Privacy Policy
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PRIVACY POLICY
pursuant to Article 13 of Regulation (EU) 2016/679
1. Preface
To facilitate a better understanding by Users and to enable them to make informed decisions, we have collected on this single page all the necessary information regarding the processing of personal data.
Any request by the Data Subject concerning the Processing carried out by WeSchool Education as Data Controller (including the exercise of the rights referred to in Article 15 and following of the GDPR) should be addressed to WeSchool Education by one of the following means:
• by post to the registered office: WeSchool Education S.r.l., Milan, Via Fabio Filzi n. 27, Postal code 20124
• by e-mail to the following address: dpo@weschool.com
(V2 – 17/06/2025)
2. Data Controller
The data controller is the company WeSchool Education S.r.l., (hereinafter also referred to as “WeSchool” or “WeSchool Education” or “The Controller”), with its registered office in Milan, Via Fabio Filzi n. 27, 20124.
In its role as Data Controller, WeSchool Education determines the manner in which personal data is processed, stored, and protected, in compliance with Regulation (EU) 2016/679 (commonly known as GDPR) relating to the protection of personal data, as well as Legislative Decree 196/2003 (the so-called Privacy Code), and subsequent amendments and integrations.
In cases where the processing of Personal Data arises from services offered in collaboration with third parties, WeSchool Education may act as Processor or as Joint Controller, as applicable.
Such situations will be specifically indicated. In the absence of these indications, the Data Controller is to be understood as WeSchool Education.
3. DPO
For any questions or requests regarding the processing of personal data, the Company has appointed a DPO (Data Protection Officer – person responsible for the protection of personal data), identified as Attorney Diego Dimalta, who can be contacted at the e-mail address dpo@weschool.com.
4. Description and Nature of the Treatment
WeSchool Education processes the following personal data, according to the following methods.
| Description of Activities |
Description and Nature of the Processing |
Legal Basis for the Processing |
| a. Website Navigation Website Use of third-party Web platforms and accessing the functionalities provided |
Automatically collected data In order to allow the User to access the website, register and perform the preliminary operations required to use the service, it is necessary to collect data derived from the navigation. These data may be collected for legal reasons (e.g. logs generated by expressed preferences), to satisfy a request by the data subject (e.g. contact form), or for legitimate interest reasons (e.g. technical cookies). For further details on the types of cookies used and their purposes, please refer to the Cookies Policy on the website. For the use of third-party Web platforms, please refer to the privacy notice of each of these services. The Processing of Personal Data is optional; without the information, the User may not be able to correctly use the service. |
Legitimate Interest pursuant to art. 6, para. 1, letter f) of the EU Reg. 2016/679 + Execution of contractual measures pursuant to art. 6, para. 1, letter b) of the EU Reg. 2016/679 + Legal obligations pursuant to art. 6, para. 1, letter c) of the EU Reg. 2016/679. |
| b. Registration for the educational path through an enrollment form | The processing involves registration for an educational path through the appropriate enrollment form. The Processing of Personal Data is necessary; without the required information, the User cannot register. |
Execution of contractual measures pursuant to art. 6, para. 1, letter b) of the EU Reg. 2016/679. |
| c. Contact Form | Contact form The Owner’s website provides a form accessible on the site for sending information requests. In order to use this service, the user is required to provide first name, last name, email address, phone number, type of affiliated organization, and to enter a free message. The Processing of Personal Data is necessary; without the required information, the User will not receive the desired contact. |
Execution of contractual measures pursuant to art. 6, para. 1, letter b) of the EU Reg. 2016/679 |
| d. Direct Marketing by WeSchool Education | With consent, the Owner may carry out Direct Marketing activities by sending, via e-mail, informative and advertising material, notifications, and invitations to the Owner’s promotional initiatives. The Processing of Personal Data is optional and any refusal by the User does not prevent access to the main services and initiatives the User intends to join. |
Consent of the data subject pursuant to art. 6, para. 1, letter a) of the EU Reg. 2016/679. |
| e. Direct Marketing by WeSchool Education on behalf of third parties | With consent, the Owner could carry out marketing activities on behalf of third parties related to digital products and services useful to Users.
|
Consent of the data subject pursuant to art. 6, para. 1, letter a) of the EU Reg. 2016/679. |
|
f. Sending communications regarding the service (e.g., Educational Communications) |
In order to better manage the service or initiative to which the User has decided to enroll, WeSchool Education S.r.l. might need to communicate with the User via email or telephone.
The Processing of Personal Data is necessary; without contact information, the User might not be enabled to register or may not be able to correctly use the service. |
Legitimate Interest pursuant to art. 6, para. 1, letter f) of the EU Reg. 2016/679. |
|
g. Compliance with legal obligations or for judicial protection |
In order to comply with legal obligations and allow WeSchool Education S.r.l. to ascertain, exercise, and defend its rights in court or before any other competent authority (such as the recording of consents, e.g. timestamp and/or IP data).
The Processing of Personal Data is necessary to protect the legal position, rights, and interests of WeSchool Education S.r.l. regarding the subscription, interpretation, and fulfillment of the General Conditions. WeSchool Education S.r.l. may retain the User’s Personal Data to protect itself in case of potential verifications or inspections by the competent authorities or claims from third parties arising from the uploading of unlawful or otherwise harmful content to the General Conditions. |
Legal obligations pursuant to art. 6, para. 1, letter c) of the EU Reg. 2016/679. |
|
h. Sending data to third parties for marketing purposes |
With consent, contact data will also be sent to third parties, partners of specific initiatives proposed by WeSchool, in order to allow them to contact the Users participating in the initiative.
|
Consent of the data subject pursuant to art. 6, para. 1, letter a) of the EU Reg. 2016/679. |
5. Consequences of Failure to Provide Data
As already highlighted, in most cases, the user is in no way obliged to provide their personal data to WeSchool Education. However, browsing the website and, if applicable, filling in forms and sending communications regarding the service involve the collection of personal data. As can be seen from the first table, the processing under points a-b-c-f-g does not require the user’s consent, but any refusal to provide such data will result in the inability to browse the website or follow up on requests submitted through forms. The processing under points d-e-h may be based on the user’s consent, which can be revoked at any time, without affecting the lawfulness of the processing carried out before the revocation.
6. Data Retention Period
Personal Data is retained by WeSchool Education for the period strictly necessary to achieve the purposes for which they were collected, as listed herein. In particular, unless the right to revoke consent mentioned in the following point 10 letter a) or the right to object mentioned in the following points 10 (f) or 12 is exercised, WeSchool Education retains the Personal Data for the following durations:
a) Cookies/Third-Party Web Platforms: it is recommended to read the Cookies Policy as per the following points 13 and 14. For the use of third-party Web platforms, please refer to the privacy notice of each of these services.
b) Registration for the educational path through an enrollment form: personal data is collected through forms – e.g., Tally.so – and includes, for example, personal details, information about the institution and the classes to be enrolled, interests, etc. They are then processed by WeSchool Education for contractual reasons, to manage the registration for the training path, to organize educational activities and, if requested, to certify hours for PCTO, orientation, civic education, and/or training, and will be deleted 10 years after the end of the course.
c) Contact form: contact data and related information shared with WeSchool following registration via the contact form will be deleted 24 months after submission.
d) Direct Marketing activities by WeSchool Education: the sending of informative and advertising material, notifications, and invitations to promotional initiatives will take place for a maximum period of 24 months from the provision of consent.
e) Direct Marketing activities by WeSchool Education on behalf of third parties: the sending of informative and advertising material, notifications, and invitations to promotional initiatives will take place for a maximum period of 24 months from the provision of consent.
f) Sending communications regarding the service, such as educational communications: 12 months from the usage of the service.
g) Compliance with legal obligations or the defense of rights: for a maximum period of 10 years from collection or for the longer duration of any judicial proceeding.
h) Sharing contacts with third parties for marketing purposes: the sending of contact details to third parties may occur up to a maximum of 24 months from the provision of consent.
Please note that once the retention periods have expired, WeSchool Education S.r.l. will automatically delete the collected Personal Data, or transform them into an irreversible anonymous form.
7. How Personal Data is collected
a) Personal Data communicated by Users
b) Personal Data communicated by authorized third parties or otherwise connected to Users, such as Organizations
c) Personal Data automatically collected through Cookies
WeSchool Education S.r.l. collects Personal Data in the following ways:
a) Personal Data explicitly communicated to WeSchool Education S.r.l. by Users either online or offline: these are the Personal Data provided, for example, by filling in a form on the WeSchool Education S.r.l. website (in case of a contact request) or collected during events and/or initiatives organized by WeSchool Education S.r.l.
b) Personal Data communicated to WeSchool Education S.r.l. by authorized third parties or otherwise connected to Users: these are the Personal Data of Users that are communicated to WeSchool Education S.r.l. by other parties (including Users) for reasons related to initiatives or projects.
c) Personal Data automatically collected during browsing: these are the Personal Data collected automatically, such as user agent or IP addresses of Users, also through Cookies (for further information, WeSchool Education S.r.l. recommends reading the Cookies Policy provided below).
8. Possible categories of recipients of Personal Data
Personal Data is processed by WeSchool Education S.r.l. and/or by third‐party partners, selected for reliability and competence, and to whom it may be communicated as necessary or appropriate, provided that it remains within Italy or the EEA. In particular, WeSchool Education S.r.l. informs Users that Personal Data may be processed by, and/or communicated to:
a) Employees and/or collaborators of WeSchool Education S.r.l.;
b) Other Users participating in the same Project as the User to whom the Personal Data refers;
c) Partners of initiatives proposed by WeSchool Education S.r.l.;
d) Third‐party platforms used to provide the services;
e) Payment service providers;
f) Reference organizations of the Users;
g) Competent authorities to carry out checks or investigations on unlawful or fraudulent acts;
h) Third parties providing automatic newsletter sending services and/or any other type of commercial communication, marketing, or promotion services;
i) With the optional consent of the User (in the case of Minor Users, by the Parent), third parties who send commercial and promotional communications related to their own products and services and/or who perform statistical analyses or market research on Users.
j) With the optional consent of the User (in the case of Minors, by the Parent), third parties for their own commercial purposes who may use them for their own activities.
The updated list of third parties is available at the Data Controller’s premises and can be requested by contacting dpo@weschool.com.
9. Transfer of Personal Data outside the EEA (including the EU)
As far as possible, WeSchool Education S.r.l. avoids transferring Personal Data outside the EEA. However, limited to the services indicated below, some service providers of WeSchool Education S.r.l. may transfer Personal Data to non-EEA countries, pursuant to Articles 44 et seq. of the GDPR, by virtue of adequate guarantees to ensure the protection of Personal Data as declared by the providers themselves as follows:
a) United Kingdom: by virtue of the United Kingdom’s adequacy decision issued by the European Commission on June 28, 2021.
i) Limited to the sending of bulk newsletters
b) United States: by virtue of the adequacy decision for certified providers under the “EU-U.S. and Swiss-U.S. Data Privacy Frameworks” issued by the European Commission on July 10, 2023.
i) Limited to payment services and anti-fraud checks, as well as limited to third-party platforms that may be used to provide the service requested by the User.
Further information on these protection measures can be requested from WeSchool Education S.r.l.
10. User rights
Pursuant to and for the purposes of the GDPR, for the period referred to in point 6 of this Notice, each User (or their representative, in the case of a Minor User) has the right to:
a) revoke consent for processing based on that legal basis, at any time without affecting the lawfulness of the processing previously carried out, by sending an email to WeSchool Education S.r.l. or by exercising the opt‐out via the appropriate button in WeSchool Education S.r.l.’s commercial communications;
b) request from WeSchool Education S.r.l. access to the Personal Data and information on the related processing, and a copy in electronic format, unless the User specifically requests otherwise (see art. 15 of the GDPR);
c) request rectification and/or completion of the Personal Data without undue delay (see art. 16 of the GDPR);
d) for specific reasons (e.g., unlawful processing, withdrawal of consent, lack of a processing purpose), request the deletion of Personal Data without undue delay, noting that the User may contact WeSchool Education S.r.l. by email for further details (see art. 17 of the GDPR);
e) in specific cases (e.g., inaccuracy of Personal Data, unlawful processing, exercise of a right in court), request restriction of processing (art. 18 of the GDPR);
f) object at any time to the processing of Personal Data by sending an email to WeSchool Education S.r.l. (see art. 21 of the GDPR);
g) in the case of automated processing, receive Personal Data in a readable format for the purpose of transmitting it to a third party, or, where technically feasible, request that WeSchool Education S.r.l. transmit the Personal Data directly to such third party (the so-called right to data portability – see art. 20 of the GDPR);
h) be informed by WeSchool Education S.r.l. without undue delay of any violations or unauthorized access by third parties to its systems containing Personal Data (so‐called data breach – see art. 34 of the GDPR);
i) lodge a complaint with the competent authority on personal data by sending the complaint to the Data Protection Authority, at Piazza Venezia, n. 11 – 00187, Rome; email: protocollo@pec.gpdp.it, or to the supervisory authority of your habitual residence, workplace, or the place where the alleged violation occurred.
The above rights may be exercised by contacting the Data Controller at the addresses indicated in Article 1 above. The exercise of your rights as a data subject is free of charge pursuant to Article 12 of the GDPR. However, in the case of manifestly unfounded or excessive requests, including because of their repetitiveness, the Data Controller may charge a reasonable fee, in light of the administrative costs incurred to manage your request, or may deny your request. Finally, please note that the Data Controller may request further information necessary to confirm the identity of the data subject.
11. Objection to the Processing of Personal Data for Direct Marketing by WeSchool Education S.r.l.
Right to object to receiving commercial and promotional communications relating to WeSchool Education S.r.l.
WeSchool Education S.r.l. notes that each User has the right to object to the processing of Personal Data for direct marketing purposes at any time and without any reason, by sending an email to dpo@weschool.com or by exercising the opt‐out via the button/link in the commercial and promotional communications received from WeSchool Education. If this right is exercised, WeSchool Education S.r.l. will cease using the User’s Personal Data for the direct marketing purposes of the services offered by WeSchool Education S.r.l. or its Partners.
12. Types of cookies and links to social networks
a) Technical cookies necessary for navigation
b) Statistical cookies
c) Marketing cookies
On the Website there are links that point to the social channels of WeSchool Education. In this regard, as specified by the Privacy Guarantor it is noted that “if on the site the advertising banners or links to social networks are simple links to third-party sites that do not install profiling cookies, there is no need for information and consent.”
In any case, please note that as highlighted by the Privacy Guarantor in the FAQ on cookies, “for third-party cookies installed through the site, the obligations of information and consent lie with the third parties, but the site owner, acting as a technical intermediary between these and the users, is required to include in the ‘extended’ notice the updated links to the privacy policies and consent forms of the third parties themselves.” Therefore, here is the link to the cookie policy of Facebook/Instagram/WhatsApp (HERE) and LinkedIn (HERE).
13. Acceptance and refusal of Cookies
Consent, banner, access to browser control panels, Your Online Choices service
The User may give their consent to the use of the Cookies described above through the methods indicated on the banner published on the Site.
However, WeSchool Education S.r.l. specifies that disabling technical Cookies is not possible as it would prevent proper navigation on the Site and/or limit its usability.
That said, with reference to all Cookies on the Site, the User may change the settings relating to them according to the methods provided in the control panels of the browser used, such as, for example:
● Google Chrome: https://support.google.com/chrome/answer/95647?hl=it-
IT&hlrm=fr&hlrm=en
● Mozilla Firefox: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie
● Microsoft Edge: https://support.microsoft.com/it-it/help/4027947/microsoft-edge-delete-
cookies
● Safari: https://support.apple.com/it-it/guide/safari/sfri11471/mac
Finally, with specific reference to marketing Cookies, in addition to being able to use the tools provided by the browser to enable or disable individual Cookies, WeSchool Education S.r.l. informs the User that the site www.youronlinechoices.com lists the main providers who work with website operators to collect and use information useful for behavioral advertising. The User can disable or enable all companies (including WeSchool Education S.r.l.) or, alternatively, adjust their individual preferences for each company. To do so, the User can use the tool available on the page www.youronlinechoices.com/it/le-tue-scelte to control every preference regarding behavioral advertising during Internet browsing.