Information regarding the processing of personal and sensitive data via website, cookies and the sending of an information brochure

INFORMATION REGARDING PRIVACY with respect to REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27th  April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and with reference to ARTICLE 13 of Law Decree  196/2003 for the collection of informed consent to the processing of sensitive personal data for the purposes of protection in accessing the website and the related services provided by this Owner.

 

Dear Sir/Madam,

with respect to Regulation (EU) 2016/679 of the European Parliament and Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and with reference to Law Decree 196/ (on the protection of personal data, hereafter referred to as “Code”)): our company, as a data processor and the owner of the information, is required to inform you regarding the processing of your personal data. We inform you that this data will be processed in an appropriate manner following principles of legality, correctness, relevance, necessity and restraint for the duration of all operations, which will be done with attention to transparency, protecting your privacy, your dignity and your rights.

 

 

These pages describe how the site is managed, with reference to the processing of user data. This information is also given with respect to Article 13 of Law Decree n.196/2003 Personal Data Protection Code, for those accessing the websites:

 

www.symenglish.com

www.symenglish.it

www.milano.symenglish.it

www.verona.symenglish.it

www.sgl.symenglish.it

 

 

which correspond to the main pages of the Owner’s websites.

This information is given only for these sites and not for other sites that the User may access via links from the Owner’s websites.

 

This information is based on DIRECTIVE 2009/136/CE OF THE EUROPEAN PARLIAMENT AND COUNCIL of 25th November 2009, Directive 2009/136/EC of the European Parliament and of the Council of 25 November 2009 amending Directive 2002/22/EC on universal service and users’ rights relating to electronic communications networks and services, Directive 2002/58/EC concerning the processing of personal data and the protection of privacy in the electronic communications sector and Regulation (EC), No 2006/2004 on cooperation between national authorities responsible for the enforcement of consumer protection laws, Directive 2009/140/EC of the European Parliament and of the Council of 25 November 2009 amending Directives 2002/21/EC on a common regulatory framework for electronic communications networks and services, 2002/19/EC on access to, and interconnection of, electronic communications networks and associated facilities, and 2002/20/EC on the authorisation of electronic communications networks and services” and Recommendation n. 2/2001 adopted by European data protection bodies on 17th May 2001 which established minimum requirements for collecting personal data online, particularly the method, timing and nature of the information that data controllers must provide to users when they connect to webpages, regardless of the purpose.

 

The disclosure also incorporates the provisions of the measures: « Identification of simplified disclosure procedures and the acquiring of consent for the use of cookies – 8th May 2014 [3118884] » and the recommendation: « Internet: Privacy guarantor, no to cookies for profiling without consent. »

 

After consulting this site, data relative to identified or identifiable persons may be processed.

 

 

  1. WEBSITE DATA PROCESSING

 

DATA PROCESSING LOCATION

 

The processing of data related to the web services of this website takes place mainly at the headquarters of the owner and are done solely by staff who have this responsibility, or by others performing occasional maintenance operations. Systems engineering activities and work on related services can also be carried out at the headquarters of external agents who have been given responsibility for this work. The servers are physically located at the ISP (Internet Service Provider)’s premises where only occasional maintenance is done.

 

In the course of normal operations, computer systems and software procedures used to operate this website acquire personal data whose transmission is implicit in the use of internet communication protocols. This information is not collected to be associated with identified persons, but by their very nature they could be used to identify users through processing and associations with data held by third parties.

 

This category of data includes IP addresses or domain names of computers used by users connecting to the site, URIs (Uniform Resource Identifier) of requested resources, request times, the method used to submit the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the response from the server (successful, error, etc…) and other parameters regarding the operating system and computer environment. This data is used only to obtain anonymous statistical information about the site and to check its correct functioning and is deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical crimes against the site: except in this case, the data on web contacts do not remain for more than seven days. They remain anonymously in order to indicate the country of origin of the computer that is logged on to the site, so as to make global statistics.

 

 

DATA PROVIDED VOLUNTARILY BY THE USER

The optional, explicit and voluntary insertion of your e-mail address in the relevant area of the site’s homepage give us consent to send you information and advertising commercial communications concerning services provided by the Owner.

At any time you can unsubscribe from the service in question via the link that will be sent via e-mail.

The optional, explicit and voluntary sending of e-mails to the addresses listed on this site involves the subsequent acquisition of the sender’s name and address, which are necessary in order to respond to requests, and any other personal data in the message.

Any specific summary information will be progressively reported or displayed in the site pages dedicated to particular services on request.

 

The optional, explicit and voluntary registration of the user through masks (so-called forms) offered by the site, in order to provide related services, involves the acquisition of personal data for performance of works as indicated in the forms.

 

The Data Processor is:

Speak Your Mind S.R.L.

VAT number 02080930239

Tax Code 02080930239

 

238 Via Federico Garofoli

37057 San Giovanni Lupatoto (VR)

Italy

 

info@symenglish.com

Tel: +39 0458030675

Fax: +39 045803603

 

 

  • Data purposes and processing methods.
    • Your data will be used to:
  • Establish and perform services which you have requested, and fulfil obligations set by the law, regulations, community norms and collective contracts;
  • The provision of services, which may also be via internet;
  • Your personal details, and in particular your name and e-mail address, which you will provide in the relevant fields (on the website’s main page) will be used to send you an informative commercial brochure. The brochure will contain information about services offered by the Owner, how to access these services and will also include other technical information. This information will also be promotional and may contain direct sales advertising and commercial communications.
    • Personal data are processed manually on paper and by computer for the time strictly necessary to achieve the purposes for which they were collected. Specific security measures are observed to prevent the loss of data, illegal or incorrect use and unauthorised access.
  • Obligatory or optional nature of data provision.
    • Apart from what is specified for navigation data, the user is free to provide personal data contained in request forms or indicated in contacts with the Owner to request the sending of informative material or other communications. The provision of personal data is completely optional and we want you to provide it consciously, feeling free to give consent to what is described. The user is not required to provide these data, which will only be used for the purposes referred to in point 1.1.
  • The consequences of refusing to respond.
    • Failing to provide these data could make it impossible for requests to be fulfilled. We inform you that communicating this data is necessary in order for us to answer requests; a failure to give them, or only partially or incorrectly, will hinder the provision of services.

Should you not give your consent by entering your name and-email address where requested and ticking the relevant boxes, there will be no negative consequences, but you will not be able to receive information from us.

It should be noted that there are clearly identified cases where it is possible for data to be processed without consent, as per Article 24 of Legislative Decree. N. 196/2003. It should also be noted that public authorities may request information as per Article 157 of Legislative Decree. N. 196/2003, in order to control the processing of personal data. In these cases, a reply is obligatory and failure to do so may result in a fine.

  • Those to whom personal data could be communicated or who could learn about them, and the scope of the dissemination of said data.
  • The Owner may communicate your data to external agents or companies who collaborate in the provision of services, or who provide the Owner with commercial services. The complete list of people and companies, here listed by category, who may learn about your data is available from the Owner on request. In relation to the purposes indicated, the Owner communicates your data to the following public bodies: police, armed forces and other public bodies as per legal requirements, regulations and EU norms.
  • Your data indicated here will not be divulged.
  • The logic that the owner applies to data processing is necessary to ensure their integrity, confidentiality and availability.

 

 

 

TITLE II – DATA SUBJECT’S RIGHTS

 

 

Section 7 (Right to Access Personal Data and Other Rights)

 

  1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form.

 

  1. A data subject shall have the right to be informed

 

  1. a) of the source of the personal data;

 

  1. b) of the purposes and methods of the processing;

 

  1. c) of the logic applied to the processing, if the latter is carried out with the help of electronic means;

 

  1. d) of the identification data concerning data controller, data processors and the representative designated as per Section 5(2); and

 

  1. e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing.

 

  1. A data subject shall have the following rights:

 

  1. a) to obtain updating, rectification or, where interested therein, integration of the data;

 

  1. b) to obtain erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;

 

  1. c) to obtain certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.

 

  1. A data subject shall have the right to object, in whole or in part,

 

  1. a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;

 

  1. b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.

 

 

 

Cookie policy

 

This site uses cookies, including those of third parties, to improve users’ experiences, to allow them to use our online services and view advertising in line with their preferences.

 

What are cookies?

Cookies are small text files which are automatically placed on the PC by the navigator inside the browser. They contain basic information on internet navigation, and thanks to the browser they are recognised every time the user visits the site.

 

Information about cookies

Cookies help improve the services we offer you. Some are strictly necessary for site functionality, while others optimise performance and offer the user a better experience.

 

Functional cookies are used to:

  • Remember your access data
  • Offer you safe navigation after access
  • Give the website coherence

 

Performance cookies are used to:

  • Optimise the website by reducing page loading times
  • Improve user experience

 

Targeting cookies are used to

  • Allow users to use the “Share” and “Like” functions

 

Examples of use:

 

Cookies help improve the services we offer you, for example:

  • Allowing certain services to work that otherwise would not
  • Allowing your computer to be recognised, avoiding the need to continue inputting the same information
  • Recognising that a user name and password have already been given, avoiding the need to continue doing so at every new webpage
  • Calculating the number of service users, facilitating use and ensuring that navigation can be fast
  • Analysing data to help understand how services are used and can be improved

 

If we are not authorised to use cookies, certain functions and pages may not perform as they should.

If you wish to eliminate cookie files already present on your computer, read the instructions on your browser after clicking help on the menu of the programme you use to view webpages.

Further information about cookies and how to manage them can be found at www.aboutcookies.org or by clicking help on your browser menu.

By continuing to navigate you give your consent to the use of cookies.

It is possible to deactivate cookies at any time; we remind you that this option may impede many functions.

 

 

Managing cookies

Technical cookies

 

Activities strictly necessary for operational activities

These technical cookies allow the site to function correctly: for example, they allow users to stay logged in, making continual logins to reach successive pages unnecessary.

 

Saving preferences

These cookies allow the site to remember user preferences, such as language preferences.

 

Statistics on user numbers and activities

These cookies allow us to understand, through data collected in anonymous and aggregate forms, how users interact with our websites, giving us information relating to sections visited, the time spent on the site and any malfunctions. This helps us to improve our website performance.

 

First-party profiling cookies

These cookies, which we manage directly, help us identify the interests of users, allowing us to provide personalised content.

NB: disabling cookie profiling does not mean you will no longer view advertising while navigating on our sites, but that the advertising you see will not be tailored to your interests and thus less relevant to you.

 

Third-party profiling cookies

We have several suppliers who can in turn install cookies to help the services they provide to function better. If you wish to have more information on third-party cookies and how to disable them, go to http://www.youronlinechoices.com/it/le-tue-scelte

 

Statistical Cookies and third-party audience measurement

These cookies (third-party web services) provide anonymous information / aggregated into how visitors navigate on the site.

 

Social media sharing cookies

These third-party cookies are used to integrate some of the common features of major social media and provide them on the site, particularly site registration and authentication via Facebook and Google Connect, sharing, adding comments on social media, and functions such as “Like” on Facebook and “+1” on G+.

 

For further information on third-party cookies see the following sites: Google Analytics, Open University, YouTube, w55c.net, Twitter…