INFORMATION ON THE PROCESSING OF PERSONAL DATA PURSUANT TO ART. 13 OF REGULATION (EU) 2016/679DF SRL, Via Madre Teresa di Calcutta 22, 70022 ALTAMURA (BA), VAT Number 07979890725, Tax Code 07979890725, as Data Controller (hereinafter: “DEAGOR” or “Controller”), pursuant to Regulation EU 2016/679 (hereinafter: “Regulation”) – considers privacy and the protection of Personal Data as one of the main objectives of its activity. Therefore, before transmitting any personal data to the Controller, we invite you to carefully read this Information: it contains important information on the processing of your Personal Data.
“Personal Data” means any information relating to an identified or identifiable natural person (“data subject”); a natural person is considered identifiable who can be identified, directly or indirectly, with particular reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.
This Information:
The Controller can be contacted at: [email protected]. The Controller has not, at present, formally appointed a Data Protection Officer pursuant to art. 37 of Regulation EU 2016/679, as it does not fall within the mandatory cases.
This document has been drafted pursuant to art. 13 of Regulation EU 2016/679 (hereinafter: “Regulation”) to allow you to know our privacy policy, understand how your personal information is processed when you use our sites (https://www.deagor.io/, hereinafter collectively referred to as “Site”) and, if applicable, to give consent to the processing of your Personal Data freely and consciously. The information and data you provide or otherwise acquired in the context of the use of DEAGOR services, – such as participation in events or training courses or subscription to the Magazine or newsletter – hereinafter “Services” -, will be processed in compliance with the provisions of the Regulation and the confidentiality obligations that inspire the activity of LOPERA.
According to the rules of the Regulation, the processing carried out by DEAGOR will be based on the principles of lawfulness, fairness, transparency, purpose limitation and storage, data minimization, accuracy, integrity and confidentiality.
The data controller of personal data is DF SRL (hereinafter “DF” or “DEAGOR”), Via Madre Teresa di Calcutta 22, 70022 ALTAMURA (BA), VAT Number 07979890725, Tax Code 07979890725, reachable at the email address [email protected].
Following the navigation of the Site, we inform you that DEAGOR will process your Personal Data which may consist of an identifier such as a name, an identification number, an online identifier or one or more factors specific to your physical, economic, cultural or social identity suitable to render the data subject identified or identifiable.
Other Personal Data provided by you freely in the information request forms (for example to obtain information on courses or for course registration requests) may be processed. Any sensitive data, as per art. 9.1 Reg. 2016/679/EU, should not be processed unless explicit consent is given by the data subject.
The computer systems and software procedures used to operate the Site acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified data subjects, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of the computers used by users who connect to the Site, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and computer environment. These data are used only to obtain anonymous statistical information on the use of the Site and to check its correct functioning, to identify anomalies and/or abuse, and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site or third parties: except for this possibility, the data on web contacts do not persist for more than seven days.
We may process personal and/or contact data such as name, surname, email and phone. Data related to educational qualifications and education contained in curricula. Data and metadata related to courses and training services, including test and exam results and related information on date, time and mode of use of training services and/or execution of tests. Data related to payments and other banking information, for example contained in payment receipts for course registration fees. Data related to the identifier of the compiler of the comic strip information generator.
If you communicate to DEAGOR Personal Data of third parties, you must ensure – assuming all responsibility – that this particular hypothesis of processing is based on an appropriate legal basis pursuant to art. 6 of the Regulation, which legitimizes the communication to DEAGOR and the related processing of the information in question.
The data processing we intend to carry out may have the following purposes:
The legal basis for the processing of Personal Data for the purposes referred to in section 3(a-b) is art. 6.1.b) of the Regulation as the processing is necessary for the provision of the Services or for the response to requests from the data subject. The provision of Personal Data for these purposes is optional but the failure to provide them would make it impossible to activate the Services provided by the Site.
For the processing falling within the statutory purposes of DEAGOR, included among those referred to in letter 3(a), data of members or subjects in regular contact with DEAGOR may be processed. If you have purchased services or goods from DEAGOR, your data may be processed for the purpose of direct sending of advertising material relating to DEAGOR products or services similar to those you purchased, without your consent (so-called “soft spam”). The processing of your data for these purposes is the legitimate interest referred to in art. 6.1.f) of the Regulation and referred to in art. 130 paragraph 4 of Legislative Decree 196/2003. In any case, pursuant to art. 21 of the Regulation, you have the possibility to oppose such processing at any time, initially or on the occasion of subsequent communications, in an easy and free manner also by writing to the Controller at the above contacts, as well as to obtain an immediate response confirming the cessation of such processing (art. 15 of the Regulation).
The purpose referred to in section 3(c) represents a processing of Personal Data carried out pursuant to art. 6.1.c) of the Regulation, for compliance with a legal obligation. Once the Personal Data has been provided, the processing is indeed necessary to comply with a legal obligation to which DEAGOR is subject. The processing for the purposes referred to in section 3(d) would be carried out pursuant to art. 6.1.f) of the Regulation.
Your Personal Data may be shared, for the purposes referred to in section 3 above, with:
The Personal Data processed for the purposes referred to in section 3(a-d) will be retained for the time strictly necessary to achieve those same purposes in compliance with the principles of minimization and storage limitation pursuant to art. 5.1.e) of the Regulation.
More information regarding the data retention period and the criteria used to determine this period can be requested by writing to the Controller.
In case, for the use of training services, platforms such as Facebook Workplace or Zoom are used, for live streaming of lessons and/or sharing of informational materials, it is noted that this use of services may necessarily involve the export of the data subject’s data (identification data, contact data, data and metadata relating to the days, times and contents of the training sessions) outside the territory of the European Union that requires such service. This transfer takes place on the basis of the derogation referred to in Article 49 paragraph 1 letter b) of the Regulation, as the transfer is occasionally necessary for the execution of the training service contracted by the data subject with the Data Controller.
Pursuant to Articles 15 and following of the Regulation, you have the right to request at any time, access to your Personal Data, rectification or deletion of the same, limitation of processing in the cases provided for by art. 18 of the Regulation, to obtain in a structured, commonly used and machine-readable format the data concerning you, in the cases provided for by art. 20 of the Regulation. At any time, you can revoke pursuant to art. 7 of the Regulation the consent given; lodge a complaint with the competent supervisory authority pursuant to article 77 of the Regulation (Data Protection Authority WWW.GARANTEPRIVACY.IT) pursuant to art. 77 of the Regulation, if you believe that the processing of your data is contrary to the law in force.
You can formulate a request to object to the processing of your data pursuant to article 21 of the Regulation in which to give evidence of the reasons justifying the opposition: the Controller reserves the right to evaluate the request, which would not be accepted in case of existence of compelling legitimate grounds to proceed with the processing that prevail over your interests, rights and freedoms.
Requests must be addressed in writing to the Controller.
This privacy policy is effective from January 1, 2020. DEAGOR reserves the right to modify or simply update its content, in part or completely, also due to changes in the applicable legislation. DEAGOR will inform you of such changes as soon as they are introduced and they will be binding as soon as they are published on the Site. DEAGOR therefore invites you to regularly visit this section to become aware of the most recent and updated version of the privacy policy so as to always be updated on the data collected and the use that DEAGOR makes of it.
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