odX Education S.r.l., having its registered office in Via De Gasperi 20, 30035 Mirano (VE), Italy, VAT and tax code 04524970276 (hereinafter “odX” or the “Company”), hereby informs users visiting the website www.odxeducation.com (hereinafter the “Website“) of the policy adopted regarding personal data protection, underlining its commitment and attention for the protection of privacy of the users of the Website.
Visitors may browse the Website freely and are not obliged to register, except in certain areas of the same, in which the user can freely and expressly provide a series of personal data in order to access specific services. Therefore, where the users intends to provide their personal data in order to access those additional services, he will be expressly informed (pursuant to Article 13 of Regulation (EU) 2016/679 – “General Data Protection Regulation”) of the purposes and methods for and with which the data will be used by odX, as well as of the right to request, at any time, that the data provided are erased or updated.
The processing of data will be carried out in compliance with Regulation (EU) 2016/679 – General Data Protection Regulation (the “GDPR“) and Legislative Decree no. 196 of 30 June 2003 – Data Protection Code (the “Data Protection Code“).
- Data controller and contact details
odX Education S.r.l., having its registered office in Via De Gasperi 20, 30035 Mirano (VE), Italy, VAT and tax code 04524970276, tel. [*], e-mail [*], pec firstname.lastname@example.org, acts as data controller with regard to the personal data processed by the Website.
- Types of personal data processed
You do not need to be registered to access the Website. However, some sections in the Website do require you to register or use a username and password (e.g. to complete the on-line purchasing process). Here is an exemplification of the type of information we process:
- ID data: name, surname, date of birth, etc.;
- Contact details: residential address, e-mail address, phone number;
- Connection data: internet protocol (IP) address, device number/ID, data about your internet connection and service provider, the equipment you use to access the Websites, login data, your browsing history, and other usage and technical details;
- Purchase details and shopping habits: data relating to your purchases on the Websites (e.g. number, value and types of purchase), your interests, preferences;
- Commercial related data: credit card number, tax code, VAT, etc.;
The users are required to indicate only personal data relating to themselves on the Websites. If personal data of third parties is indicated, the users must expressly declare and recognise that they have obtained consent from third parties for processing of the corresponding personal data by the Company.
Data relating to Website connection and browsing (such as the addresses in the URI-Uniform Resource Identifier notation of the requested resources, the time of the request, the method used to submit 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-success, error, etc.- and other parameters related to the operating system and the user’s computer environment) is collected for the sole purpose of obtaining anonymous statistical information on the use of the Websites and improve it, as well as to monitor its correct functioning, and is deleted immediately after its processing.
Data may be used to ascertain responsibility in case of hypothetical cybercrimes to the detriment of the Website: with the exception of this possibility, the data will be deleted after the time necessary for the provision of the services outlined on the Website.
With reference to data relating to browsing within the Website, see also point 7 below regarding the profiling tools used by the Website.
- Purposes and legal basis for processing
The data are collected and processed for purposes strictly related to the usage of the Website and its services. The specific purposes for processing may be described in detail in specific privacy notices provided by the Website in all cases of data collection. Please read carefully the privacy notices which from time to time illustrate the characteristics of the processing that will be carried out by odX (e.g. to register to the Website, purchase content, etc.).
We collect your personal data in for various purposes related to the functioning of our Website or the execution of the services offered by odX, including, but not limited to:
- allow you to register an account with us or log in and make changes to your online account;
- purchase video contents (i.e. full courses, webinars) from us;
- allow you to receive marketing communications from us;
- interact with our social media profiles; and
- contact us (including over the phone, or via email, post, live chat or social media messaging);
- improve the Website and our services.
The processing of your data will be carried out in full compliance with the privacy regulation [LINK 1].
- Optional nature of the user’s decision to provide personal data
The user can provide the personal data at his/her own discretion. Some of the personal data requested on the Website (such as your first and last name, telephone number, and e-mail address) may be marked as “mandatory” [e.g., indicated with an (*)] as they are necessary to access the services of the Websites you wish to use (e.g., if you purchase video contents online). Failure to provide this data marked as “mandatory” may prevent odX from allowing access to the Website services or to answer to the users’ requests. Failure to provide data marked as “optional” will simply not allow us to use your data for the purposes you did not grant your consent with (e.g. to send you marketing communications).
- Data processing procedures and recipients
The data can be processed both electronically and in paper form. odX guarantees that the personal data provided will be processed lawfully and correctly, in compliance with the legislation in force and in any event in such a manner as to ensure their security and confidentiality and prevent unauthorized disclosure or use, alteration or destruction. All the information collected is sent via a protected connection to prevent it from being intercepted by third parties.
Data will not be communicated or disseminated to third parties except within the limits and under the conditions expressly indicated in the information notices provided to the user from time to time on the Website, and only upon receipt of authorization from the same (e.g. to the companies offering their products on the Website). The data will be processed (solely within their respective areas of competence) by persons in charge of the processing expressly authorized by the Company to manage the Website.
Moreover, for solely organizational and functional needs, the Company has appointed some service providers necessary for the management of the Website as data processor for the users’ personal data for purposes strictly connected and related to the provision of services, including: (i) companies that provide odX with services that are instrumental in the functioning of the Website (e.g. suppliers of cloud services); (ii) companies, which on our behalf perform the analysis of the user’s participation in our competitions/initiatives, purchases and use of the Website; (iii) companies appointed to carry out promotional activities (limited to name, surname and address for sending general mail; email address for sending e-mails; telephone/mobile phone number for telemarketing activities); (iv) companies that organize and manage market research on our behalf; (v) companies tasked on our behalf with management of our customer care service; (vi) legal, tax and accounting advisors; (vii) credit institutions and payment processors (in relation to the management of the payment of your purchases). These providers act as data processors or as independent data controllers. A complete list of the data processors can be required by sending a communication to [*].
- Link to other sites
- “Profiling” and/or customization tools
odX does not carry out any promotional communication and/or advertising activities without the user’s prior explicit consent, without prejudice to the right of the Company to use your e-mail address supplied in the context of the sale of our products and services for direct marketing of products and services similar to those that have been the subject of the sale. You will always have the right to object to the sending of commercial communications by means of a notice to be addressed to the contact displayed at point 10 below.
The Website uses both technical (aimed at enabling browsing and Website usage) and profiling (aimed at analyzing the users, their behavior and their preferences and to provide customized advertising) “cookies”.
- Location of data processing
The data related to the services provided by the Website are processed at odX’s registered office indicated at point 1 above by the persons expressly in charge of the processing.
- Storage period
Your data will be processed for the period indicated in the specific privacy notices provided at the moment of collection (e.g. registration to the website, etc.). Please click here for further details [LINK 3].
- Rights of the data subjects
By sending a notice to [*] or email@example.com you may at any time exercise the rights [LINK 4] provided for by articles 15 to 22 of the GDPR, such as requesting information on which data we are processing, in which manner and for which purpose we are using them, amending the data you have provided us or erasing them, asking us to limit use of your data, and requesting receipt or transmission of your data to another data controller in a structured, commonly used and machine-readable format, all of the above without prejudice to the possibility of changing the user’s consent (if provided).
You may at any time object to processing of personal data concerning you for marketing or preferences analysis purposes.
- Complaint before the Data Protection Authority
Should you consider the processing of your data infringes the GDPR, you may in any event lodge a complaint before the Italian Data Protection Authority (www.garanteprivacy.it), or to the Data Protection Authority of the Member State of your habitual residence, place of work or place of the alleged infringement.
- Applicable Law
The integral text of Legislative Regulation (EU) 2016/679 – “General Data Protection Regulation” can be consulted on the Website of the Italian Data Protection Authority www.garanteprivacy.it/.
13.Right to review
LINK DI COLLEGAMENTO
The legal basis for processing your data will be:
- the compliance with legal obligations pursuant to Article 6(1)(c) of the GDPR related to the services provided by the Website;
- the execution of a contractual relationship pursuant to Article 6(1)(b) of the GDPR as regard the management of the services provided by the Website, your purchases and to answer to the requests strictly functional to the use of the services offered by the Website;
- your consent or our legitimate interest pursuant to Article 6(1)(a) and (f) of the GDPR, as regard our marketing and analysis activities.
In any case, the data will be processed in compliance with the legislation in force.
If you decide to create your account by registering to the Website, your data will be processed as long as your account stays active. You may close your account at any time and your request will be processed immediately. If your account stays inactive for three (3) years, OdX will contact you to find out if you wish to keep or close your account. If you do not intend to keep your account active, it will be closed and your data will be deleted. Any back-up copies will be kept for a maximum period of [*].
The data will processed for the management of your purchases shall be kept for as long as it is necessary to comply with tax, accounting and legal obligations and to exercise the rights connected with or deriving from the purchase, in any event, for a period not exceeding the period of limitation of rights in civil proceedings. Thereafter, the data will be destroyed or anonymized.
Should you have granted us with your consent, your contact details will be processed for the purpose of sending commercial and promotional communications for the entire duration of your registration on the Website, or – in any case – until your consent is withdrawn. After [*] years from the acquisition, odX reserves the right to contact you to find out if you wish to continue receiving communications on odX products, services, offers, news and events. If you withdraw your consent to these marketing purposes or object to such processing, your data will be deleted within [*].
Articles 15 to 22 of the GDPR recognise specific rights, such as:
- obtaining confirmation as to whether or not personal data concerning you is being processed
- obtaining access to your personal data and to the information set out in Article 15 of the Regulation;
- obtaining the rectification of the inaccurate personal data that concern you without undue delay or the supplementing of incomplete personal data;
- obtaining the erasure of the personal data that concern you without undue delay;
- obtaining the restriction of processing the personal data that concern you;
- being informed of any rectifications or erasures or restrictions of processing in relation to the personal data that concern you;
- receiving in a structured, commonly used and machine-readable format the personal data that concern you;
- objecting at any time, on grounds associated with your specific situation, to the processing of the personal data that concern you.
The above is without prejudice to your right to withdraw at any time whatsoever consent to data processing you might have granted, as well as to object to processing of personal data concerning you for marketing or preferences analysis purposes.