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Privacy Policy

The purpose of this privacy policy is to provide all the information on the processing of personal data carried out by Saint Louis Music Center srl when the User accesses and navigates this site and/or the social pages linked to it (as better indicated below).

1. INTRODUCTION – WHO WE ARE

Saint Louis Music Center srl with registered office in Via Cimarra, 19/b, 00184, Rome (RM), Fiscal Code No. 05731131008, VAT No. (IT) 12581670960 and registration number with the Register of Companies of 12581670960 (hereinafter, “Owner“), owner of the website www.saintlouis.eu and the social pages linked to it (hereinafter, the “Site“), as the owner of the processing of personal data of users who browse the site (hereinafter, “Users“) provides below the privacy policy pursuant to Art. 13 of EU Regulation 2016/679 of April 27, 2016 (hereinafter, “Regulation,” or “Applicable Legislation“).

2. HOW TO CONTACT US?

The Owner holds in the highest regard the right to privacy and protection of personal data of its Users. For any information in relation to this privacy policy, Users may contact the Controller at any time using the following methods:

  • By sending a registered letter with return receipt to the Holder’s registered office at Via Cimarra, 19/b, 00184, Rome (RM);
  • By sending an e-mail message to. privacy@saintlouis.eu.

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.

3. WHAT DO WE DO? – PURPOSE OF PROCESSING AND LEGAL BASIS

Through browsing the Site, as well as by consulting the Holder’s social pages linked to it, the User can find out about services offered by the Holder, events organized (e.g., open days), educational offerings, news related to the school and its locations, and can also purchase products through the online shop. Through its social pages, it can also interact with the Holder and its community.

In addition, the User may:

    1. Access the school’s restricted area to enable students to use online academic services, manage authentication credentials, ensure account security, and use educational and administrative services related to the student-school relationship (hereinafter, “Restricted Area Access“);
    2. Requesting information services, guidance, submitting requests as well as Participate in educational and professional activities promoted by the school or proceed with the purchase of the products displayed in the online shop, such as:
      • Submit requests regarding the publication of content, profiles or projects in dedicated sections of the site (e.g., Alumni area or similar initiatives) and manage the resulting communications with the interested party
      • Request more information about the various courses offered by the school (hereinafter, “Course Information“);
      • Book an orientation meeting to get detailed information or visit campuses (hereinafter, “Individual Interview“);
      • Ask about all scholarships (hereafter, “Scholarships“);
      • Participate in master classes organized by the Holder by filling out the “Masterclass” form (hereinafter, “Masterclass“);
      • Apply for specific services, such as, but not limited to, enrolling in Career Service, by filling out the appropriate “Are you an artist?” form (hereafter, “
      • Career Service“);
      • Submit your own project by filling out the “Propose Your Project” form;
      • Send your spontaneous application in the “Work with Us” section via the “Sponataneous Application” form;
      • Contact the Holder using the contact information provided or by filling out the form, both of which can be found in the “Contact Us” section (hereinafter “Contact the Holder“);
      • Submit a direct application (for which, however, please refer to related privacy policy, which can be reached from the dedicated form).
      • Interacting with the Owner’s social community, (hereinafter, “Social Interaction“).
      • Enroll in Holder’s courses, including but not limited to three-year, master’s, creative experience courses (hereinafter,“Courses“);
      • Become a partner of the owner by filling out the appropriate form “Are you a company?” (hereinafter“Become a Partner“);
      • Apply for the Erasmus program as a student or faculty member (hereinafter, “Erasmus Program“).
      • Request information on conventions offered by Saint Louis (hereinafter, “Convention Information“);
      • Register for the open day to learn more about the school (hereinafter, “Open Day“);
      • Purchase products (by way of example only, books and records), in execution of the Terms and Conditions of the Service, and the handling of orders, shipments, and any after-sales service (hereinafter, “Shop“).

(hereinafter, all together the “Service” or the “Services“).

In connection with the Service, the Owner collects personal data about Users.

Specifically, personal data of Users will be lawfully processed by the Data Controller for the following purposes. purpose of treatment:

(a) Provision of Service: To enable the provision of the Service by the User’s browsing of the Site.

Depending on the specific aspect of the Service enjoyed, the Owner may process:

  • Browsing data: all those personal data whose transmission is implicit in the use of Internet communication protocols, such as: IP addresses used by users who connect to the Site, the URI (Uniform Resource Identifier) notation addresses of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, log files and other parameters relating to the User’s operating system and computer environment.
  • First name, last name, e-mail address, telephone number, as well as all further personal information requested within the various forms and/or communicated within the chat, as well as all further data eventually and voluntarily communicated by the User including, where deemed necessary by the interested party/functional to the request, any data belonging to the special categories ex art. 9 of the Regulations (e.g. data related to health).
  • Billing information: i.e., first name, last name, VAT or tax identification number, country/region, street and number, city, province, zip code, telephone, email.
  • (in the case of Social Interactions) the nickname and contact details of the User on the specific social network used, as well as comments and interactions with the content of the Owner’s social pages.

Unless the User gives the Data Controller a specific and optional consent to the processing of his/her data for the additional purposes provided in the following paragraphs, the User’s personal data will be used by the Data Controller for the sole purpose of ascertaining the identity of the User (including by validating the e-mail address), thus avoiding possible fraud or abuse, and contacting the User for service reasons only (e.g., sending notifications regarding the services offered by the Data Controller). Notwithstanding the provisions elsewhere in this privacy policy, under no circumstances will the Owner make Users’ personal data accessible to other Users and/or third parties.

In some forms, required data will be indicated with an asterisk: in the absence of such a symbol, it should be understood that all required data are required.

(b) administrative-accounting purposes, or to carry out activities of an organizational, administrative, financial and accounting nature, such as internal organizational activities and activities functional to the fulfillment of contractual and pre-contractual obligations;

(c) legal obligations, or to fulfill obligations required by law, authority, regulation or European legislation.

The provision of personal data for the above processing purposes is optional but necessary, as failure to provide such data will make it impossible for the User to browse the site and take advantage of the Services offered by the Owner on the Site.

Notwithstanding the provisions elsewhere in this privacy policy, under no circumstances will the Owner make Users’ personal data accessible to other Users and/or third parties.

In relation to the purposes described, the following are identified. legal bases Of treatment:

  • Service Management (as described by par. 3, lett. above. (a)): the legal basis consists of Art. 6, para. 1, lett. (b) of the Regulations, i.e. the processing is necessary for the performance of a contract to which the User is a party or the performance of pre-contractual measures taken at the User’s request. In case of processing of personal data belonging to special categories, the legal basis consists of Art. 9 para. 2, lett. (a) of the Regulations, or the explicit consent given by the data subject by voluntarily communicating such data to the Controller within the open fields of the form or of the chat.
  • Administrative-accounting purposes (as described by Sec. 3(b) above): the legal basis consists of Art. 6(1)(b) of the Regulations, insofar as the processing is necessary for the performance of a contract and/or the execution of pre-contractual measures taken at the User’s request.
  • Legal obligations (as described by Sec. 3(c) above): the legal basis consists of Art. 6(1)(c) of the Regulations, as the processing is necessary to fulfill a legal obligation to which the Data Controller is subject.

4. ADDITIONAL PROCESSING PURPOSES

4.1 Marketing (sending advertising material, direct sales and commercial communication)
In case of user registration via dedicated webform and/or provision of consent during another request, some of the User’s personal data (i.e. first name last name, e-mail address and phone number) may also be processed by the Controller for purposes of marketing (sending of advertising material, direct sales and commercial communication), or so that the Owner can contact the User by e-mail (newsletter), mail, telephone (fixed and/or mobile, with automated calling or call communication systems with and/or without the intervention of an operator) and/or SMS and/or messaging services and/or for the purpose of creating custom audience o lookalike on the Holder’s social pages, to propose to the User services offered by the same Holder and/or partners, present offers, promotions and business opportunities.

If consent is not given, the ability to subscribe to the Site will not be affected in any way.
In case of consent, the User may revoke it at any time by making a request to the Controller in the manner indicated in paragraph 8 below.

Specification on e-mail communications (newsletters): the User may also easily object to further sending of promotional communications via e-mail also by clicking on the appropriate link for withdrawal of consent, which is present in each e-mail Of the newsletter. If the User wishes to withdraw his or her consent to the sending of promotional communications via telephone, while continuing to receive promotional communications via e-mail, or vice versa, please send a request to the Holder in the manner indicated in Section 8 below.

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 User will continue to receive some additional promotional messages. Should the User continue to receive promotional messages after 24 hours have elapsed since the exercise of the right to object, please report the problem to the Controller, using the contact details given in paragraph 8 below.

Specification on promotional activities through social networks: in particular with regard to the interaction with social pages, if the User has given consent to the use of profiling cookies on the Site, the Owner may also, process the User’s contact data (in particular the email address) and the data communicated by the User during the interaction with the social pages – such as the information provided by the User to the social media according to the privacy settings selected on such social media – in order to show the User promotional ads and content consistent with his/her interests, based on the preferences and consumption habits identified through cookies and/or other tracking systems of social media operators (to whose terms and conditions please refer) and/or as a result of the analysis that the social media themselves perform on their users.

In particular, the Owner may display through digital platforms relevant marketing content and advertisements based on the User’s interests, whose information about preferences and interests, consumption habits, spending margins, etc. Have been acquired: (i) as a result of profiling activity performed on the Site and shared (including via API) with digital platforms, ; or (ii) based on the match between the preferences and interests expressed by the User who visited the Site and accepted the profiling cookies and the cluster of users identified by the social platform (e.g., retargeting); (iii) using the targeting tools made available by social platforms, defining the target of users potentially interested in the Owner’s services and targeting social platforms to disseminate advertising messages in a targeted manner to the users of those platforms who coincide with the defined target. In the event that the User interacts with that advertisement in the social platform, that interaction may be evaluated for the purposes of the effectiveness of the campaign itself, where the User has agreed to the use of tracking tools, such as but not limited to the Meta or Tik Tok Pixel, installed on the Site, through cookie management tools (e.g., prospecting). More information on processing by tracking tools is available in the Cookie Policy.

5. PROCESSING METHODS AND DATA RETENTION TIMES

The Data Controller will process Users’ personal data using manual and computerized tools, with logic strictly related to the purposes themselves and, in any case, in such a way as to ensure the security and confidentiality of the data.

Personal data of Users of the Site will be retained for the time strictly necessary to fulfill the primary purposes outlined in paragraph 3 above, or otherwise as necessary for the protection in civil law of the interests of both Users and the Data Controller.

In the cases referred to in paragraph 4 above, Users’ personal data will be retained for the time strictly necessary to fulfill the purposes illustrated in the same and, in any case, until the User revokes his or her consent.

6. SCOPE OF COMMUNICATION AND DISSEMINATION OF DATA
The User’s personal data may be transferred outside the European Union and, if so, the Controller will ensure that the transfer is made in accordance with Applicable Law 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 Regulations.

The personal data of Users may come to the attention of the employees and/or collaborators of the Owner in charge of managing the Site and Users’ requests. Such individuals, who have been instructed to do so by the Owner pursuant to Art. 29 of the Regulations, will process Users’ data exclusively for the purposes indicated in this notice and in compliance with the provisions of the Applicable Regulations.

Third parties who may process personal data on behalf of the Data Controller in the capacity of:

  1. Data Processors, such as, but not limited to, IT and logistics service providers functional to the operation of the Site, outsourcing or cloud computing service providers, professionals and consultants. Specifically, with reference to the newsletter service, data are also processed through the platform and IT tools offered by the “Benchmark Email” service, of the American company Benchmark Internet Group, LLC, 10621 Calle Lee, Building 141 Los Alamitos, CA 90720;
  2. Data controllers, such as, but not limited to, payment service providers for the online shop;

Users have the right to obtain a list of any data processors appointed by the Controller by making a request to the Controller in the manner indicated in paragraph 8 below.

7. RIGHTS OF INTERESTED PARTIES

Users may exercise the rights guaranteed to them by the Applicable Regulations by contacting the Owner in the following ways:

  • By sending a registered letter with return receipt to the Holder’s registered office at Via Cimarra, 19/b, 00184, Rome (RM);
  • By sending an e-mail message to: privacy@saintlouis.eu.

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.

Pursuant to the Applicable Legislation, the Owner informs that Users have the right to obtain the indication (i) Of the origin of personal data; (ii) Of the purposes and methods of processing; (iii) of the logic applied in case of processing carried out with the aid of electronic tools; (iv) of the identification details of the owner and responsible parties; (v) of the individuals or categories of individuals to whom the personal data may be communicated or who may become aware of them in their capacity as managers or appointees.

In addition, Users have the right to obtain:

  1. access,update, rectify or, when they have an interest,supplement the data;
  2. the cancellation, transformation into anonymous form or limitation of data 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;
  3. 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, Users have:

  1. The right to withdraw consent at any time if the processing is based on their consent;
  2. The right to data portability (the right to receive all personal data concerning them in a structured, commonly used, machine-readable format);
  3. the Right to object:
    1. in whole or in part, for legitimate reasons to the processing of personal data concerning them, even if relevant to the purpose of collection;
    2. 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;
    3. where personal data are processed for direct marketing purposes, at any time to the processing of their data carried out for that purpose, including profiling insofar as it is related to such direct marketing.
  4. if they believe that the processing concerning them violates the Regulations, the right to file a complaint with a regulatory authority (in the member state where they usually reside, where they work, or where the alleged violation occurred). The Italian supervisory authority is the Garante per la protezione dei dati personali, headquartered at Piazza Venezia no. 11, 00187 – Rome(http://www.garanteprivacy.it/).

The Holder is not responsible for updating all the link viewable in this Notice; therefore, whenever a link is not functional and/or updated, Users acknowledge and agree that they should always refer to the document and/or section of the websites referred to by that link.

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