Information on the processing of personal data

Pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (GDPR)

Foreword

This information is provided for the www.upskill40.it/(Site) and for the platforms its.upskill40.co.uk/ e companies.upskill40.co.uk/ (jointly Platforms, individually Platform).

The Site and Platforms are owned by Upskill 4.0 S.r.l., headquartered at Via Torino, 107 - 30172 Venice - Mestre (VE), Registered with the Chamber of Commerce of Venice Rovigo, with VAT No. 04582300275(Data Controller), as the Data Controller under the GDPR.

Registration

The information and data requested in the case of registration will be used to enable you both to access the restricted area of the Site and the Platforms and to take advantage of the online services offered by the Data Controller to registered users.

Marketing

Subject to your consent, the Data Controller may process the personal data you provide in order to send you advertising material and/or newsletters relating to its own or third parties.

Profiling

Subject to your consent, the Data Controller may process your personal data for profiling purposes, i.e. for the analysis of your consumption choices through the revelation of the type and frequency of your purchases, in order to send you advertising material and/or newsletters related to its own or third parties, of your specific interest.

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In compliance with the GDPR, we hereby wish to inform you that the Data Controller will process your personal data under the following conditions.

Art. 1. Purpose and legal basis of processing. Compulsory or optional conferment. Consequences of refusal to process.

The processing of personal data is directed toward achieving the following purposes:

a. to allow registration on the Site and/or the Platforms and access to services reserved for registered users as well as to allow compliance with obligations arising from the law or regulations in force, in particular, in the administrative, accounting, public security. The legal basis for the processing is the Data Controller's need to execute pre-contractual measures adopted at the request of the data subject or to comply with a legal obligation;

b. subject to your consent, for sending newsletters and conducting market surveys, also aimed at assessing the degree of user satisfaction, and sending advertising material relating to the Data Controller's and/or third parties, by means of systems such as email(marketing purposes); subject to your consent, for the processing of your commercial profile, through the detection and processing of your purchasing choices and habits, in order both to monitor the degree of customer satisfaction, and to send you advertising material, relating to of the Data Controller and/or third parties, of your specific interest, by means of systems such as email(profiling purposes). The legal basis for the processing is the consent of the data subject;

c. to enable the Data Controller to carry out the activities necessary and within its competence to enable the private organization, which has expressed its interest and to which the user is a member as a contact person, to access the funding payable by the Ministry of Education, University and Research(MI);

d. to enable the Data Controller to carry out the activities necessary and within its competence to enable the private organization, which has expressed its interest and to which the user belongs as a contact person, to access the initiatives specified from time to time on the Site with the private, public or institutional partners indicated from time to time with reference to the specific initiative on the Site.

e. to respond to Your inquiries through the service. Providing this information is optional, but your refusal will make it impossible for the Data Controller to respond to your inquiries through this service. The legal basis for the processing is the legitimate interest of the Data Controller in fulfilling your requests. This legitimate interest is equivalent to the user's interest in receiving responses to communications sent to the Data Controller;

f. to respond by email to Your requests. The provision is optional, but your refusal will make it impossible for the Data Controller to respond to your requests. The legal basis for the processing is the legitimate interest of the Data Controller in responding to your requests. This legitimate interest is equivalent to the user's interest in receiving responses to communications sent to the Data Controller.

g. to execute the benefits and services made available by the Site and the Platforms. In particular, for activities pertaining to applications for the funding disbursable by the MI and for the initiatives and projects present on the Platforms. The legal basis for the processing is the obligation of the Data Controller to implement contractual obligations incumbent on the Data Controller. In particular, this includes obligations between the Data Controller and private organizations wishing to apply for funding.

Consent to the processing of your data for marketing and profiling purposes is purely optional. Failure to consent will only imply the consequences described below.

Failure to consent to the processing of data for marketing purposes will result in the impossibility for you to receive advertising material related to of the Data Controller and/or third parties as well as the impossibility for the Data Controller to conduct market surveys, including those aimed at assessing the degree of user satisfaction, as well as to send you newsletters.

Failure to consent to the processing of your personal data for profiling purposes will make it impossible for the Data Controller to elaborate your commercial profile, through the detection of your purchasing choices and habits as well as to send you advertising material, related to of the Data Controller and/or third parties, of your specific interest.

Notwithstanding the foregoing, it is understood that the Data Controller may still use your personal data for the sole purpose of properly fulfilling its obligations under applicable laws and its obligations arising from the contractual relationship between you and the Data Controller.

Please note that you may also object to the processing of your personal data via the appropriate link at the bottom of any promotional content email sent by the Data Controller.

Special or judicial data

The Data Controller does not process special or judicial data.

Art. 2. Modalities of processing.

The processing of your personal data will be mainly carried out with the aid of electronic or otherwise automated means, in the manner and with the appropriate tools to ensure their security and confidentiality in accordance with the GDPR.

The information acquired and the manner of processing will be relevant and not excessive in relation to the type of services rendered. Data will also be managed and protected in environments whose access is under constant control.

Art. 3. Communication and dissemination of data

Your data may be disclosed:

  • To the MI. Communication is required to manage the application for funding of projects that are uploaded, shared and submitted through the Platform
  • To the various Ministries, Entities and public or private entities to which the communication is necessary in order to implement the projects and initiatives specified from time to time on the Site and to which the user intends to join, or to manage the application for funding of the projects that are uploaded, shared and submitted through the Platform and referred to these various Ministries, Entities and public or private entities
  • to all those entities (including Public Authorities) that have access to personal data by virtue of regulatory or administrative measures
  • to companies, consultants or professionals that may be entrusted with the installation, maintenance, updating and, in general, the management of the hardware and software of the Data Controller or that the latter uses for the provision of its services
  • to external companies in charge of sending advertising communications on behalf of the Data Controller
  • to employees and/or collaborators of the Data Controller
  • to all those public and/or private entities, individuals and/or legal entities (legal, administrative and tax consulting firms, Judicial Offices, Chambers of Commerce, Chambers and Offices of Labor, etc.), if the communication is necessary or functional for the proper fulfillment of obligations arising from the law
  • to all those entities, public or private, to which communication is necessary in order to properly execute the activity of communication to the MI for the application for funding, or possibly to other Ministry for the same purpose or for different purposes from time to time specified online on the Site and/or on the Platforms.

Art. 4. Data Controller.

The Data Controller can be contacted at the following contact details:

Upskill 4.0 Ltd.
Address: Via Torino, 107 - 30172 Venezia - Mestre (VE)
Email: info@upskill40.it
Through the contact form on the Site.

Art. 5. Retention of personal data

Personal data will be retained according to the following logics: (i) for purposes of legal defense of the Data Controller, until the relevant judgment becomes final; (ii) for purposes of complying with the legislation applicable from time to time, for the time necessary for this purpose; (iii) for the purpose of performing any service requested through the Site or the Platforms, including the request for funding to the MI (i.e. to the various Ministries, public or private entities indicated in Art. 3), for the time necessary to execute the request; (iv) to demonstrate that the Data Controller's contractual obligations have been properly fulfilled; (v) for marketing purposes, until consent is revoked. For inactive users, personal data will be deleted after one year from the sending of the last email possibly viewed.

Art. 6. Rights of the data subject

Pursuant to Article 13 of the Privacy Regulations, the Data Controller informs you that you have the right to:

  • to request from the Data Controller access to and rectification or erasure of personal data or restriction of processing concerning you or to object to its processing, as well as the right to data portability
  • Revoke consent at any time without affecting the lawfulness of processing based on consent given before revocation
  • Propose a complaint to a supervisory authority (e.g., the Data Protection Authority).

The above rights may be exercised with a request addressed without formality to the Data Controller at the contacts indicated above.

Art. 7. Amendments

The Data Controller reserves the right to make changes to this policy at any time, giving appropriate publicity to the users of the Site and ensuring in all cases an adequate and similar protection of personal data. In order to view any changes, you are encouraged to consult this policy on a regular basis.

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