future – be mentioned in other sections of this page or in information statements shown at the same time as the collection of the data within the specific sections, if any.
Personal data can be voluntarily entered by the user or collected automatically during the use of this application.
The use of cookies – or other tracking tools – by this application or by the owners of third-party services, where not otherwise stated, aims to identify the user and record the relevant preferences for aims strictly linked to the provision of the services/information requested by the user.
Failure by the user to provide certain personal data may prevent this application and our association to provide our services and to reply /follow up your requests. Please see the cookie policy for details.
The user takes responsibility for third party data published or shared via this website and guarantees that he or she has the right to communicate or disclose them, freeing the data controller from any liability to third parties.

Conditions for data processing

The conditions for data processing (without prejudice to the standards and regulations to which the data controller is subject), are as follows:
* Application for admission / Enrolment contract to the selected course
* Statutory and/or regulatory provisions for the sector to which Polimoda belongs;
* Applications / Requests from the data subject
* Verification of compliance with requirements for participation in the selection for scholarship assignment
* Access / Use of Library services made available by Polimoda.

Purposes of the processing

Standard Purposes (necessary consensus)

a) Purposes connected and instrumental to the management of the contractual relationship (represented by your enrolment in our Courses) signed or being finalized and the management of the related obligations (proper management of your insurance, taxation, economic, and education position and for all institutional/associative activities generally inherent to the relationship in place).
b) Purposes connected to the admission, also jointly with or through third parties (e.g. home institution, agency appointed for selection, etc.), to courses / study programs carried out by Polimoda (also in collaboration with third party organizations), to the relative attendance at these and to all related activities, as co-Data Controllers.
c) Purposes aimed at issuing information about the Courses and other activities that Polimoda carries out and/or about your admission to/enrolment in the Courses and activities, the resulting attendance and all other activities connected and/or supporting the training course, including possible internship envisaged for the course-end, including but not limited to those for the performance of ancillary services needed for the delivery of service (authorizations and consular services; notices and communications concerning the lessons, fieldtrips organization and related booking, etc.);
d) Purposes connected to receiving and monitoring the payment related to your enrolment in our Courses;
e) Purposes instrumental to the receipt of an application to participate in the selection for the assignment of scholarship(s) made available by Polimoda;
f) Purposes instrumental to the use of your data for access to all services offered by the Polimoda Library as well as for the other ancillary activities connected with and/or in support of the above services such as, by way of a non-limiting example, the use of library resources and of the material in general kept therein, present and made available, the insertion of the data in a database dedicated to the handling of the above-mentioned library resources and of any other materials, the possibility of being contacted by Polimoda by means of automated tools and/or telephonically for regulating and/or registering movements of resources, subject to your compliance with the Regulations governing the use of Library services;
g) Purposes connected and instrumental to the fulfilment of the obligations established by laws, regulations and European legislation;
h) Purposes aimed at asserting the rights also by third parties before the courts as well as arbitration and administrative bodies in compliance with regulatory restrictions;
i) Purposes connected to providing information and/or communications from Polimoda to your parents (where indicated at the time of enrolment) about your class attendance, the grades obtained, payments of tuition fees in order to keep them updated about the overall teaching progress and your accounting position;
j) Purposes connected to providing to your selected Agency clearly marked in your admission form, or through which your admission to the course has been agreed / formalized, any notifications useful to obtain student visas and/or residence permit and/or necessary for the resolution of issues related to your enrolment/attendance in the course.
k) Purposes aimed at supplying and/or acquiring from third parties, as co-Data Controllers, with whom the courses may be organized and/or carried out in collaboration, and/or at whose premises part of the course is delivered, your personal data for the purposes of joint management of the course, the data relating to your academic progress and to the awarding of grades, communications relating to obtaining a study visa and/or residence permit and/or necessary for resolving issues concerning your course enrolment / admission / attendance;
l) Purposes connected to the assistance provided to students by Polimoda in finding suitable accommodations in Hotels, Serviced apartments, and Apartments.
m) Purposes connected to the planning of the internship which may be provided (also including sending CVs and portfolios) at third-party companies.

Marketing Details

Promotional purposes and similar (optional consensus)

Purposes connected to planning and perform, through computerized instruments and through other instruments (that is, traditional methods such as snail mail and/or operator-assisted calls) marketing analysis and strategic and operational marketing activities, even after the end of the course that you have followed/chosen, or the granting/termination of the scholarship and of the related course of study or, in any case after the termination of the relationship for any kind of contractual service between you and Polimoda, to inform you about commercial and promotional activities regarding services or events (including recreational and social ones) related to the ones for which the relationship was previously established, as well as to monitor, in aggregate form, the enrolment trends for the course and of any further activities that you have followed / chosen, even through the use of CRM – Customer Relations Management. The purpose in hand may therefore be pursued for reasons other than those strictly related to the fulfilment of the contractual obligations or ancillary to these, in the case you decide to give consent (after reviewing this privacy policy); if you do not give your consent (optional) for the aforementioned purpose, the contractual relationship will not be compromised or altered.

Clarification:
– After having given your consent, it is your right to oppose, at any time, the processing of your data for this purpose;
– if you wish at any time to exercise the right of opposition to the processing, you may do so even through different and independent means respect to the contact methods mentioned above.

Mailing list and / or newsletter

When the user signs up for the mailing list or newsletter, his or her email is automatically entered in a list of contacts to whom email messages containing information, including of a sales and promotional nature regarding our services, can be sent. The user’s/customer’s/student’s email address can also be added to this list as a result of the registration for website applications or after making a request.

Interaction with social networks and external platforms

This type of service offers interactions with social networks or other external platforms, directly from the pages of this website.
The interactions and information acquired by this application are in any case subject to the relevant privacy settings of the user for all social networks. In the event that there is a service to interact with social networks installed, it is possible that this will record traffic for the pages on which it is installed, even if the user is not using the service.

Other purposes

Use of audio and video recordings (optional consent)

In case that explicit consent is provided personal data (in this case such as video shoots, photos and audio recordings of the data subject -including his /her voice-, which may also be taken by way of a limiting example during events, fairs, conferences, etc.) are collected and processed exclusively:

– for the internal educational activities to complete and update the electronic register of the teacher;
– to design and produce promotional material and material presenting the corporate activity (e.g. preparation of brochures or ads, publication of corporate articles on magazines and newspapers, the creation of corporate website pages and/or on social media network platforms related to the corporate profile);
– to publish and display the above mentioned material (containing such data) in the context of events / publications organized / produced also in collaboration with third parties

always in compliance with limitations and regulations in force.

Profiling

Relating to the activity in question, it must be noted that automated profiling of users/students (generally of individuals) may be carried out for the purpose of analysing or forecasting aspects that concern professional performance, economic position, health, personal preferences or interests, reliability or behaviour, location and movements of the person concerned to the extent in which this enables a profile of the person to be outlined with consequent actions, mainly promotional or targeted at him/her.

We would mainly arrange to analyse and create a personalized profile for you, based on the preferences and tastes shown by you in the context of the relationship with Polimoda, and have you receive advertising messages in line with your profile. In this way advertising messages/communications/notices etc. that you may receive will be of greater interest to you. As dictated by the prevailing regulations on privacy, in order to be able to carry out this activity your prior consent is required.

Methods and criteria for processing your personal data

Your personal data will be processed using manual, computer and/or telematic instruments, with methods and logics strictly related to the purposes above indicated, in a way that guarantee the confidentiality and safety of you data. In the event you should require more information, we remind you of your guaranteed rights, as specified here.

Protection of minors

Given that minors have additional guarantees in terms of confidentiality, consent for the processing of data concerning persons under the age of 18 should in any case be formalised by a parent or carer.
Minors must always ask a parent’s permission before sending data to this or any other website or subject online. Our website does not allow minors to register. In any case, in the event that the parent or carer of a minor should believe that said minor has in any case provided information of a personal nature to this website, they are kindly asked to contact us in good time.

In any case, should we find ourselves in possession of personal information belonging to a minor, we will immediately delete any information in our files.
Should we be provided with untruthful data, the association will be considered held free and harmless from any responsibility and/or claims, without prejudice to the controls which it undertakes to make.

Provision of data

The provision of personal data to the data controller represents an obligation by the data subject only insofar as same are necessary to answer, give indications, and provide services (i.e. admission to and /or enrolment in the courses, reply to request of information, courses on line purchases, selection procedures concerning the granting of scholarships requested, use of Library services); in the case that personal data is not issued, the data controller will not be able to meet such conditions. The same applies for data that the data controller is obliged to acquire in order to comply with legislative and/or regulatory requirements.
Optional entry of data in the form on the website (newsletter, contact form, etc.) as well as the optional, explicit and voluntary sending of data via web form or email to the addresses provided on this website, aimed to obtaining specific services and/or communication and information, involves the successive acquisition of the address/reference of the sender, necessary to respond to the request or provide the services, communications or information required, as well as of any other personal data entered.

Categories of recipients of personal data (subjects to which personal data can be communicated/transferred)

Generally, we may communicate your data, this being intended that the data will be disclosed solely to specific subjects or be hosted on third-party servers which Polimoda uses for the development and implementation of various services, as follows:
* to third parties who may access the data according to provisions of law, regulations or European Union legislation, within the limits established by these regulations;
* to third parties who need to access your data for purposes ancillary to the relationship existing between you and us, within the limits strictly necessary to carry out related tasks (public safety and other public and private subjects to fulfil obligations established by law also of a fiscal, administrative, and financial nature and the like);
* Polimoda employees and assimilated workers operating under its authority and duly trained and instructed by the data controller pursuant to the applicable legislation, as well as to teaching staff and personnel in charge of course orientation and teaching methods for the proper implementation of the training process to be carried out at our facility, limited to the communication needs connected to it (names and details concerning the educational activity, as well as e-mail addresses and any other contact details that you provided);
* to third parties who collaborate with Polimoda for the organization and/or performance of teaching activities (e.g. companies / agencies with which collaboration teaching projects are carried out, agencies who organize competitions, etc.);
* to third parties with whose collaboration the courses attended may be carried out, or who anyway host / deliver a part of the course, or together with whom the admissions to the courses are managed, as co-Data Controllers;
* to our consultants within the limits necessary to carry out their duty for our organization, in compliance with current provisions of laws and regulations;
* to external consultants such as lawyers, accountants, business consultants, trade associations, etc.;
* limited to the case of your enrolment in courses and your consequent attendance and performance of the required training process, to your parents and /or carer and your selected Agency clearly marked in your admission form / enrolment contract;
* to third parties who carry out or provide specific services instrumental to the performance of the relationship with you, such as by way of example but not limited to the company VAR Group SpA, Via della Piovola 138-50053 Empoli – FI which carries out on our behalf tasks of a technical or organizational nature instrumental to the provision of the required services, and/or – limited to your enrolment to the Courses and consequently, to your attendance and related training process – to public or private bodies, and social development and support organizations (for example ASL, hospitals, private clinics, banks, and insurance companies);
* to third parties who, for contractual needs and purposes preliminary to the management of the activities agreed with you and/or ancillary services and/or your specific requests, must acquire one or more set of data about you, by way of example but not limited to: VAR Group SpA Via della Piovola 138-50053 Empoli – FI and to external subjects (agencies, associations, companies, cooperatives) with which Polimoda has in place Agreements aimed, for example local health authorities, hospitals, private clinics, banks, and insurance companies);to third parties who, for contractual needs and purposes preliminary to the management of the activities agreed with you and/or ancillary services and/or your specific requests, must acquire one or more set of data about you, by way of example but not limited to: VAR Group SpA Via dellaPiovola 138-50053 Empoli – FI and to external subjects (agencies, associations, companies, cooperatives) with which Polimoda has in place Agreements aimed, for example, at finding accommodation in apartments suitable for the needs of end-users of its Courses and activities or for the purposes of providing for the psychological and physical support of the student;
* to individuals experts in graphic design and advertising (e.g. for the processing of brochures, corporate presentations, etc.);
* to individuals with whom Polimoda collaborates to organize events (e.g. shows, exhibitions, etc.) and/or promotional or publishing initiatives;
* to the web administrators of Polimoda’s corporate website (to date Moze Srl with registered office in Milan, Via Merano, 16) and of the newsletter platform service, as well as to VAR Group SpA Via della Piovola 138-50053 Empoli FI (for implementation and personalization of the CRM (Customer Relation Management) system), performing on our behalf technical or organizational tasks instrumental to the supply of the requested services as well as any third party involved in various ways with the corporate activities;
* to third parties carrying out technical IT services with servers located in the European Union and/or also in non-EU countries (a list and attached documentation may be available at the Association’s headquarters by request of the interested party using the procedures envisioned for the exercise of the rights), with which Polimoda might collaborate in the future in order to fulfil specific obligations and in any case for the organization and performance of all the activities connected to course enrolment and relative attendance, including any ancillary services;
* to system administrators specifically authorized by the undersigned in compliance with regulatory requirements.
Without prejudice to the recipients nominally mentioned here, reference should be made to the categories of goods/services referred to in the previous points, as suppliers may obviously vary over time; in any case Polimoda manages and updates a list of recipients/external managers/system administrators, which may be requested by the interested party using the procedures envisioned for the exercise of the rights.

Important note: your data will not be disclosed to third parties for their marketing purposes.

Transfer to third-party (non-EU) countries

The Data Controller: intends to transfer the personal data to non-EU countries (a list and attached documentation are available at the Association’s headquarters by request of the interested party using the procedures envisioned for the exercise of the rights).

Retention period

Your personal data will be stored on our files for the purposes mentioned here and based on your permission, for the period considered necessary, i.e.: Your personal data will be stored on our files for the purposes mentioned here and based on your permission, for the period considered necessary, i.e. 10 years, to be renewed automatically for a period of equal duration unless consent is withdrawn.
This is without prejudice to the possibility to revoke consent at any time without prejudice to the lawfulness of treatment based on authorisation issued before the cancellation.

Complaints to the Privacy Authority

You can submit complaints to the supervisory authorities:
– in Italy (where the Italian authorities are competent) using the form that can be downloaded from the link: www.garanteprivacy.it in the dedicated section;
– outside Italy, based on specific instructions from the EU member state:
* of usual residence
* of work
* of the place in which the presumed breach occurred

Your rights

Right of access: you can receive a copy of the personal data subject to processing at any time.
Right to restrict the data: this right can only be exercised in case of a breach of the lawful premises to the processing, but also in cases in which you request that the data be corrected or object to the processing; the Data Controller undertakes to identify the data in question when assessing the procedure to be followed by implementing organisational measures suited to this purpose.
Right to correct the data: you can obtain without undue delay the rectification of inaccurate personal data concerning your person and you can also have incomplete personal data completed, including by means of providing a supplementary statement
Right to object to the data: you can object, on grounds relating to your particular situation, at any time to processing of your personal data also if these are processed for direct marketing or profiling activities.
Right to revoke consent: if your consent is provided, by means of example, for marketing purposes.
Right to be forgotten: Data Subjects can request the enforced deletion of their data, for example, also after withdrawing authorisation for their data to be processed.
Right to portability: not applicable to non-automated processing and therefore to paper files and/or hard copies of registers; additionally; this is applicable only to the data provided by the Data Subject to the Data Controller and processed with the authorisation of the former or based on a contract established with the Data Controller.

Terms and methods of response to data subjects

Please note that when you exercise your rights, the Data Controller must provide a written answer, also using electronic means that allow accessibility (orally, only upon the express request of the Data Subject), within the term of 1 (one) month and that in cases of specific complexity this can be extended to 3 (three) months, without prejudice to the obligation to provide a response within one month of the request, even in case of denial.
The Data Controller, after assessing the complexity of the request formulated by the Data Subject, may set the amount of any contributions to be requested from the same, but only if the requests prove manifestly groundless or excessive.

In order to exercise your rights, you can contact Polimoda as follows

E-mail: privacy@polimoda.it
Headquarter: Via Curtatone n. 1, 50123 Firenze
Telephone number: +39 055 275061
Fax: +39 055 275020

Privacy Policy Website

Information for the interested parties pursuant to art. 13 of the European Regulation on the Protection of Personal Data (GDPR) No. 679/2016 and related provisions issued by the National and European Authorities

Privacy protection

Ente per le Arti Applicate alla moda ed al costume (hereafter Polimoda) constantly commits to provide visitors with a web experience in full respect and full protection of their privacy and welcomes you on the website www.polimoda.com.

We invite you to read our Privacy Policy and to read the following information provided pursuant to article 13 of the GDPR (General Data Protection Regulation) No. 679/2016 – EU Privacy Regulation; they are addressed to everyone who interacts with the web services directly provided by Polimoda and accessible electronically from www.polimoda.com and they wish to describe the methods adopted for the management of the aforementioned website and not for other external websites that may be browsed by the user via links. Additional information may be provided within the various access channels.

The Data Controller – Identification and Contacts

Ente per le arti applicate alla moda ed al costume (Polimoda), with registered office in Villa Favard – Via Curtatone, 1 – 50123 Florence (tel. +39 055 2750639 – fax +39 055 2750720 e-mail: privacy@polimoda.com).

Data Protection Officers and location of the processing

Summary:
External parties other than the Data Controller that may manage your personal data in our name and behalf. The list is available at our office and that can be requested by using the aforementioned contact information.

In more details:
The list of data protection officers identified and specifically bound by contract or other legal deed as well as the system administrator(s) is available at our headquarters. The data processing connected to the web services offered by this website takes place at the Polimoda headquarters and at the premises of any external data protection officers as well as at the offices of other duly authorised parties (as specified below) and they are managed by entities in charge of the management of the services requested, for the preservation and processing of the data and for the necessary maintenance operations.
We would like to specify that in the case of need, the data related to the web services may be processed by the staff of the company in charge of web maintenance and specifically the company Moze S.r.l. with registered office in Milan, Via Merano, 16, while the newsletter service platform is managed by Mailchimp, as well as the company VAR Group S.p.A. Via della Piovola 138 – 50053 Empoli (FI) (for details, see the specific information in the various sections of the website).
With the consent of the interested parties, if required by law, and in any case subject to adequate notification specifying the various purposes, your personal data may be disclosed to third parties, public and private, unrelated to Polimoda, who will process them as independent data controllers (or if applicable, as data protection officers). In this regard, Polimoda cannot be deemed liable and does not assume responsibility for:

  1. rules and methods for the management of personal data of other websites, accessible from the pages of www.polimoda.com through links and/or references;
  2. the content of possible e-mail services, web spaces, and chat forums provided to users.

Legal basis of the processing/Why we process your data

Basic purpose (mandatory consent)

Summary:

  • Statistical purposes
  • User contact purposes
  • Regulatory and/or legislation provisions
  • Specific sector’s provisions
  • Requests received by the user

In more details:
Your personal data are collected for the following purposes and using the following services:

Statistical purposes
The services contained in this section allow the Data Controller to monitor and analyse traffic data and are used to keep track of User behaviour.
Google Analytics (Google Inc.)
Google Analytics is a web analytic service provided by Google Inc. (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this App, compiling reports and sharing them with other services developed by Google. Google may use the Personal Data to contextualise and personalise the advertisements of its advertising network.
Personal data collected: Cookies and usage data Location of the processing: USA – Privacy – Opt-out

Contact management and submitting messages
This type of service allows managing a database of email contacts, telephone contacts or contacts of any other type, used to communicate with the User. These services may also allow us to collect data related to the date and time in which the messages are seen by the User, as well as track User’s interaction with them, such as information on clicks on the links included in the messages.
MailChimp (The Rocket Science Group, LLC.)
MailChimp is an email management and message forwarding service provided by The Rocket Science Group, LLC.
Personal Data collected: email addresses.
Location of the processing USA – Privacy Policy

Fulfilment of the obligations established by contractual agreements, laws, regulations and/or EU standards;
Asserting the rights also by third parties before the courts, in arbitration and during administrative proceedings in compliance with the limits established by the legislation.

Replies to specific user requests:
In the case of specific requests submitted by the User, Polimoda undertakes to respond without storing the data provided for further purposes whose consent is optional (see below).

Promotional activities (optional consent)

Summary:
Forwarding of commercial communications, newsletters, direct marketing, market analysis, etc. through:

  • automated means (e.g. sms and chat, e-mail, automated phone calls)
  • traditional means (e.g. snail mail, operator telephone calls).

In more details:
All your data/data of the minor under your care may be processed as part of the standard activities of Polimoda exclusively for the following purposes: to send, via computer and other non-computerised means (such as traditional snail mail and/or operator calls) communications for the purpose of course updates on courses and/or teaching activities of Polimoda, as well as to plan and carry out analytical, strategic and operational marketing, and to provide information on commercial and promotional activities concerning services or events (including social and recreational ones) developed by our association, using CRM – Customer Relations Management.
Consent, if you wish to provide it, will be valid for contacts both via traditional means and computerised ones (e.g. e-mail, sms, mms, fax, automated calls …); after providing your consent, however, you will maintain the right to oppose, at any time and free of charge, the processing of your data for said purposes; if you wish at any time to exercise the right to oppose the processing of your data, you may also do so in a diversified and independent way for each one of the methods of contact (computerised and traditional ones).
The operations related to the purposes described herein will be carried out by the undersigned in full compliance with all current regulatory and legislation provisions as well as in compliance with internal procedures for the management of personal data always in compliance with the legislative requirements. Therefore, no commercial activity will be carried out unless specifically authorized by the interested party.

Profiling (optional consent)

Summary:
Profiling procedures may be used to create your own personalised profile, based on your preferences and tastes, and to let you receive advertising messages consistent with your profile. In this manner, the advertising messages that you may receive will be more interesting for you. As established by the current regulations on privacy, in order to be able to perform said activity, your prior consent is required and said consent is revocable at any time.

In more details:
Concerning the activity in question, it should be noted that automated profiling of users (in general related to natural persons) may be carried out to analyse or predict professional performance, economic status, health, preferences or personal interests, reliability or conduct, the location and the movements of the interested party to the extent that this allows outlining a profile of the interested party with consequent promotional and targeted actions. Mostly, we would analyse and create your own personalised profile based on the preferences and tastes expressed by you when browsing and when entering data on the Polimoda website, and thus sending you advertising messages consistent with your profile. In this manner, our advertising messages/communications/notifications etc. that you may receive will be more interesting for you. As established by the current regulations on privacy, in order to be able to perform said activity, your prior consent is required and said consent is revocable at any time.

How do we process your data and which data are processed?

Summary:
Cookies
Browsing and usage data
First Name and Surname – E-mail address – System log profile and maintenance

In more details:
Personal Data may be entered voluntarily by the User, or collected automatically during the use of this App.
Any use of Cookies – or other tracking tools – by this App or by third party service providers used by this App, unless otherwise specified, has the purpose of identifying the User and recording the related browsing activities. Failure to provide the User with some of your Personal Data may prevent the App from providing its services (for more information, see the cookie policy).
The User assumes the liability of the Personal Data of third parties published or shared through this App and guarantees to have the right to communicate or disseminate them, holding the Data Controller harmless against any liability towards third parties.

Interaction with social networks and external platforms
These services allow you to interact with social networks, or other external platforms, directly from the pages of the App. The interactions and information acquired by this Application are in any case subject to the User’s privacy settings related to each social network. If a service of interaction with social networks is installed, even if the Users do not use the service, said service may collect traffic data related to the pages in which it is installed.
The “Like” button and Facebook social widget (Facebook, Inc.): The “Like” button and Facebook social widgets are interactive services used with the Facebook social network, provided by Facebook, Inc. Personal data collected Cookies and Usage Data Location of the processing USA – Privacy

Displaying content from external platforms
These services allow you to view content hosted on external platforms directly from the pages of this App and to interact with them. If a service of this type has been installed even if the Users do not use the service, said service may collect traffic data related to the pages in which it is installed.
Widget Google Maps (Google Inc.)
Google Maps is a map display service operated by Google Inc. which allows this App to integrate such contents in its pages. Personal data collected: Cookies and usage data
Location of the processing USA – Privacy Policy

System and maintenance log
For needs related to the operation and maintenance, this App and any third party services used by it may collect System Logs, that is files that record the interactions and that may also contain Personal Data, such as the User’s IP address.

Processing methods

Summary:
Paper and Computerised methods

In more details:
The processing of your data is carried out by using manual and automated tools, with methods strictly related to the purposes indicated above and, in any way, in order to guarantee the security and confidentiality of your data.
If you wish to obtain further information, we would like to remind you of the rights granted to you as specified herein.

When are you obligated to provide us with your data?

Summary:
Basic purpose: mandatory
Other purposes (marketing/promotion): optional

In more details:
The types of personal data collected and processed on www.polimoda.com are those required to provide the requested services and in the remaining cases originate from the user’s browsing activity. Therefore, it is clear that, if such data are not provided, the services that require the use of these tools cannot be provided to you. If you do not provide your consent to receive advertising notifications or direct sales advertising or interactive commercial communication, your e-mail and telephone number will not be used for this purpose. Any voluntary submission of email messages to the addresses indicated on the site involves the acquisition of the sender’s address as well as any other information contained in the message; such personal data will be used for the sole purpose of performing the service requested.

Protection of minors

Summary:
Data processing related to minors may take place to the extent that consent is provided or authorised by the parents of guardian of the minor.

In more details:
Polimoda does not intentionally collect personal information (such as name, address and telephone number, etc.) of minors. We do not allow minors to register on our websites or to participate to online contests or promotions. In any case, if the parent or guardian of a minor should deem that the minor may have provided any personal information, he/she should contact us to delete such information from our archives. If Polimoda becomes aware of being in possession of personal information related to a minor, shall immediately proceed to erase the information provided from its databases. If false data are provided, Polimoda shall be held harmless from any liability and/or claim without prejudice to the mandatory inspections under its responsibility. In addition, please note that all minors must, however, receive the proper authorisation from their parents or guardians before using or making public the information on websites of any type.

Categories of recipients to which the personal data may be communicated

Summary:

  • employees and salary-equivalent employees of Polimoda qualified as parties “authorized to the data processing” (administrative, commercial and marketing personnel, system administrators, etc. ) and personnel duly trained and monitored by the Data Controller;
  • teaching staff;
  • external parties (e.g. agents, legal and administrative consultants, sector’s regulations experts, technical service providers, hosting providers, information service companies, communication agencies, commercial partners where necessary to fulfil specific obligations, etc.).

In more details:
Your data/data of the minor in your care will not be disclosed by us, by which we mean that we will not disclose said data to unknown parties, including via data availability or consultation.
Your data/data of the minor in your care may be disclosed by us, by which we mean that we will make said data available to specific subjects within the following terms:

  • to parties that may access data due to legal provisions, EU regulations and within the limits established by those regulations;
  • subjects that need to access your data for purposes strictly linked to meeting your request and for purposes not directly linked to same, within the limits strictly necessary to perform the tasks connected (public safety and other public or private subjects for the performance of legal obligations in administrative and similar terms);
  • employees of the company, qualified as parties in charge of the processing of personal data as well as the teaching staff (which consists of employed personnel as well as independent professionals) and to personnel in charge of replying to your requests limitedly to the communication requirements in question (specifically name and email address and any other contact information you may provide);
  • to the web masters of the Polimoda corporate website (Moze S.r.l. with registered office in Milan, Via Merano 16), which carry out, on our behalf, technical or organisations tasks needed for the provision of the requested services, as well as any third parties involved in the various activities;
  • to subjects who assist us in the forwarding of communications with commercial/promotional purposes;
  • to system administrators properly appointed by the company in compliance with the legal provisions.

Important: your data will not be communicated to third parties for marketing purposes.

Storage period of the personal data

Summary:
10 years

In more details:
Your personal data will be stored in our archives for the purposes mentioned herein and on the basis of your authorisations for the period considered appropriate or for a maximum of 10 years. This time period may be reduced and/or increased (after informing the interested parties) in the case, by way of example, of information originating from Agencies and/or Control Authorities.
At any time you have the right to revoke your consent without prejudice to the lawfulness of the processing based on the consent issued prior to the revocation.

Transfer to non-EU countries

Summary:
The data controller may transfer your data to countries outside the EU to use services such as archiving or creating mailing lists; of course, in this case Polimoda undertakes to verify the security of the transfer of personal data with the criteria established by the regulation (for example: the presence of a “legally binding instrument” having executive effect between public authorities or public bodies; corporate binding regulations, data protection provisions adopted by the Commission, codes of conduct, and certification mechanisms).

In more details:
The transfer of personal data outside the European Union:

  • may bring forth greater risks and as such it must be protected adequately;
  • this is a complex activity that requires specific knowledge.
    The starting point of an organisation to this end must be to adopt countermeasures suitable to maintain the same level of protection that the personal data would have by remaining within the EU.
    If Polimoda makes use of this opportunity, it commits to collect ahead of time and make available to the interested parties all the support documentation (for example: the presence of the “legally binding instrument” being effective between public authorities or public bodies; binding corporate regulations; the provisions for the protection of personal data adopted by the Committee; code of conduct and certification mechanisms) with the same methods with which said rights can be exercised.

Filing Complaints to the Privacy Protection Authority

  • The procedures and protection measures available to you (in addition to exercising your rights towards us) are the following:
    Accessing the website www.garanteprivacy.it in the appropriate section dedicated to complaints if the Italian Authority is the one having jurisdiction;
    or
  • respecting the procedures established by the Data Protection Authority of the Member State (if other than Italy) in which you typically resides, work or where the alleged violation has occurred.

Your rights

Summary:
Access – Limitation – Correction – Opposition – Revocation of consent – Erasure (Right to be Forgotten) – Portability

In more details:
Access right: you may receive a copy of your personal data being processed at any time.
Limitation right: this right can be exercised not only in case of a breach of principles of legitimacy of the data processing but also to request the correction of the data or to oppose the data processing. The Data Controller undertakes to mark the data in question during the evaluation period to decide the course of action through the use of organisational measures suitable for this purpose.
Correction right: you may obtain without delay the correction of your personal data if they are inaccurate and may also obtain the integration of incomplete personal data by providing an integrative statement.
Opposition right: you have the right to oppose, at any time and for reasons connected to your particular situation, the processing of your personal data even if they are used for direct marketing and/or profiling.
Revocation right: you have the right to revoke your consent if issued, for example, for marketing purposes and the like. Erasure right (right to be forgotten): it is possible to request the deletion of your personal data in a strengthened form, for example even after the revocation of consent for the processing of your personal data.
Portability right: it does not apply to non-automated processing; therefore it is not applicable to archives and/or paper records. Furthermore, only the data that are provided by you to the Data Controller and processed with your consent or on the basis of a contract stipulated with the Data Controller are deemed portable.

Which contact details should you to use to exercise your rights?
E-mail: privacy@polimoda.com
Phone: +39 055 2750639
Fax: +39 055 2750720
Snail Mail: Ente per le Arti Applicate alla Moda ed al Costume – Polimoda”, Villa Favard – Via Curtatone, 1 – 50123 Florence

Term and methods of reply by the Data Controller to those who wish to make use of the rights associated with their personal data

Summary:
1 (one) month extendible up to 3 (three) months in the most complex cases in written form

In more details:
We would like to inform you that if you exercise your rights, the Data Controller must provide you with a written reply through electronic means that facilitate accessibility (verbally only on specific request of the interested party) within 1 (one) month, which, in those cases of particular complexity, can be extended to 3 (three) months without prejudice to the obligation to provide a reply within one month from the date of the request even in the case of refusal.
The Data Controller, after having assessed the complexity of the request submitted by the interested party, may establish the amount of any fee that may be requested but only if the requests are clearly unfounded or excessive.

Amendments to this information sheet
The Data Controller reserves the right to apply changes to this information page at any time by providing notification to the Users here. Therefore, we would recommend to visit this page often and to refer to the last date of changes specified at the bottom. If you do not agree with the changes applied to this privacy policy, you are requested to stop the use of the App and you may require to the Data Controller to delete your personal data. Unless otherwise specified, the aforementioned information sheet will continue to apply to the Personal Data collected up to that time.

Update date: 23th may 2018