PRIVACY POLICY

INTRODUCTION.
This privacy policy (hereinafter referred to as the “Privacy Policy”) is drafted in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and the Legislative Decree 101/2018, that entered into force on 19 September 2018, and amended a number of provisions of the Legislative Decree 196/2003 (hereinafter referred to as the “Privacy Code”), as well as the introduced transitional provisions regulating the migration to the new regime.

The Privacy Policy guarantees that personal data processing is carried out in compliance with fundamental rights and freedoms, as well as in respect of the dignity of the interested party with particular reference to privacy, personal identity and the right to protect personal data.

The Privacy Policy may be modified or simply updated, in whole or in part, in the light of any legislative changes.

DATA CONTROLLER.
Family District S.r.l., with registered office in Milan, via Giovanni Bellezza n. 11, Fiscal Code/VAT number 12751300968, PEC: familydistrictsrl@pecimprese.it, (hereinafter referred to as “Family District”) is the data controller (hereinafter referred to as the “Data Controller”).

For any requests regarding the processing of personal data, please contact directly by e-mail the data protection officer (hereinafter referred to as the “Data Protection Officer”) at the following e-mail address: amministrazione@familydistrict.it

PURPOSES OF PROCESSING PERSONAL DATA.
Family District processes personal data to lawfully and legitimately carry out its activities, including the educational activity. With specific reference to the educational part, Family District collects and keeps students and parents’ information when necessary, in order to:
1. ensure that the student meets the admission criteria;
2. provide educational services including the support for learning, monitor and report on pupil progress;
3. provide to the students medical and nurse attention, catering service and school transportation, plus other related services;
4. meet the educational, social, physical and emotional requirements of each student;
5. comply with the applicable laws and regulations regarding data sharing;
6. comply with legislative or administrative requirements;
7. enable parents/others to be contacted in case of emergency or in case of school closure, or to inform parents of their child’s educational progress and/ or about school events, etc.
8. send commercial communications if previously requested and authorised by the data subject. Commercial communications will include: newsletters and notices from the webpage, referral of commercial advertisements through e-mail, SMS, MMS, social networks or any other electronic or physical means, present or future, which enables such commercial communication. It will be possible to unsubscribe from the receipt of commercial communications by clicking in the “unsubscribe” section found in all these kind of e-mails sent by Family District.

TYPES OF PROCESSED PERSONAL DATA.
Family District processes personal data from the students and their families and / or competent people and also from employees, candidates, suppliers, contractors, prospective customers and third parties interested in finding out more about Family District within the systems controlled by Family District as Data Controller.
The personal data processed is mainly the following:

• Names, addresses, telephone numbers, e-mail addresses and other contact details;
• Family details;
• Education and employment data;
• Images, audio and video recordings, including CCTV footage (video images);
• Financial information;
• Other schools previously attended.

Other types of data that can be collected and processed, according to Family District purposes, are related to health condition and/or other sensitive information related to an individual, such as:
• Information about health status or provision of health care linked to a specific individual;
• Behavioural information;
• Special educational needs;
• Ethnicity;
• Religion.

HOW PERSONAL DATA ARE COLLECTED AND PROCESSED.
Family District collects information in several ways, including:
• Personally and over the phone;
• Through the Family District website;
• From email and hand delivery paper documentation: including job applications, emails, invoices, letters, consent forms;
• Through online tools: such as apps, educational platforms and other software used by our staff;
• Through any CCTV cameras located at our premises or sites.

Data processing is carried out mainly electronically by Family District and/or by other selected parties.
Data will not be disclosed to third parties, except in cases where the disclosure is required by law or for purposes envisaged by the law for the pursuit of which the consent of the interested subject is not required. In such cases, the data can be made available to third parties who will process it independently and exclusively for such purposes (for example, in the case of requests made by the police or by courts or other competent authorities).
The personal data shall be neither rented nor sold to third parties.

DURATION AND CONSERVATION OF DATA.
Personal information will only be retained for the period of time required to fulfil the purpose for which it was collected unless for a longer time for public interest archiving, scientific or historical research, or statistical purposes. Once the personal information is no longer required or permitted to be retained for legal or business purposes, it will be destroyed or made anonymous.

PERSONAL RIGHTS.
Pursuant to the applicable laws and regulations, there is the right to exercise at any time and freely specific rights such as accessing the data, obtaining confirmation of the existence or not of personal data, even if not yet registered, to know their origin and content, to verify their accuracy and to request their integration, updating or correction, as well as to request cancellation, transformation into anonymous form or blocking of data that may be processed in violation of the law, as well as to oppose, for legitimate reasons, to their treatment.
The data can be accessed at any time and it will be possible to exercise the own rights, by sending a written communication to amministrazione@familydistrict.it.
Any request is subject to certain exemptions, limitations or contractual obligations. Data belonging to or identifying other individuals is exempt from right of access and will be subject to legal privilege. We cannot disclose confidential information on any of our staff.

CONSENT.
There the right and possibility to withdraw the consent for any specific purpose granted at any given time without prejudice of the legality of processing according to the consent given before withdrawal.

STORING AND SECURING INFORMATION.
Family District shall use the appropriate technical and organisational measures to ensure the security, confidentiality, integrity and privacy of the personal data, preventing from unauthorised access or unlawful processing as well as accidental loss, destruction or damage of the files.

COMPLAINTS.
In case of complaints regarding this Privacy Policy and/or the processing of the data by Family District, please contact the Data Protection Officer at amministrazione@familydistrict.it or address your request for mediation to the Italian data protection authority, (“Garante per la protezione dei dati personali”), addressed at Piazza Venezia n. 11 – 00187 Roma, www.garanteprivacy.it and email protocollo@gpdp.it, although it is recommended that previous steps are taken to resolve the matter with Family District before involving the authority.

In this section you can find the necessary information about cookies of familydistrict.it website and on how to identify, disable or delete them.
This Policy can be updated at any time due to changes in current legislation or for any change in the configuration and type of cookies used.

ABOUT COOKIES.
A cookie is a text file saved on your computer or mobile device that allows a website to remember your browsing preferences for more efficient performance.
Thanks to cookies, the interaction between the website and the user is more efficient.

HOW THEY ARE WORKING.
Cookies can only memorize text, always in anonymous and encrypted form.

No personal information will be stored, nor can it be associated with identified or identifiable persons.
The data allow this type of information to be maintained between the pages, avoiding the re-entry of the same information.

ACCEPT COOKIES.
It is possible to change the cookie settings and choose between unconditional acceptance, the display of a popup window that requires explicit action on the part of the user or the refusal of cookies without distinction.
To manage the use of cookies it is necessary to change the browser settings using the relevant toolbar.

It is necessary to set cookie preferences for each device and each browser used to navigate the Internet.