Processing of Personal Data

INFORMATION NOTICE TO DATA SUBJECTS

(Art. 13 of Legislative Decree 196/2003 – Italian Privacy Code; Art. 13 of the EU General Data Protection Regulation No. 679/2016)

The Accademia di Cultura Italiana, as the data controller pursuant to Articles 4 and 28 of Legislative Decree no. 196 of 30 June 2003 – Italian Privacy Code (hereinafter, the “Code”) and Articles 4, 7, and 24 of EU Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (hereinafter, the “Regulation”), hereby informs you, pursuant to Art. 13 of the Code and Art. 13 of the Regulation, that it will process your personal data for the purposes and in the manner described below. For the purposes of this notice, processing of personal data means any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, including collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction. The processing will be carried out manually (e.g., collection of paper forms) and electronically, or by means of computerized or automated tools. In accordance with the principles established by the Code and the Regulation, all processing performed by the Accademia di Cultura Italiana will comply with the principles of lawfulness, fairness, transparency, and protection of your privacy and rights. Pursuant to Article 13 of the Code and the Regulation, we therefore provide you with the following information.

A) Source of Personal Data and Categories of Data Processed.

Personal data may be collected in connection with requests for information, enrollment in language courses, or the use of services provided, including online. The categories of personal data processed consist of common personal data (both for the primary purposes of processing, as further detailed in Section B below, and for secondary purposes – marketing and profiling – as further detailed in Section C, and only where the legally required consent has been provided).

B) Primary Purposes of Processing.

Personal data are processed by the Accademia di Cultura Italiana for activities related to the teaching of language, Italian culture, and teaching methodologies, as well as for the promotion and dissemination of offered courses. Personal data will be processed primarily for purposes strictly connected and instrumental to procedures for requests for information, enrollment in language or training courses, or the use of the services provided, in particular:

• For entry into the Accademia’s IT systems of the personal records of information recipients and service users on the portal;

• To carry out the requests mentioned above, including related or ancillary activities or the provision of requested connected services;

• For management of the Accademia’s website;

• For the management of information flows and communications.

The request for information constitutes the legal basis for processing pursuant to Art. 13(1)(c) of the Regulation. Following the request, you will also have access to online services available on the Accademia di Cultura Italiana website.

C) Communication and Disclosure of Personal Data.

In all the above cases, for the pursuit of primary purposes, the Accademia di Cultura Italiana may disclose personal data to the following third parties where necessary:

• Entities, companies, or persons that maintain a support relationship with the Accademia for activities such as organization, management, advertising, or sponsorship of events;

• All natural or legal persons where disclosure is necessary for the primary purposes of processing.

D) Optional or Mandatory Nature of Consent.

In all cases described in Sections B and C (for disclosure to third parties), the Accademia di Cultura Italiana is not required to obtain specific consent for processing personal data. Should you choose not to provide the personal data required and necessary as described above, it will not be possible to process your requests.

E) Data Retention Periods and Other Information.

Data will be retained in accordance with applicable law, as specified below pursuant to Art. 13(2)(a) of the Regulation: ten years for documents and related civil, accounting, and fiscal data, as required by current legislation. With regard to personal data processed for marketing or profiling purposes, such data will be retained in compliance with the principle of proportionality and in any case until the purposes of processing are achieved or until specific consent is revoked by the data subject.

F) Data Controller and Data Processors.

The data controller is the Accademia di Cultura Italiana. To communicate directly and effectively with the Accademia di Cultura Italiana, you may use the following email address: accademiaculturaitaliana@gmail.com

G) Exercise of Data Subject Rights.

Pursuant to Article 7 of the Italian Privacy Code and Articles 13(2)(b) and (d), 15, 18, 19, and 21 of the Regulation, the data subject is informed that:

• They have the right to request from the Accademia di Cultura Italiana, as data controller, access to their personal data, rectification, deletion, or restriction of processing, or to object to processing, where applicable;

• They have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) following the procedures and instructions published on the official Authority website at www.garanteprivacy.it;

• Any corrections, deletions, or restrictions of processing carried out upon the data subject’s request – unless impossible or involving disproportionate effort – will be communicated by the Accademia di Cultura Italiana to all recipients to whom personal data have been disclosed. Upon request, the Accademia may provide the data subject with a list of such recipients.

Exercising these rights is free of charge and may be carried out without any specific form. The address for exercising these rights is: accademiaculturaitaliana@gmail.com