Our Privacy Policy

Owner and manager of the processing of personal data

IAN Academy is trademark of Multibrand Project 3.0 Srls with registered office in Via Cupa Vicinale Sant’Agnello 140, 80046, San Giorgio a Cremano, Naples VAT number 08579071211 (hereinafter “IAN” or “Owner”), as Data Controller, will process your personal data provided through the website www.ian-edu.com (hereinafter the “Site”) in compliance with the provisions of the applicable legislation on the protection of personal data and this Notice.

Responsible for the protection of personal data (DPO)

IAN has appointed a Personal Data Protection Officer (DPO) who can be contacted at the following e-mail address: responsible@ian-edu.com

Object and methods of treatment

IAN will process the personal data communicated by you or legitimately collected (“Personal Data”). In particular, the following Personal Data may be processed: 

As identification data: data that allow direct identification, such as personal data (such as name, surname, tax code, VAT number, address, etc.), given to the Data Controller and processed for the purpose of signing and managing the contract; 

As service data: data relating to the provision of services, collected and processed during the duration of the contract; 

Economic and Financial data: data necessary for payments (eg. IBAN or bank current accounts) or that prove the execution of payments (payment identification details) and any other data relating to the customer’s solvency and punctuality; 

Contact data: contact information such as telephone numbers, landline and /or mobile, email address, provided to the Data Controller during the signing phase or during the duration of the contract or acquired by the Data Controller himself, which allow you to contact you for management purposes the contractual relationship and / or to provide you with services suited to your needs;

Personal area data: data requested during registration, if done, and necessary for the use of the related services offered by companies accessible from the web. When creating the profile, you will be asked to provide some personal data such as: name, surname, email address, mobile number and others. IAN also allows you to access the personal reserved area also through the APP or through the use of credentials provided by a social network (so-called “social login”), in particular using the identities created on Facebook and Google+; 

Navigation data: the IT and telematic systems and software procedures used to operate the site, or dedicated to the operation and use of the APPs made available by IAN, acquire, during their normal operation, some data (eg date and ” time of access, the pages visited, the name of the Internet Service Provider and the address of the Internet Protocol (IP) through which you access the internet, the internet address from which you connected to the site, etc.), the transmission of which is implicit in the use of web communication protocols or is useful for better management and optimization of the data and e-mail sending system; 

Data acquired by the customer service: data provided during interactions with the Online Reception Service;

Data acquired by other customer care: data provided on the occasion of interactions with IAN’s customer care, including the recordings of telephone calls, if you have consented to their registration or in cases where the registration is carried out by virtue of a legal obligation or regulation.
The processing of personal data for the purposes of this information is to be understood as any operation or set of operations, carried out with the aid of automated processes and applied to personal data, such as the collection, registration, organisation, structuring, storage ,adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, cancellation or destruction. We inform you that such personal data will be processed manually and / or with the support of IT or telematic means.

 

Purpose and legal basis of the processing

IAN will process your personal data for the achievement of specific purposes of which it will be informed from time to time and only in the presence of a specific legal basis provided for by the applicable law regarding the protection of personal data. Specifically, IAN will process your personal data only when one or more of the following legal bases are met: 

  • you have given your free, specific, informed, unequivocal and express consent to the processing;
  • the processing is necessary for the execution of a contract of which you are a party or for the execution of pre-contractual measures adopted at your request; 
  • in the presence of a legitimate interest of IAN provided that the interests or fundamental rights and freedoms of the data subject that require the protection of personal data do not prevail;
  • by virtue of a legal obligation.

The granting of consent to the processing of personal data is never necessary for the processing connected and / or indispensable to fulfill legal obligations and / or European legislation, to fulfill pre-contractual and contractual obligations. To follow up, before the conclusion of the contract, to your specific requests and to fulfill the obligations deriving from a contract, you are free to provide the personal data requested from time to time. However, their failure, partial or inaccurate conferment could make it impossible to provide the requested services.
The consent of the interested party is necessary for the pursuit of the purposes indicated in the table for which the legal basis of the processing is your consent.

Consent for these purposes is always optional and where given it may be revoked at any time, according to the methods described in the “Rights of the interested party” section of this notice. In the absence of your consent but without prejudice to your right to object to the processing in the manner described in the “Rights of the interested party” section of this notice, IAN may send commercial communications using the e-mail coordinates provided by you in the context of the relationship existing contract for the sending of commercial offers according to the “soft-spam” logic.

ID profile: registration to the reserved area and social login you can access the reserved area. Already registered users, in order to continue to access the reserved area, must accept the Terms and Conditions for the creation of the new ID profile, not being no longer can use the former.

Access to the reserved area is allowed by creating an account through the web portal and the IAN mobile APP.

The following list states the purposes for which your personal data are processed by IAN and the legal basis on which the processing is based.

Registration

Personal Data is collected when the profile is created on one of the web portals or apps dedicated to this enabling. The creation of the profile allows you to access, with a single username and password, the web portals and mobile app of the IAN. 

Access after registration: You can access the reserved area only through the profile created. After creating the ID profile, some Personal Data may be made available to other partner companies enabled for the profile if you wish to access the respective reserved areas of the web portals and mobile app. The data will be processed for the sole purpose of verifying your credentials and allowing you to access it easily and without further charges from any country in which an IAN company is present.

Access to the reserved area is allowed in the following ways:

a) By creating an account through this web portal, or other portals or mobile apps of the company enabled to create the profile; 

b) Through the use of credentials provided by a social network (so-called “social login”), in particular the identities created on Facebook and Google+.
In the event that you decide to access the reserved area via the credentials of a social network, IAN will have to acquire some of your personal data (Name, Surname, Email) in accordance with the authorizations you have issued to the social network of reference. You are therefore required to check the settings provided by the reference social network and to carefully read the related privacy policies, as they may authorize the social network to share your personal data with IAN, thus authorizing IAN to collect information such as contacts, friends and other personal data. In any case, IAN will not be aware of the registration data used by you. 

IAN will keep the identification code associated with your account at the reference social network service when you use it to login to IAN or to share content hosted by the site; storage will take place for as long as necessary to provide the requested services.

If you create an IAN account or use the site’s services by connecting through the social login, IAN may use the information contained in the source account to complete your profile on the site. You can update or change your profile information and contact details at any time through the social login.

Marketing and / or profiling purposes

Within the reserved area, in the “Consent Management” section, you can freely decide whether to consent to the use of your personal data for sending advertising material, direct sales, including telephone, for the placement of products or services, for commercial communications or marketing activities and for carrying out market research relating to the products and / or services offered by IAN, relative companies, subsidiaries and / or associates or commercial partners of IAN.

Furthermore, within the reserved area you can freely decide whether to consent to the use of your personal data by IAN, by parent companies, subsidiaries, affiliates or commercial partners of IAN, for profiling activities on your consumption habits and on personal data and information acquired by observing the use of the products or services offered, in order to propose personalized offers.

The prior acquisition of your consent for the purposes of marketing and profiling as described above is not required when contact is made through telephone numbers (landline and / or mobile) and paper mail addresses belonging to subjects present in public telephone directories, relation to which the discipline on the subject of the Public Register of Oppositions is applicable, which allows the processing of such contact data for those who have not exercised the right of opposition.

Consent for the aforementioned marketing and profiling purposes is optional and does not prevent the possibility of using the products or services offered by IAN.

Recipients of personal data

For the pursuit of the aforementioned purposes, IAN may need to communicate, in Italy and abroad, including countries not belonging to the European Union, your personal data to third parties, to execute the contract, in fulfillment of obligations of law or for carrying out activities instrumental to the provision of the requested services. Employees, consultants, collaborators, temporary workers and / or any other natural person who carries out their business on the basis of instructions received from IAN may be recipients of the data or may learn about them. These subjects are specially designated persons authorized for the processing. Furthermore, data recipients may be subjects belonging to the following categories:

a) bodies, public and private authorities and supervisory and control bodies, when this is necessary for the granting of grants, contributions, subsidies and facilities of any kind, connected with the supply of IAN products and / or services, or when required by specific legislative, regulatory and authorization provisions;

b) subjects who perform tasks of a technical or organizational nature on behalf of IAN; carry out acquisition, data entry, storage and processing services of the data necessary for the use of the services offered; provide services for the management of the IAN technological infrastructure; carry out transmission, enveloping, transport and sorting of communications to the customer; they carry out customer assistance activities; carry out checks, audits and certification of the activities carried out by IAN, also in the interest of their customers;

c) Banking institutions and credit card companies; other operators in the sector for the management of related relationships; firms and companies in the field of assistance and consultancy relationships, including legal;

d) external companies, including foreign companies, which operate in the insurance sector and in the granting of loans, including payment extensions, when permitted by current legislation, for the purposes of preventing and controlling the risk of insolvency, fraud control and credit protection, as well as subjects operating in the field of out-of-court and judicial credit recovery (companies and / or law firms), banks or factoring companies, in the event of credit assignments;

e) companies that are part of parent companies, subsidiaries and affiliates of IAN, for administrative and accounting management and control purposes;

f) external companies, including foreign companies, operating in the sector of providing analysis and processing of consumption data services and digital consumption monitoring services;

g) affiliated companies, subsidiaries or associates, third parties, business partners of IAN, for direct marketing purposes, in compliance with the provisions of the GDPR, subject to obtaining your consent.

The subjects belonging to the above categories will process the data as autonomous autonomous Data Controllers or as Data Processors or Authorized Persons, specially designated by IAN. To the managers and persons authorized for processing, possibly designated, IAN will issue adequate instructions, aimed at the adoption of adequate security measures, in order to ensure the confidentiality, security and integrity of the data.

Transfer of personal data

Your personal data will be processed within the European Union and stored on servers located within the European Union. The same data may be processed in countries outside the European Union, provided that an adequate level of protection is guaranteed, recognized by a specific adequacy decision of the European Commission. Any transfers of personal data to non-EU countries, in the absence of an adequacy decision by the European Commission, will be possible only if adequate guarantees of a contractual or contractual nature are provided by the Data Controllers and Managers involved, including binding corporate rules and standard contractual clauses of data protection.

The transfer of your personal data to third countries outside the European Union, in the absence of an adequacy decision or other adequate measures as described above, will be carried out only if you have explicitly consented to it or in the cases provided for by the GDPR and will be treated in his interest. In these cases, we inform you that, although IAN adopts operating instructions common to all the countries in which it operates, the transfer of your personal data may be exposed to risks associated with the peculiarities of local legislation on the processing of personal data.

In the event that you access IAN services through the platform outside the European Union, your personal data may be transferred to third countries to allow you to use these services. In the absence of an adequacy decision or other appropriate measures, these will be processed in your interest and only for the purpose of executing the contract or pre-contractual measures requested by you.

Retention period of personal data

The Personal Data processed for the purposes described in the chapter “Purpose and legal basis of the processing” will be kept in compliance with the principles of proportionality and necessity, and in any case until the purposes of the processing have been pursued.

In the event that you have signed a contract with IAN, your personal data will be stored and processed as long as the contractual relationship exists and in any case your personal data will be kept for a period of 10 years from the termination of the contractual relationship after which will be deleted, without prejudice to further conservation of the same where necessary to fulfill specific legal obligations or provisions of the Authority, for the collection of residual credits and for the management of disputes, complaints and legal actions.

In the event that you have given consent to the processing of your personal data for the marketing and / or profiling purposes referred to in chapter 6 of this information, your personal data will be processed for the aforementioned purposes:

In force of the contractual relationship, until the revocation of the consent given; – from the moment of termination of the contractual relationship, for a period not exceeding 24 months, for marketing purposes, for a period of 12 months for profiling purposes, without prejudice to the right to object at any time and to withdraw consent provided in the manner described in the paragraph “Rights of interested parties”.

Rights of interested parties Pursuant to art. 15 - 22 of the GDPR

In relation to the Personal Data processed, you have the right, where applicable, to:
a) Access and request a copy;
b) Request rectification;
c) Request cancellation;
d) Obtain the limitation of processing;
e) Opposition to the processing;
f) Receive in a structured format, commonly used and readable by an automatic device and to transmit such data without hindrance to another data controller; where technically feasible.

The interested party also has the right not to be subjected to a decision based solely on automated processing unless the decision is necessary:
a) for the conclusion or execution of a contract with the owner;
b) is authorized by law
c) is based on explicit consent.

In cases a) and c) the interested party has the right to express their opinion, contest the decision and obtain human intervention from the Data Controller.

We inform you that you still have the right to object at any time to the processing of your personal data for direct marketing purposes, including profiling, to the extent that it is connected to such direct marketing. The right to object to such processing carried out through automated means of contact also extends to the processing of personal data through traditional means of contact, unless you wish to object only in part.

If you object to the processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

To exercise your rights and to withdraw your consent, you can send a communication to the dedicated email address: privacy@ian-edu.com.

For more information relating to your personal data, you can contact the Data Protection Officer, who can be reached at the following dedicated e-mail address: RESPONSIBLE@ian-edu.com.

We remind you that it is your right to lodge a complaint with the Guarantor for the Protection of Personal Data, by:
a) registered letter with return receipt addressed to the Guarantor for the protection of personal data, Via Cupa Vicinale Sant’Aniello, 140, 80046, San Giorgio a Cremano Naples;
b) e-mail to the address: info@ian-edu.com Information updated January 2021

Cookie management through browser settings

Almost all Internet browsers allow you to check which cookies are present on your hard drive, block all cookies or receive a warning every time a cookie is installed. In some cases, however, failure to install a cookie may make it impossible to use some parts of the site.

Below are the methods offered by the main browsers to allow the user to express their options regarding the use of cookies:
• Internet Explorer
• Chrome 

• Firefox
•Opera
• Safari
• Android.

If you use a mobile device, you should refer to its instruction manual to find out how to manage cookies.

For more information on cookies, including how to view those that have been set on your device, how to manage and delete them, visit www.allaboutcookies.org. Facebook and Adobe Marketing Cloud cookies can be rejected according to the procedure indicated by the two suppliers. Therefore, using the site without rejecting these cookies implies the user’s consent to the processing of their data by Facebook and Adobe Marketing Cloud, limited to the methods and purposes indicated above.

To consult the privacy policy of the Facebook company, the user is requested to visit the website: https://www.facebook.com/policies/cookies/.

To consult the Adobe Marketing Cloud privacy policy, the user is requested to visit the website: https://www.adobe.com/it/privacy.html

Google Analytics cookies can be rejected according to the procedure indicated by Google (see: https://tools.google.com/dlpage/gaoptout?hl=it).

Therefore, use of the site without rejecting Google cookies implies the user’s consent to the processing of their data by Google, limited to the methods and purposes indicated above.

To consult the privacy policy of the Google company relating to the Google Analytics service, the user is requested to visit the website: http://www.google.com/analytics/learn/privacy.html 

To learn about Google’s privacy policies, the user is requested to visit the website: http://www.google.com/intl/it/privacy/privacy-policy.html

If the user does not want to associate the visit to the pages of the site with his social account, he must log off. Below are the methods offered by the main social networks to allow the user to disable social plugins:
• Facebook: access your account, privacy section
• Twitter
• LinkedIn
• Firefox
• Google+

For more information on the processing and use of data through social networks, as well as on the settings for the protection of privacy, it is advisable to check the privacy policies of the respective social networks or websites. Below are the links in question:
• Facebook
• Twitter
• LinkedIn
• Google+

For more information on the processing of the user’s personal data, consult the Privacy Policy or contact us at info@ian-edu.com

 

Last Update + 13 January 2021