Privacy Policy
WeSchool Education Srl
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PRIVACY POLICY
pursuant to Articles 13 and 14 of Regulation (EU) 2016/679
WeSchool Education S.r.l., with headquarter in Milan, Via Fabio Filzi no. 27, has taken over some of the activities previously carried out by WeSchool S.r.l. for the users of its platform. This takeover also involved the transfer of ownership of some personal data, of which WeSchool Education S.r.l. has become the Data Controller.
The personal data transferred from WeSchool S.r.l. to WeSchool Education S.r.l. will be processed exclusively for the purposes indicated in this policy and in compliance with current legislation on personal data protection.
(V1 – March 18th 2025)
1. Definitions
1.1 Educational Communications: communications relating to educational initiatives or services, without any commercial purpose, necessary for the management and use of the service.
1.2 General Conditions: general conditions of the Services offered by WeSchool Education S.r.l.
1.3 Cookies: text files (letters and/or numbers) that contain packets of information stored on the User’s computer or mobile device whenever they visit a website through a browser or through a webapp. At each subsequent visit, the browser sends cookies to the website that originated them. Cookies can be stored only for the time of use of a particular site (i.e., session cookies), or for a longer period of time independent of the session (i.e., persistent cookies).
1.4 Personal Data: any information relating to an identified or identifiable natural person, directly and indirectly, by reference to a name, an identification number, location data, an online identifier or to elements characteristic of their physical, physiological, genetic, mental, economic, cultural or social identity.
1.5 Educators: People from the WeSchool team (or Partners) who provide their Services to Users.
1.6 GDPR: EU Regulation 2016/679 of April 27, 2016.
1.7 Privacy Policy: information on the processing of Personal Data and information relating to Cookies that constitute this document. This Privacy Policy does not cover any Processing of Personal Data conducted through any third-party sites, pages or online services of third parties, accessible by the User via links. The Privacy Policy is available and easily accessible from the WeSchool Education S.r.l. site www.weschool.com.
1.8 Adult Users: Users aged at least 18 years.
1.9 Minor Users: Users under the age of 18 who use the Services, possibly (where necessary) by virtue of specific authorization from the Parent.
1.10 Direct Marketing: marketing activities carried out by the Data Controller in its own interest, via e-mail, relating to the Services offered by WeSchool Education S.r.l., as well as relating to similar products and initiatives organized also by WeSchool Education S.r.l.’s Partners.
1.11 Organization: a School, a University, a company, a public administration, a non-profit entity, a freelancer or any other legal entity.
1.12 Project: educational training initiative developed by WeSchool Education S.r.l. and intended for Users.
1.13 Site: the official website of WeSchool Education S.r.l. as well as the sites of initiatives organized by the Controller.
1.14 School: educational institution of any level or grade.
1.15 EEA: “European Economic Area” made up of the member countries of the European Union, Norway, Iceland and Liechtenstein.
1.16 Services: educational, training and professional services provided by WeSchool Education S.r.l. to Users.
1.17 Controller: the natural or legal person, public authority, service or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.
1.18 Processing: any operation or set of operations concerning Personal Data, such as, by way of example, collection, organization, structuring, storage, modification, extraction, consultation, use, communication, interconnection, limitation, cancellation and destruction.
1.19 University: a scientific-didactic and cultural institution, public or private, representing the highest level of education.
1.20 Users: all users of WeSchool Education S.r.l. services.
1.21 WeSchool Education S.r.l.: WeSchool Education S.r.l., with headquarters in Milan, Via Fabio Filzi no. 27, 20124 (MI), C.F./P.IVA 13971580967 and Milan Business Register MI – 2754271
1.22 WeSchool S.r.l.: WeSchool S.r.l. in Liquidation, with registered office in Via Guido Reni 42, 20133, Milan C.F./P.IVA 07236760968 and Milan Business Register MI-1946066
2. Data Controller
With reference to the processing covered by this policy, the Data Controller is WeSchool Education S.r.l.
In the case of Services offered in collaboration with third-party Partners, WeSchool Education S.r.l. may act in a joint controllership relationship with the Partner itself.
Any request from the User relating to Processing carried out by WeSchool Education S.r.l. as Controller (including the exercise of rights under Article 15 et seq. of the GDPR) should be addressed to WeSchool Education S.r.l. by one of the following means:
- by post to the registered office: WeSchool Education S.r.l., in Milan, Via Fabio Filzi n. 27, ZIP 20124
- by e-mail to the following address dpo@weschool.com
3. Data Protection Officer (DPO)
For any doubts or requests regarding the methods of processing personal data, the Company has appointed a DPO (Data Protection Officer), identified in the person of Avv. Diego Dimalta, who can be contacted at the e-mail address dpo@weschool.com
4. Purposes, Nature and Legal Bases of Processing
Purpose of Processing | Nature of processing | Legal bases | Data retention |
a. Management of Services
Allow the User to use the Services offered by WeSchool Education S.r.l. which will consequently manage the related administrative-accounting and after-sales relationship |
Necessary
The Processing of Personal Data is necessary for the use of the Services offered by WeSchool Education S.r.l. and any refusal prevents the use of such Services according to the provisions of the General Conditions. |
Execution of contractual measures pursuant to Art. 6, par. 1, letter b) of Reg. EU 2016/679.
Legal obligations pursuant to Art. 6, par. 1, letter c) of Reg. EU 2016/679. |
10 years from service provision. |
b. Direct Marketing by WeSchool Education S.r.l.
With consent (possibly provided to WeSchool S.r.l.) carry out Direct Marketing activities by WeSchool Education S.r.l., by sending, via e-mail, informational and advertising material, notifications and invitations to promotional initiatives of the Controller. |
Optional
The Processing of Personal Data is optional and any refusal by the User does not prevent the use of services and initiatives that the User intends to register for. |
Consent of the data subject pursuant to Art. 6, par. 1, letter a) of Reg. EU 2016/679. Consent may have been provided by the User to WeSchool S.r.l. | 24 months from consent. |
c. Direct Marketing by WeSchool Education S.r.l. on behalf of third parties
With consent (possibly provided to WeSchool S.r.l.) carry out marketing activities on behalf of third parties relating to digital products and services useful to Users. |
Optional
The Processing of Personal Data is optional and any refusal by the User does not prevent the use of services and initiatives that the User intends to register for. |
Consent of the data subject pursuant to Art. 6, par. 1, letter a) of Reg. EU 2016/679. Consent may have been provided by the User to WeSchool S.r.l. | 24 months from consent. |
d. Fulfillment of legal obligations or for judicial protection
Fulfill legal obligations and allow WeSchool Education S.r.l. to ascertain, exercise and defend its rights in court or before any other competent authority. |
Necessary
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 store the User’s Personal Data, in order to protect itself in the event of potential checks or investigations by the competent authorities or claims by third parties arising from the uploading of illegal content or otherwise harmful to the General Conditions. |
Legal obligations pursuant to Art. 6, par. 1, letter c) of Reg. EU 2016/679. | 10 years from service provision. |
e. Sending communications regarding the service (e.g.: Educational Communications)
In order to better manage the service or initiative that the User has decided to register for, WeSchool Education S.r.l. may need to communicate with the User by email or telephone. |
Necessary
In the absence of contact information, the User may not be enabled to register or may not be able to correctly use the service. |
Legitimate Interest pursuant to Art. 6, par. 1, letter f) of Reg. EU 2016/679. | 12 months from service usage. |
It should be noted that, once the retention periods have expired, WeSchool Education S.r.l. will automatically delete the Personal Data collected, or transform them into anonymous form in an irreversible manner.
5. Methods of collecting Personal Data
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 collected automatically through Cookies
WeSchool Education S.r.l. collects Personal Data with the following methods:
a) Personal Data expressly communicated to WeSchool Education S.r.l. by Users in online or offline mode: these are Personal Data provided, for example, by filling out a form, on the WeSchool Education S.r.l. website (in case of 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 Personal Data of Users that are communicated to WeSchool Education S.r.l. by other subjects (including Users) for reasons related to initiatives or Projects.
c) Personal Data collected automatically during navigation: these are Personal Data collected automatically such as, for example, user agents or IP addresses of Users, also through Cookies (for further information, WeSchool Education S.r.l. recommends reading the Cookies Policy reported below).
6. Possible categories of recipients of Personal Data
Personal Data are processed by WeSchool Education S.r.l. and/or by third-party partners, selected for reliability and competence, and to whom they may be communicated as necessary or appropriate, provided that they are 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 the initiatives proposed by WeSchool Education S.r.l.;
D.Third-party platforms used to provide services;
E. Reference Organizations of Users;
F. Payment service providers;
G. Authorities competent to carry out checks or investigations on illegal or fraudulent acts;
H. Third parties who provide automatic services for sending newsletters and/or any other type of commercial communication, marketing services, promotion;
I. Subject to optional consent of the User (in the case of Minor Users, by the Parent), third parties who send commercial and promotional communications relating to their products and services and/or who carry out statistical analyses or market research on Users.
7. Transfer of Personal Data outside the EEA (including the EU)
Whenever possible, WeSchool Education S.r.l. avoids the transfer of 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 UK adequacy decision issued by the European Union Commission on June 28, 2021.
a. Limited to newsletter sending Three Hearts Digital Ltd. (E mail Octopus), with registered office at 86-90 Paul Street, London, EC2A 4NE, United Kingdom.
B. United States: by virtue of the adequacy decision for providers certified under the “EU-U.S. and Swiss-U.S. Data Privacy Frameworks” issued by the European Union Commission on July 10, 2023.
a. Limited to payment services and anti-fraud controls, as well as limited to third-party platforms possibly used for the provision of the service requested by the User;
Further information on these protection measures can be requested from WeSchool Education S.r.l.
8. User rights
Pursuant to and for the purposes of the GDPR, for the period referred to in point 8 of this Policy, each User, in particular the Parent in their own name as well as in the name and on behalf of the Minor User, has the right to:
a) withdraw consent, for processing based on this legal basis, at any time without prejudice to the lawfulness of the Processing previously carried out, by sending an e-mail to WeSchool Education S.r.l. or by exercising the opt-out through the appropriate button present in the commercial communications of WeSchool Education S.r.l.;
b) ask WeSchool Education S.r.l. for access to Personal Data and information on the relevant Processing and possibly a copy in electronic format, unless otherwise specifically requested by the User (see Article 15 of the GDPR);
c) request the rectification and/or integration of Personal Data, without undue delay (see Article 16 of the GDPR);
d) for specific reasons (for example, unlawful processing, withdrawal of consent, non-existence of the purpose of the Processing), request the deletion of Personal Data, without undue delay, it being understood that the User can contact WeSchool Education S.r.l. via e-mail for more details (see Article 17 of the GDPR);
e) in specific cases (for example, inaccuracy of Personal Data, unlawfulness of Processing, exercise of a right in court), request the limitation of Processing (Article 18 of the GDPR);
f) object at any time to the Processing of Personal Data, by sending an e-mail to WeSchool Education S.r.l. (see Article 21 of the GDPR);
g) in case of automated Processing, receive Personal Data in readable format, for the purpose of communicating it to a third party, or, where technically feasible, request the transmission of Personal Data by WeSchool Education S.r.l. directly to such third party (so-called right to data portability – see Article 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 Article 34 of the GDPR);
i) lodge a complaint with the supervisory authority of the EU country in which they reside, work or in which they believe the violation of their rights occurred (see Article 77 of the GDPR);
For further information on the terms and conditions for exercising the rights recognized to the User, the latter can consult the text of the EU GDPR published at the following link, or contact WeSchool Education S.r.l. at the contacts indicated in this Policy.
9. Opposition to Processing relating to direct marketing of 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. highlights that each User has the right to object to the Processing of Personal Data processed for direct marketing reasons at any time and without any motivation, by sending an e-mail to dpo@weschool.com or by exercising the opt-out via the button/link present in the commercial and promotional communications received from WeSchool Education S.r.l.. In case of exercise of this right, WeSchool Education S.r.l. will stop using the User’s Personal Data for the purposes of Direct Marketing of the Services offered by WeSchool Education S.r.l. or its Partners.
10. Types of cookies
a) Technical cookies necessary for navigation
b) Statistical cookies
c) Marketing cookies
11. Acceptance and waiver 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 using the methods indicated on the banner published on the Site.
However, WeSchool Education S.r.l. specifies that the deactivation of technical Cookies is not possible, as it would prevent correct navigation on the Site and/or would limit its usability.
This said, with reference to all Cookies of the Site, the User may modify the settings relating to them, according to the methods provided in the control panels of the browser used, such as by way of 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
- Internet Explorer: https://support.microsoft.com/it-it/help/278835/how-to-delete-cookie-files-in-internet-explorer
- 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