Privacy Policy

Privacy policies

PRIVACY POLICY STUDENTS AND CANDIDATES

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.

1. 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;

2. Type of personal data processed:

I) 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.

 

II) 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).

III) 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.

VI) specific personal data: information on health

E.g.: to manage medical certificates for absences, insurance practices, etc.

3.     Purpose of data processing and legal basis

I) 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.

II) 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.

III) 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.

IV) 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

- 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

- 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

Processing is subject to consent

- creation of web/social media pages or published products for the dissemination and distribution of these activities

Processing is subject to consent

- promotional activities, enquiries linked to market research initiatives;

Processing is subject to consent

V) internal security and organisational 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 organisation.

VI) registration and participation in competitions, scholarships, competitions

Processing is based on contract or consent.

VII) 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

VIII) 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.

4.     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 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 programmes 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 programmes, etc.
5. 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 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 processing or to cancel or delete consent.
6. 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.
7. 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 055275020
Post: Via Curtatone n.1 - 50123 Florence.

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.

 

 

 

 

 

 

 

 

 

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 processing is considered to be in breach of the GDPR or Italian law.

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.

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 Officer: rpd@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: 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; 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

Data Protection Officer: rpd@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 Florenc

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

PRIVACY POLICY LIBRARY

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 vis ited 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). With this document, we inform you that, to:

provide the services you request, access to the Polimoda Library and the use of related services and materials establish and execute contractual relations with you, including in the future, provide information, including of a promotional nature (compliant with the applicable regulations) we need to acquire data concerning you;

such data are considered “personal data” by GDPR no. 679/2016.

This standard sets down that those subjects obliged to comply with the prescriptions it contains and who process personal data are obliged to inform the data subject – notwithstanding simplifications in legislation – of the elements relating to the processing operations: the policy statement must, to safeguard your privacy and your rights, be concise, transparent, intelligible and easily accessible (therefore, reference should be made to the summary document on the cover).

Pursuant to this article, we are providing you with the following information, in line with the principles of correct management of personal data. We must inform you that this document will be integrated with an approach to icons after they have been agreed unequivocally and at European level.

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 information of the Responsible of the protection of personal data (RPD o DPO – Data Protection Officer) The Association Polimoda, having carried out the relevant assessments, has identified a person to be responsible for the protection of personal data (DPO – Data Protection Officer), who can be contacted at rpd@polimoda.com.

The Data Processors

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

Common data: name and surname telephone number mobile number residence/domicile address e-mail gender place and date of birth educational qualification 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. Source of data Personal data processed by us are collected/received directly or by third party institutions that collaborate with Polimoda and require subscription for access to the Library for the benefit of their staff/students etc. Conditions for processing The conditions for data processing (without prejudice to the standards and regulations to which the data controller is subject), are as follows:

Request for access to the Polimoda Library in order to access related services, with permission to consult the materials exclusively on site; Regulation / Guidelines relating to access to the Library and to the use of the relative hard-copy and electronic materials; Regulatory and/or legislative provisions specific to the sector of which Polimoda is a part;

Applications/Request from the data subject

Purposes of the processing Standard purposes (consent necessary)

Purposes related to the use of your data for access to the services offered by the Polimoda Library and other ancillary activities related to and/or in support of these services, which are, purely by way of example and not limited to: use of the Library’s resources and of the materials in general in the Library and available for consultation;

insertion of data in a database dedicated to monitoring the above-mentioned library resources and any other materials;

the possibility of being contacted by Polimoda through IT tools (see email) and/or by telephone to check the movement of resources and materials mentioned herein (recalling that for external users it is not permitted to take any materials home for consultation) without prejudice to the Regulation / Guidelines governing the use of the Library services.

Purposes – in case of donation of volumes and/or other materials – inherent to the acquisition and assessment of the volumes and/or other materials donated, in order to manage subsequent communications that might prove to be appropriate or necessary though the use of references supplied by you. Purposes connected to receiving and monitoring the payment related to your access to and use of the services;

Purposes connected and instrumental to the fulfilment of the obligations established by agreements, also of contractual nature, by laws, regulations and/or by the European legislation; 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;

Purposes related and instrumental to the management of the contractual relationship (which is embodied in the acceptance of your request to access the Polimoda Library) stipulated or in the process of definition and the relative obligations.

Promotional purposes and similar (optional consensus)

Marketing Details 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 Profiling

No automatic profiling activities are implemented with regard to the Library’s patrons (generally, to natural persons) for the purpose of analysing or forecasting areas that will concern professional performance, economic status, health, personal preferences or interests, reliability or behaviour, or the location and movements of the data subject to the extent that this would allow the data subject’s profile to be mapped, with resulting targeted – and mainly promotional – actions towards you.

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 your 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. 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.

Provisions 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; 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

Your data in general can be communicated by us, by which we mean notifying specific subjects or be hosted on third-party servers, located in the territory of the European Union and /or outside of the European Union, which Polimoda uses for the development and implementation of various services with the following terms:

Polimoda employees and assimilated workers operating under its authority (administrative personnel, etc.) and duly trained, monitored and instructed by the data controller and in particular to the personnel responsible for the management and supervision of the Library, limited to the requirements of related communications (name and email address and/or phone number and any other means of contact you have 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 individuals/parties who may access the data according to provisions of law, regulations or European Union legislation, within the limits established by these regulations;

to individuals/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 to subjects who need to access the data for purposes strictly linked to administering your request to access the Library and/or donate materials to the Library, within the limits strictly necessary to perform the related tasks (public safety subjects and other public or private subjects for the performance of legal obligations foreseen by the law including administrative and other obligations);

to external consultants such as lawyers, accountants, business consultants, trade associations, etc.; to third parties that carry out or provide specific services instrumental to the performance of the relationship with you; to individuals/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; 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 S.r.l. with registered offices in Milan, Via Merano, 16);

to web administrators of the newsletter platform service to other subjects/hosting providers/suppliers of technical services who carry out, on our own behalf, tasks of a technical and/or organizational nature instrumental to the provision of the services required or 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 S.p.a., Via della Piovola 138, – 50053 Empoli – FI), as well as to any third party in various capacities involved in the related activities;

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.

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.: up to 10 years based on different criteria according to the nature of the data subject based on specific criteria according to the purpose for which the data are processed 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.

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).

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.

You can exercise your rights by contacting

Polimoda

E-mail: privacy@polimoda.com

Data Protection Officer: rpd@polimoda.com

Registered offices: Via Curtatone n. 1, 50123 Firenze

Telephone number: +39 055 275061 Fax: +39 055 275020