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PRIVACY POLICY (Art. 13 del d.lgs. 196/2003 - Codice della privacy Art. 13 del Regolamento Generale UE sulla protezione dei dati personali n. 679/2016) Francesca Romana Patrizi, based in Roma, Via Giovanni Maggi 75, P.IVA 15481271003, email: info@lit-school.com, phone numbers: +393405915833, (hereinafter referred to as “Manager”) manages, under the name L’IT – L’italiano per stranieri, Italian language for foreigners courses and training courses, as part of the activities of Italian language and culture school. The manager decides, as the order-holder in accordance with the law, the purpose and the tools for processing the personal data of the users-clients and, ultimately, is responsible for processing and protecting the data in compliance with the legal, national and Community provisions. The manager believes that data protection is a very serious matter and therefore wishes to communicate correctly, completely and transparently, as it proceeds on the personal data protection of its users-clients. When enrolling in an L’IT – L’italiano per stranieri course, a series of personal data are necessarily entrusted to the owner-manager. Personal data are all types of information that can be connected, directly or indirectly, with a natural person. These include, among other things, the name, the residence, the e-mail address, the telephone number, the profession. In addition, the IP address or any information on the use of a PC can also be considered as personal data under certain circumstances. The manager illustrates below the L’IT - L’italiano per stranieri customer (hereinafter referred to as the “customer”) how data are collected, for which purpose, and to whom such data can be transmitted. The manager collects personal data during the registration and use of the services offered by L’IT - L’italiano per stranieri. In order to show the user how his/her data are processed, the manager lists below the three ways in which the user’s personal data are collected. 1. Data communicated by the customer to the manager. When the customer registers for a L’IT – L’italiano per stranieri course, he/she communicates information about his/her person to the manager. The personal data in this category are communicated in an active way by the user, for example by completing the registration form, by contacting the school or by means of the feedback that the user communicates through functions specifically set up in computer. For the purpose of completing the correct procedure, the customer, at the specific time of registration provides, according to the L’IT – L’italiano per stranieri regulation, all the personal data requested in the registration form. 2. Data collected during the use of the school service. The data communicated are saved by the manager to identify the customer and to ensure the regular and optimal supply of the school services. The manager saves information when the customer contacts the manager in order to help the customer and better answer his questions, for example when the customer sends an e-mail to the school’s customer assistance. The manager can also use anonymous and aggregated data related to these requests for the improvement of services. During the use of the school services, the manager can gather additional information about the customer and about his activity in the context of the L’IT – L’italiano per stranieri services. These include: a. Contact details: the manager collects contact information such as name, age, residence address, email address, telephone number and any addresses associated with the customer’s account. The manager uses the contact details in order to communicate directly with the user about the services purchased and sold through the school and about questions or problems raised by the customers. b. Comments and opinions: When the customer directly contacts the manager, for example by e-mail, telephone, post or through an online form, the manager can register requests, comments and opinions. The manager will also record comments and opinions expressed by the user when responding to surveys, participating in promotions or posting in the message areas. The manager uses comments and opinions to answer questions, problems and issues raised by users and to improve, where possible, the services offered by L’IT – L’italiano per stranieri. c. Payment information and transactions: the manager records the products purchased or sold through L’IT – L’italiano per stranieri, who bought the service and the total amount of the transaction, in addition to the payment methods. d. Technical information about the device and the customer’s Internet connection. Using the server’s logs and other web tools, the operator, through his own website, can collect information on the device and internet connection of the customer, including the operating system, browser version, IP address, cookies and other unique identifiers. To analyze how the services of the manager are used, the technical information is generally processed as aggregated data. However, the aggregated data can also be linked to the costumer’s account to adapt L’IT’s services to the device used by the user. e. Information on the use of the L’IT – L’italiano per stranieri services. The manager can record the customer’s activities, for example login and logout from the user account on the L’IT – L’italiano per stranieri website, purchase of services and L’IT courses, attendance to courses electronically and on paper. The manager also saves information about the customers visits to the L’IT – L’italiano per stranieri website. The manager uses all this information, among other things, to prevent abuse and to improve L’IT’s services. f. Information on fraudulent or criminal activity related to an account: the manager uses information on fraudulent or criminal activities related to the use of the service in order to identify and prevent fraud or crimes and to promptly inform the competent authorities. g. All personal information and sensitive data: the manager uses all the personal information collected to implement, monitor and improve the school service, procedures and processes. The manager also uses the personal information collected to develop new products and services, to resolve disputes with users, to provide support to users, to solve problems and apply the correct terms of L’IT – L’italiano per stranieri regulation and policies, including that on privacy. PURPOSE OF THE DATA PROCESSING The manager process the customer data for the following purposes. Summary of the objectives: The manager processes the customer’s data for 1) to provide L’IT’s services and, therefore, on a contractual legal basis, with the primary purpose of satisfying the requests of the customer, from a purely commercial point of view; 2) to improve and further develop L’IT’s services, with constant attention to customer needs; 3) to know the trend of the reference market; 4) to prevent, stem and ascertain the possible abusive use of L’IT’s services, especially on the web platform. 1. Supply of services In order to offer their own educational services, based on the conclusion of a contract (legal basis of acquisition), the manager must acquire the customer’s personal data and information, as well as a limited set of sensitive data. 2. Improvement and development of L’IT’s services The manager uses information to improve the school services, for example by making the registration procedure on paper, the online registration, login or payment procedure as simple as possible for the customer. The manager transmits to the customer messages regarding upcoming changes or improvements of L’IT’s services, possibly using his/her e-mail address or through other notification. 3. Advertisement, offers and personalized advices The manager can put advertisements on his/her platform or collaborate in the promotion, advertising, and optimization of his own or third party advertisements with external partners. 4. Analysis of market trends The manager analyzes the data to better understand the trends and to adjust and continue to develop L’IT’s services. The analysis of trends can be performed by the manager himself or by third parties who, on behalf of the manager, process the data. Collaboration with third parties for data interpretation is based on data processing agreements in full respect of confidentiality and integrity. 5. Prevent and ascertain the abusive use of L’IT’s services The manager can use the information to prevent in any possible way the abusive use of the L’IT’s services, especially with regard to the web platform THIRD PARTIES USE OF DATA For all services that use social networking features, such as Facebook’s Like button or Instagram button, it should be noted that Facebook and other social network providers may collect data about the customer even if he/she is not registered on a page or if he/she has consented to the exchange of data. Through the use of popular features, such as the “Like button” of Facebook or the “Follow” of Instagram, providers of these services can obtain data on visits to certain pages or on the use of internet by the customer. Third parties to whom data have been transmitted may collect and use such data for the improvement of their services or for analysis purposes. The publication of data is only possible in aggregate form. TRANSMISSION OF PERSONAL DATA The manager will not share, sell, transfer or make personal data accessible in any way different from what is described in this data protection provision, unless the manager is called to do so by law or the customer has not given explicit authorization . The transmission of personal data is only possible for the following reasons: 1. Data transmission to third parties: The manager may possibly share personal data with digital-social platforms such as Facebook, Instagram, to which data are transmitted for the sole purpose of pursuing the business objectives of L’IT – L’italiano per stranieri, already indicated. The manager may transmit personal data to the police or other authorities if there is a suspicion of illegal behavior linked to the use of the L’IT – L’italiano per stranieri services and if there is a court order or a provision of the administrative authority. The disclosure of personal data to other third parties is possible if they can demonstrate a prevalent legal interest in determining the identity of a user and a certain illegal circumstance and if they are able to demonstrate that knowledge of such information constitutes an essential premise for the legal proceeding. The foregoing does not preclude the manager from using service providers who process data for the manager on the basis of a related service agreement. The service provider to whom personal data is transferred for processing (for example to make payments or to save information on your server) may process the data only for the purposes indicated in this provision and relating to the protection of data. CANCELLATION OF DATA AND ACCOUNT The user is authorized to have his data and his account deleted at any time and without any reasons. The request must be sent to the address info@lit-school.com With the cancellation of data and account, all personal and/or sensitive data are deleted. The manager reserves the right to keep personal data relating to a customer or a closed account. This may be due, among other things, to the application of the General Terms of Contract / regulation, in compliance with the provisions of law, to support investigations, to the implementation of current business or to the settlement of disputes. When the retention of personal data is no longer necessary for the manager, he will destroy them immediately. The manager informs all the recipients to whom the data have been transmitted the request for cancellation by the user, unless this is not impossible or involves a disproportionate expense. It should be remembered that the timely cancellation of search results in search engines cannot be guaranteed by the manager. If the customer, under the provisions of the law, uses the right to cancel, correct or delete, he / she is entitled to correct and / or cancel his / her personal data, at any time and without motivation; if the customer decides to withdraw his consent to the data protection provision, he/she may send a request to the manager indicated at the beginning of this document. The processing of the user’s request described in this point can take up to 8 weeks. LENGTH OF DATA PROTECTION The manager does not save personal data for a period longer than required for the fulfillment of the contractual and commercial purposes indicated above and in any case for a maximum amount of time equal to the permanence of the customer registration in the school. The personal data of the users are deleted and made anonymous when they are no longer relevant for the purposes indicated. The manager saves personal data until the user has been deleted or until the user has issued a declaration of revocation or until the data are required for the provision of the services of L’IT – L’italiano per stranieri or until there is a legal limitation of any kind. ACCESS AND RECTIFICATION OF PERSONAL DATA The customer has the following rights in relation to his personal information: (i) the right to be informed about how to use his personal data; (ii) the right to access the personal information that the L’IT – L’italiano per stranieri holds; and (iii) the right to request the correction of inaccurate personal data concerning him/her and to request the block, suspension of use or cancellation of his personal data at any time and without any reason or when processing is not in compliance to local and community data protection laws. FINAL ARRANGEMENTS 1. Change of data protection provision When the manager changes this data protection provision, the modified version is published with the date of the updated version. No explicit warning is sent to the modification of the data protection provision. It is necessary to periodically check that no changes have been made to the data protection provision. In the event that the customer does not agree with the changes, he / she will be free to request the cancellation of the registration or account or to revoke his authorization to the provision for data protection. 2. Liability The manager, by implementing all appropriate security measures according to the law, is not liable for unauthorized access to the user data, for example by hackers or system errors. 3. Applicable law Only Italian law applies. The exclusive court of jurisdiction is the court of Rome, Italy 4.Complaint The customer has the right, at any time, to lodge a complaint with the competent Authority, for the purposes of protection of his right to privacy, pursuant to Article 58 of the EU Regulation 679/2016 and according to the methods best described on the website of the Italian guarantor authority (www.garanteprivacy.it). 5. Safeguard clause In the event that individual provisions of this Data Protection Arrangement are ineffective or unenforceable, or become ineffective or unenforceable after conclusion of the contract, this will not compromise the effectiveness of the contract. The rule deemed invalid or unenforceable must be replaced by a valid and applicable one, which reflects as much as possible the economic purpose pursued by the contracting parties with the original rule which is not valid or not applicable. The above rules apply if the contract is not complete.