EU Regulation 2016/679 – GDPR (General Data Protection Regulation)
Alfio Bardolla Training Group S.p.A. (hereafter “ABTG”) cares about the personal data provided by the user of its website (hereafter “Website).
The Website is open to the public and can be visited without registration. However, users will be requested to provide some personal data in case they want to purchase the products or access the freemium content offered on the Website. Said personal data are collected inasmuch necessary or propaedeutic for the formation of contract agreements. In such a case, when a user decides to buy products or access freemium content on the Website, ABTG will duly inform the user pursuant to sec.13 of EU Regulation 2016/679 (hereafter “GDPR”).
Personal data protection
Pursuant to GDPR requirements, ABTG declares that:
1. Data Controller
The Data Controller of your personal data is Alfio Bardolla Training Group S.p.A. (Italian public company, registered office: Via G. Ripamonti n. 89, Milan 20141) in the person of his legal representative Alfio Davide Bardolla; email address: firstname.lastname@example.org. Any communication concerning your data shall be addressed in writing to the DPO either via e-mail or certified post.
2. Types of data
No registration is required to access the Website. However, some of the services offered on the Website do require the user to provide his/her personal data (i.e. in order to purchase the products offered on the Website or to download ebooks, as well as to contact ABTG or to request information, etc.)
Pursuant to GDPR article 13, whenever ABTG collects a user’s personal data, said user will be duly informed on the how his/her data will be used and for which purpose. When needed, ABTG will require the user’s specific consent for using the user’s personal data. For example, the user may be requested to provide his first and last names, email address, postal address, telephone number and other information through an electronic form in order to use some of ABTG’s services. In such a case, ABTG will only use said personal data for the purpose(s) described in the legal notices accepted by the user upon submitting the form.
All the data concerning the navigation on and the connection to the Website (as the URI-Uniform Resource Identifiers of the user’s requests, the request timestamp, the method used to post the request to the server, the size of the file returned by the server and the server response code (successful request, error etc.) and other parameters about the user’s operating system and software) are collected anonymously as statistical records to control the Website service status and usage and are deleted after elaboration. Should the Website be subject to hacking attacks, said data may be used to track responsibilities, otherwise they will be cancelled as soon as the services they were collected for will have been provided.
3. Data provision discretionality
The provision of personal data by the user is elective (i.e. in order to receive commercial offers or information). However, failing to provide one’s personal data can in some case exclude a user from accessing particular services and fulfill his/her requests.
4. Data processing and communication
All data collected by ABTG can be processed both on electronic or paper format. ABTG guarantees that personal data will be processed licitly, respecting the correctness of the personal data submitted through the Website, according to current regulations and respecting the data subject’s privacy.
All the personal data collected are transmitted through protected connection so to exclude it may be exposed to interception by third parties. The Website safety is guaranteed and certified by a leader internet security provider.
User’s personal data will not be shared or transmitted to third parties unless the data subject has agreed so by submitting specific privacy agreements that may be presented to him from time to time.
5. Links to other websites
6. Data processing location and communication
Personal data provided for the services offered on the Website will be processed at ABTG registered office (as defined above in 1) by the Data Processors.
In same cases, personal data may be processed at ABTG’s providers’ premises, for instance when said providers need to process such data to manage and maintain the Website or to allow or facilitate the services offered by ABTG. These providers are nominated Data Processor by ABTG pursuant to GDPR article 28. Additionally, personal data may be momentarily transferred abroad, even outside the European Union, but solely for the purposes mentioned above, according the guarantees of GDPR article 46, section 3, letter a. (Subject to the authorisation from the competent supervisory authority, the appropriate safeguards referred to in paragraph 1 may also be provided for, in particular, by … a)contractual clauses between the controller or processor and the controller, processor or the recipient of the personal data in the third country or international organisation) and according to the provisions of GDPR article 49, section 1, letter b (“In the absence of … appropriate safeguards pursuant to Article 46, including binding corporate rules, a transfer or a set of transfers of personal data to a third country or an international organisation shall take place only on … … … b) the transfer is necessary for the performance of a contract between the data subject and the controller or the implementation of pre-contractual measures taken at the data subject’s request”).
We ask the users to read all the privacy statements published on the Website, especially those on registration and purchase forms, as in those documents we specify which subjects can collect personal data.
7. Data Subject Rights
You may, at any moment, request to the Data Controller:
- access to your personal data;
- changes to your personal data;
- cancellation of your personal data;
- limitations to the use of your personal data;
You also may oppose the processing of your data and request their portability (you can ask for all of your data in Alfio Bardolla Training Group S.p.A. database to be transmitted to you in a structured, commonly used and electronic format in order to transfer those to a third party).
Additionally, you have the right to file a claim on how we handle your data to the Italian Data Protection Authority.
8. Applicable law
9. Revision Clause