ACT OF INFORMATION PURSUANT TO ART. 13 OF EU REGULATION N. 2016/679
COOPSELIOS Cooperativa Sociale S.C., (Tax Code and VAT n.: 01164310359) (hereinafter “COOPSELIOS”), in the person of its legal representative pro tempore, with registered office in Reggio Emilia (RE), via A. Gramsci, 54/S, and PROGETTARE ZEROSEI S.r.l., (Tax Code and VAT n.: 02001330352) (hereinafter “P06”), in the person of its legal representative pro tempore, with registered office in Reggio Emilia (RE), via A. Gramsci, 54/V, in their capacity as Joint-Controllers pursuant to art. 4 n. 7) and 26 of EU Regulation n. 2016/679 (GDPR), inform you, pursuant to art. 13 of GDPR, that your personal data described in article 1 will be processed, by Joint-Controllers, for execution of the purpose described in article 2.
Hereinafter, COOPSELIOS and P06 may be jointly referred as “Joint-Controllers”.
- Category of personal data being processed.
1.1. For execution of purpose described in article 2, Joint-Controllers process your personal data pursuant to art. 4 n. 1) of GDPR so called identification data, collected through the specific contact form on this website and explicitly indicated therein as compulsory by means of an asterisk (e.g. first name; surname; email address; information contained in the text of message to be sent to Joint-Controllers; city of residence/domicile/residence) (hereinafter “personal data”).
- Purposes of processing and related legal basis.
2.1. Your personal data is processed, by Joint-Controllers, for execution of following purpose:
- Contact, by Joint-Controllers (also separately), aimed at organizing a specific and personalized free consultation regarding the “Learning by Languages” method or other services/activities/products/methods of Joint-Controllers.
In compliance with art. 13 paragraph 2) letter e) of GDPR, Joint-Controllers hereby inform you that any failure to communicate (even partial) your personal data may result in impossibility for Joint-Controllers to perform, in a correct and complete manner, the purpose set out in art. 2.1. letter a) above.
In this regard, Joint-Controllers specify that the legal basis of the purpose referred in art. 2.1. letter a) is found in art. 6 paragraph 1) letter b) of GDPR.
- Retention period.
3.1. In accordance with art. 13 paragraph 2) letter a) of GDPR, Join-Controllers communicate the following retention period, after which your personal data will be subject to deletion, destruction or anonymization: (i) for execution of purpose referred in art. 2.1. letter a): term (maximum) of n. 5 years, where, following the performance of this special and personalized free advice, a contractual relationship is not established between you and Joint-Controllers, even separately from each other; on the other hand, in the event that a contractual relationship is established between you and Joint-Controllers, even separately from each other, following the carrying out of this appropriate and personalized free consultation, the term is n. 10 years pursuant to art. 2220 and 2946 of Italian Civil Code starting from definitive termination of related contractual relationship.
- Target audience.
4.1. In compliance with art. 13 paragraph 1) letter e) of GDPR, Joint-Controllers specify that your personal data may be subject to communication, if appropriate and necessary, to one or more recipients pursuant to art. 4 n. 9) of GDPR, identified as follows, in general, by category: (i) for execution of purpose referred in art. 2.1. letter a): subjects authorised pursuant to art. 4 n. 10), 29 and 32 paragraph 4) of GDPR to the processing by Joint-Controllers; companies controlled (even indirectly) or otherwise connected to Joint-Controllers, even separately; consultants or companies of various kinds that provide, however, services (including professional services) connected, even indirectly, to execution of this purpose (e.g. IT companies; call centre companies).
Finally, Joint-Controllers specify that your personal data will not be disseminated.
5.1. Your personal data is stored in automated, partially automated and/or non-automated archives belonging to or anyway traceable, even indirectly, to Joint-Controllers (even separately), and located within European Economic Area (EEA).
- Data subject’s rights.
6.1. In relation to your personal data, Joint-Controllers hereby inform you of your right to exercise the following rights, which may be subject to the limitations provided in articles 2 undecies and 2 duodecies of amended Legislative Decree n. 196/2003 (Privacy Code): right of access pursuant to article 15 of GDPR: right to obtain confirmation as to whether or not personal data is being processed, as well as the information referred in article 15 of GDPR (e.g. purpose of processing, storage period); right to rectification pursuant to article 16 of GDPR: right to correct, update or supplement personal data; right to erasure ex art. 17 of GDPR: right to obtain erasure or destruction or anonymization of personal data, where, however, the conditions listed in the same article apply; right to restriction of processing ex art. 18 of GDPR: right to obtain the limitation of the processing of personal data in the cases provided for by art. 18 of GDPR; right to data portability under art. 20 of GDPR: right to obtain the personal data, provided to Joint-Controllers, in a structured, commonly used and machine-readable format (and, if required, to transmit them directly to another Controller), where the specific conditions provided for by the same article exist (e.g. legal basis of the consent and/or execution of a contractual agreement with a third party; personal data provided by the data subject); right to object ex art. 21 of GDPR: right to obtain the cessation, on a permanent basis, of a specific processing of personal data; right to lodge a complaint with the Control Authority (i.e. Italian Privacy Guarantor) ex art. 77 of GDPR: right to lodge a complaint where it is believed that the processing under analysis violates national and EU legislation on the protection of personal data.
6.2. In addition to the rights described in art. 6.1. above, Joint-Controllers specify that, in relation to your personal data, there is, if possible and conferring, the right to exercise, on the one hand, the (sub)right provided by art. 19 of GDPR (“The controller shall communicate to each of the recipients to whom the personal data have been transmitted any rectification or erasure or restriction of processing carried out pursuant to article 16, article 17 (1) and article 18, unless this proves impossible or involves a disproportionate effort. The data controller shall inform the data subject of such recipients if the data subject so requests”), to be considered connected and related to the exercise of one or more of the rights regulated in articles 16, 17 and 18 of GDPR; on the other hand, Joint-Controllers specify that, in relation to your personal data, there is, if possible and conferring, the right to exercise the right provided for in art. 22 paragraph 1) of GDPR (“The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or significantly affects him or her in a similar way”), subject to the exceptions provided for in paragraph 2) below.
6.3. In accordance with article 12 paragraph 1) of GDPR, Joint-Controllers undertake to provide the communications referred in articles 15 to 22 and 34 of GDPR in a concise, transparent, intelligible, easily accessible form and with simple and clear language: such information shall be provided in writing or by other electronic means, if any, or, at the request of the data subject, shall be provided orally provided that the identity of the data subject is proven by other means.
6.4. In compliance with article 12 paragraph 3) of GDPR, Joint-Controllers inform that it undertakes to provide information regarding the action taken with respect to a request pursuant to articles 15 to 22 of GDPR without undue delay and, in any event, at the latest within one month from the receipt of such request; such period may be extended by n. 2 months if necessary, taking into account the complexity and number of requests (in such case, Joint-Controllers undertake to inform of such extension and the reasons for the delay, within one month from the receipt of the request).
6.5. The rights described above (with the exception of the right pursuant to article 77 of GDPR) may be exercised using the contact details set out in article 7 below.
- Contact details.
7.1. COOPSELIOS can be contacted at the following address: email@example.com; P06 can be contacted at the following address: firstname.lastname@example.org
7.2. Data Protection Officer (DPO) ex art. 37 of GDPR, appointed by COOPSELIOS, can be contacted at the following address: email@example.com; Data Protection Officer (DPO) ex art. 37 of GDPR, appointed by P06, can be contacted at the following address: firstname.lastname@example.org
Reggio Emilia (RE), 10.11.2021 (date of last update)
COOPSELIOS Cooperativa Sociale S.C. and PROGETTARE ZEROSEI S.r.l.
(in the person of their respective pro tempore legal representatives)