Nova Consulting Learning

The data processed, provided by the data subject at the time of registration and required for the use of the Moodle e-learning platform (https://www.novaconsulting-learning.it), are collected and used within the limits established by law and are processed for the purpose of participating in the courses in which the user is enrolled.

The Personal Data collected by this Website, either independently or through third parties, may include: first name; last name; email address; place and date of birth; business sector; company of affiliation; Usage Data; Tracking Tools relating to time spent in courses; responses to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; and touch events.

Full details on each type of Personal Data collected are provided in the dedicated sections of this privacy notice or through specific information notices displayed before the Data are collected.

Personal Data may be freely provided by the User or, in the case of Usage Data, automatically collected while using this Website.

Unless otherwise specified, all Data requested by this Website are mandatory. If the User refuses to provide them, this Website may be unable to provide the Service. Where this Website specifically indicates that some Data are optional, Users are free not to provide such Data without any consequences for the availability or operation of the Service.

Users who are uncertain about which Data are mandatory are encouraged to contact the Data Controller.

Any use of Cookies - or other tracking tools - by this Website or by the providers of third-party services used by the training platform is intended to provide the Service requested by the User, in addition to the further purposes described in this document and in the Cookie Policy.

The User assumes responsibility for any third-party Personal Data obtained, published or shared through this Website.

Please note that processing is carried out in compliance with the general principles of lawfulness, fairness, transparency, adequacy, relevance, necessity and data minimisation under Article 5 of the GDPR, and that the data will be processed exclusively, including with the aid of electronic systems, for the following purposes:

• to offer learners the opportunity to participate in e-learning courses in order to enhance their knowledge within the organisation to which they belong.
• to offer teachers the opportunity to deliver courses in e-learning mode.

The Data Controller processes Personal Data relating to the User where one of the following conditions applies:

• the User has given consent for one or more specific purposes;
• processing is necessary for the performance of a contract with the User and/or for the implementation of pre-contractual measures;
• processing is necessary for compliance with a legal obligation to which the Data Controller is subject;
• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
• processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by third parties.

In any case, the User may always ask the Data Controller to clarify the specific legal basis of each processing operation and, in particular, whether the processing is based on law, provided for by a contract, or necessary to enter into a contract.

Nova Consulting S.p.A.Via di San Tarcisio 400178 Rome, ItalyEmail: mail@novaconsulting.itCertified email (PEC): postacertificata@pec.novaconsulting.eu

The data subjects involved in the processing of data on the Moodle e-learning platform are:

• Teachers
• Learners

The provision of personal data is mandatory, unless otherwise specified, for the use of the Moodle platform. The only personal data required are common identification data for identification purposes and for issuing course attendance certificates (first name, last name, date of birth, place and province of birth), the email address (for course enrolment and communications), and certain additional data required for the creation of groups within the platform (company of affiliation and job role). IP addresses are collected solely for technical purposes. The data will not be visible to other learners, but only to the platform administrator and to teachers; the latter will only have visibility of the data of users enrolled in the courses they teach.

Users of the platform undertake to comply with the rules for the proper use of the service and, in particular, undertake:

• to keep their personal password confidential and not allow other persons to use it;
• to immediately inform the site administrator if they are unable to access their account or if they suspect that others may have access to it;
• not to allow others, under any circumstances, to use the platform;
• not to disclose any confidential information of which they may become aware regarding the activities of other persons using the service;
• to use the services offered solely for the training activities for which the profile was created; the profile may not be used outside the platform for personal purposes, such as receiving, sending or sharing files, videos or other materials from external sources;
• not to transmit, distribute, share or retain any material that violates any applicable law or regulation.

The Data Controller adopts appropriate security measures designed to prevent unauthorised access, disclosure, modification or destruction of Personal Data. Processing is carried out by means of IT and/or telematic tools, using organisational methods and logic strictly related to the purposes indicated.

In addition to the Data Controller, in some cases other subjects involved in the organisation of novaconsulting-learning.it (administrative staff, sales staff, marketing staff, legal advisers, system administrators) or external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) may have access to the Data, where necessary appointed as Data Processors by the Data Controller. An updated list of Data Processors may always be requested from the Data Controller.

The Data are processed at the operating offices of the Data Controller and in any other place where the parties involved in the processing are located. For further information, please contact the Data Controller. To obtain further information on the place of processing, the User may refer to the section concerning details on the processing of Personal Data.

The data will not be disclosed to third parties except where necessary to comply with legal obligations or to respond to legal or judicial requests, and will not in any way be disseminated.

The data collected are stored in Italy and will not be transferred to other countries.

Personal Data are collected for the following purposes and by using the following services:

Google reCAPTCHA is an anti-spam protection service provided by Google LLC. The use of the reCAPTCHA system is subject to Google's Privacy Policy and Terms of Service.

For an understanding of how Google uses data, please consult Google's partner policy.

Personal Data processed: clicks; Usage Data; keypress events; motion sensor events; touch events; mouse movements; scroll position; responses to questions; Tracking Tools.

Place of processing: United States - Privacy Policy.

This type of service allows User Data to be used for commercial communication purposes. Such communications are displayed on this Website in the form of banners and other advertising formats, possibly also in relation to the User's interests. This does not mean that all Personal Data are used for this purpose. The relevant data and conditions of use are set out below.

Some of the services listed below may use Tracking Tools to identify the User or use behavioural retargeting techniques, namely the display of personalised advertisements based on the User's interests and behaviour, including behaviour detected outside this Website. For further information, Users are encouraged to consult the privacy notices of the respective services.

Services of this kind generally allow Users to opt out of such tracking. In addition to any opt-out function provided by any of the services listed in this document, the User may read more about how to opt out of interest-based advertising in the relevant section of this document entitled "How to opt out of interest-based advertising".

This Website uses the User's Data to propose and advertise services and products provided by third parties, whether or not related to the product or service provided by this Website.

Direct advertising may involve the use of Tracking Tools in order to monitor Users' behaviour and show them personalised advertisements. Users may opt out of ad personalisation through their device settings or by following the instructions provided by YourOnlineChoices and AdChoices.

In addition to the relevant device settings, the User may always exercise the rights described in the section on the User's rights in this privacy notice.

Personal Data processed: Usage Data; Tracking Tools.

Google Fonts is a font display service operated by Google Ireland Limited that allows this Website to incorporate such content into its pages.

Personal Data processed: Usage Data; Tracking Tools.Place of processing: Ireland - Privacy Policy.

This type of service allows content hosted on external platforms to be displayed directly from the pages of novaconsulting-learning.it and enables interaction with such content. These services are often referred to as widgets, namely small elements embedded in a website or application. They provide specific information or perform a particular function and often allow interaction with the user.

YouTube is a video content display service operated by Google Ireland Limited that allows novaconsulting-learning.it to incorporate such content into its pages.

Personal Data processed: Usage Data; Tracking Tools.

Place of processing: Ireland - Privacy Policy.

This type of service analyses the traffic of novaconsulting-learning.it, which may contain Users' Personal Data, for the purpose of filtering traffic, messages and content recognised as SPAM or protecting the Website from malicious bot activity.

In addition to any opt-out function provided by any of the services listed in this document, Users may read more about how to opt out of interest-based advertising in the relevant section of the Cookie Policy.

Unless otherwise indicated in this document, Personal Data are processed and retained for as long as required by the purpose for which they were collected and may be retained for a longer period due to legal obligations or on the basis of the User's consent. The User's Data are collected in order to allow the Data Controller to provide the Service, comply with legal obligations, respond to requests or enforcement actions, protect its own rights and interests (or those of Users or third parties), detect any malicious or fraudulent activity, as well as for the following purposes: display of content from external platforms, advertising, and protection from spam and bots.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until such contract has been fully performed.
• Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest has been fulfilled.
• Where processing is based on the User's consent, the Data Controller may retain the Personal Data for a longer period until such consent is withdrawn.
• The Data Controller may also be required to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, Personal Data will be deleted. Therefore, upon expiry of such period, the rights of access, erasure, rectification and data portability may no longer be exercised.

Please refer to the specific notice entitled "Cookie Policy".

Pursuant to Articles 15-21 of Regulation (EU) 2016/679 and applicable law, the data subject has the right to request from the Data Controller: access to personal data, rectification, erasure, restriction of processing, objection to processing, and data portability.

In particular, the data subject may:

• withdraw consent at any time. The User may withdraw consent previously given for the processing of their Personal Data at any time.
• object to the processing of their Data. The User may object to the processing of their Data where such processing is carried out on a legal basis other than consent.
• access their Data. The User has the right to obtain information about the Data processed by the Data Controller, on certain aspects of the processing, and to receive a copy of the Data processed.
• verify and request rectification. The User may verify the accuracy of their Data and request that it be updated or corrected.
• obtain restriction of processing. The User may request restriction of the processing of their Data. In such case, the Data Controller will not process the Data for any purpose other than storage.
• obtain the erasure or removal of their Personal Data. The User may request the erasure of their Data by the Data Controller.
• receive their Data or have them transferred to another controller. The User has the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to have them transferred to another controller without hindrance.
• lodge a complaint. The User may lodge a complaint with the competent data protection supervisory authority or take legal action. (www.garanteprivacy.it)

Users also have the right to obtain information regarding the legal basis for transfers of Data abroad, including to any international organisation governed by international law or set up by two or more countries, such as the UN, and regarding the security measures adopted by the Data Controller to protect their Data.

Where Personal Data are processed in the public interest, in the exercise of official authority vested in the Data Controller, or for the purposes of the legitimate interests pursued by the Data Controller, Users have the right to object to such processing on grounds relating to their particular situation.

Users are informed that, where their Data are processed for direct marketing purposes, they may object to such processing at any time, free of charge and without giving any reason. Where Users object to processing for direct marketing purposes, the Personal Data will no longer be processed for those purposes.

The data subject may exercise all the above rights by sending an email to the contact details of the Data Controller and site administrator (admin@novaconsulting-learning.it).

To exercise their rights, Users may send a request to the contact details of the Data Controller indicated in this document. Requests are free of charge and the Data Controller will respond as soon as possible and, in any event, within one month, providing the User with all information required by law. Any rectification, erasure or restriction of processing will be communicated by the Data Controller to each recipient, if any, to whom the Personal Data have been disclosed, unless this proves impossible or involves a disproportionate effort. The Data Controller shall inform the User of such recipients if the User so requests.

The User's Personal Data may be used by the Data Controller in legal proceedings or in the preparatory stages leading to possible legal action, for the defence against abuse in the use of this Website or related Services by the User.

The User declares that they are aware that the Data Controller may be required to disclose the Data by order of public authorities.

Upon request of the User, in addition to the information contained in this privacy notice, this Website may provide the User with additional and contextual notices regarding specific Services, or the collection and processing of Personal Data.

For operation and maintenance purposes, this Website and any third-party services used by it may collect system logs.

Personal Data means any information that, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data are the information collected automatically through novaconsulting-learning.it (including by third-party applications integrated into novaconsulting-learning.it), including: the IP addresses or domain names of the computers used by the User who connects with novaconsulting-learning.it, the URI (Uniform Resource Identifier) addresses, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the response from the server (successful outcome, error, etc.), the country of origin, the features of the browser and operating system used by the visitor, the various time details of the visit (for example, the time spent on each page), and the details relating to the path followed within the Application, with particular reference to the sequence of pages viewed and the parameters relating to the User's operating system and IT environment.

The individual using novaconsulting-learning.it who, unless otherwise specified, coincides with the Data Subject.

The natural person to whom the Personal Data refer.

Any natural person, legal person, public administration or other body that processes personal data on behalf of the Data Controller, as described in this privacy notice.

The natural person or legal person, public authority, service or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data and the tools adopted, including the security measures relating to the operation and use of novaconsulting-learning.it. Unless otherwise specified, the Data Controller is the owner of novaconsulting-learning.it.

The hardware or software tool by means of which Users' Personal Data are collected and processed.

The Service provided by novaconsulting-learning.it as defined in the relevant terms and conditions, if any, on this website/application.

Unless otherwise specified, any reference in this document to the European Union shall be deemed to include all current Member States of the European Union and of the European Economic Area.

Cookies are Tracking Tools consisting of small portions of data stored within the User's browser.

Tracking Tool means any technology - e.g. Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that allows Users to be tracked, for example by collecting or storing information on the User's device.

Unless otherwise specified, this privacy notice concerns novaconsulting-learning.it exclusively.

By approving this policy, the User consents to the processing of the data provided for the purposes set out above.