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Privacy Notice – For Users of our website, clients and suppliers

(Art.13 Lgs. Decree 196 dated 30 June 2003, Articles 13 and 14, EU Regulation 2016/679)


A.P.A. Spa takes your privacy very seriously.

This privacy statement is intended to define your rights and answer any questions related to your personal information.

If you have entered into a contract with us, we inform you that the “controller” of your data is A.P.A. Spa, with registered office in via Marradi 6, Milano, Italy, VAT Number and Tax Id. 04072260153, share capital €. 130,000.00 fully paid in, in the person of the pro tempore legal representative Marco Antonio Corazza.

Our privacy policy and procedures for handling personal information have been developed in line with the requirements of the European Union Data Protection Directive 1995 (Directive 95/46/EC) and the General Regulation on the Protection of Personal Data (in force since 25 May 2018) and the applicable national law.

1. What personal data do we collect?

We collect different types of information from and on users of our websites, including the information through which you can be identified personally, such as name, mailing address, e-mail address and telephone number, and through which you can be contacted online or offline (“personal data”).

We also collect information about you, but that does not identify you individually, such as information on your Internet connection, the equipment you use to access our websites and usage details.

We collect this information:

  • • directly from you when you provide it by filling in some forms on the site or when you purchase from us;
    • automatically when you browse our websites. The information collected automatically may include usage details, IP addresses and information collected through cookies;
    • we collect and process personal data about you when you interact with us for our services and when you purchase services from us.

The personal data processed may include:

  • • your name and the names of the personnel of the companies with which we maintain business relationships;
    • tax data (VAT No., Tax Id.), PEC (Certified Email Address), addresses of offices, etc.
    • data for payment management (Bank, IBAN, etc.);
    • work addresses, e-mail address and/or telephone number, fax number, IP address in case of completion of one of our forms (for event registration, information requests, newsletter subscriptions, for accessing downloadable material, etc.)
    • job responsibilities.

2. How do we use this personal data and what is the legal basis for this use?

We process the personal data listed in paragraph 1 above for the following purposes:

  • • to establish and fulfil a contract requested by you, for example, if you make a purchase from us or enter into an agreement to enrol in one of our courses. This may include verifying your identity and the solvency of your company, and communicating your company’s data to banks to manage payments;
    • to enter into a contract with you (we are unable to do so without it);
    • to comply with laws and regulations applicable to business contracts or public funding;
    • in accordance with our legitimate interests, to protect our business interests and legal rights, including but not limited to, use in connection with legal claims, regulatory compliance and investigative purposes (including disclosure of such information in connection with legal process or litigation);
    • with your express consent, to respond to any comments or complaints we may receive from you subsequent to our business relationship or other;
    • we may use information you provide to personalise (i) our communications to you; (ii) our website; and (iii) products or services for you;
    • to monitor use of our websites and online services. We may use your information to help us check, improve and protect our products, content and Websites, both online and offline, in accordance with our legitimate interests;
    • with your explicit consent, we may use your information to invite you to participate in events connected with the interests you have shown by coming into contact with us. We may also send you direct marketing in relation to relevant products and services. Electronic and hardcopy (letters) direct marketing will only be sent where you have given your consent to receive it.
    You will continue to be able to opt-out of electronic direct marketing at any time by following the instructions in the relevant communication.

3. With whom and where will we share your personal data?

We may share your personal data with the below third parties:

  • • our professional advisors such as our auditors and tax, legal and IT consultants;
    • banks for payment management, debt collection agencies;
    • partners for the organisation and management of complex training programmes and projects;
    partners for the organisation of promotional events you have expressly requested to attend;
    • Web marketing, website management and communication agencies where they have agreed to process your personal data in line with this Privacy Notice;
    • our suppliers and business partners;
    • search engines and web analytics, e-mail marketing platforms.Personal data may be shared with government authorities and/or law enforcement officials if mandated by law or if needed for the legal protection of our legitimate interests in compliance with applicable laws.

Personal data may also be shared with third-party service providers who will process it on behalf of A.P.A. Spa in Italy for the purposes above.

Such third parties include, but are not limited to, the website hosting provider (Seweb Italia), in charge of site maintenance, and the manager of the e-mail marketing platform.

Specifically, if you subscribe to our newsletter, your data will be communicated to Hoplo Srl, Piazza Castello, 26 20121 Milano, Italy, VAT Number and Tax Id. 08450220010 (https://www.infomail.it/informativa-privacy/), the manager of the e-mail marketing platform for newsletter management.

The persons appointed act according to the instructions and under the direct authority of the controller.

4. How long will we keep your personal data?

We will not keep your personal data for any purpose longer than necessary to fulfil the original purpose and we will only store the personal information necessary to achieve the purpose for which you have provided it.

We are required to retain certain information by law for as long as reasonably necessary to meet regulatory or tax requirements, ensure that lenders can verify the financing, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.

Where you are a customer or a supplier, we will keep your personal data for a period of up to 10 years.

Where you are a prospective customer and you have expressly consented to us contacting you, we will only retain your personal data (a) until you unsubscribe from our communications; or, if you have not unsubscribed, (b) while you interact with us and our content; or (c) for 12 months from when you last interacted with us or our content.

5. Where is your data stored and how do we take care of it?

The personal data that we collect from you is stored within the European Economic Area (“EEA”) and is processed by staff operating within the EEA who work for us or for one of our suppliers.

We have implemented technical and organisational measures in order to protect personal data from unlawful or unauthorised access, loss or destruction or unauthorised use and disclosure.

We store personal information on secure servers protected by FIREWALL, latest generation antiviruses, etc. that are managed by us and our service providers, and occasionally on paper files archived in a safe place in Italy.

The personal information we store or transmit is protected by security and access controls, including authentication with username and password.

6. What are your rights in relation to your personal data?

You have the right to ask us not to process your personal data for marketing purposes.

You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data, clicking the unsubscribe button on any communication we have sent to you or by contacting us.

Where you have consented to us using your personal data, you can withdraw that consent at any time.

If the information we hold about you is inaccurate or incomplete, you can notify us and ask us to correct or supplement it.

You also have the right to ask us to provide a copy of any personal data we hold about you.

Where you have provided your data to us and it is processed by automated means, you may be able to request that we provide it to you in a structured format.

If you have a complaint about how we have handled your personal data, you may be able to ask us to restrict how we use your personal data while your complaint is resolved.

In some circumstances you can ask us to erase your personal data (a) by withdrawing your consent for us to use it; (b) if it is no longer necessary for us to use your personal data; (c) if you object to the use of your personal data and we don’t have a good reason to continue to use it; or (d) if we have not handled your personal data in accordance with our obligations.

7. Where can you find more information about A.P.A. Spa’s handling of your data?

Should you have any queries regarding this Privacy Notice, about A.P.A. Spa’s processing of your personal data or wish to exercise your rights you can contact

  • • via e-mail: ttdp@apaspa.com
    • via fax: +390295966335
    • or via mail: A.P.A. Spa, Via Ruffilli 6 – 20042 – Pessano con Bornago, Italy.

8. To whom can you report or claim a violation you think we may have committed?

You can send a registered letter with return receipt to Garante della Privacy, Piazza di MONTE CITORIO 121 00186 Roma, Italy An e-mail to urp@gdp.it or urp@pec.gdp.it A fax to +3906696773785

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