Updated to EU Reg 2016/679
(European personal data protection Regulation)

Introduction

PHOENIX WORLDWIDE CENTER SRLS does take user privacy seriously and is committed to respecting it. The current privacy policy describes the personal data protection activities performed by PHOENIX WORLDWIDE CENTER SRLS through the site www.koinecentre.com and the relating duties the Company takes on in this area. PHOENIX WORLDWIDE CENTER SRLS may treat user personal data when he visits the Site or uses services and functions present thereon. In the Site section gathering user personal data, a specific report pursuant to art. 13 /15 of EU Reg. 2016/679 is published.

Where provided for by EU Reg. 2016/679, user consent will be requested before proceeding with the treatment of his personal data. If the user supplies third party personal data, he must see that data communication to PHOENIX WORLDWIDE CENTER SRLS and following treatment for purposes specified in the applicable information form conforms to EU Reg. UE 2016/67 and applicable norms.

Holder’s identification details

PHOENIX WORLDWIDE CENTER SRLS PIAZZA SAN GIOVANNI IN LATERANO 48 ROMA TEL 0696038365

Type of data treated

Site visit and consultation do not generally involve the gathering and treatment of user personal data, except for surfing data and cookies, as specified later. In addition to so-called “surfing data” (see below), personal data voluntarily supplied by the user may be subject to treatment, when he interacts with Site functions or asks to use services offered by the Site. With respect to the Privacy Code, PHOENIX WORLDWIDE CENTER SRLS may also gather user personal data at third parties in performing its activities.

Cookies and surfing data

The Site uses “cookies”. Using the Site, the user consents to cookie use conforming to this Privacy Policy. Cookie are small files memorised on the user’s computer hard disk. There are two cookie macro-categories: technical cookies and profiling cookies.

Technical cookies are necessary for a web site to work properly, and to let the user surf; without them, the user may be unable to see the pages correctly or use some services.

Profiling cookies are there to create user profiles so as to send advertising messages in line with preferences he showed during surfing.

Cookies may also be classified as:

  • “Session” cookies, which are cancelled immediately on closing the surfing browser;
  • “Persistent” cookies, which stay inside the browser for a specific time period. For example, they are used to recognize the device connecting to a Site using user identification operations;
  • “Own” cookies, generated and run directly by the subject managing the web Site the user is surfing on;
  • “Third party” cookies, generated and managed by other subjects than the one managing the web Site the user is surfing on.

Cookies used on the Site

The Site uses these types of cookie:

  • Own, session and persistent cookies, necessary to allow Site surfing, for the purposes of internal security and system administration;
  • Third party, session and persistent cookies, necessary to let the user use multimedia elements present on the Site, such as images and videos;
  • Third party, persistent, cookies the Site uses to send statistic information to the Google Analytics system, via which PHOENIX WORLDWIDE CENTER SRLS may perform statistic analysis of Site access / visits. The cookies used are only for statistic purposes and gather information in aggregate form. Via a pair of cookies, one persistent, one session (expiring on browser closure), Google Analytics also saves a register with Site visit opening and closing times. You can block Google’s data reveal via cookies and following data elaboration by downloading and installing the browser plug-in from the following address: http://tools.google.com/dlpage/gaoptout?hl=it
  • Third party, persistent, cookies the Site uses to include some social-network buttons (Facebook, Twitter and Google+) in its pages. Selecting one of these buttons, the user can publish on his personal related social-network page contents of the Site web page he is visiting.

The Site could contain links to other sites (so-called third sites). PHOENIX WORLDWIDE CENTER SRLS does not access or control the cookies, web beacons and other technology to trace users that could be used on the third sites via which the user may access the Site; PHOENIX WORLDWIDE CENTER SRLS does not non control contents and material published by or received via third sites, or the related user personal data treatment modalities, and expressly refuses all related responsibility for such eventualities. The user is obliged to check the third sites’ privacy policy he accesses via the Site and find out about the conditions applicable to his personal data treatment. The current Privacy Policy only applies to the Site as defined above.

How to disable cookies in browsers

  • Internet Explorer: To block cookies, click the gearing icon located above right and select the heading Internet Options from the menu appearing. In the window opening, select the file Privacy and click on the Further button. At this point, put the check mark next to the heading Substitute automatic cookie management and select the option Block both under the text Web site cookies and under the text Third party cookies;
  • Google Chrome: Click on the button Menu placed above right and select the heading Settings from the menu appearing. In the page opening, click on the heading Show advanced options, which is located below, and press the button Content setting. Then put the check mark next to the heading Block sites from setting data to forbid cookie use from sites visited directly and/or next to the heading Block third party cookies and site data to stop third party sites saving cookies on the computer;
  • Firefox: To disable cookies in Mozilla Firefox, click on the button Menu placed above right and select the heading Options from the menu appearing. In the window opening, go to the file Privacy, set the drop down menu to Chronology settings on personalized setting use and deselect the option Accept cookies from sites; but if you want to block cookies only for third party sites, set the drop down menu accept cookies from third parties to Never;
  • Safari: If using a Mac, select the heading Preferences from the Safari menu (above left), going to the Privacy file and putting the check mark next to the heading Always Block.

Conservation of personal data

Personal data is conserved and treated via computer systems owned by PHOENIX WORLDWIDE CENTER SRLS, managed by PHOENIX WORLDWIDE CENTER SRLS or third parties supplying technical services.

Data treatment purposes and methods

PHOENIX WORLDWIDE CENTER SRLS may treat common user personal data for these purposes: usage by users of service and functions present on the Site, Request management and notifications by its own users, sending newsletters, managing candidacies arriving via the Site.

Personal data is treated electronically and inserted into the company computer system in full conformity with the EU Reg 2016/679, including security and confidentiality profiles, and availing the principles of treatment correctness and lawfulness. As per the EU Reg 2016/679, data is safeguarded and conserved for 10 years.

Personal data security and quality

PHOENIX WORLDWIDE CENTER SRLS is committed to protecting user personal data security and respects rules regarding security provided for by norms applicable so as to avoid data loss, illegitimate or illicit data use and access not authorised thereto, with special reference to Technical Orders regarding minimal security measures. Further,  the information systems and computer programs used by PHOENIX WORLDWIDE CENTER SRLS are set so as to reduce personal data and identification use to the minimum; such data is only treated to perform specific purposes pursued each time. PHOENIX WORLDWIDE CENTER SRLS uses multiple advanced security technology and procedures designed to foster user personal data protection; for example, personal data is conserved on secure servers located in protected, controlled security areas. The user may help PHOENIX WORLDWIDE CENTER SRLS update and keep correct his personal data, communicating any modification related to his address, qualifications, contact information, etc…

Communication field and data access

User personal data may be communicated to:

  • all subjects whose right to access this data is recognised by regulatory measures;
  • our collaborators, employees, in the field of related tasks;
  • all those physical and/or legal, public and/or private people when the communication appears necessary or functional for performing our activities and in the ways and for the purposes illustrated above.

Personal data supply nature

The user must supply certain personal data so the Company can manage communication, requests arriving from the user or to recontact the user himself to let his request go ahead. This type of data is marked by the asterisk symbol [*] and in this case its supply is compulsory so the Company can let his request, which failing this cannot be evaded, go ahead, while gathering other data not marked by an asterisk is optional: failure to supply it brings no consequence for the user.

The user is not obliged to supply personal data for marketing purposes, as specified in the section “Treatment purpose and method”, and refusal to supply it brings no consequences. Consent supplied for marketing purposes is understood as spread to sending communication performed by both automated and traditional means and/or contact methods, as indicated above.

Rights of the data subject

On the basis of Regulation (artt. 15-22), the data subject may exercise the following rights towards the data treatment holder/co-holder:

  • Right to Access: The data subject has the Right to access personal data regarding him undergoing treatment so as to check his personal data is treated in conformity with the law;
  • Right to Ratification: The data subject has the Right to obtain ratification of possible imprecise o incomplete information relating to himself, so as to guarantee such information is correct on the basis of treatment purpose;
  • Right to Cancellation: The data subject has the Right to ask the data holder to cancel his information and no longer treat such data;
  • Right to Limit Treatment: The data subject has the Right to ask the data holder to limit his data treatment;
  • Right to Data Portability: The data subject has the Right to receive personal data in a structured format, for common use and readable from an automatic device and broadcast this data to other treatment holders;
  • Right to oppose treatment: The data subject has the Right to oppose data treatment in cases provided for by GDPR, in any moment and without having to justify his decision;
  • Right not to be subject to automated decision processes: The data subject has the Right not to undergo a decision based exclusively on automated data treatment, including profiling, affecting him legally or significantly involving his person analagously.

He also has the Right to make out a complaint at the control authorities.

Revoking treatment consent

If the treatment is based on consent, as per art. 7 of EU Regulation UE 2016/679, he may opt to revoke consent to his personal data treatment, without prejudicing the lawfulness of treatment prior to revoking, sending a mail with the subject line “CONSENT REVOKING” to this Email address: languagecourses@koinecentre.com

If he would like further information on his personal data treatment, or exercise rights as per the preceding point 7, he may send a registered letter to this address: PHOENIX WORLDWIDE CENTER SRLS – Piazza San Giovanni in Laterano, 48 – Roma. Before he can supply this, or modify any information, it may be necessary to check his identity and reply to some questions. A reply will e delivered as soon as possible.