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PRIVACY POLICY – MATRICULATION APPLICATION

Matriculation at Saint Louis Music Center S.r.l. and attendance and participation in courses, lectures and, in general, in educational activities, entails the collection of information that constitutes personal data under d. lgs. 196/2003 and ss.mm.ii. (hereinafter the “Code“) as well as Regulation (EU) 2016/679 (hereinafter the “GDPR“). Therefore, all information about the processing of personal data related to the Contest is rendered here.

1. DATA CONTROLLER

The Data Controller is Saint Louis Music Center S.r.l. (“the Company“), with registered office at Via Cimarra 19/B, Rome CF and VAT 05731131008, (hereinafter, the “DataController“), and provides

  • to students (hereinafter, the “Students” or “Students“) who complete the application for registration and enrollment in courses, classes, and further services offered by the Holder (hereinafter, the “Application“),
  • to their respective guarantors, who sign the Application to confirm and guarantee all obligations undertaken by the Student with the same (hereinafter, the “Guarantors” and, jointly with the Students, the “Interested Parties“),

The privacy policy in accordance with Art 13 of the GDPR.

At any time you can contact the Holder at the following contact details: privacy@saintlouis.eu or at the above address. The Owner has not identified a Data Protection Officer (DPO or DPO), as it is not subject to the designation requirement under Art. 37 of the Regulations. The Holder is part of a group of companies (hereinafter, the “Group“), which designs and delivers training in the business and education sectors.

2. DATA PROCESSED.

Biographical and Contact Information

Matriculation and attendance and participation in the Holder’s courses, classes and, in general, in the Holder’s educational activities also requires that the Learners provide – by filling out the appropriate application for matriculation and enrollment – information such as first name, last name, place and date of birth, nationality, residence/domicile, family income (ISEE), level of education and degree (hereinafter the ” PersonalData “), as well as telephone number and e-mail (hereinafter the “Contact Data“) and all additional personal data contained in the identification documents attached to the application for matriculation and enrollment. This data is necessary for the valid formalization of the application for registration and enrollment in the services offered by the Holder. In addition, the Holder expects the Guarantor to provide-at the time of completion of this application for registration and enrollment-his Personal Data.

Special Categories of Data

In the case of Pupils with specific learning disorders, disabilities or incapacities, the Holder will acquire, in addition to the Personal Data and Contact Data necessary for enrollment, also some data related to the health status of the Pupil in order to grant him/her some facilities in payments, as well as for educational purposes, including those related to logistical organization.

Student pictures

In the course of the educational and training activities in which the Learner is matriculated and enrolled, the Holder will acquire videos and/or images extracted from them made by employees and contractors of the Holder and/or other learners (hereinafter the “Materials“). The Materials may contain personal data that are likely to be punctually associated with identified individuals and that, in any case, by their very nature, could allow for the identification of students and/or employees of the Owner. All personal data listed in this paragraph are hereinafter also referred to as “Data.”

3. PURPOSE AND LEGAL BASIS FOR PROCESSING

The Materials, Biographical Data and Contact Data and, only in the case of a Learner with specific learning disorders, disabilities and/or incapacities, the Particular Categories of Data provided to him/her, will be used exclusively for:

  1. The receipt, evaluation, acceptance of the application for matriculation and enrollment submitted by the student and the full formalization of the same;
  2. Access to forms of subsidies and/or funding, on an ISEE basis, for the right to study and the calculation of school fees;
  3. Accessing and creating a student profile on the Holder’s platform in accordance with the privacy policy;
  4. Sending and receiving promotional communications and updates on the initiatives and activities of the Owner and/or other companies in the Group;
  5. verification of the degree of satisfaction with the quality of the product/service provided, statistical and market research, studies, directly or through specialized companies, interviews or other means;
  6. Direct sale and/or placement by the Holder of products and/or services, facilities and promotions of the Holder and/or other Group companies;
  7. To promote and manage placement initiatives;
  8. Direct sale and/or placement by the Data Controller of products/services, facilities and promotions of the Data Controller and/or other companies in the Group, as well as third party companies, through different sales channels or contracted third party companies;
  9. with exclusive reference to the Materials, disseminate the Materials themselves by publication and dissemination, in any form, on the Holder’s various communication channels such as but not limited to, posters and advertising pages, flyers, flyers, annual reports, video, TV and web commercials, social networks as well as on the Holder’s website, including in the form of advertising, within the limits of what is agreed to by the Student by signing the Application;
  10. Communication to companies belonging to the same Group for business and administrative needs.

The Holder also processes Guarantor Data always to the extent that this is necessary to manage the payment related to the Application and to guarantee the obligations undertaken by the Student: to such processing (xi) this privacy policy shall apply, to the extent relevant.

The legal basis on which the treatments referred to in paras. (i), (ii), (iii), (ix), and (xi) is the performance of a contract to which the Student and the Guarantor, as data subjects, are parties (the “Application“) and/or the performance of pre-contractual measures taken at the request of the data subjects (Art 6(1)(b) of the GDPR); with respect to the processing referred to in paras. (iv), (v), (vi), (vii) and (viii) is the consent of the Students registered with the Holder, given by ticking the appropriate box in the box at the bottom of this notice (Art. 6(1)(a) of the GDPR).

On the other hand, with regard to the processing under (x), the legal basis is the pursuit of the legitimate interest of the Data Controller, in line with Recital no. 48 GDPR under which “Data controllers that are part of a business group or entities related to a central body may have a legitimate interest in transmitting personal data within the business group for internal administrative purposes, including the processing of personal data of customers […].”

With regard to marketing purposes (sending and receiving promotional communications and updates on the initiatives of the Owner and/or other companies in the Group; the verification of the degree of satisfaction with the quality of the product/service provided, statistical and market research, studies, directly or through specialized companies, interviews or other means; to promote and manage placement initiatives) it is clarified that some of the Learner’s personal data (i.e., first name, last name, address e-mail…) may also be processed by the Owner for this purpose, i.e. so that the Owner may contact the Student by mail, e-mail, telephone (fixed and/or mobile, with automated call or call communication systems with and/or without the intervention of an operator) and/or SMS or other messaging systems to propose to the Student the purchase of products and/or services offered by the Owner itself and/or third party companies, present offers, promotions and business opportunities.

In the case of consent, the Learner may at any time revoke it by making a request to the Holder using the contact methods indicated in paragraph 1 above.

The Learner may also easily object to further sending of promotional e-mail communications by also clicking on the appropriate opt-out link in each promotional e-mail. Upon revocation of consent, the Holder [will send the Student an e-mail message/show the Student an on-screen message of successful disenrollment]. If the Learner wishes to revoke his or her consent to the sending of promotional communications by telephone, while continuing to receive promotional communications by e-mail, or vice versa, please send a request to the Holder in the manner indicated in paragraph 1 above.

The Holder informs that, following the exercise of the right to object to the sending of promotional communications via e-mail, it is possible that, for technical and operational reasons (e.g., formation of contact lists already completed shortly before the Holder’s receipt of the request for objection) the Learner will continue to receive some additional promotional messages. Should the Learner continue to receive promotional messages after 24 hours have elapsed since the right to object has been exercised, please report the problem to the Holder, using the contact details given in paragraph 1 above.

Finally, should the Data Controller process data belonging to special categories (e.g., in the case of a Pupil with a disability or incapacity), it will do so lawfully under Art. 9(2)(a) of the GDPR, namely the explicit consent of the data subject, as well as Art. 9(2)(f) in order to establish, exercise or defend a right in court or whenever the judicial authorities exercise their jurisdictional functions, putting in place appropriate safeguards for your fundamental rights and interests as well as applying suitable and adequate processing methods and security measures chosen by the Data Controller by virtue of and in compliance with the principle of accountability of the Data Controller, provided for by the GDPR and, in any case, in compliance with any instructions and/or specific fulfillment provided for by the Supervisory Authorities on the processing of personal data.

4. RECIPIENTS OF DATA COMMUNICATION

The Data will be communicated to and may be known by: (i) employees and collaborators of the Owner, duly designated for processing pursuant to Art. 29 of the GDPR; (ii) third parties who provide services ancillary or instrumental to the management of the Holder’s school activities, enrollment and registration applications, duly appointed as external data controllers or independent data controllers; (iii) third party providers of IT services, IT consulting, e-mail marketing, duly appointed as external data controllers or independent data controllers, for the management of internal IT systems, business management and the career platform, including the sending of electronic communications and newsletters; (iv) the companies operating the social networking and/or instant messaging platforms for the eventual publication of the Materials; and finally (v) consultants, as autonomous owners, for the management of administrative and tax activities, litigation management and legal assistance in the event of any disputes for which their involvement would be necessary.

The Student may also request from the Controller the list of individuals who will act as data processors (in which case, they are appointed in writing by the Controller, pursuant to Article 28 of the GDPR, and will process personal data on behalf of the Controller) or as autonomous data controllers. In any other case, the Data will not be disclosed to third parties, unless this is necessary to comply with requests from public authorities.

5. PLACE OF DATA PROCESSING

The processing of Data will take place at the aforementioned location of the Data Controller. Data will be stored at servers and/or physical archives located exclusively within the European Union. However, in the event that Data is transferred outside the European Union, the Data Controller will ensure that the transfer takes place in accordance with the GDPR and, in particular, in accordance with Articles 45 (Transfer on the basis of an adequacy decision) and 46 (Transfer subject to adequate safeguards) of the GDPR.

In no case will Data be processed or transferred outside the territory of the European Union or to countries that do not provide adequate guarantees of personal data protection. Regarding the publication on social networks of Images more information on the management of personal data by these platforms can be found in their terms and conditions of use.

6. PROCESSING METHODS, STORAGE PERIOD AND SECURITY MEASURES

The Data Controller will process the Data with and without the aid of electronic, computerized or automated tools, taking specific and adequate logical, organizational and technical security measures to prevent the loss of the Data or their unauthorized or unlawful use.

Data will not be processed and stored for longer than is strictly necessary to achieve the purposes for which it was collected. In particular, a period that allows: (i) to the Learner to attend courses and classes organized and rendered by the Holder; (ii) to collect, organize, neatly store registration applications and releases; and (ii) to publish the Materials also for promotional purposes.

More precisely:

  • the image will be retained in the manner and at the times defined by the release in Article 9 of the Application;
  • the Data collected for the pursuit of marketing purposes will be retained for the time strictly necessary to fulfill the purposes outlined in paragraph 3 above and, in any case, until the Student revokes his or her consent and in any case for no longer than 24 months;
  • Data contained in registration and enrollment applications and releases will be retained for a period equal to the period required by the statute of limitations, subject to the need to protect the interests of the Holder and the Student in civil law.

7. MANDATORY NATURE OF DATA PROVISION

The provision of Data for the purposes set forth in paragraph 3. (i), (ii), (iii), (ix) and (x) is optional, but necessary since failure to provide the same will result in the inability of the Student to submit the Application and perform the commitments made therewith.

In the case of Pupils with specific learning disorders, disabilities or incapacities, the provision of certain data related to the health status of the Pupil is optional but necessary, as, without it, it will not be possible to (a) grant him any facilities, or (b) for educational purposes, and thus to enable the Holder to better organize logistics in the interest of the Student.

With reference to the marketing purpose (paragraph 3 (iv), (v), (vi), (vii) and (viii)) the provision of Data is merely optional, in fact; even in case of refusal, the Student will still be able to submit the Application and take the exams.

8. RIGHTS OF THE DATA SUBJECT

Data Subjects are holders of rights conferred by the GDPR. In particular, under Articles 15-22 of the GDPR they have the right to request and obtain the indication:

  • Of the origin of personal data;
  • Of the purposes and methods of processing;
  • Of the logic applied in the case of processing carried out with the aid of electronic instruments;
  • Of the identifying details of the owner and responsible parties;
  • Of the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of them in their capacity as managers or appointees.

In addition, Learners have the right to obtain:

  • access,update,rectifyor, when they have an interest,supplementthedata;
  • thecancellation,transformation into anonymous formorlimitationofdata processed in violation of the law, including data whose retention is not necessary in relation to the purposes for which the data were collected or subsequently processed;
  • A statement that the operations referred to in paras. (a) and (b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except where this proves impossible or involves the use of means manifestly disproportionate to the right protected. 
  • In addition, Students have:
  • The right towithdraw consentatany time if the processing is based on their consent;
  • The right todata portability(the right to receive all personal data concerning them in a structured, commonly used, machine-readable format);
  • theright to object:
    • in whole or in part, for legitimate reasons to the processing of personal data concerning them, even if relevant to the purpose of collection;
    • in whole or in part, to the processing of personal data concerning them for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication;
  • where personal data are processed fordirectmarketing purposes, at any time to the processing of their data carried out for that purpose, including profiling insofar as it is related to suchdirectmarketing;
  • should they believe that the processing concerning them violates the GDPR, the right tolodge a complaint with a Supervisory Authority(in the Member State where they usually reside, in the Member State where they work, or in the Member State where the alleged violation occurred). The Italian supervisory authority is theGarante per la protezione dei dati personali, based at Piazza Venezia no. 11, 00187 – Rome (http://www.garanteprivacy.it/).

In order to exercise your rights, you can always contact the Controller at the contact details above.

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