Eurocultura srl website Privacy Police

EUROCULTURA SRL WEBSITE PRIVACY POLICY
under art. 13 EU Regulation 2016/679

This Privacy Notice (hereinafter referred to as the “Notice”) is provided pursuant to art. 13 of the EU Regulation 2016/679 and describes:
1) the management methods of Eurocultura srl’s websites www.eurocultura.it, www.ingermania.it, www.learningmobility.it, studyvisit.eurocultura.it, www.destinazionesvezia.it (hereinafter referred to as the “Websites”) and the processing of personal data of Users who consult these Websites;
2) the processing of personal data of those who, as customers or suppliers or consultants, potential employees or collaborators, or to any other title, maintain relationships or contacts with Eurocultura srl or otherwise provide Eurocultura srl with their own personal data, for purposes indicated in this Notice.

1. Controller of your personal data and address to contact us
The Controller of personal data is: Eurocultura srl, with registered office in 36100 Vicenza (VI) via Morsolin, n. 6 and principal place of business in 36100 Vicenza (VI), Viale Del Mercato Nuovo, n. 44/G, VAT 03759950243, legal representative Mrs. Luciana Bettin. Eurocultura srl collaborates with Eurocultura, a private-law association, with registered office in 36100 Vicenza (VI) via Morsolin, n. 6 and principal place of business in 36100 Vicenza (VI) Viale Del Mercato Nuovo n. 44/G. Eurocultura srl and Eurocultura are joint controllers of the processing of the personal data.
Eurocultura srl and the association Eurocultura inform you, as joint controllers of processing according to art. 13 of the quoted Regulation, that the data requested and supplied by you in case of request of information, as well as for the ones requested for the additional services offered by us, can be used by each of them, pursuant to law provisions and in relation to the main purposes, as described in the present Notice.
Eurocultura srl is a company that deals with research, training and consulting on the world of work and training in Italy and abroad. In particular, it carries out activities of:

a) “Individual counseling” of orientation to international mobility (work, study, internship, volunteering abroad);
b) Organizes “Seminars and workshops” of orientation to international mobility;
c) welcomes in Italy both students participating in linguistic / work placements and workers who intend to learn about Italian best practices in their field (so-called Study visit);
d) sends Italian students abroad to participate in study courses;
e) carries out activities of promotion of job offers abroad / internship / volunteering;
f) organizes tour packages related to the activities described above.

The Association Eurocultura, offers consulting activities to its members in the field of career guidance in Italy and abroad and participates in European projects in various fields including: training and work, youth, inclusion, entrepreneurial activity, racism, xenophobia, gender mainstreaming and culture.
If you have any questions regarding the processing of your personal data, or would like to exercise your rights or withdraw your consent or object to processing based on legitimate interests, please contact us at the e-mail address privacy@eurocultura.it. In this Notice with the term “We”, we refer to Eurocultura srl.

2. Definition of “personal data” and “data-subject” (so-called “User”)
A “personal data” pursuant to art. 4 paragraph 1 of EU Regulation 2016/679 is: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
“Data subject” is the natural person to whom the personal data refers. The Data subject is therefore the subject protected by the personal data protection rules. In this Notice with the term “you” and “your data”, We address the Data subject. The data of a legal person is therefore not personal data and is not subject to protection by our legal system.
The Data subject who accesses the website is called “User” and this Notice addresses him.

3. Method of collecting personal data – own or third party data – Update personal data
The processing connected to the web services of this Website, as well as the processing that We carry out for any reason pursuant to this Notice, take place at our registered offices and are managed by an internal officer with IT technical skills, specifically appointed in writing or by personnel outside our organization after appointment of processor pursuant to art. 29 of the EU Regulation 2016/679.
We process personal data when the following situations occur:
a) when you enter your e-mail to subscribe to our newsletter “Muoversi” on our wesbite www.eurocultura.it;
b) when you enter your e-mail to subscribe to our newsletter “Ingermania” on our website www.ingermania.it;
c) when you enter your e-mail to subscribe to our newsletter in English and German on our websites www.learningmobility.it, studyvisit.eurocultura.it;
d) when you enter your personal data in our application form on our website www.ingermania.it or in other web pages of Eurocultura;
e) when you contact us by phone or e-mail to request information about our services or when we reply to your requests.
In the event that you communicate to us personal data of another subject, before the communication, you must make sure that data-subject has read our Notice.
In the event that your data undergoes changes, please inform us of the changes made (e.g. change of e-mail address), so that we keep your personal data up to date.

4. Type of personal data collected
The type of personal data We process can be the following:
a) Contact details: name, address, phone number, e-mail;
b) Personal data if the customer is a natural person: copy of the identification card, fiscal code;
c) Sensitive data for the carrying out of the services you requested;
d) Information on the use of Website: information on how you use our Website, including information collected via cookies and other tracking technologies. To that purpose see the the link
e) Images: photos and/or videos taken at events and/or fairs that portray you.

5. Legal basis for the processing of personal data (Lawfulness of processing)
The processing of personal data in compliance with the EU regulation 2016/679 must be justified by a legitimate “legal basis” and We are obliged to indicate the legal basis for each treatment described in this Notice. The legal basis recognized by the UE Regulation 2016/679 are the following:
a) Consent: If you have consented to the use of your personal data with the release of consent which may be withdrawn at any time by sending an e-mail to privacy@eurocultura.it;
b) Execution of pre-contractual measures or fulfilment of contractual obligations: your personal data is used to conclude a contract (e.g. sending an offer following a request), or to fulfil a contract (e.g. communication of your data to a hotel at the time of booking);
c) Statutory obligations: your personal data is used to comply with the law;
d) Legitimate interest: your personal data is used: i) to pursue our legitimate interest or a third-party’s legitimate interest, unless your interests, rights or fundamental freedoms prevail; ii) if it is necessary to defend ourselves, to take legal action in case of claims made towards you, us or third parties.

6. Purpose of the processing of personal data
Personal data will be processed, for the purposes described below, by appropriate paper-based, electronic and/or telematic tools:
a) to process your requests: e.g. request for a quote, dispatch of order confirmation, dispatch information material on our services, etc.
Eurocultura srl collects the contact data in order to respond to your requests, also sharing such information with the association Eurocultura that will act as a data controller of personal data upon release of their own Notice.
Legal basis for processing: execution of pre-contractual measures (see art. 5 lett. b);
b) To provide support in managing the sales contract and / or supply services: e.g. contacts during the execution of the contract with data sharing with host families that will act as data processors, in accordance with art. 28 of the EU Regulation 2016/679.
Legal basis for treatment: Fulfilment of contractual obligations (see article 5 letter b);
c) for legitimate interest (marketing activities so-called “soft spam”): to send informative and promotional communications similar to that of the sale by e-mail, pursuant to art. 130 paragraph 4 of the Privacy Code (Legislative Decree 196/2003) and pursuant to Recital 47 of EU Regulation 2016/679 (see art. 5 letter d);
d) for legal obligations and protection in legal proceedings: in compliance with the legally binding requests of your personal data and legal protection of our right in order to comply with legal obligations, regulations or provisions of the judicial authority, as well as to defend a right in court.
Where it is required, We will provide information that concerns you to the organisms responsible for the application of the law, regulations and judicial documents anywhere in the world. Furthermore, Eurocultura srl may process your personal data if it has the need to defend a right in court.
Legal basis for processing: legal obligations, legitimate interest (see art. 5 letter c and letter d).
It is our legitimate interest to protect and defend our rights. You may object to the processing of your data based on our legitimate interest, if the conditions are met.

7. Security measures taken to protect your personal data
We use technical and organizational measures to protect your data and our security measures are constantly updated on the basis of technological development. In particular, in our internal procedures, We take security measures such as:
a) restriction of access to your personal data, as needed and for the sole purposes communicated in this Notice;
b) the transfer of data electronically only in encrypted form;
c) use of firewalls and antivirus to prohibit unauthorized access.
All your personal data is stored on digital and paper support.

8. Retention of your personal data
Your personal data is kept only for the time necessary to achieve the purposes for which they was collected or for any other legitimate related purpose (for example, where it is relevant to a defence against claims made against us or in the presence of a legitimate interest). Therefore, if the personal data is processed for two different purposes, We will keep this data until the purpose with the longer term expires.
Your personal data that is no longer necessary, or for which there is no longer a legal requirement for its conservation, is irreversibly anonymised (and thus can be stored) or permanently deleted. To this end, personal data will be kept for the time necessary to achieve the purposes for which it was collected. For greater clarity, We report the retention periods related to the main purposes:
a) Marketing purposes: personal data processed for marketing purposes may be stored for 10 (ten) years from the date on which We have obtained your last consent for that purpose (except in the case where you have subsequently denied consent and with the exception of soft spam activity referred to in art. 6 letter c) of this Notice);
b) Fulfilment of contractual obligations: the data processed to fulfil any contractual obligation with you, may be kept for the entire duration of the contract as well as for subsequent 10 (ten) years from the end of the fiscal year following that of competence, to face any investigation and / or a tax and / or legal dispute;
c) In case of disputes: in the event that it is necessary to defend or act or even make claims against you or third parties, We may retain personal data that We will reasonably need to process for such purposes, for the time when such claim can be prosecuted.

9. Communication of your personal data
Your data is not subject to disclosure, so it is not brought to the attention of undetermined subjects.
Your personal data may be accessed by our staff, the host families and companies, teachers, additional suppliers and / or external consultants, designated as processors, who are given adequate operating instructions for the compliance with the legislation on the processing of personal data.These subjects are included in the following categories: a) banks and credit institutions; b) insurance companies; c) independent professionals and / or consulting companies; d) subjects to whom the right to access personal data is recognized by law, regulations or community regulations; f) subjects to whom the communication of the Data is necessary or is in any case functional to the management of the pre-contractual and / or contractual relationship with the Customers; g) association Eurocultura as joint controller with regard to the purposes referred to in the previous art. 6.

10. Data transfer abroad
The personal data can be transferred to subjects in countries outside the European Economic Area (EEA) for one of the purposes established in article 6 of the present Notice, whose data protection laws may be of a lower standard than the EEA. In that last case, We will make sure that all of your personal data accessible outside the EEA is processed with appropriate safeguards.
Countries outside the EEA may have been authorized by the European Commission as they provide protection similar to the EEA legislation on data protection and therefore no additional legal safeguards are required. In the case of foreign countries which have not obtained such authorization, you will be asked to consent to the transfer, or your personal data will be transferred using the contractual clauses approved by the European Commission. These clauses impose similar obligations in the protection of data directly from the consignee, unless it is granted by applicable law regarding protection.

11. Your rights regarding the protection of personal data
Under current legislation, you have the right to ask us about your data:
a) right of access;
b) right to rectification and erasure (“right to be forgotten”);
c) right to restriction of processing;
d) right to data portability;
e) acceptance of the withdrawal of consent, if the processing has its legal basis in consent as in marketing activity;
f) to oppose any treatment based on legitimate interests unless the reasons for which We are obliged to perform such treatment overcome any prejudice to your data protection rights.
The exercise of these rights is subject to certain exceptions aimed at safeguarding the public interest (for example the prevention or identification of crimes) and our interests. In the event that you exercise any of the aforementioned rights, it will be our responsibility to verify that you are entitled to exercise them and We will give you a reply as a rule within a month.
In the event that you, if the conditions are met, withdraw your consent or exercise the right of erasure it will be necessary to consider that this operation will require a technical processing time that will be our best to minimize, but during which you could still be contacted due to the marketing activities already carried out.
If you are not satisfied with the way in which We process your personal data, or of our reply, you will have the right to complain to the supervisory authority, competent according to the art. 77 of EU Regulation 2016/679 (in particular, in the Member State in which you usually reside, work or where the alleged violation has occurred).