Privacy Policy

Privacy policies

Student Privacy Policy

This policy statement describes the standard processing carried out by Polimoda on the personal data of registered students, future students and any students using the training and educational services of Polimoda, based on agreements with third-party Institutions, even if headquartered outside the EU, highlighting the data subject's guaranteed rights.

The policy statement is regularly updated to adapt it to current laws or to new methods of processing personal data.

Data Controller

The Data Controller is the Ente per le Arti Applicate alla Moda e al Costume, known as “Polimoda”, with headquarters at Villa Favard, Florence

Tax ID code 94015750485

VAT. Reg. no. 03758580488

Addresses:

Villa Favard, Via Curtatone n.1, Cap 50123;

Certified email: direzione@pec.polimoda.biz 

Standard email: privacy@polimoda.com 

DPO: Avv. Lorenzo Calucci, rpd@polimoda.com

Type of personal data processed

1 identification and contact data for the data subject

E.g.: name, surname, place and date of birth, tax ID code, ID documents, citizenship, image; address of residence; email; telephone; bank details.

2 data concerning previous school, academic or professional experience, as well as data concerning the courses at Polimoda

E.g. CV, examinations, tests, work, projects, final dissertation. Polimoda will also keep documents on the assessment of skills, experience, and study abroad (internships and other), details of examinations and any initiatives (competitions, scholarships).

3 Information on the data subject’s economic or personal situation, including specific data concerning health

Note: we can process these data to provide customised assistance, if expressly requested, in the event it is necessary to obtain grants/benefits as envisaged by law or provided by Polimoda for the requirements of same.

Purpose of data processing and legal basis

1 management, from an administrative viewpoint, of all training-related processes, including the processing needed to sign registration agreements electronically, using OTP, and purchase, if necessary, of on-line educational services as offered by Polimoda.

Processing is required to continue the relationship or for precontractual measures implemented at the request of the data subject.

2 performance of institutional activities and tasks: for your participation in initiatives linked to obligatory or additional activities on the curriculum, or institutional events, placement services and internships, and networking, even after completion of your course of study. Polimoda may also carry out customer relations management activities, identifying your profile, interests, experience, skills, and knowledge to offer you opportunities for professional and personal growth on an individualised basis.

Processing is necessary to continue the relationship under the terms envisaged by the agreement or to perform activities concerning services for which the data subject has shown specific interest.

3 access to services offered by Polimoda: consultation and use of Library resources, access to the free Housing service

Processing is required for the use of goods and services requested or for which the data subject has registered.

4 sending of communication or newsletters to the address provided by you:

- sending of newsletters in hard copy and/or electronic format with content concerning Polimoda’s educational offer and services in line with the student’s preferences and interests, as shown in the choice of educational course.

Processing is legal provided it is related to the performance of activities performed as well as for the related institutional notices.

- institutional notices concerning, for example, career or events/initiatives promoted by the Data Controller during the registration period, attendance of classes, seminars, orientation events, etc.

Processing is lawful because it is related to and instrumental for institutional activities, or subject to consent.

- creation of editorial/digital/hard copy/social products for communication purposes, promoted by the entity requiring the use of images created within Polimoda or on events created from/in collaboration with Polimoda-creation of web/social media pages or published products for the dissemination and distribution of these activities.

Processing is subject to the consent

- promotional activities, inquiries linked to market research initiatives.

Processing is subject to consent.

5 internal security and organizational reasons for the allocation of badges, recording images collected as part of the closed-circuit video surveillance system.

Processing is necessary to protect the legal interests of Polimoda or third parties, such as safeguarding company assets and inhouse organization.

6 registration and participation in competitions, scholarships, competitions.

Processing is based on contract or consent.

7 sending of notices and information using automated and non-automated contact by third parties (e.g. notification of events organised by Polimoda partners and/or third-party subjects).

Processing is based on consent

8 performance of legal obligations to which the Data Controller is subject.

E.g. performance of administration, accounting, tax, and balance sheet activities.

Processing is necessary to comply with a legal obligation.

Data communication

The Data Subject’s data can only be accessed by employees and collaborators of Polimoda for the purpose of supplying the services requested and limited to information that is instrumental and connected to the same.

Specifically, administrative staff, teaching staff, academic tutors, and collaborators.

Note: our employees and collaborators are informed and trained in the subject of compliance with personal data principles and regulations processing.

Moreover, the Data Controller will share the Data Subject’s information to some suppliers for the purpose of providing specific services as requested; for this purpose, these suppliers are named “Processors”.

In all other cases, the Data Controller will not communicate personal information to other parties without your consent, unless this is required by law or a public Authority.

Specifically:

national and international public entities and public administration offices for the performance of institutional tasks, including relevant to processes for the issue of foreigners’ permits off stay; credit institutes;

third parties (natural/physical, public/private entities/associations, including professional firms and companies) used by Polimoda for the provision of insurance services and in general, of use in the management and performance of the contract; third parties used by Polimoda for the delivery of study bursaries; third parties used by Polimoda to offer placement services and internships; masterclasses; international entities for participation in exchange programs when the destination country complies with the adequacy principle.

At this point, Polimoda will decide, jointly and in conjunction with third parties, the purposes and means of processing, which will be appointed co-processors, based on a specific agreement (art 26 GDPR).

For example, for the Housing service, to dispense services carried out in compliance with foreign institutes, student exchange programs, etc.

Data retention period

Data will be used by Polimoda for the whole duration of the relationship. Upon termination of same, only data for which retention is required by law or accounting or for taxation purposes, or to safeguard the entity, which is set at 10 years by law.

Images and films used will be stored for as long as the institutional aims are in place.

Images and films that are processed based on consent will be retained until the withdrawal of consent, in which case, your distinguishing features will be obscured or deleted.

Regarding the sending of notices and newsletters or which consent is given, contact details will be retained for as long as Polimoda retains a legitimate interest in the performance of said activities and in any case until the data subject exercises their right to oppose the processing or to cancel or delete consent.

International data transfer

The subject’s personal data are transferred abroad for the provision of certain services; in these cases, transfers are based on decisions of suitability or on the standard clauses of the European Commission.

Students can receive more information on the destination countries and the services involving transfer by contacting privacy@polimoda.com.

If the student applies to take part in international exchanges, they will receive a specific policy statement to highlight the relevant transfer of personal data abroad.

Data Subject’s rights

In your capacity of data subject, you will be guaranteed all the rights specified in art. 15-20 GDPR. It is possible to request:

  • the correction of personal data in our possession if these are not correct;
  • the deletion of personal data;
  • the limitation of our data processing activities;
  • if processing is based on consent, to revoke this consent, without compromising the legitimacy of our consent-based processing before it is revoked;
  • to receive the personal data in our possession in a specific format;
  • to oppose one of our specific processing activities, for reasons connected to individual specific situations, if it is deemed that the impact is disproportionate to these rights.

The abovementioned rights can be used in writing by email, certified email, or fax, or by registered letter with recorded delivery to the headquarters of Polimoda at the following address:

Email: privacy@polimoda.com 

Certified email: direzione@pec.polimoda.biz 

Fax no.: +39 055 275020

Post: Via Curtatone n.1 - 50123 Florence.

It is also possible to make a complaint to the Privacy Authority (in the relevant section for complaints on the website www.garanteprivacy.it) if the processing is considered to be in breach of the GDPR or Italian law.

Note: regarding the right to portability, this does not apply to processing that is not automated and therefore to archives and/or hard copy registers; only data supplied by the Data Subject to the Data Controller and processed with the consent of this latter, or based on a contract signed with the Data Controller.

Note: if our treatment of personal data is based on your consent, or if your consent is subsequently withdrawn, we may not be able to supply all or some aspects of our services and/or this may influence the supply of these services.

The terms and methods used by the Data Controller to reply to those wishing to apply their rights with regard to their personal data are set at 1 month, which can be extended to three (3) in particularly complex circumstances, without prejudice to the obligation to reply no more than 1 month from the request, even in the event that this is denied.

Occasional Contacts Privacy Policy

This policy statement describes the standard processing carried out by Polimoda on the personal data in order to respond to the request for information, questions or any other kind of request made by its forms.
Data collected from you will be processed according to the following principles: lawfulness, fairness and transparency; purpose limitation; data minimization; accuracy; storage limitation; integrity and confidentiality. 
 
1. Data Controller
 
The Data Controller is  Ente per le Arti Applicate alla Moda e al Costume, hereinafter referred to  as “Polimoda” having its registered office in Villa Favard, Via Curtatone n.1, Florence
Certified email direzione@pec.polimoda.biz; Standard email: privacy@polimoda.com
 
2. Type of personal data we may collect
 
Your name and contact information (such as address, email address and telephone number, as well as your date of birth, national insurance number, or other tax identification number, passport number or national identity card details, country of domicile and nationality, your image - picture and/or video).
Information related to your education and/or employment history and professional profile. We will also keep records on your interaction with the University and your preferences.
 
3. Modality of the Treatment
 
The personal data is processed either in paper or electronic format. In the latter case, automatic instruments will be used. The data will be kept strictly for the time and scope for which they were collected. Specific security measures are adopted for preventing data breaches, illicit or non correct uses and non-authorized access.
 
4. Purposes of Data Processing and legal basis
 
The processing of your information (also by electronic or automated means) are carried out in the performance of the institutional tasks of Polimoda. Please note that this privacy policy shall apply as long as you do not enter in another relationship with the University.
The personal data may be processed for the following purposes:
a) to respond to your particular queries and the usage of requested services
b) for providing you with information related to similar services to those requested, in line with the preferences and interests as shown, institutional communications and retargeting purposes
c) for security and internal organization purposes
d) for research and statistical purposes
e) with your consent, for sending of newsletters in hard copy and/or electronic format with content concerning Polimoda’s educational offer and services
 
Polimoda may process your personal data because it is necessary for responding to a particular request from you, for its legitimate interests, because there is a legal obligation or because you have expressed consent.
Please note that the following data are not subject to consent: data processed for security and internal organization purposes; data for the usage of available academic goods and services; data processing institutional tasks of the University as well as the performance of activities and communications related to products and services where the individual has shown particular interest;  data processing for the compliance of legal obligations.
 
5. Data communication
 
Data may be accessed by employees and collaborators of Polimoda, for the purpose of supplying the services requested and limited to information that is instrumental and connected to same.
Moreover, the Data Controller will share the Data Subject’s information to some suppliers for the purpose of providing specific services as requested; for this purpose, these suppliers are named “Processors”.  The access of data is always linked to the purposes pointed out previously.
 
6.  International data transfer
 
The subject’s personal data may be transferred abroad for the provision of certain services; in these cases, transfers are based on decisions of suitability or on the standard clauses of the European Commission
 
7.  Data Subject's Rights 
 
As data subject, you have the following rights:
- to require us to correct the personal data we hold about you if it is incorrect;
- to require us to erase your personal data;
- to require us to restrict our data processing activities (and, where our processing is based on your consent, you may withdraw that consent without affecting the lawfulness of our processing based on consent before its withdrawal);
- to receive from us the personal data we hold about you which you have provided to us in a reasonable format specified by you including the purpose of your transmittal to another data controller;
- to object, on grounds related to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights.
 
Please note that the above rights are not absolute and we may be entitled to refuse requests where exceptions apply.
If you have given your consent and you wish to withdraw it, please contact the responsible of the relevant department using the contact details set out below. Please
note that where our processing of your personal data relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of our services to you and/or it may affect the provision of those services.
 
8.  Contact us
 
If you have any queries about this privacy notice or how we process your personal data, you can contact our Data Protection Officer at the following e-mail address: privacy@polimoda.com.

Privacy Policy and photo-video Disclaimer

This policy statement describes the standard processing carried out by Polimoda on the personal data of individuals visiting or interacting with the internal website platform, for virtual events (Event) promoted by Polimoda, as Data Controller.

For the purpose of the GDPR

  • Data Subject is the natural person to whom personal data refers
  • The controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of the personal data (The data Controller is the Ente per le Arti Applicate alla Moda e al Costume, known as "Polimoda", with headquarters at Villa Favard, Via Curtatone n.1, Florence. Certified email direzione@pec.polimoda.biz; standard email: privacy@polimoda.com)
  • A processor is a natural or legal person who processes personal data on behalf of the controller (Polimoda has appointed "Cantiere Creativo s.r.l." as a Data processor on its website).

Purpose of data processing and legal basis

The treatment of personal data is based on your consent, which is free and optional, but also necessary for the performance of the service requested; denying to provide it, makes Polimoda not able to supply all or some aspects of its services.

Processing is required:

  • to provide the services requested (e.g. registration to the Platform, application to participate in the Events, virtual visits, live broadcasts, workshops, access to the Meeting rooms, interaction with other participants, and persons in charge of the service, webinar, videoconferences...)
  • to respond to your particular queries and the usage of the services on the site;
  • to perform all the administrative and organizational activities related to these services;
  • for the compliance with contractual and legal obligations;
  • for the performance of Polimoda’s institutional tasks as well as the performance of activities and communications related to Polimoda’s products and services: this will also include sending multimedia aids, circulation of periodical publications (soft spam) from Polimoda or third parties in so far as Partner of the Event, for services in line with the preferences and the choice you make with regard to the Event. It is intended that you may always object to the processing by simply contacting the DPO (Data Protection Officer) at the address at the end of this notice.

The data you provide may also be processed to analyze your interests and preferences within the activities promoted by Polimoda, in order to provide targeted communications, focused on the interests you have shown, and for improving our services.

The described processing is lawful in so far as the following applies:

  • free and express consent (art.6.1. a GDPR);
  • it is necessary for responding to a particular request of service from you, to interact with you, to deal with any concerns or feedback you may have (art. 6.1. b GDPR);
  • it is necessary to comply with a legal obligation (art. 6.1.c GDPR);
  • it is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, believing that such interests are not overridden by your interests or fundamental rights (art 6.1. f GDPR, art. 130, D.lgs 196/2003) in that related products and services that objectively might be of professional interest or in line with the preferences expressed. Your consent can be freely withdrawn, in any case.

Type of personal data processed

We may collect the following types of personal data about you:

  • the contact information you input in open text fields in help/contact us forms of our websites: your name, address, email address and telephone number, as well as your date of birth, tax identification number and your passport number or national identity card details, country of domicile, nationality, bank data;
  • information related to your education and employment history and your professional profile. We will also keep records on your interaction with Polimoda and your preferences;
  • information passively collected during your visit to our websites that may include navigational data and device information (like IP address, hardware model, operating and mobile network information);

We can process specific data (information relating to your health or your personal situation, art 9.1 GDPR) only if expressly requested by you in order to provide personalized assistance. 

Your data can only be accessed by employees and collaborators of Polimoda to supply the services requested and limited to information that is instrumental and connected to the same. 

Moreover, Polimoda will share your information with some suppliers to provide specific services, these suppliers are named "Processors" (their list is constantly updated and available on request by contacting the address below or sending an e-mail to privacy@polimoda.com).

In all other cases, Polimoda as Data Controller will not communicate personal information to other parties without your consent, unless this is required by law or a public authority.

Data recorded on web-Platform will not be disseminated or disclosed to third parties without your expressed consent.

With reference to personal images, please refer to the following special article. 

Modality of treatment

Personal data is processed either in paper or electronic format. In the latter case, automatic instruments will be used.

The Data will be kept strictly for the time and scope for which they were collected, except data for which retention is required by law or accounting or for taxation purposes, or to safeguard the entity, which is set at 10 years by law.

Images and films used will be stored for as long as the institutional aims are in place.

Images and films that are processed based on consent will be retained until the withdrawal of consent, in which case, your distinguishing features will be obscured or deleted.

Specific security measures are adopted for preventing data breaches, illicit or incorrect use, and unauthorized access.

Use of the services offered by the web application

As this processing is required to allow the registration in the web-Platform and related services provided (Events, including virtual visits, live broadcasts, workshops, access to the Meeting rooms, interaction with other participants and the persons in charge of the service, live chats, videoconferences) please note that browsing some areas inevitably makes visible some personal data (e.g. your name or image to other users online) as well as interacting with the reference persons for the Events (as above specified) allows them to view and acquire some data.

Processing of images

During the event, your user name and profile image may be displayed if some social network functions are used (e.g. by registering on-line with a Google account, Facebook account, Linkedin account, etc).

In addition, for the performance of Polimoda’s institutional tasks, as well as the performance of institutional communication campaigns, we can use video footage, pictures, and more materials about the Events which may accidentally include your personal image. The implementation of such activities is for informational and promotional purposes concerning the Events and can be promoted on media as well as social networks.

In no case are individual virtual meetings recorded. Your images will not be identified using full names or personal identifying information without prior written approval, except in the case you are logged into one of your social media accounts.

The abovementioned contents are protected and defended by current legislation on copyright and the use of images (RD 633/1941) as well as the GDPR. 

That said, as Data subject, having nothing to claim, you:

  • authorize Polimoda or any Data processor appointed by Polimoda, for the abovementioned legitimate purposes, to acquire pictures, video, audio recordings, and grant Polimoda – free of charge – the right to use those recordings for their dissemination and publication on its official communication channels and/or in any other form of publication aimed at promoting the Events; 
  • acknowledge and accept that Polimoda cannot be considered in any way responsible for any incorrect use of your images that anyone may make, waiving any claims against it;
  • declare to have read and agreed to the privacy policy and by ticking the box specifically approve the release and transfer of rights, under your own responsibility.

Data Subject’s rights

In your capacity of the data subject, you will be guaranteed all the rights specified in art. 15 - 20 GDPR. 

You have the right to:

  • obtain access to your personal data;
  • rectify inaccurate personal data;
  • have personal data erased without undue delay if none of the grounds indicated in art. 17 applies;
  • restrict the processing of your personal data under the condition laid down in art. 18;
  • the portability, in a specific format, of your personal data that is in Polimoda's possession;
  • withdraw your consent, without compromising the legitimacy of the consent-based processing before your consent is revoked;
  • oppose one of our specific processing activities, for reasons connected to individual specific situations, if it is deemed that the impact is disproportionate to your rights;

In any case, you shall have the right to complain to the supervisory national Authority, through the apposite form on the website (http://www.garanteprivacy.it/).

The abovementioned rights can be exercised in writing by email, certified email, or fax, or by registered letter with recorded delivery to the headquarters of Polimoda at the following address:

Email: privacy@polimoda.com 

Certified email: direzione@pec.polimoda.biz 

Fax no.: +39 055275020

Post: Via Curtatone n.1 - 50123 Florence