This document informs Users about the technologies that help this Website to achieve the purposes described below. Such technologies allow the Owner to access and store information (for example by using a Cookie) or use resources (for example by running a script) on a User’s device as they interact with this Website.
For simplicity, all such technologies are defined as "Trackers" within this document – unless there is a reason to differentiate.
For example, while Cookies can be used on both web and mobile browsers, it would be inaccurate to talk about Cookies in the context of mobile apps as they are a browser-based Tracker. For this reason, within this document, the term Cookies is only used where it is specifically meant to indicate that particular type of Tracker.
Some of the purposes for which Trackers are used may also require the User's consent. Whenever consent is given, it can be freely withdrawn at any time following the instructions provided in this document.
This Website uses Trackers managed directly by the Owner (so-called “first-party” Trackers) and Trackers that enable services provided by a third-party (so-called “third-party” Trackers). Unless otherwise specified within this document, third-party providers may access the Trackers managed by them.
The validity and expiration periods of Cookies and other similar Trackers may vary depending on the lifetime set by the Owner or the relevant provider. Some of them expire upon termination of the User’s browsing session.
In addition to what’s specified in the descriptions within each of the categories below, Users may find more precise and updated information regarding lifetime specification as well as any other relevant information — such as the presence of other Trackers — in the linked privacy policies of the respective third-party providers or by contacting the Owner.
This Website uses so-called “technical” Cookies and other similar Trackers to carry out activities that are strictly necessary for the operation or delivery of the Service.
This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data processed: Tracker.
Place of processing: Ireland – Privacy Policy.
This type of service allows this Website to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.
The iubenda Cookie Solution allows the Owner to collect and store Users’ preferences related to the processing of personal information, and in particular to the use of Cookies and other Trackers on this Website.
Personal Data processed: Tracker.
Place of processing: Italy – Privacy Policy.
Storage duration:
This Website uses Trackers to provide a personalized user experience by improving the quality of preference management options, and by enabling interaction with external networks and platforms.
This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Font Awesome is a typeface visualization service provided by Fonticons, Inc. that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Tracker and Usage Data.
Place of processing: United States – Privacy Policy.
Google Fonts is a typeface visualization service provided by Google Ireland Limited that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Tracker and Usage Data.
Place of processing: Ireland – Privacy Policy.
This Website uses Trackers to measure traffic and analyze User behavior with the goal of improving the Service.
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Cookies and Usage Data.
Place of processing: US – Privacy Policy – Opt Out.
Storage duration:
Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for this Website (demographics means age and gender Data).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Tracker and unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Place of processing: Ireland – Privacy Policy – Opt Out.
Storage duration:
Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Meta Platforms, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, that connects data from the Meta advertising network with actions performed on this Website. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.
Personal Data processed: Tracker and Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Storage duration:
The services contained in this section allow the Owner, through the use of third-party Trackers, to collect and manage analytics in an anonymized form.
Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
Personal Data processed: Tracker and Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
This Website uses Trackers to deliver personalized marketing content based on User behavior and to operate, serve and track ads.
This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
Facebook Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, that connects the activity of this Website with the Facebook advertising network.
Personal Data processed: Tracker and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Storage duration:
This Information note contains the information required pursuant to art. 13 of the European Regulation (EU) 2016/679, concerning the protection of natural persons with regard to the processing of personal data (hereinafter "GDPR") as well as of European or national legislative measures and / or provisions of the Supervisory Authorities following publication of the present.
We inform you that the personal data (hereinafter, the "Data") provided by you, through the forms available at the URL http://www.giocamondostudy.it, to GIOCAMONDO STUDY Srl (hereinafter, the "Company"), which allows you to stay informed about the services offered by the Company, to book and, subsequently, to use the services themselves, will be treated by the same within the limits indicated in this statement.
In the form you can also enter any "sensitive data", pursuant to art. 4, 1 paragraph, lett. d) of the Privacy Code, by way of example, the state of health, such as belonging to protected categories) will be processed by the Company within the limits indicated in this statement.
1. LEGAL BASIS AND PURPOSE OF THE TREATMENT
PURPOSE OF PRE-CONTRACT NATURE (BOOKING SERVICES OFFERED BY THE COMPANY).
Processing is necessary for the implementation of informative and pre-contractual measures taken at your request. Therefore your data will be processed by the Company for purposes related to or instrumental to the booking activity and, subsequently, participation in services offered by our Company.
Furthermore, always in relation to the main purpose of implementing the pre-contractual measures, your data will be processed by the Company also for:
● fulfill the contractual and tax obligations deriving from relations with you in existence;
● fulfill the obligations established by law, by a regulation, by community legislation or by an order of the Authority
● exercise the rights of the owner, for example the right to defense in court.
Pursuant to art. 13, co. 1, lett. b) and c) of the Privacy Code, we inform you that the provision of data marked with an asterisk (*) in the online form is mandatory for the pursuit of the purposes mentioned above; therefore, any refusal to provide such Data could prevent the sending of information and booking.
PURPOSES OF PROMOTIONAL, ADVERTISING AND MARKETING NATURE ON THE SIDE.
The personal data collected will be processed to pursue purposes of commercial promotion, advertising, solicitation to purchase behavior, market research, surveys (including telephone, online or through forms), statistical processing (identifying), other sample searches marketing in a broad sense of services referable to the Company (hereinafter, as a whole, "Treatment for Marketing Purposes").
By granting consent to the processing for marketing purposes, the data subject specifically acknowledges the promotional, commercial and marketing purposes in the broad sense of the processing (including the consequent management and administrative activities) and expressly authorizes said processing under the GDPR whether the means used for the Treatment for Marketing Purposes are the telephone 1
1 Similarly, in the GDPR, as defined below, art. 4., point 1, "personal data" means "any information concerning an identified or identifiable natural person (" concerned "); an identifiable natural person can be identified, either directly or indirectly, with
with operator or other non-electronic means, not telematic or not supported by automatic, electronic or telematic mechanisms and / or procedures, as well as that the means are the electronic mail, the fax , SMS, MMS, automatic systems without operator intervention and similar, including electronic platforms and other telematic means.
Pursuant to the General Provision of the Privacy Guarantor of May 15, 2013 entitled "Consent to the processing of personal data for" direct marketing "purposes through traditional and automated contact tools", the relevant focus of the WP is specifically recalled on the fact that :
1. the consent given for the sending of commercial and promotional communications, on the basis of art. 130, paragraphs 1 and 2 of the Code (ie through the use of electronic mail, fax, sms, mms, automated systems without operator intervention and similar, including electronic platforms and other electronic means) will involve the receipt of such communications, not only through these automated methods of contact, but also through traditional methods, such as paper mail or calls by operator;
2. the right to oppose the data processing of personal data for purposes of "direct marketing" through the aforementioned automated methods of contact, will in any case extend to the traditional ones and, even in this case, the possibility of exercising such law in part, as required by art. 7, paragraph 4, of the Code, both with respect to certain means and with respect to certain treatments;
3. the possibility remains for the interested party who does not intend to give consent in the terms indicated above, to express any wish to receive communications for the aforementioned marketing purposes exclusively through traditional methods of contact, where provided for: this will be exercised for free by changing the consent settings in the "Privacy" area of the site.
To proceed with the Treatment for Marketing Purposes it is mandatory to acquire a specific, separate, expressed, documented, preventive and completely optional consent.
Consequently, if the person concerned decides to give the specific consent, he must be informed and aware in advance that the purposes of the treatment pursued are exclusively of a specific commercial, advertising, promotional and marketing nature and that the registration requested on the Website does not pursue that these purposes, with the consequence that if the interested party does not intend to receive marketing communications, he will be free not to register and will be able to surf the site freely. With a view to absolute transparency, the Company informs the data subject will be collected and subsequently processed on the basis of a specific consensus:
● to send advertising and informative material (eg Newsletters), of a promotional nature or otherwise of a commercial nature, pursuant to Article 23 and 130 of the Privacy Code;
● to carry out direct sales or placement of products or services of the Company;
● to send commercial information or to make interactive commercial communications also pursuant to article 58 of Legislative Decree 206/2005 through the use of email;
● to develop studies, research, market statistics;
● to send unsolicited commercial communications pursuant to Article 9 of Legislative Decree 9 April 2003 no. 70 of the implementation of the c.d. Directive on Electronic Commerce 2000/31 / EEC, which provides that unsolicited commercial
particular reference to an identifier such as a name, an identification number, location data, an online ID or one or more characteristic elements of his physical identity, physiological, genetic, psychological, economic, cultural or social ".
communications must be immediately and unequivocally identifiable as such and contain the indication that the recipient of the message may object to receiving such communications in the future.
Therefore, by granting the optional consent, the interested party specifically takes note of and authorizes such treatments and / or treatments that pursue similar purposes.
2. DATA RELATED TO MINORS
In relation to the purpose of a pre-contractual nature, its registration includes the data of the minor who will participate in our activities: among the data that, knowingly and intentionally, it will provide us could also include sensitive and / or judicial data.
Processing is necessary for the implementation of informative and pre-contractual measures taken at your request. Therefore your data will be processed by the Company for purposes related to or instrumental to the booking activity and, subsequently, participation in services offered by our Company.
Furthermore, always in relation to the main purpose of implementing the pre-contractual measures, your data will be processed by the Company also for:
● fulfill the contractual and tax obligations deriving from relations with you in existence;
● fulfill the obligations established by law, by a regulation, by community legislation or by an order of the Authority
● exercise the rights of the owner, for example the right to defense in court.
3. METHOD OF TREATMENT
The processing of your data will be based on the principles of correctness, lawfulness and transparency and can also be carried out through automated procedures designed to store, manage and transmit them and will take place using appropriate tools, as far as reason and state of the art, to ensure safety and confidentiality through the use of appropriate procedures that avoid the risk of loss, unauthorized access, illicit use and dissemination.
4. COMMUNICATION AND DISSEMINATION OF PERSONAL DATA FOR THE PURPOSE OF THE INDICATED PURPOSES
For the same purposes referred to in paragraph 1.1 of the previous Paragraph 1, the Company informs the data subject that the data could also be communicated to other companies constituting the "Network Contract".
The consent to the processing - where provided by the interested party - does not also cover the different and further marketing treatment represented by the communication to third parties of the data. In order to proceed with such external communication it is obligatory to acquire from the interested party a further, separate, additional, documented, expressed and completely optional informed consent.
The management and storage of personal data will be carried out on servers located within the European Union of the Owner and / or third-party companies appointed and duly appointed as Data Processors. Currently the servers are located in Italy.
The data will not be transferred to outside the European Union.
In any case, it is understood that the Data Controller, where necessary, will have the right to move the server location to Italy and / or the European Union and / or non-EU countries. In this case, the Data Controller hereby ensures that the transfer of non-EU data will take place in accordance with the
applicable legal provisions, stipulating, if necessary, agreements that guarantee an adequate level of protection and / or adopting the standard contractual clauses provided for European Commission.
5. DATA STORAGE PERIOD
The Data will be included in the company database used for the booking of management of the services offered by the Company and kept for 15 years. Once this deadline has expired, the Data will be destroyed.
The same rule applies to all computer and paper documents that the Company should always manage for the purposes indicated above and for which it has given its consent.
6. RIGHTS OF THE INTERESTED PARTY
You have the right to ask the Owner to access the data concerning him / her, their correction or deletion, the integration of incomplete data, the limitation of processing; to receive the Data in a structured format, commonly used and readable by automatic device; to revoke any consent given regarding the processing of your sensitive data at any time and object in whole or in part to the use of the Data; to propose a complaint to the Authority, as well as to exercise the other rights recognized by the applicable regulations.
These rights may be exercised by writing to GIOCAMONDO STUDY Srl in Ascoli Piceno (AP) - 63100, via Napoli No. 8 / G or by e-mail to the following e-mail address: privacy@giocamondo.it. It is understood that, where the request for access is presented by electronic means, the information will be provided in a commonly used electronic format.
7. IDENTITY AND CONTACT DATA OF THE HOLDER OF THE TREATMENT
Owner of the processing of your data is GIOCAMONDO STUDY Srl in the person of the legal representative pro tempore, with registered office in Ascoli Piceno (AP) - 63100, via Napoli No. 8 / G
This Information note contains the information required pursuant to art. 13 of the European Regulation (EU) 2016/679, concerning the protection of natural persons with regard to the processing of personal data (hereinafter "GDPR") as well as of European or national legislative measures and / or provisions of the Supervisory Authorities following publication of the present.
We inform you that the personal data (hereinafter, the "Data") provided by you, through the forms available at the URL http://www.giocamondostudy.it, to GIOCAMONDO STUDY Srl (hereinafter, the "Company"), which allows you to stay informed about the services offered by the Company, to book and, subsequently, to use the services themselves, will be treated by the same within the limits indicated in this statement.
In the form you can also enter any "sensitive data", pursuant to art. 4, 1 paragraph, lett. d) of the Privacy Code**, by way of example, the state of health, such as belonging to protected categories) will be processed by the Company within the limits indicated in this statement.
1. LEGAL BASIS AND PURPOSE OF THE TREATMENT
1.1 PURPOSES OF PROMOTIONAL, ADVERTISING AND MARKETING NATURE ON THE SIDE.
The personal data collected will be processed to pursue purposes of commercial promotion, advertising, solicitation to purchase behavior, market research, surveys (including telephone, online or through forms), statistical processing (identifying), other sample searches marketing in a broad sense of services referable to the Company (hereinafter, as a whole, "Treatment for Marketing Purposes").
By granting consent to the processing for marketing purposes, the data subject specifically acknowledges the promotional, commercial and marketing purposes in the broad sense of the processing (including the consequent management and administrative activities) and expressly authorizes said processing under the GDPR whether the means used for the Treatment for Marketing Purposes are the telephone with operator or other non-electronic means, not telematic or not supported by automatic, electronic or telematic mechanisms and / or procedures, as well as that the means are the electronic mail, the fax , SMS, MMS, automatic systems without operator intervention and similar, including electronic platforms and other telematic means.
**
Similarly, in the GDPR, as defined below, art. 4., point 1, "personal data" means "any information concerning an identified or identifiable natural person (" concerned "); an identifiable natural person can be identified, either directly or indirectly, with particular reference to an identifier such as a name, an identification number, location data, an online ID or one or more characteristic elements of his physical identity, physiological, genetic, psychological, economic, cultural or social ".
Pursuant to the General Provision of the Privacy Guarantor of May 15, 2013 entitled "Consent to the processing of personal data for" direct marketing "purposes through traditional and automated contact tools", the relevant focus of the WP is specifically recalled on the fact that :
1. the consent given for the sending of commercial and promotional communications, on the basis of art. 130, paragraphs 1 and 2 of the Code (ie through the use of
electronic mail, fax, sms, mms, automated systems without operator intervention and similar, including electronic platforms and other electronic means) will involve the receipt of such communications, not only through these automated methods of contact, but also through traditional methods, such as paper mail or calls by operator;
2. the right of opposition of the data processing of personal data for purposes of "direct marketing" through the aforementioned automated methods of contact, will in any case extend to the traditional ones and, even in this case, the possibility of exercise this right in part, as required by art. 7, paragraph 4, of the Code, both with respect to certain means and with respect to certain treatments;
3. the possibility remains that the person concerned who does not intend to give consent in the terms indicated above, to express any desire to receive communications for the aforementioned marketing purposes exclusively through traditional methods of contact, where provided: this will be exercised for free by changing the consent settings in the "Privacy" area of the site.
To proceed with the Treatment for Marketing Purposes it is mandatory to acquire a specific, separate, expressed, documented, preventive and completely optional consent.
Consequently, if the person concerned decides to give the specific consent, he must be informed and aware in advance that the purposes of the treatment pursued are exclusively of a specific commercial, advertising, promotional and marketing nature and that the registration requested on the Website does not pursue that these purposes, with the consequence that if the interested party does not intend to receive marketing communications, he will be free not to register and will be able to surf the site freely. With a view to absolute transparency, the Company informs the data subject will be collected and subsequently processed on the basis of a specific consensus:
to. to send advertising and informative material (eg Newsletters), of a promotional nature or otherwise of a commercial nature, pursuant to Article 23 and 130 of the Privacy Code;
b. to carry out direct sales or placement of products or services of the Company;
c. to send commercial information or to make interactive commercial communications also pursuant to article 58 of Legislative Decree 206/2005 through the use of email;
d. to develop studies, research, market statistics;
is. to send unsolicited commercial communications pursuant to Article 9 of Legislative Decree 9 April 2003 no. 70 of the implementation of the c.d. Directive on Electronic Commerce 2000/31 / EEC, which provides that unsolicited commercial communications must be immediately and unequivocally identifiable as such and contain the indication that the recipient of the message may object to receiving such communications in the future.
Therefore, by granting the optional consent, the interested party specifically takes note of and authorizes such treatments and / or treatments that pursue similar purposes.
3. METHOD OF TREATMENT
The processing of your data will be based on the principles of correctness, lawfulness and transparency and can also be carried out through automated procedures designed to store, manage and transmit them and will take place using appropriate tools, as far as reason and state of the art, to ensure safety and confidentiality through the use of appropriate procedures that avoid the risk of loss, unauthorized access, illicit use and dissemination.
4. COMMUNICATION AND DISSEMINATION OF PERSONAL DATA FOR THE PURPOSE OF THE INDICATED PURPOSES
For the same purposes referred to in paragraph 1.1 of the previous Paragraph 1, the Company informs the data subject that the data could also be communicated to other companies constituting the "Network Contract".
The consent to the processing - where provided by the interested party - does not also cover the different and further marketing treatment represented by the communication to third parties of the data. In order to proceed with such external communication it is obligatory to acquire from the interested party a further, separate, additional, documented, expressed and completely optional informed consent.
The management and storage of personal data will be carried out on servers located within the European Union of the Owner and / or third-party companies appointed and duly appointed as Data Processors. Currently the servers are located in Italy.
The data will not be transferred to outside the European Union.
In any case, it is understood that the Data Controller, where necessary, will have the right to move the server location to Italy and / or the European Union and / or non-EU countries. In this case, the Data Controller hereby ensures that the transfer of non-EU data will take place in accordance with the applicable legal provisions, stipulating, if necessary, agreements that guarantee an adequate level of protection and / or adopting the standard contractual clauses provided for European Commission
5. DATA STORAGE PERIOD
The Data will be included in the company database used for marketing activities on the services offered by the Company and kept for 30 years.
Once this deadline has expired, the Data will be destroyed.
The same rule applies to all computer and paper documents that the Company should always manage for the purposes indicated above and for which it has given its consent.
6. RIGHTS OF THE INTERESTED PARTY
You have the right to ask the Owner to access the data concerning him / her, their correction or deletion, the integration of incomplete data, the limitation of processing; to receive the Data in a structured format, commonly used and readable by automatic device; to revoke any consent given regarding the processing of your sensitive data at any time and object in whole or in part to the use of the Data; to propose a complaint to the Authority, as well as to exercise the other rights recognized by the applicable regulations.
These rights may be exercised by writing to GIOCAMONDO STUDY Srl in Ascoli Piceno (AP) - 63100, via Napoli No. 8 / G or by e-mail to the following e-mail address: privacy@giocamondo.it. It is understood that, where the request for access is presented by electronic means, the information will be provided in a commonly used electronic format.
7. IDENTITY AND CONTACT DATA OF THE HOLDER OF THE TREATMENT
Owner of the processing of your data is GIOCAMONDO STUDY Srl in the person of the legal representative pro tempore, with registered office in Ascoli Piceno (AP) - 63100, via Napoli n ° 8/G
JoStudy Privacy Policy governs any kind of processing where we are acting as a data controller or co-controller (including collection, use, transfer, storage and deletion) of personally identifiable information. This policy applies to our processing of data collected through any means, actively as well as passively, from persons located anywhere in the world. Any question regarding our processing of personal data may be directed to school@jostudy.com
Please read the following policy and our Data Impact Assessments carefully to understand what information we may collect from you, how we may use it, and your rights in respect of our use.
We will be guided by the following principles when processing data:
• We will only collect data for specific and specified purposes; we will make it clear at the point when we request your information, what we are collecting it for and how we are going to use it.
• We will not collect data beyond what is necessary to accomplish those purposes; we will minimise the amount of information we collect from you to what we need to deliver the services required.
• We will collect and use your personal information only if we have sensible business reasons for doing so, such as managing a booking or gathering necessary information about a new member of staff, activity leader or homestay.
• We will not use data for purposes other than that for which the data was collected, except as stated, or with prior consent.
• We will seek to verify and/or update data periodically, and we will accept requests for amendments of personal data.
• We will apply high technical standards to make our processing of data secure.
• Except when stated, we will not store data in identifiable form longer than is necessary to accomplish its purpose, or as is required by law.
Information collected on students
We collect information on you:
• When you apply to join a course or programme at the school
• When you contact us for information, via our website, by email, by phone, in person or via social media channels.
Before you start and during your course with us we will collect, store and process the following personal data:
• Full Name
• Address
• Contact telephone numbers
• Contact email address
• Date of birth
• Passport number
• Photo or Video
• Next of kin contact details
• Course and language capability details
• Medical details
Permission to collect and store data of students under the age of 18 is obtained directly from the child’s parents or legal guardian through our parental consent form.
Who has access to your personal data?
We are committed to restricting access to personal data to just those individuals who may need it to meet their or the school’s obligation. The specific data each individual has access to is limited to only that which is necessary for them to be able to carry out their function. For us this means the following may have access to some or all of your data:
• The Directors
• Members of the Accommodation department
• Members of the Registration department
• Members of the Reception team
• Members of the Welfare team
• Members of the Finance department
• Members of the Marketing team
• Academic staff
Who do we share your personal data with outside of the school?
In order to fulfil our regulatory and contractual obligations we will need to share your personal data with third parties outside of the school. We have also chosen to outsource some of our operational requirements and our outsourced suppliers also need access to your personal data. In all cases we have committed to limiting the personal data that we share to only that which is necessary for them to be able to carry out the function we have contracted with them to perform. However, we take your privacy seriously and will therefore, never sell your personal data to anyone and will take precautions to keep it secure. Your data may be shared with:
• Education Travel Organisations (Agents)
Quality Standard Inspectorates e.g., ABLS
• Hotels, student residences and host families as appropriate
• Government Enforcement Agencies e.g. the Home Office.
We will retain all your personal data for the duration of your contract and then for a further 5 years to enable us to meet our regulatory and legal obligations; to ease administration should you wish to return to undertake further studies; and to keep you up to date with news from our school which may be of interest to you. After 5 years all records will be deleted.
Legal bases for processing your data The General Data Protection Regulation (GDPR) establishes 6 legal bases on which we can process your data: these are Consent, Contract, Legal Obligation, Vital Interests, Public Task and Legitimate Interests. For further information about these legal bases and fuller definitions, please refer to the ICO website. We use different legal bases for processing your data depending on the purpose for collecting your data in the first instance:
• For all data collected as part of the process of enquiring about, applying for and booking a course or for any other related service (e.g. homestay, airport transfer, social programme, insurance to cover you during your stay, or where you give us feedback about aspects of this provision, we process using Contract or Legitimate Interests, namely the fulfilment of the booking. This may include sending of your data to our partners such as Educational Tour Operators (ETOs), Government Agencies or Schools. Where required by law to do so, we may also process your data under Legal Obligation.
• Any processing of customer data not directly related to the fulfilment of a booking or related services, such as signing up for newsletters or sending messages to you on behalf of third parties, is managed under Consent. From time to time, we may use elements of the data you supply to target the messages we send to you. For example, we may use your location to send you information about an event or opportunity happening in your area. During your stay at The Heart of England Study Programmes, we may take photographs or videos of you, and the use and processing of these is also managed through Consent.
• For all data collected as part of managing our relationship with commercial partners, such as ETOs, Government Agencies and Schools, we process using Contract, Legitimate Interest and Legal Obligation, namely the maintenance of the commercial relationship. As newsletters to commercial partners are an important part of how we communicate with them, these are managed under Legitimate Interest.
• We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is Legitimate Interest, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
• We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is Legitimate Interest, namely the proper protection of our business against risks. We will make it as easy as we can for you to opt out of unwanted processing under Consent, providing it does not restrict our ability to provide you with the primary service you have requested.
We collect data for a wide range of purposes. Data is managed to ensure that it is either erased from our system when it is no longer required for the purpose for which it was collected, retained for legal reasons, or minimised and retained. We are co-processors of information relating to marketing and booking clients with partners overseas (for example ETOs, schools, government and national sponsors). As such, we may transfer some data outside of the EU, but this will be limited to data necessary for the performance of a contract made in the interests of the individual (which is an exemption to the 8th principle of the GDPR legislation). We remain responsible for the data held, processed or sent via our systems. We are not responsible for the security and processing of data which is held, processed or sent via our partners’ systems. However, we require all of our partners overseas to confirm that they will process data securely in line with the requirements of GDPR or the equivalent in their country. We do not sell your data at any time.
Special Category Data/Criminal Record Data
We may request health data from potential students. This data has special protection under the GDPR under the specific conditions listed in Article 9 (2) of the GDPR that processing is necessary either to protect the vital interests of the data subject, (or of another natural person where the data subject is physically or legally incapable of giving consent), or where processing is necessary for the purposes of preventive or occupational medicine or the assessment of the working capacity of an employee.
The school has safeguarding responsibilities and carries out DBS checks on all staff and other people who are likely to have direct supervisory responsibility for or unsupervised contact with young people under the age of 18. We may process and record securely risk assessments of these DBS checks where the disclosure is not clear. These risk assessments will be disposed of securely when that person no longer has supervisory responsibility or unsupervised contact with young people under the age of 18 on behalf of the school.
Children under 18
We collect or store personal information about children under the age of 18 in the context of managing bookings and directly related products, and for safeguarding purposes. Permission is obtained directly from a legal adult guardian to collect this information through our Parental Consent Form. As part of this process, we request special category data relating to the health of the child, which we manage through Vital Interest. We also gain consent from parents for the use of photos or video taken during their child’s stay at The Heart of England Study Programmes through the Parental Consent Form. Information collected via our website
How we will use information collected by our website
We may use information held about you in the following ways:
• To process a booking for one of our courses or products.
• To manage an application.
• To create a profile for you to help us provide a more personalised service which is suited to meet your preferences.
• To ensure that content from our site is presented in the most effective manner for you and your computer.
• To send you our newsletters or provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
• To allow you to participate in interactive features of our service, when you choose to do so.
• To notify you about changes to our service.
Links from our website
Our website contains links to and from websites operated by individuals and companies over which we have no direct control. If you follow a link to any of these websites, please note that these websites have their own privacy and terms of use policies and that we do not accept any responsibility or liability for these policies. We advise you to check these policies before you submit any personal data to these websites.
Cookies
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Our service providers use cookies and those cookies may be stored on your computer when you visit our website. These cookies do not contain any information that is personally identifiable to you.
• Google Analytics - used to analyse the usage of our website.
• Google Translate - provides a translation service to our website visitors.
• Facebook - used to offer "like" and "share" buttons to like/share pages from our website on Facebook.
• Twitter - used to offer "follow" buttons to follow The Heart of England Study Programmes on Twitter.
• LinkedIn - used to offer "follow" buttons to follow The Heart of England Study Programmes on LinkedIn.
• YouTube - used to embed videos on our website.
• LiveChat - provides a chat service to our website visitors.
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
• https://support.google.com/chrome/answer/95647?hl=en (Chrome);
• https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
• http://www.opera.com/help/tutorials/security/cookies/ (Opera);
• https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-managecookies (Internet Explorer);
• https://support.apple.com/kb/PH21411 (Safari);
• https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.
What to do if you believe that the information we have collected and are using is incorrect?
It is important for both you and us that we hold up to date and accurate information and that the accuracy is maintained during your relationship with us. For this reason we shall be conducting annual internal audits of the data we hold. If you become aware of any inaccuracies or you change address, telephone number, email, etc., it is your responsibility to bring this to our attention as quickly as possible. Please inform us as soon of any changes by emailing school@jostudy.com . You also have the right to withdraw consent to the processing of information for which you have previously given consent. You may also request access to the data we hold on you. Provision of such information will be subject to:
a) The payment of a fee (currently fixed at £20)
b) The supply of appropriate evidence of your identity.
We may withhold personal information that you request to the extent permitted by the law. To make any of these requests relating to your personal data, please contact us at: school@jostudy.com or contact the Office Manager (tel: +44 1926 311375)
What to do if you have a concern or complaint about how we store, use or share your personal data?
Initially, we would encourage you to raise this with the appropriate department depending on the nature of the concern or complaint who should be able to resolve the matter informally. If following this you do not believe that your concern has been adequately addressed, than you should raise your complaint in writing to our Office at The Heart of England Study Programmes, 14 Hamilton Terrace, Leamington Spa, Warwickshire, CV32 4LY UK.
In the unlikely event that we have been unable to address your concern internally, you may call the Information Commissioner’s Office helpline on 0303 123 1113. Changes to our Privacy Policy Any changes we may make to our Privacy Policy in the future will be posted on our website in this document. Please check from time to time to ensure that you are aware of any changes to our Privacy Policy.
There are various ways to manage Tracker related preferences and to provide and withdraw consent, where relevant:
Users can manage preferences related to Trackers from directly within their own device settings, for example, by preventing the use or storage of Trackers.
Additionally, whenever the use of Trackers is based on consent, Users can provide or withdraw such consent by setting their preferences within the cookie notice or by updating such preferences accordingly via the relevant consent-preferences privacy widget, if available.
It is also possible, via relevant browser or device features, to delete previously stored Trackers, including those used to remember the User’s initial consent preferences.
Other Trackers in the browser’s local memory may be cleared by deleting the browsing history.
With regard to any third-party Trackers, Users can manage their preferences via the related opt-out link (where provided), by using the means indicated in the third party's privacy policy, or by contacting the third party.
Users can, for example, find information about how to manage Cookies in the most commonly used browsers at the following addresses:
Users may also manage certain categories of Trackers used on mobile apps by opting out through relevant device settings such as the device advertising settings for mobile devices, or tracking settings in general (Users may open the device settings and look for the relevant setting).
Notwithstanding the above, Users may follow the instructions provided by YourOnlineChoices (EU and UK), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar services. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.
The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.
Users are free to decide whether or not to allow the use of Trackers. However, please note that Trackers help this Website to provide a better experience and advanced functionalities to Users (in line with the purposes outlined in this document). Therefore, if the User chooses to block the use of Trackers, the Owner may be unable to provide related features.
Jostudy by Giocamondo Study
P.IVA 02301140444
Via Napoli 8/G, 63100, Ascoli Piceno (AP), Italia
Owner contact email: info@jostudy.co.uk
Since the use of third-party Trackers through this Website cannot be fully controlled by the Owner, any specific references to third-party Trackers are to be considered indicative. In order to obtain complete information, Users are kindly requested to consult the privacy policies of the respective third-party services listed in this document.
Given the objective complexity surrounding tracking technologies, Users are encouraged to contact the Owner should they wish to receive any further information on the use of such technologies by this Website.
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
The means by which the Personal Data of the User is collected and processed.
The service provided by this Website as described in the relative terms (if available) and on this site/application.
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
This privacy policy relates solely to this Website, if not stated otherwise within this document.
Latest update: January 18, 2022
iubenda hosts this content and only collects the Personal Data strictly necessary for it to be provided.
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