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Introduction
KOINÉ CENTRE – COACHING & FORMAZIONE takes user privacy seriously and is committed to respecting it. This privacy policy ("Privacy Policy") describes the personal data processing activities carried out by KOINÉ CENTRE – COACHING & FORMAZIONE through the website www.koinecentre.com and the related commitments undertaken by the Company. KOINÉ CENTRE – COACHING & FORMAZIONE may process the user's personal data when they visit the Website and use the services and features available on the Website. A specific notice is published in the sections of the Website where the user's personal data is collected, pursuant to Articles 13/15 of EU Regulation 2016/679.
Where required by EU Regulation 2016/679, the user's consent will be requested before processing their personal data. If the user provides personal data of third parties, they must ensure that the communication of the data to KOINÉ CENTRE – COACHING & FORMAZIONE and the subsequent processing for the purposes specified in the applicable privacy policy comply with EU Regulation 2016/679 and applicable law.
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Identification details of the data controller
KOINÉ CENTRE – COACHING & FORMAZIONE koinecentre@pec.it
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Type of data processed
Visits to and consultation of the Site do not generally involve the collection and processing of the user's personal data, except for navigation data and cookies, as specified below. In addition to so-called "browsing data" (see below), personal data voluntarily provided by the user may be processed when interacting with the Site's features or requesting to use the services offered on the Site. In compliance with the Privacy Code, KOINÉ CENTRE – COACHING & FORMAZIONE may also collect the user's personal data from third parties in the course of its business activities.
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Cookies and Browsing Data
The Site uses "cookies." By using the Site, the user consents to the use of cookies in accordance with this Privacy Policy. Cookies are small files stored on the user's computer's hard drive. There are two main categories of cookies: technical cookies and profiling cookies.
Technical cookies are necessary for the proper functioning of a website and to enable user navigation; without them, the user may not be able to correctly view the pages or use certain services.
Profiling cookies are used to create user profiles in order to send advertising messages in line with the preferences expressed by the user while browsing.
Cookies can also be classified as: _ "session" cookies, which are deleted immediately when the browser is closed; _ "persistent" cookies, which remain in the browser for a specified period of time. They are used, for example, to recognize the device connecting to a site, facilitating user authentication;
- "first-party" cookies, generated and managed directly by the operator of the website the user is browsing;
- "third-party" cookies, generated and managed by parties other than the operator of the website the user is browsing.
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Cookies used on the Site
The Site uses the following types of cookies:
- first-party, session, and persistent cookies, necessary to enable navigation on the Site, for internal security and system administration purposes;
- third-party, session, and persistent cookies, necessary to allow the user to use multimedia elements on the Site, such as images and videos;
- third-party, persistent cookies, used by the Site to send statistical information to the Google Analytics system, through which [KOINÉ CENTRE – COACHING & FORMAZIONE] can perform statistical analyses of accesses/visits to the Site. The cookies used are used exclusively for statistical purposes and collect information in aggregate form. Through a pair of cookies, one persistent and the other session (expiring when the browser is closed), Google Analytics also saves a log of the times of the start and end of visits to the Site. You can prevent Google from collecting data via cookies and from processing it by downloading and installing the browser plug-in available at the following address: http://tools.google.com/dlpage/gaoptout?hl=en
- Persistent third-party cookies used by the Site to include buttons for certain social networks (Facebook, Twitter, and Google+) on its pages. By selecting one of these buttons, the user can publish the contents of the Site's web page they are visiting on their personal page on the relevant social network.
The Site may contain links to other sites (so-called third-party sites). KOINÉ CENTRE – COACHING & FORMAZIONE does not access or control cookies, web beacons, and other user tracking technologies that may be used by third-party sites that the user can access from the Site; KOINÉ CENTRE – COACHING & FORMAZIONE does not monitor the content and materials published by or obtained through third-party websites, nor their methods of processing users' personal data, and expressly disclaims any liability for such eventualities. Users are responsible for reviewing the privacy policies of third-party websites accessed through the Site and for learning about the terms and conditions applicable to the processing of their personal data. This Privacy Policy applies only to the Site as defined above.
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How to disable cookies in browsers
Internet Explorer: To block cookies, click the gear icon in the top right and select Internet Options from the menu that appears. In the window that opens, select the Privacy tab and click the Advanced button. Then, check the box next to Override automatic cookie handling and select the Block option under both the Website Cookies and Third-party Cookies headings.
Google Chrome: Click the Menu button in the top right and select Settings from the menu that appears. On the page that opens, click Show advanced settings at the bottom and press the Content settings button. Then, check the "Block sites from saving data" box to prevent the use of cookies by sites you visit directly and/or "Block third-party cookies and site data" box to prevent third-party sites from saving cookies on your computer.
Firefox: To disable cookies in Mozilla Firefox, click the Menu button at the top right and select Options from the menu that appears. In the window that opens, go to the Privacy tab, set the "Firefox: History" drop-down menu to "Use custom settings for history" and deselect "Accept cookies from sites." To block cookies only for third-party sites, set the "Accept third-party cookies" drop-down menu to "Never."
Safari: If you're using a Mac, select "Preferences" from the Safari menu (top left), go to the "Privacy" tab, and check "Always block."
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Storage of Personal Data
Personal data is stored and processed using IT systems owned by PHOENIX WORLDWIDE CENTER SRLS and managed by [PHOENIX WORLDWIDE CENTER SRLS] or by third-party technical service providers;
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Purposes and methods of data processing
KOINÉ CENTRE – COACHING & FORMAZIONE may process the user's common personal data for the following purposes: use of services and features on the Site by users, management of requests and reports from its users, sending newsletters, and managing applications received through the Site.
Personal data is processed electronically and entered into the company information system in full compliance with EU Regulation 2016/679, including security and confidentiality measures, and in accordance with the principles of fairness and lawfulness of processing. In accordance with EU Regulation 2016/679, the data is stored and retained for 10 years.
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Security and quality of personal data
KOINÉ CENTRE – COACHING & FORMAZIONE is committed to protecting the security of your personal data and complies with the security provisions of applicable legislation to prevent data loss, illegitimate or unlawful use of data, and unauthorized access, with particular reference to the Technical Regulations regarding minimum security measures. Furthermore, the information systems and software used by KOINÉ CENTRE – COACHING & FORMAZIONE are configured to minimize the use of personal and identifying data; such data is processed only to achieve the specific purposes pursued from time to time. KOINÉ CENTRE – COACHING & FORMAZIONE uses multiple advanced security technologies and procedures to promote the protection of users' personal data; for example, personal data is stored on secure servers located in locations with protected and controlled access. You can help KOINÉ CENTRE – COACHING & TRAINING update and maintain your personal data by communicating any changes to your address, qualifications, contact information, etc.
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Scope of communication and access to data
Your personal data may be disclosed to:
- all persons granted access to such data by law;
- our collaborators and employees, within the scope of their respective duties;
- all natural and/or legal persons, public and/or private, when disclosure is necessary or functional to the performance of our business and in the manner and for the purposes described above;
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Nature of provision of personal data
The provision of some personal data by the user is mandatory to allow the Company to manage communications and requests received from the user, or to contact the user to follow up on their request. This type of data is marked with an asterisk [*], and in this case, provision is mandatory to allow the Company to process the request. Failure to provide this data will prevent the Company from fulfilling the request. Conversely, the collection of other data not marked with an asterisk is optional; failure to provide it will not have any consequences for the user.
The provision of personal data by the user for marketing purposes, as specified in the "Purposes and Methods of Processing" section, is optional, and refusal to provide it will have no consequences. Consent granted for marketing purposes is deemed to extend to the sending of communications via both automated and traditional methods and/or means of contact, as exemplified above.
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Rights of the Data Subject
Pursuant to the Regulation (Articles 15-22), the data subject may exercise the following rights against the data controller/joint controllers:
- Right of Access: The data subject has the right to access personal data concerning him or her that is being processed in order to verify whether his or her personal data is being processed in accordance with the law.
- Right to Rectification: The data subject has the right to obtain the rectification of any inaccurate or incomplete information concerning him or her, in order to ensure the accuracy of such information based on the purposes of the processing.
- Right to Erasure: The data subject has the right to request that the data controller erase his or her information and no longer process such data.
- Right to Restriction of Processing: The data subject has the right to request that the data controller restrict the processing of his or her data.
- Right to Data Portability: The data subject has the right to receive personal data in a structured, commonly used, and machine-readable format and to transmit such data to another data controller.
- Right to object to processing: The data subject has the right to object to data processing in the cases provided for by the GDPR, at any time and without having to justify his or her decision.
- Right not to be subject to automated decision-making: The data subject has the right not to be subject to a decision based solely on automated processing of his or her data, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
You also have the right to lodge a complaint with the supervisory authority.
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Withdrawal of consent to processing
If the processing is based on consent, pursuant to art. 7 of EU Regulation 2016/679, you have the right to withdraw your consent to the processing of your personal data, without prejudice to the lawfulness of the processing carried out before the withdrawal, by sending an email with "REVOCATION OF CONSENT" in the subject line to the following email address: languagecourses@koinecentre.com
If you would like more information about the processing of your personal data, or to exercise the rights referred to in point 7 above, you can send a certified email to the following address: koinecentre@pec.it. Before we can provide or modify any information, we may need to verify your identity and answer some questions. A response will be provided as soon as possible.