PRIVACY POLICY & COOKIES

Who we are

SIENA EXPERIENCE ITALIAN HUB is property of SIENA PROGRAM ABROAD – Srls .
Our website address is: https://www.sieitalianhub.com

Our commitment to protect your privacy

SIENA PROGRAM ABROAD – Srls is committed to protecting the privacy of its current and future customers. The SIENA PROGRAM ABROAD – Srls privacy policy (“Privacy Policy”) applies to all Personal Data (as defined below) processed by us, including Personal Data collected or sent through our website, our applications for mobile devices, our official social media pages or through other online and offline channels as described in more detail below (collectively “Products”). If you cannot, or do not wish to provide us with the personal information we reasonably request, we may not be able to provide you with the information, products or services you have requested. The company SIENA PROGRAM ABROAD – Srls, the data controller of your Personal Data, has the responsibility to ensure that your Personal Data is processed in compliance with the applicable privacy and data protection regulations.

Personal Data

The “Personal Data” are information or parts of information that could allow your identification, such as:

  • Name and contact details (eg postal address, email address, phone number)
  • Account information (e.g. user name, profile picture or social media account ID)
  • Country of residence
  • Date of birth
  • Technical information, eg username, IP address, browser and device data, information collected through cookies, pixel tags and other technologies, server log file data, app usage data and location data
  • Preferences (eg favorite training courses)
  • Name and address of the school or company
  • Credit and debit card number
  • Clinical situation (eg allergies or illnesses)

How do we collect Personal Data?

We collect Personal Data in various ways:

1. Directly from you: We get information directly from you when you provide it to us explicitly or when your actions allow us to collect it. For example:

  • Offline: We collect your Personal Data offline, for example when you contact customer service, sign up for a program or book a service or provide us with information by writing to us.
  • Online: We collect your Personal Data through the SIENA PROGRAM ABROAD – Srls channels, for example when you sign up for a newsletter or request a catalog, or when you take advantage of a product or service. We also collect Personal Data:
  • Through cookies. Cookies allow a web server to transfer data to a computer or device for archiving and other purposes. If you do not want information to be collected through the use of cookies, most browsers provide a simple procedure that allows you not to authorize their use. For more information on cookies, visit http://www.allaboutcookies.org/. For detailed information on the cookies we use and the purposes for which we use them, see our cookie policy below.
  • Through your use of a mobile application. When you download and use one of our mobile applications, and to the extent permitted by your privacy settings related to the application itself, we track and collect usage data for that application, such as the date and time it was run access to our servers and what information and files have been downloaded based on your device number.
  • Through your device. If you have enabled the relevant function on your device, we detect itsphysical location to provide you with customized services and content based on your location. You can get more information on this type of services in the “How do we use Personal Data?” section below.

2. From our collaborators. We may receive Personal Data from other parties together with yours course / program, including: Our affiliates manage customer service in their country of residence and provide us with Personal Data necessary to reach an agreement related to your request.

3. From other sources. We may receive your Personal Data from other sources, such as: public databases; business partners such as marketing agencies or software vendors and services for the automation of digital marketing and analysis; social media platforms that include, among others, Facebook, Instagram, YouTube and messaging services such as WhatsApp or Facebook Messenger; people you are friends with or otherwise connected to on social media platforms, and other third parties. For example, if you decide to link your social media account to our social media accounts the Personal Data you have saved in your profile will be shared with us, such as email address, phone number, postal address, date of birth , name and username. We also use cookies to track social network members as described in more detail in our cookie policy below.

4. If you visit our website. We may also collect information from an IP address that is
automatically identified and recorded in our server log files whenever you visit our site, along with the time of the visit and the pages that have been visited. This data is stored and used together with other Personal Data that you have sent only if you have given your consent. You can get more information on collecting your IP address and other browsing data in our cookie policy below.

How do we use Personal Data?

Your Personal Data will be processed by SIENA PROGRAM ABROAD – Srls to complete your booking, to provide you with the services you have requested, for administrative services or for other purposes necessary for the execution of the contract stipulated with us or as specified in more detail in the present information.

We may also use Personal Data:

  • For statistical purposes, to calculate usage levels, to help diagnose server problems related to SIENA PROGRAM ABROAD – Srls Products and to ensure that these products work properly.
  • To allow you to contact and be contacted by other users through the Products of SIENA PROGRAM ABROAD – Srls, in the ways foreseen by the product used.
  • To allow you to participate in forums, chats, profile pages and blogs and use other services that allow you to publish information and materials.
  • If you have given your consent:
    – To analyze and improve our offers by identifying usage habits, determining the effectiveness of our promotional campaigns and customizing the experience and content of SIENA PROGRAM ABROAD – Srls Products based on your previous interactions with our website.
    – To provide you with customized services and content based on your location by using the physical location of your device. For example, if your device indicates that you are browsing from your country of residence, you will be redirected to the SIENA PROGRAM ABROAD – Srls website.
    – To advertise our products and services, including special promotions based on your interests, for example through management software for managing marketing campaigns via email. All email communications of this type will include a clear and obvious link in order to unsubscribe.

How do we share Personal Data?

We share your Personal Data with our collaborators. Our employees promote sales of our services and manage customer service in your country of residence or school in your destination country that provides some of the services you have requested.

We have put in place adequate guarantees for the transfer of your data in Italy. For more information on the standard data protection clauses used, please refer to the Contact Us section below, which also includes the standard data protection clauses adopted by the European Commission, available on https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32004D0915.

We also share Personal Data to the extent that we deem it necessary: (a) pursuant to applicable laws; (b) to fulfill legal obligations; (c) to respond to requests from public and governmental authorities outside your country of residence; (d) to enforce our terms and conditions or a contract; (e) to protect our operations or those of our affiliates; (f) to protect our rights, our privacy, our security or our property, and / or those of our affiliates, customers or others; and (g) to allow us to pursue available solutions or limit the damage we could sustain.

On what do we base our right to collect and use Personal Data?

Our right to collect and use your Personal Data is based on the need to obtain such information to be able to provide the services you have requested, or on the presence of a legitimate interest for us (ie the service provider) to use your Personal Data , for example for advertising services similar to those you have already purchased from the same legal entity.

When we use sensitive Personal Data, we do so with your explicit consent. Sensitive data can be, for example, information on health, ethnicity or religious beliefs. You can get more information on this in the “Sensitive Data” section. When we use your Personal Data to send you offers beyond what is considered to be within our legitimate interest, such as advertising services, we do so with your specific consent.

Security

We use appropriate organizational, technical and administrative measures to keep Personal Data accurate and up to date under our control and to protect them from unauthorized or illegal processing and their accidental loss, destruction or damage.

Cancel Subscription

If at any time you wish to stop receiving marketing communications from us, you can use the subscription cancellation feature contained in the received business message or tell us your intention using the contact information listed in the “Contact Us” section. In your request, indicate that you no longer wish to receive marketing communications from us. Changes may not take effect immediately. We will try to satisfy your requests as soon as reasonably possible.

Third Party Sites

This Privacy Policy does not deal with, and we are not responsible for, privacy, information or other third-party practices, including those that manage sites that can be accessed from a link contained in our website.

How long do we keep personal data?

We store your Personal Data only for the time necessary for the purposes for which it was collected or in compliance with the time limits stipulated by the law and market practice; exceptions are cases in which it is necessary to keep Personal Data longer in compliance with legal obligations or to establish, exercise or defend a right by judicial process, and cases in which a specific period of time has been communicated. We will retain limited parts of your Personal Data as necessary for marketing purposes until you
withdraw your consent; in any case they will not be stored for more than 10 years from the conclusion of the last service you used or from the last delivery of a product.

If you have less than 16 years

If you are under 16 you should examine this document with a parent or guardian to make sure you both understand it. It is not our responsibility to check your age, but sometimes we carry out checks. If we find out that you are under the age of 16 and we have collected information about you without the consent of a parent or guardian, we will delete the information as soon as possible and you will not be able to use our information site.

Sensitive Data

Generally we do not collect any Sensitive Data. Sensitive Personal Data are data relating to ethnic or racial origin, political opinions, religious or philosophical beliefs, clinical situation or health conditions, criminal records or membership of trade unions. In certain situations, this may however be necessary (for example to provide you with services and products that you have requested and with respect to your insurance). It will be our duty to ensure that you have your explicit consent for the processing of this type of information, which we will handle safely.

Updates to this Privacy Policy

Our Privacy Policy may change from time to time. We will not drastically reduce your rights described in this Privacy Policy without informing you. We will post any changes to this Privacy Policy on this page and, before implementing such changes, we will highlight an explicit warning. Where required by law, we will request your consent to any changes.

Your Rights

You have the right to contact us, at no additional cost, to find out what information about you is used. You have the right to receive your Personal Data in a format that can be read by an automatic device and you have the right to transfer your personal data to another data controller. You have the right, at any time, to withdraw your consent or object to the use of your Personal Data for direct marketing purposes; you can also, at any time, request that the use of your Personal Data be limited or that these be deleted. However, deleting the Personal Data or limiting its use may prevent us from providing you with the information, services and products you have requested. At your request we are also required to correct your Personal Data if they are incorrect, incomplete or misleading.

Contact us

If you wish to have a copy of the information that SIENA PROGRAM ABROAD – Srls holds about you; a copy of the standard data protection clauses or you wish to exercise one of your rights, please contact us. If you have complaints about our management of your Personal Data, you have the right to contact the supervisory authority of the country where you live.

SIENA PROGRAM ABROAD Srls – P.iva / C.F. 01491310528
Email: info@sieitalianhub.com
PEC: sienaprogramabroad@pec.it
Telephone: + 39 0577 891908

Cookies Policy

What is a cookie? Cookies are short text files that are downloaded to the user’s device when visiting a website. At each subsequent visit, cookies are sent back to the website that originated them (first-party cookies) or to another site that recognizes them (third-party cookies). Cookies are useful and have different purposes such as, for example, allowing you to efficiently navigate between pages, remember your favorite sites and, in general, improve your browsing experience. They also help to ensure that the advertising content displayed online is more targeted to the user and his interests (cookie targeting).

Cookies can be temporary that have a limited duration of the visit and are deleted when the browser is closed, or persistent cookies, which remain stored on the device even after leaving the website or closing the browser: these cookies remain until they expire expected or until they are manually deleted by the user. Use of cookies by SIENA PROGRAM ABROAD SRLS: as with most websites, a visit to the www.sieitalianhub.com site also requires the use of cookies to improve user experience. The cookies used on the site www.sieitalianhub.com are only “technical” or aimed at allowing you to navigate between pages efficiently.

The cookies used are:

  • Session cookies (or technical): temporary cookies that allow the user to access personalized services and to take full advantage of the site’s features.
  • Analysis cookies: both temporary and permanent, they allow aggregate information regarding the behavior of users on the site to be collected and thus improve the experience and contents provided. The information collected in this way has no personal value as the data is collected and analyzed anonymously. We specifically use Google Analytics * cookies in the manner described on this page.

Cookies are not used for marketing purposes (targeting cookie) or to profile user behavior while browsing. Third-party cookies are also not used. Please refer to the website of the guarantor http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/3118884 for further details on the legislation governing the matter. You can enable or disable all cookies or a part of them, or delete already defined cookies, by changing the related settings from the Help menu of the internet browser. In doing so, it is important to know that all the interactive features of the website will no longer be available.

Accepting or refusing cookies is your right. By default, browsers generally accept the use of cookies both from our site and from third-party sites. It is however possible to change these settings. To manage the use of cookies it is necessary to change the browser settings via the relative toolbar.

Below are the links to resources that describe how to manage cookies for the most popular browsers:

It is possible to disable Google Analytics cookies by visiting the Google web page Google GaOptOut and downloading the add-on for the browser used. Please note that if you change or customize your cookie preferences, they must be set for each device and
each browser used in internet browsing. To allow the website to function properly, to exploit its features and use in its entirety, we recommend that you accept the use of cookies, both ours and those of third parties.