Privacy Policy of Svoltastudenti APS ETS

This Website collects some Personal Data from its Users.

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Data Controller

Svoltastudenti – APS ETSVia Marco Aurelio 8, 20127 MilanoCF: 97567800152VAT: 07382300965

Controller’s email address: contact@svoltastudenti.it

Types of Data collected

Among the Personal Data collected by this Website, independently or through third parties, are: Cookies; phone number; email; first name; last name; Usage Data; question responses; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Data communicated while using the service.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the Data collection.Personal Data may be freely provided by the User or, in the case of Usage Data, automatically collected during the use of this Website.Unless otherwise specified, all Data requested by this Website is mandatory. If the User refuses to communicate them, it might be impossible for this Website to provide the Service. In cases where this Website indicates some Data as optional, Users are free to abstain from communicating such Data, without this having any consequence on the availability of the Service or its operation.Users who may have doubts about which Data is mandatory are encouraged to contact the Controller.Any use of Cookies – or other tracking tools – by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service requested by the User, in addition to any other purposes described in this document and in the Cookie Policy.

The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through this Website.

Methods and place of processing the collected Data

Processing methods

The Controller adopts appropriate security measures aimed at preventing unauthorized access, disclosure, modification, or destruction of Personal Data.Processing is carried out using computer and/or telematic tools, with organizational methods and logics strictly related to the indicated purposes. In addition to the Controller, in some cases, other subjects involved in the organization of this Website (administrative, commercial, marketing, legal personnel, system administrators) or external subjects (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) appointed, if necessary, as Data Processors by the Controller may have access to the Data. The updated list of Processors can always be requested from the Controller.

Place

Data is processed at the Controller’s operating offices and in any other place where the parties involved in the processing are located. For further information, please contact the Controller.The User’s Personal Data may be transferred to a country other than the one in which the User is located. For further information on the place of processing, the User can refer to the section concerning details on the processing of Personal Data.

Storage period

Unless otherwise specified in this document, Personal Data is processed and stored for the time required by the purpose for which it was collected and may be stored for a longer period due to any legal obligations or based on Users’ consent.

Purpose of Processing the collected Data

The User’s Data is collected to allow the Controller to provide the Service, comply with legal obligations, respond to enforcement requests, protect its rights and interests (or those of Users or third parties), identify possible malicious or fraudulent activities, as well as for the following purposes: Optimization and traffic distribution, Contacting the User, Advertising, Displaying content from external platforms, SPAM protection, Hosting and backend infrastructure, and Managing contacts and sending messages.

To obtain detailed information on the purposes of processing and on the Personal Data processed for each purpose, the User can refer to the section “Details on the processing of Personal Data”.

Details on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Contacting the User

Phone contact (this Website)

Users who have provided their phone number may be contacted for commercial or promotional purposes related to this Website, as well as to satisfy support requests.

Personal Data processed: phone number.

Category of Personal Information collected according to CCPA: identifiers.

This type of processing constitutes:

Contact form (this Website)

By filling in the contact form with their Data, the User consents to their use to respond to information requests, quotes, or any other nature indicated by the form’s header.

Personal Data processed: last name; email; first name; phone number.

Category of Personal Information collected according to CCPA: identifiers.

This type of processing constitutes:

Contact management and message sending

This type of service allows managing an email contact database, phone contacts, or contacts of any other type, used to communicate with the User. These services might also allow collecting data relating to the date and time when messages are viewed by the User, as well as when the User interacts with them, such as clicking on links inserted in messages.

SendinBlue Email (SendinBlue SAS)

SendinBlue is an address management and email message sending service provided by SendinBlue SAS.

Personal Data processed: Usage Data; email; Tracking Tools.

Place of processing: France – Privacy Policy.

Category of Personal Information collected according to CCPA: identifiers; internet or other network activity information.

This type of processing constitutes:

Hosting and backend infrastructure

This type of service has the function of hosting Data and files that allow this Website to function, allow its distribution, and provide a ready-to-use infrastructure to deliver specific functionalities of this Website.

Some services among those listed below, if present, may work on geographically distributed servers, making it difficult to determine the actual location where Personal Data is stored.

iubenda Consent Solution (iubenda srl)

The Consent Solution offered by iubenda allows storing and consulting records relating to consent and preferences expressed by end Users regarding the processing of their Personal Data.

Personal Data processed: Data communicated during service use; Tracking Tool.

Place of processing: Italy – Privacy Policy.

Category of Personal Information collected according to CCPA: internet or other network activity information.

This type of processing constitutes:

Traffic optimization and distribution

This type of service allows this Website to distribute its content through servers located throughout the territory and optimize its performance. The Personal Data processed depends on the characteristics and implementation method of these services, which by their nature filter communications between this Website and the User’s browser. Given the distributed nature of this system, it is difficult to determine the places where content is transferred, which could contain User’s Personal Data.

Cloudflare (Cloudflare Inc.)

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc. The way Cloudflare is integrated means that it filters all the traffic through this Website, i.e., communication between this Website and the User’s browser, while also allowing the collection of statistical data about it.

Personal Data processed: Cookies; various types of Data as specified in the service’s privacy policy.

Place of processing: United States – Privacy Policy.

Category of Personal Information collected according to CCPA: internet or other network activity information.

This type of processing constitutes:

• a Sale in California

SPAM protection

This type of service analyzes the traffic of this Website, potentially containing Users’ Personal Data, in order to filter it from parts of traffic, messages, and content that are recognized as SPAM.

Google reCAPTCHA (Google LLC)

Google reCAPTCHA is a SPAM protection service provided by Google LLC. The use of the reCAPTCHA system is subject to Google’s privacy policy and terms of use.

For an understanding of Google’s use of data, please consult Google’s partner policy.

Personal Data processed: clicks; Usage Data; keypress events; motion sensor events; touch events; mouse movements; scroll position; question responses; Tracking Tool.

Place of processing: United States – Privacy Policy.

Category of Personal Information collected according to CCPA: internet or other network activity information; inferences drawn from other personal information.

This type of processing constitutes:

Advertising

This type of service allows using User Data for commercial communication purposes. These communications are displayed on this Website in the form of banners and other advertisements, including in relation to the User’s interests. This does not mean that all Personal Data is used for this purpose. Data and conditions of use are indicated below. Some of the services listed below may use Tracking Tools to identify the User or use the behavioral retargeting technique, i.e., displaying personalized advertisements based on the User’s interests and behavior, including those detected outside this Website. For more information about this, we suggest checking the privacy policies of the respective services. Generally, these types of services offer the possibility to opt out of such tracking. In addition to any opt-out function provided by any of the services listed in this document, Users can learn more about how to disable interest-based advertising in the dedicated section “How to disable interest-based advertising” in this document.

Direct Email Marketing (DEM) (this Website)

This Website uses User Data to send commercial proposals related to services and products provided by third parties or unrelated to the product or service provided by this Website.

Personal Data processed: last name; email; first name.

Category of Personal Information collected according to CCPA: identifiers.

This type of processing constitutes:

• a Sale in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, and Montana
• a Share in California

Display of content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Google Fonts (Google LLC)

Google Fonts is a font style visualization service managed by Google LLC that allows this Website to integrate such content within its pages.

Personal Data processed: Usage Data; Tracking Tool.

Place of processing: United States – Privacy Policy.

Category of Personal Information collected according to CCPA: internet or other network activity information.

This type of processing constitutes:

• a Sale in California

Information about how to disable interest-based advertising

In addition to any opt-out function provided by any of the services listed in this document, Users can learn more about how to disable interest-based advertising in the dedicated section of the Cookie Policy.

Additional information on Personal Data processing

Personal Data collected through sources other than the User

The Controller of this Website may have legitimately collected Personal Data relating to the User without their involvement, drawing from sources provided by third parties, in accordance with the legal bases described in the section relating to the legal bases of processing. Should the Controller have collected Personal Data in this way, the User can find specific information regarding the sources in the respective sections of this document or by contacting the Controller.

User identification through universal unique identifier (UUID)

This Website may track Users by saving the so-called “universal unique identifier” (UUID) for statistical analysis purposes or to store Users’ preferences. This identifier is generated upon installation of this Application, is not canceled when the Application is closed or updated, but is permanently removed only if the User decides to uninstall the Application from their device. If the application is reinstalled, a new UUID is generated.

Unique device identification

This Website may track Users by saving a unique identification code of their device, for statistical purposes or to store Users’ preferences.

Online sale of goods and services

The Personal Data collected are used for the provision of services to the User or for the sale of products, including payment and possible delivery. The Personal Data collected to complete the payment may be those related to the credit card, the bank account used for the transfer, or other payment instruments provided. The payment Data collected by this Website depends on the payment system used.

Cookie Policy

This Website makes use of Tracking Tools. To learn more, Users can consult the Cookie Policy.

Additional information for Users

Legal basis of processing

The Controller processes Personal Data relating to the User if one of the following conditions exists:

• the User has given consent for one or more specific purposes;
• processing is necessary for the execution of a contract with the User and/or for the execution of pre-contractual measures;
• processing is necessary to fulfill a legal obligation to which the Controller is subject;
• processing is necessary for the performance of a task carried out in the public interest or for the exercise of public powers vested in the Controller;
• processing is necessary for the pursuit of the legitimate interest of the Controller or third parties.

It is always possible to request the Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on law, provided for by a contract, or necessary to conclude a contract.

Additional information on storage time

Unless otherwise specified in this document, Personal Data is processed and stored for the time required by the purpose for which it was collected and may be stored for a longer period due to any legal obligations or based on Users’ consent.

Therefore:

• Personal Data collected for purposes related to the execution of a contract between the Controller and the User will be retained until such contract has been fully executed.
• Personal Data collected for purposes related to the legitimate interest of the Controller will be retained until such interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the Controller.

When processing is based on the User’s consent, the Controller may keep Personal Data longer until such consent is revoked. Furthermore, the Controller may be obliged to keep Personal Data for a longer period to comply with a legal obligation or by order of an authority. At the end of the retention period, Personal Data will be deleted. Therefore, at the expiration of this term, the right of access, deletion, rectification, and the right to data portability can no longer be exercised.

User rights based on the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding Data processed by the Controller.

In particular, within the limits provided by law, the User has the right to:

• withdraw consent at any time. The User can withdraw consent to the processing of their Personal Data previously expressed.
• object to processing of their Data. The User can object to the processing of their Data when it occurs on a legal basis other than consent.
• access their Data. The User has the right to obtain information about the Data processed by the Controller, about certain aspects of the processing and to receive a copy of the Data processed.
• verify and request rectification. The User can verify the accuracy of their Data and request its update or correction.
• obtain processing limitation. The User can request the limitation of the processing of their Data. In this case, the Controller will not process the Data for any other purpose than storing it.
• obtain the deletion or removal of their Personal Data. The User can request the deletion of their Data by the Controller.
• receive their Data or have it transferred to another controller. The User has the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to obtain its unhindered transfer to another controller.
• lodge a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or act in court.

Users have the right to obtain information regarding the legal basis for the transfer of Data abroad including to any international organization governed by international law or set up by two or more countries, such as the UN, as well as regarding the security measures adopted by the Controller to protect their Data.

Details on the right to object

When Personal Data is processed in the public interest, in the exercise of public powers vested in the Controller or to pursue a legitimate interest of the Controller, Users have the right to object to the processing for reasons connected to their particular situation.

Users are reminded that, should their Data be processed for direct marketing purposes, they can object to the processing at any time without providing any justification. If Users object to processing for direct marketing purposes, the Personal Data is no longer processed for such purposes. To find out whether the Controller processes Data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise rights

Any requests to exercise User rights can be directed to the Controller through the contact details provided in this document. The request is free and the Controller will respond in the shortest possible time, in any case within one month, providing the User with all information required by law. Any rectifications, deletions, or limitations of processing will be communicated by the Controller to each of the recipients, if any, to whom the Personal Data has been transmitted, unless this proves impossible or involves disproportionate effort. The Controller informs the User about these recipients if the User requests it.

Additional information for Users in Brazil

This section of the document supplements and completes the information contained in the rest of the privacy policy and is provided by the entity that operates this Website and, if applicable, its parent company and its subsidiaries and affiliates (for the purposes of this section collectively referred to as “we”, “us”, or “our”).This section applies to all Users in Brazil (such Users are referred to below simply as “you”, “your”, “yours”), according to the “Lei Geral de Proteção de Dados”, and for such Users prevails over any other possibly divergent or conflicting information contained in this privacy policy.In this part of the document, the term “personal information” is used as defined by the LGPD.

Legal bases under which we process your personal information

We process your personal information only if one of the legal bases for such processing exists. Legal bases are as follows:

• your consent to the processing activities in question;
• compliance with legal obligations that we are required to meet;
• the carrying out of rules set forth by laws or regulations or by contracts, agreements, or other similar legal instruments;
• studies conducted by research entities, preferably carried out on anonymized personal information;
• the execution of a contract and its preliminary procedures, in cases where you are a party to such contract;
• the exercise of our rights in judicial, administrative, or arbitration procedures;
• the protection of life or physical safety of you or a third party;
• the protection of health – in procedures carried out by health entities or professionals;
• our legitimate interest, provided that your fundamental rights and freedoms do not prevail over such interests; and
• the protection of credit.

To learn more about the legal bases, you can contact us at any time using the contact details provided in this document.

Categories of personal information processed

To learn which categories of personal information are processed, you can refer to the section “Details on the processing of Personal Data” present in this document.

Why we process your personal information

To learn why we process your personal information, refer to the sections “Details on the processing of Personal Data” and “Purposes of Processing collected Data” present in this document.

Your privacy rights in Brazil, how to submit a request and how we will handle it

Your privacy rights in Brazil

You have the right to:

• obtain confirmation of the existence of processing activities concerning your personal information;
• access your personal information;
• have your incomplete, inaccurate, or outdated personal information corrected;
• obtain the anonymization, blocking, or deletion of unnecessary or excessive personal information, or of information that is processed in non-compliance with the provisions of the LGPD;
• obtain information about the possibility to provide or deny your consent and about the consequences thereof;
• obtain information about the third parties with whom we share your personal information;
• obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
• obtain the deletion of personal information processed if the processing was based on your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
• revoke your consent at any time;
• lodge a complaint related to your personal information with the ANPD (National Data Protection Authority) or with consumer protection bodies;
• oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
• request clear and adequate information regarding the criteria and procedures used for an automated decision; and
• request the review of decisions that affect your interests, made solely on the basis of the automated processing of your personal information. These include decisions to establish your personal, professional, consumer, or credit profile or aspects of your personality.

You will never be discriminated against, or in any way subjected to any unfavorable treatment, due to the exercise of your rights.

How to submit a request

You can submit an explicit request to exercise your rights free of charge, at any time, using the contact details provided in this document, or through your legal representative.

How and when we will handle your request

We will do our best to respond to your request in the shortest possible time.In any case, should it be impossible for us to do so, we will make sure to communicate to you the factual or legal reasons that prevent us from immediately or permanently fulfilling your request. In cases where your personal information is not processed by us, if we are able to do so, we will indicate to whom you should address your request.

In the event that you file an access request or a request for confirmation of the existence of personal information processing, please make sure to specify whether you prefer to receive your personal information in electronic or printed form.You will also need to let us know if you want an immediate response, in which case you will receive a simplified response, or if you need a complete disclosure.In the latter case, we will respond within 15 days from the time of your request, providing you with all information about the origin of your personal information, confirmation of whether or not we have your personal information, any criteria used for the processing and the purposes of such processing, while safeguarding our commercial and industrial secrets.

In the event that you file a request for rectification, deletion, anonymization or blocking of personal information, we will ensure we immediately notify of your request the other parties with whom we have shared your personal information so that they can also fulfill your request – except in cases where such communication proves impossible or involves disproportionate effort.

Transfer of personal information outside of Brazil in permitted cases

We may transfer your personal information outside of Brazilian territory in the following cases:

• when the transfer is necessary for international legal cooperation between public intelligence services, investigative and prosecutorial bodies, according to the international law instruments made available;
• when the transfer is necessary to protect your life or physical safety or those of a third party;
• when the transfer is authorized by the ANPD;
• when the transfer results from a commitment undertaken in an international cooperation agreement;
• when the transfer is necessary for the execution of a public policy or legal attribution of public service;
• when the transfer is necessary for compliance with a legal obligation, the execution of a contract and the respective pre-contractual procedures, or the regular exercise of rights in judicial, administrative, or arbitration procedures.

Further information on the processing

Defense in court

The User’s Personal Data may be used by the Controller in court or in the preparatory stages for its possible establishment for the defense against abuse in the use of this Website or related Services by the User. The User declares to be aware that the Controller may be obliged to disclose the Data by order of public authorities.

Specific information

Upon request of the User, in addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System logs and maintenance

For operation and maintenance purposes, this Website and any third-party services it uses might collect system logs, which are files that record interactions and that may also contain Personal Data, such as the User’s IP address.

Information not contained in this policy

More information in relation to the processing of Personal Data may be requested at any time from the Controller using the contact details.

Changes to this privacy policy

The Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Website as well as, if technically and legally feasible, sending a notice to Users via any contact information available to the Controller. Please therefore consult this page regularly, referring to the date of last modification indicated at the bottom.Should the changes affect processing activities performed on the basis of the User’s consent, the Controller shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data) / Personal Information (or Information)

Any information that directly or indirectly, including in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Sensitive Personal Information

Sensitive Personal Information means all Personal Information that is not publicly available and that reveals information considered sensitive under applicable privacy law.

Usage Data

Information collected automatically through this Website (including by third-party applications integrated into this Website), including: the IP addresses or domain names of the computers used by Users who connect to this Website, the URI (Uniform Resource Identifier) addresses, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s response (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system used by the visitor, the various time details per visit (e.g., the time spent on each page) and the details about the path followed within the Application, with particular reference to the sequence of pages visited, to the parameters related to the operating system and the User’s IT environment.

User

The individual using this Website who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural or legal person, public authority, agency, or other body which processes personal data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Controller)

The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data and the tools adopted, including the security measures relating to the operation and use of this Website. The Data Controller, unless otherwise specified, is the owner of this Website.

This Website (or this Application)

The hardware or software tool through which the Personal Data of Users is collected and processed.

Service

The Service provided by this Website as defined in the relative terms (if available) on this site/application.

Sale

Sale means any exchange of Personal Information from the Owner to a third party in exchange for monetary or other valuable consideration, as defined by applicable US state privacy law. Please note that the exchange of Personal Information with a service provider under a written contract that meets the requirements established by the applicable law, does not constitute a Sale of your Personal Information.

Share

Share means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, of a consumer’s Personal Information by the business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged, as defined by California privacy laws. Please note that the exchange of Personal Information with a service provider under a written contract that meets the requirements established by California privacy laws, does not constitute a Share of your Personal Information.

Targeted Advertising

Targeted Advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across non-affiliated websites or online applications to predict such consumer’s preferences or interests, as defined by applicable US state privacy law.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are Tracking Tools consisting of small sets of data stored in the User’s browser.

Tracking Tool

Tracking Tool means any technology – e.g., Cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting – that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Legal references

This privacy policy is drawn up based on multiple legislative systems.

Unless otherwise specified, this privacy policy relates exclusively to this Website.