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PERSONAL DATA PROCESSING POLICY

REG EU 2016/679 and Italian privacy legislation

DATA CONTROLLER: Accademia d’Arti e Mestieri dello Spettacolo Teatro alla Scala (hereinafter “Academy”)
Registered Headquarters: Via Santa Marta n. 18, Milano tel. (+39) 02-8545111; fax (+39) 02-86460020; email: privacy@accademialascala.it

 

LAWFULNESS AND PURPOSES OF PERSONAL DATA PROCESSING

  1. assessment of requisites for participation in selective admissions processes and for enrollment in and attendance of a course/workshop/seminar/career guidance service, and the performance of activities necessary to complete the enrollment process should the candidate be accepted for admission;
  2. management of contractual relationships, which may regard enrollment at the Academy, assessment of requisites for scholarships or registration fee exemptions (see specific forms issued to applicants who pass the selection process) and related administrative processes, which may be carried out by banks; management of reimbursements of travel expenses; meal tickets; administrative management of contracts and payments; invoicing; and legal bookkeeping and administrative obligations;
  3. dispute management and safeguarding of Academy rights;
  4. educational and training activities, including those relating to internships, which may include teaching office services (including provision of course information), organization and management of the course, management (also by electronic means) of attendance, the issuance of attendance certificates, periodic and final testing, participation in events organized by the Academy or external organizations collaborating with the Academy, participation in courses funded by public institutions or corporations and fulfillment of associated obligation to provide attendance data, either individually or on an aggregate basis, fulfillment of obligations deriving from relations with relevant public corporations (e.g. INAIL, DPL, INPS, ENPALS) and with funders (e.g. Regione Lombardia);
  5. participation in educational/training activities relating to the course/workshops/seminar/career guidance service/employment (e.g. internship);
  6. as required for drawing up insurance policies;
  7. with Data Subject consent—or consent of parent/legal guardian for minors—to provide information via mail, telephone (including text messages), or IT device regarding the presentation or promotion of courses/open days/artistic events/educational events/career guidance services/events or activities organized or managed by the Academy and/or its partners according to the applicable calendar, and surveys for statistical purposes. The personal data may be communicated to third parties, with the exception of those regarding artistic and/or educational events. During activities or events in which the Data Subject may participate, recordings may be made to document said activities or events. The Academy may use images of the Data Subject either directly or indirectly for any purpose, including advertising/publicity, and in any way or form (e.g. publicizing via internet, publication in print media, etc.) as will be further specified at the proper time, without compromising Data Subject’s dignity;
  8. with Data Subject consent—or consent of parent/legal guardian for minors—the Academy may communicate certain personal data of students or former students to public or private corporations or institutions, private individuals, or partners, who may request it, including those headquartered outside of Italy or the European Union, in order to facilitate employment or professional placement of the student or former student;
  9. with Data Subject consent—or consent of parent/legal guardian for minors—the sending of promotional or informational materials (Academy Newsletter) by mail, telephone, or IT device.

 

 

 

PERSONAL DATA STORAGE PERIOD

For purposes A–F, the personal data storage period depends on legislation in force to safeguard the rights of the Data Subject and the Data Controller, and for the purposes of maintaining a historical archive;

For purposes G­–I, the personal data will be stored until the Data Subject, parent, or legal guardian withdraws consent; without prejudice to legitimized processing based on said consent prior to its withdrawal.

Personal data storage times and criteria are documented in detail in the personal data processing registry of the Academy; specific times will be communicated to Data Subject per request. The request must be sent to privacy@accademialascala.it. Access to these data is subject to an assessment of the legitimacy of the request.

 

PERSONAL DATA SUBJECT TO PROCESSING AND METHOD OF PROCESSING

In processing personal data that may be used to identify the Data Subject either directly or indirectly, the Academy shall adhere to the principle of strict necessity and seek to ensure the confidentiality of the processed data. We shall thus collect personal data and provide them to the data recipients and subjects authorized to process said data, including internship hosts and third parties where applicable (see “Data Recipients and Subjects Authorized to Process Personal Data” below), only those data necessary for accomplishing the above-specified purposes. Personal data will be processed in printed or computerized form by Academy offices and departments using methods and within the limits necessary for accomplishing said purposes. No sensitive data will be requested during the online registration process for courses/workshops/seminars/career guidance services and/or associated events or activities organized or managed by the Academy and/or its partners (purposes A–E). Should sensitive data—exclusively of a medical nature—be requested in a subsequent phase, excluding legal requirements associated with injuries and their communication to relevant agencies, these data will not be provided via electronic means. The Data Subject will also be required to produce printed materials bearing the Data Subject’s original signature, or that of a parent or legal guardian in the event that the Data Subject is a minor, as specified in the relevant course announcement. Names (or codes) and other data (e.g. photographs or nationality) of those who pass the selection process and are admitted or considered eligible for admission to the Academy may be posted on notice boards at Academy facilities or published online on the accademialascala.it website and/or on Academy social media pages. The names and other data of individuals who do not pass the selection process will not be made public. Further information on this point may be requested by writing an email to relazioni.esterne@accademialascala.it.

 

DATA PROVISION REQUIREMENT

 The provision of personal data is necessary for accomplishing the purposes set forth above. Specifically:

  • the provision of personal data for purposes A–F, above, is necessary in order to assess the eligibility of the applicant to be included in the selection process as described in the relevant course announcement, to receive financial aid, if requested (see course announcement and forms regarding student loans or scholarships), and to enroll and attend the course/workshop/seminar/career guidance service and/or associated events or activities organized or managed by the Academy and/or its partners. Enrollment and requests for student loans or scholarships require filling out specific printed forms with the personal data provided previously and the provision of an IBAN, consent for which is understood to be provided by the Data Subject’s (or parent’s or legal guardian’s) signature on the form. Failure to provide personal data for these purposes will make it impossible to enter into or execute a contract, however provision of said data does not imply consent to their transfer outside of the European Union for the purposes of internships or participation in events;
  • the provision of personal data for purposes G–I above is optional. The refusal to provide data for these purposes will not prejudice in any way the Data Subject’s eligibility to participate in the selection process for, and to enroll in and attend, the course/workshop/seminar/career guidance services and/or associated events or activities organized or managed by the Academy and/or its partners.

 

Certain data (e.g. birthdate, city of residence, gender) may be collected and processed to produce aggregate statistics, without any possibility of identifying the Data Subject. These statistics have the purpose of assessing the quality of services offered and may also be produced by the funding organization.

 

LEGAL BASIS FOR PERSONAL DATA PROCESSING

The legal basis for personal data processing regarding purposes A–F is the legitimate interest of the Academy to fulfill its charter and provide the services implicit therein and to comply with national and regional legislation regarding the management and administration of educational programs (including internships and practicums) and career services, contract law, and associated applicable legislation. As regards purposes G–I, personal data is processed to comply with Data Subject requests.

 

DATA RECIPIENTS AND SUBJECTS AUTHORIZED TO PROCESS PERSONAL DATA

The following parties may have access to Data Subject personal data: Academy personnel (employees, collaborators, authorized professionals) for administrative, organizational, or promotional purposes, and members of selection committees or members of interim (if applicable) or final testing committees. Personal data, including that of a sensitive nature, provided by applicants to the Ballet School as required by the selection process as described in the course announcement may also be processed by specialized medical personnel authorized by the Academy to carry out medical evaluations. The personal data as requested of applicants admitted to a course/workshop/seminar/career guidance service, including personal data of a sensitive nature, may also be processed by the occupational health physician designated by the Academy and charged with assessing risks and for any medical services that may become necessary during the academic year.

Certain third parties, who may provide services on an outsourcing basis, are specifically charged with operating and maintaining information systems used to process Data Subject personal data. As a result, said data may be processed by personnel of these third parties acting as external data processors on behalf of the Academy and/or as system administrators, if so named, and applying appropriate measures to ensure data confidentiality and protection.

For purposes A–F, Data Subject personal data may be communicated to relevant public corporations or bodies such as: Ispettorato del Lavoro [Labor Oversight Authority] as regards participation in internships, events, or performances; National Institute for Insurance against Workplace Accidents and Occupational Disease (INAIL) and insurance companies in the event of workplace injuries (in which case the Academy may gain knowledge of Data Subject’s sensitive personal data relating to the Data Subject’s injury), or for the administration of insurance policies provided by the Academy; Academy partners and relevant public and private corporations and institutions in relation to projects for which they provide funding (in which case, data regarding course attendance and associated participation in events or performances may also be provided); banks (as pertinent to student loans, scholarships, etc.); internship partner companies; tax and legal consultants as regard Academy legal and fiscal affairs; third-party oversight organizations (e.g. ISO 9001 certification bodies, oversight bodies, data protection officers, Regione Lombardia); parties providing consulting and/or support services for marketing and other promotional activities; parties to whom personal data must be communicated to comply with laws or regulations in force.

Where provided, Data Subject personal data will also be processed by employees, collaborators, and any external data processors of the internship host organization or organizer of events in which the Data Subject participates. Data Subject personal data may also be communicated to organizations providing funding for internships or events.

Some personal data provided to authorized external data processors may be transmitted via platforms made available by these processors.

The list of external parties who process personal data on behalf of the Data Controller (the Academy) is available upon request from privacy@accademialascala.it. Access to this list is provided only to those parties whose request is deemed to be legitimate by the Data Controller.

 

 

SECURITY OF DATA

Data Subject personal data will be processed using automatic tools in keeping with the principle of necessity and proportionality, avoiding processing of personal data when the operations can be carried out using anonymous data or in other ways. The Academy has implemented specific security measures to prevent loss of personal data, illicit or improper use of personal data, and unauthorized access to personal data.

 

DATA TRANSFER

Although all parties that process personal data on behalf of the Academy as external data processors are currently based in the European Union, in the future it may be necessary to transfer said data to parties based outside of the European Union in countries that do not ensure an adequate level of protection per the European General Data Protection Regulation (EU 2016/679). The Academy will only transfer personal data outside of the European Union if the relevant external data processors have implemented the security measures set forth in the Italian Personal Data Protection Code and the European General Data Protection Regulation and provided to the Academy the necessary guarantees, and only with the consent of the Data Subject.

 

DATA SUBJECT’S RIGHTS

By contacting the Data Controller via the Company Privacy Policy Contact at privacy@accademialascala.it, the Data Subject may exercise applicable rights as regards his or her personal data, including deletion of personal data, correction of inexact data, addition of missing data, limitations to processing, data portability, or objection to data processing without adversely affecting the rights and freedoms of the Data Controller.

The Data Subject’s consent to processing his or her personal data for any of the purposes indicated herein may be withdrawn at any time.

The Data Subject has the right to lodge a complaint with a supervisory authority in the EU member state where the Data Subject maintains his or her principal residence or in the state in which the presumed violation occurred. Further information on the Data Subject’s right to lodge a complaint may be found at: https://goo.gl/GLbTN9. The Data Subject will not be subject to a decision based solely on automated processing or profiling. 

 

ACADEMY PRIVACY POLICY CONTACT

For clarifications, information, exercise of Data Subject’s rights, or other requests, contact the Academy Privacy Policy Contact at: privacy@accademialascala.it or by phone: (+39) 02-85451192 or (+39) 02-85451171.

 

ACADEMY DATA PROTECTION OFFICER

In order to ensure the security of Data Subject’s personal data and observance of Data Subject’s rights, the Academy has appointed a Data Protection Officer having support, oversight, consultancy, instructional, and informational functions, cooperating and acting as liaison with the Italian Data Protection Authority for issues relating to personal data processing. The Academy Data Protection Officer may be contacted at:

 dpo@accademialascala.it   tel. (+39) 02-85451192 or (+39) 02-85451171.

 

 

PERSONAL DATA PROCESSING POLICY FOR USING THE ACADEMY WEBSITE

REG EU 2016/679 and Italian privacy legislation

DATA CONTROLLER: Fondazione Accademia d’Arti e Mestieri dello Spettacolo Teatro alla Scala (above and hereinafter “Academy”)
Registered Headquarters: Via Santa Marta n. 18, Milano, tel. (+39) 02-8545111; fax (+39) 02-86460020; email: privacy@accademialascala.it

 

LAWFULNESS AND PURPOSES OF PERSONAL DATA PROCESSING

The processing of personal data of subjects using the Academy website is justified by the legitimate interest of the Academy.

Instructions on requesting information or subscribing to the Newsletter using forms provided on the Academy website are found on the dedicated web pages.

 

PERIOD OF PERSONAL DATA STORAGE

As long as the user (Data Subject) is connected to the website. When the user disconnects, the personal data will be eliminated, erased, or rendered anonymous (if not already collected in anonymous form).

 

PERSONAL DATA SUBJECT TO PROCESSING AND METHOD OF PROCESSING

The IP address or domain name of the computer used by the Data Subject to connect to the Academy website,  URI (Uniform Resource Identifier) addresses of requested resources, the time of the request, the method used to submit the request to the server, the dimension of the file obtained in response, the numerical code indicating the server response status (success, error, etc.), and other parameters regarding the Data Subject’s operating system and IT environment may be collected and processed. 

In processing personal data that may be used to identify the Data Subject either directly or indirectly, the Academy shall adhere to the principle of strict necessity and seek to ensure the confidentiality of the processed data. The Academy has configured its website in such a way that the use of personal data is minimized, and personally identifiable data is processed only if strictly necessary or requested by regulatory or law enforcement authorities (for example: traffic data, how long the Data Subject is connected to the website, and the Data Subject’s IP address) or as evidence in the event of a cybercrime against the Academy.

The personal data will be processed in anonymous form using computerized means by Academy teaching personnel and Academy marketing and public relations personnel.

 

PERSONAL DATA PROVIDED VOLUNTARILY

In certain sections of the website (information request and Newsletter subscription), the user is asked to provide personal data. In such cases, the user will be asked to acknowledge the Academy Privacy Policy pursuant to Article 13 of the EU General Data Protection Regulation (EU 2016/679 – “GDPR”) and Article 13 of the Italian privacy law (Legislative Decree no. 196 of June 30, 2003) regarding the processing of personal data for each specific purpose.

 

PERSONAL DATA SHARED ON SOCIAL MEDIA

The Data Subject is exclusively liable for any content he or she posts on any social network(s) (Facebook, Twitter, YouTube, Instagram, etc.). The Data Subject is responsible for consulting the privacy policy of each social network where he or she posts content.

 

LOCATION DATA

The Academy website may collect location data with anonymized IP address via Google Analytics (https://policies.google.com/privacy?hl=en) which makes it impossible to identify the user. No geographic data or information is processed.

 

PERSONAL DATA PROVISION REQUIREMENT

Certain personal data are strictly necessary in order to access and use the Academy website. Other personal data are processed exclusively for anonymous statistical purposes on website use and to ensure the proper functioning of the website. These latter data are erased immediately after processing.

 

DATA RECIPIENTS AND SUBJECTS AUTHORIZED TO PROCESS PERSONAL DATA

Personal data are processed by Academy employees or consultants or by external parties acting as authorized external data processors who provide technical, administrative, and/or organizational services for the Academy. While some information system maintenance services are contracted to external parties that have implemented appropriate measures to ensure confidentiality, personal data will not be published or communicated to third parties.

The list of external parties who process personal data on behalf of the Data Controller (the Academy) is available upon request from: privacy@accademialascala.it

 

SECURITY OF PERSONAL DATA

Data Subject personal data will be processed using automatic tools in keeping with the principle of necessity and proportionality, avoiding processing of personal data when the operations can be carried out using anonymous data or in other ways. The Academy has implemented specific security measures to prevent loss of personal data, illicit or improper use of personal data, and unauthorized access to personal data.

 

DATA SUBJECT’S RIGHTS

By contacting the Data Controller at: privacy@accademialascala.it, the Data Subject may exercise applicable rights as regards his/her personal data, including deletion of personal data, correction of incorrect data, addition of missing data, limitations to processing, data portability, or objection to data processing without prejudicing the rights or freedoms of the Data Controller.

The Data Subject has the right to lodge a complaint with a supervisory authority in the EU member state where the Data Subject maintains his or her principal residence or in the state in which the presumed violation occurred.

Latest update: June 2018

 

 

Information on cookies

  1. What are cookies?

Cookies are small text files that are sent from websites to the devices of users who visit the website and are sent back to the website if and when the user visits it again. There are different types of cookies that serve different purposes. The cookies may belong to the domain name shown in the web browser’s address bar, in which case they are first-party cookies, or they may belong to a different domain name, in which case they are third-party cookies.

This document provides information on cookies used by the Academy website www.accademialascala.it and how the user may set his or her cookie preferences.

  1. Cookies used by this website 
    This website uses technical, navigation, analytical, and third-party cookies. The cookies used by this website do not allow the Academy to acquire user personally identifiable information. The user may deactivate the cookies at any time by changing his or her browser settings. It is also possible to delete all cookies after each website session.

 

The owner of the website is Fondazione Accademia Teatro alla Scala (“Academy”), Via Santa Marta 18, 20123, VAT no. 03413630967. The use of cookies by the Academy is regulated by the Academy privacy policy.

2.1. Cookies not requiring user consent 
Certain indispensable technical cookies are installed automatically when the user accesses the Academy website and do not require user consent. These cookies are necessary to allow the user to navigate throughout the Academy website, including protected pages, and use all of its functionalities. Without these cookies, certain necessary services, such as filling out online forms, may not be available.

 

Statistical cookies are used directly by the website administrator to collect information in aggregate form (for example, to count the number of accesses by the user’s browser).

 

The following technical cookies are automatically installed:

 

Name of cookie

Category

Function

pll_language

– first-party technical cookie

Remembers user’s language choice

– duration: one year

woocommerce_cart_hash

– first-party technical cookie

Woocommerce uses this cookie to associate the user with a shopping cart.

– duration: one session

woocommerce_items_in_cart

– first-party technical cookie

Woocommerce uses this cookie to store information on the number of items in the shopping cart.

– duration: one session

wordpress_logged_in_*

– first-party technical cookie

WordPress uses this cookie to indicate when the user is logged in and who the user is for most interfaces.

– duration: one session

wordpress_test_cookie

– first-party technical cookie

WordPress sets up this cookie when the user accesses the login page. The cookie is used to verify whether the browser is set up to allow or deny cookies.

– duration: one session

wordpress_*

– first-party technical cookie

WordPress uses this cookie to memorize the authentication credentials and their use. This cookie is limited to the admin area.

– duration: one session

wp-settings-*, wp-settings-time-*

– first-party technical cookie

WordPress uses this cookie to personalize the admin interface and perhaps also the main website interface.

duration: one year

wp_dlm_downloading,

– first-party technical cookie

WordPress uses this cookie when some resource is downloaded.

duration: one day

_dlm-gf-cookie

– first-party technical cookie

WordPress uses this cookie when a form is filled out to allow download of a resource.

– duration: one session

wp_woocommerce_session_*

– first-party technical cookie

woocommerce uses this cookie  to identify the logged-in user.

 

 

 

2.2. Cookies requiring user consent 
Cookies other than those above are installed or activated only if the user provides consent the first time he or she visits the website: these are technical function cookies that allow the website to record user choices (such as name, language, or home region) and provide advanced personalized functionalities. These cookies can also be used to record modifications to font, character size, and other parts of the web page that can be personalized. Consent may be tacitly expressed by continuing to use the website, it can be denied, or it can be selectively expressed.

 

Third-party cookies 
Information regarding visitors to the website may be used by third parties, including Google, to display publicity materials regarding Fondazione Accademia Teatro alla Scala on other websites.

 

Below we list the websites of third parties that install cookies on the user’s device when connected to this website. Also listed are links to the privacy policies and consent forms for each. Closing this web page does not imply denial of consent:

 

Google Tag Manager is used according to the Google terms of use (https://www.google.com/intl/en/policies/terms/), the Google Privacy Policy (https://www.google.com/intl/en/policies/privacy/), and the Google Tag Manager Use Policy (https://www.google.com/analytics/tag-manager/use-policy/).

You may request deactivation of cookies by Google on the Google’s Ads Settings page.

 

www.google.it/intl/it/analytics: this website uses Google Analytics to assess the performance of the website and track how users use the site. In observance of contract obligations with Google and excluding all liability on Google’s part regarding content therein, we inform the user that Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on the user’s computer, to help the website analyze how users, who remain anonymous, use the site. The information generated by the cookie about the user’s use of the website will be transmitted to and stored by Google on servers located in the United States. Google will use this information on behalf of the operator of this website for the purpose of evaluating how visitors use the website, compiling reports on website activity for website operators and providing them other services relating to website activity and internet usage. Google may also transfer this information to third parties where this is required by law or where said third parties process said information on behalf of Google. The IP address that the user’s browser conveys within the scope of Google Analytics will not be associated with any other data held by Google. The user may refuse the use of cookies by selecting the appropriate settings on his or her browser, however, this may compromise the user’s ability to use the full functionality of the website. By using the website without modifying browser settings to refuse cookies, the user consents to the processing of his or her personal data by Google in the ways and for the purposes outlined above.

 

policy: https://support.google.com/analytics/answer/6004245;  
description of installed cookies:  https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage;
Link to download page that allows deactivation of installation of said cookies: https://tools.google.com/dlpage/gaoptout.

 

 

Modifying browser settings 
The user can disable cookies in his or her browser settings. The procedures for most browsers is the following:

  • select “Options” or “Preferences” from one of the following menus: Tools; View; Edit;
  • select “Privacy” or “Protection” or “Download files” and choose the preferred settings.

The following are links to the cookie settings screens for the following browsers:

 

Latest update: September 2018

 

 

 

PERSONAL DATA PROCESSING POLICY WITH REGARD TO REQUESTS FOR MEETINGS, INFORMATION, NEWSLETTERS, OR COURSE BROCHURES/ANNOUNCEMENTS

(REG EU 2016/679 and Italian privacy legislation)

 

DATA CONTROLLER: Accademia d’Arti e Mestieri dello Spettacolo Teatro alla Scala (hereinafter “Academy”)
Registered Headquarters: Via Santa Marta n. 18, Milano tel. (+39) 02-8545111; fax (+39) 02-86460020; email: privacy@accademialascala.it

 

LAWFULNESS AND PURPOSES OF PERSONAL DATA PROCESSING

  1. reservations of meetings with Academy representatives and/or partners;
  2. reception via mail, telephone (including texts), email or other computerized means of information regarding the presentation or promotion of courses, Open Days, artistic/training events, and/or orientation/career counseling services, or regarding any related events or activities organized or managed by the Academy or its partners according to the relevant calendar, as well as reception of evaluation materials for statistical purposes;
  3. participation in Open Days or presentations, events which may entail recording of video and/or photographic images;
  4. reception of the Academy Newsletter in printed or electronic form;
  5. downloading of course announcements/brochures (personal data is processed here for statistical purposes).

 

PERIOD OF PERSONAL DATA STORAGE

The personal data storage period depends on legislation in force to safeguard the rights of the Data Subject and the Data Controller, and to regulate historical archives of such data. Personal data will be stored until such consent is withdrawn, without prejudice to the legitimate processing based on said consent prior to its withdrawal.

Personal data storage times and criteria are documented in detail in the personal data processing registry of the Academy; specific times will be communicated to Data Subject per request. The request must be sent to privacy@accademialascala.it. Access to these data is subject to an assessment of the legitimacy of the request.

 

PERSONAL DATA SUBJECT TO PROCESSING AND METHOD OF PROCESSING

In processing personal data that may be used to identify the Data Subject either directly or indirectly, the Academy shall adhere to the principle of strict necessity and seek to ensure the confidentiality of the processed data. The Academy shall thus collect personal data and provide them to the data recipients and subjects authorized to process said data, including internship hosts and third parties where applicable (see “Data Recipients and Subjects Authorized to Process Personal Data” below), only those data necessary for accomplishing the above-specified purposes. Personal data will be processed in printed or computerized form by Academy offices and departments using methods and within the limits necessary for accomplishing said purposes.

 

PERSONAL DATA PROVISION REQUIREMENT

The provision of personal data is necessary for fulfilling the purposes set forth above. Specifically:

Reserving a meeting (Purpose A):

  • the provision of personal data is necessary to reserve a meeting;
  • the provision of personal data for Purposes B and D is optional. If the Data Subject declines to provide his/her personal data for these purposes, he/she will still be eligible to reserve a meeting;
  • the provision of personal data for Purposes C and E is not applicable here.

Certain data (e.g., birthdate, city of residence, gender) may be collected and processed in aggregate form for statistical purposes and to assess the quality of services offered without any possibility of identifying the Data Subject.

Receiving information via mail, telephone (including texts), email or other computerized means on courses, Open Days, artistic events, etc. (Purpose B):

  • the provision of personal data is necessary for receiving the information specified above under Purpose B;
  • the provision of personal data for Purpose D is optional. If the Data Subject declines to provide his/her personal data for Purpose D, he/she will still be eligible to receive the information specified above under Purpose B;
  • the provision of personal data for Purposes A, C, and E is not applicable here.

Certain data (e.g., birthdate, city of residence, gender) may be collected and processed in aggregate form for statistical purposes and to assess the quality of services offered without any possibility of identifying the Data Subject.

 Signing up for Open Days (Purpose C):

  • the provision of personal data for Purposes B and C is necessary for signing up for Open Days or presentations in order to receive all information pertinent to those events;
  • the provision of personal data for Purpose D is optional. If the Data Subject declines to provide his/her personal data for Purpose D, he/she will still be eligible to participate in Open Days or presentations;
  • the provision of personal data for Purposes A and E is not applicable here.

Certain data (e.g., birthdate, city of residence, gender) may be collected and processed in aggregate form for statistical purposes and to assess the quality of services offered without any possibility of identifying the Data Subject.

Receiving the Newsletter (Purpose D):

  • the provision of personal data is necessary for receiving the Newsletter;
  • the provision of personal data for Purpose B is optional. If the Data Subject declines to provide his/her personal data for these purposes, he/she will still be eligible to receive the Newsletter;
  • the provision of personal data for Purposes A, C, and E is not applicable here.

Certain data (e.g., birthdate, city of residence, gender) may be collected and processed in aggregate form for statistical purposes and to assess the quality of services offered without any possibility of identifying the Data Subject.

Downloading course announcements or brochures (Purpose E):

  • the provision of personal data is necessary for downloading course announcements and brochures;
  • the provision of personal data for Purposes B and D is optional. If the Data Subject declines to provide his/her personal data for these purposes, he/she will still be able to download course announcements and brochures;
  • the provision of personal data for Purposes A and C is not applicable here.

Certain data (e.g., birthdate, city of residence, gender) may be collected and processed in aggregate form for statistical purposes and to assess the quality of services offered without any possibility of identifying the Data Subject.

 

LEGAL BASIS FOR PERSONAL DATA PROCESSING

The legal basis for personal data processing per Purposes A–E is to respond to the requests of the Data Subject.

Regarding Purpose C and limited to the recording of any video and/or photographic images, the processing of personal data pertains to the legitimate interest of the Academy to promote and publicize its activities and to update its historical archives. 

The processing of personal data for Purposes D and E regards the Academy’s interest in performing anonymous market and statistical analyses in order to improve the quality of its services and educational programs. 

 

DATA RECIPIENTS AND SUBJECTS AUTHORIZED TO PROCESS PERSONAL DATA

Academy personnel (employees, consultants, authorized professionals) may have access to personal data for administrative, organizational, and promotional activities.

Furthermore, certain third parties, who may provide services on an outsourcing basis, are specifically contracted to operate and maintain information systems. If said third parties are designated as external data processors or system administrators on behalf of the Academy, and as such required to implement appropriate measures to ensure the confidentiality and security of personal data, they may process personal data collected by the Academy. 

For the purposes listed above, personal data may be communicated to third parties who provide consulting and/or support services for the management of promotional and marketing activities. Parties to whom personal data must be communicated to comply with laws or regulations in force will also be data recipients.

Some personal data provided to authorized external data processors may be transmitted via platforms made available by these processors.

For Purpose A, if the meeting takes place within the context of a project funded by public or private bodies, and for Purpose C, in the case of Open Days or presentations organized in collaboration with a partner, said parties (public or private bodies, or partners) may have access to personal data within the limits specified in pertinent statements or agreements and in keeping with the principle of data minimization (GDPR). Said parties may be designated as Joint Data Controllers (also know as Autonomous Data Controllers) subject to all limits provided in specific statements or agreements.   

Regarding Purpose C, personal data collected during Open Days or presentations in the form of video or photographic images may be published and used directly or indirectly for any purpose, including promotion and publicity, and in any form (images may be processed, edited, and published on the Academy website or in brochures) via means that will be defined in greater detail in the appropriate context. Said video and/or photographic images will be recorded in a way that does not compromise the dignity of the Data Subject.

The list of external parties who process personal data on behalf of the Data Controller (the Academy) is available upon request from privacy@accademialascala.it. Access to this list is provided only to those parties whose request is deemed to be legitimate by the Data Controller.

 

SECURITY OF PERSONAL DATA

Data Subject personal data will be processed using automatic tools in keeping with the principle of necessity and proportionality, avoiding processing of personal data when the operations can be carried out using anonymous data or in other ways. The Academy has implemented specific security measures to prevent loss of personal data, illicit or improper use of personal data, and unauthorized access to personal data.

 

DATA TRANSFER

Although all parties that process personal data on behalf of the Academy as external data processors are currently based in the European Union, in the future it may be necessary to transfer said data to parties based outside of the European Union in countries that do not ensure an adequate level of protection per the European General Data Protection Regulation (EU 2016/679). The Academy will only transfer personal data outside of the European Union if the relevant external data processors have implemented the security measures set forth in the Italian Personal Data Protection Code and the European General Data Protection Regulation and provided to the Academy the necessary guarantees, and only with the consent of the Data Subject.

Further information, including a list of parties belonging to the specified categories who operate principally as joint data controllers, and a list of data processors is available at Academy offices and may be requested from the office of the Academy Privacy Policy Contact.

 

DATA SUBJECT’S RIGHTS

By contacting the Data Controller via the Academy Privacy Policy Contact at privacy@accademialascala.it, the Data Subject may exercise applicable rights as regards his/her personal data, including deletion of personal data, correction of incorrect data, addition of missing data, limitations to processing, data portability, or objection to data processing without prejudicing the rights or freedoms of the Data Controller.

The Data Subject’s consent to processing his or her personal data for any of the purposes indicated herein may be withdrawn at any time.

The Data Subject has the right to lodge a complaint with a supervisory authority in the EU member state where the Data Subject maintains his or her principal residence or in the state in which the presumed violation occurred. Further information on the Data Subject’s right to lodge a complaint may be found at: https://goo.gl/GLbTN9

The Data Subject will not be subject to a decision based solely on automated processing or profiling.

 

ACADEMY PRIVACY POLICY CONTACT

For clarifications, information, exercise of Data Subject’s rights, or other requests, contact the Academy Privacy Policy Contact at: privacy@accademialascala.it or by phone: (+39) 02-85451192 or (+39) 02-85451171.

 

ACADEMY DATA PROTECTION OFFICER

In order to ensure the security of Data Subject’s personal data and observance of Data Subject’s rights, the Academy has appointed a Data Protection Officer having support, oversight, consultancy, instructional, and informational functions, cooperating and acting as liaison with the Italian Data Protection Authority for issues relating to personal data processing. The Academy Data Protection Officer may be contacted at:

 dpo@accademialascala.it   tel. (+39) 02-85451192 or (+39) 02-85451171.