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Privacy Notice
art. 13 Regulation EU 2016/679

Dear User,

according to Art. 13 et seq. Reg. Eu 679/2016 and, in any case, in compliance with the entire legislation on the matter, the company Hi Performance s.r.l. informs you that your personal data will be processed according to the principles of lawfulness, fairness, transparency, minimization and confidentiality in compliance with EU Regulation 679/2016.

  1. data controller – Hi Performance S.r.l., (henceforth also just "Hi Performance" or "Data Controller") with registered office in Via Cesare Fracassini, 4 - 00196 Rome, Tax Code and VAT No. 05600831001 (email: [email protected])
  2. processed data – The Data Controller processes your personal data, and accordingly the data collected and provided by you, such as: direct and indirect personal identification data of the person (name and surname, date and place of birth, residence, Tax code and/or part. VAT, email addresses and telephone numbers).
    In addition, with your consent to the processing, the data you provide may also be merged and combined with the following categories of data legitimately drawn from other sources: data collected from social media; data collected from your browsing on Hi Performance websites or from the use of our applications; data related to the use of services, including financial services, partners of Hi-Performance; statistical data; data acquired about your interests and preferences from third parties.
  3. purposes and legal basis for the processing – The Data Controller processes your personal data, and thus the data collected and provided by you, in order to and for
    a) promotion purposes of its courses and Thus marketing purposes, promotional purposes, data transfer to third parties and profiling purposes (with prior consent): promotion of the courses sold/managed/organized by Hi Performance both directly and through third parties through communications carried out both by automated means (e.g., e-mail, sms, instant messaging apps, etc.) and non-automated means (e.g., regular mail, telephone with operator, etc.). of its products and offers; communications with the customer; mailing and sending of informative material. Profiling activities, i.e., analysis, including by means of systems (including automated) profiling, of customer preferences and, in particular, preferences regarding interests, educational options or preferred activities. This activity may also take place through the administration of satisfaction questionnaires. In particular, the purposes of marketing and profiling are addressed to send you advertising, promotional initiatives and offers that are or may be to your satisfaction. Your personal data for the purpose of promoting the products and/or services of Hi Performance allow us to create a profile of you in order to analyze, follow and anticipate your preferences and interests for our products and services. Similarly, your data, along with that of our other customers, through extrapolation, profiling at scale, and use of intelligent algorithms, allow us to better understand the use and success of our products and services and to improve them for the benefit of our customers. We seek to collect only data closely related to our products and services. We inform you that, where possible, your data will also be processed in anonymous, aggregated or pseudonymized form in compliance with the principles of minimization and pseudonymization provided by EU Regulation 679/2016. In addition, it is represented that for the purpose explained here, Hi-Performance has a legitimate interest in knowing the preferences of its customers in order to better customize its offers and to offer products and services that better meet the needs and desires of its customers. In this case, you, as a data subject, may at any time activate your rights as set out below in point 9) of this letter. In order to follow up on these purposes, we inform you that it is also necessary to provide consent to the processing as indicated in point 5.1) hereof. Therefore, the legal basis of the purpose set out in this point is to be found, in the provisions of Article 6, paragraph 1, letters a), b) and f), Reg. Eu 679/2016.
    b) regulatory purposes: to execute legal obligations, regulations, national, EU and international regulations or resulting from provisions issued by Authorities legitimized to do so by law (including - possibly - by foreign countries); to pursue, ascertain and/or defend, if needed, a right or legitimate interest of Hi-Performance in the management of any litigation, including judicial litigation; to fulfill obligations provided for in the tax and accounting area; to fulfill obligations related to health and safety regulations; to fulfill obligations related to regulations; accounting administration, invoice issuance and management, contract management, payment and collections management. Therefore, the legal basis for the purpose set forth in this point is to be found, in the provisions of Art. 6(1)(c), Reg. Eu 679/2016.
    c) legitimate interest: to pursue, verify and/or defend, possibly, a right or legitimate interest of the Data Controller in the management of any litigation, including judicial litigation. Therefore, the legal basis of the purpose set out in this point is to be found, in the provisions of Art. 6, paragraph 1, letter f), Reg. Eu 679/2016. The Data Controller does not process your special or judicial data under Art. 9 and 10 EU Reg.
  4. processing methods – The processing is carried out in full compliance with the Law and the appropriate technical organizational security measures of the Data Controller in accordance with the provisions of EU Reg. 679/2016, in order to minimize the risks of unauthorized disclosure and access, accidental or unlawful access to personal data transmitted, destruction, modification, loss, unavailabilitỳ. The processing is carried out through the use of tools, computerized, telematic and manual/paper, in order to ensure, first and foremost, the confidentiality of the data. Your data will be processed by the Data Controller's internal staff and therefore by individuals specifically appointed as authorized or as processors, as provided for in EU Reg. 679/2016. Your data may be stored on servers of third-party cloud service providers. We inform you that the personnel authorized to process the data collected have been adequately educated and trained on the purposes and methods to be followed in carrying out the relevant task. We inform you that, where possible, your data will also be processed in anonymous, aggregated or pseudonymized form in compliance with the principles of minimization and pseudonymization set forth in EU Regulation 679/2016.
  5. disclosure or communication of data and possible receipients – Your data will not be disclosed to third parties, with the exception of what is provided for in this privacy notice. With such limitations, your data may be disclosed and/or shared to third party partners of Hi-Performance who are engaged in similar activities or partners of Hi-Performance appointed as Data Processors or partners with whom there is a joint controller agreement pursuant to Art. 26 GDPR. In addition, your data may be disclosed to the Data Controller’s suppliers; external consultants and IT technicians; persons, companies, associations or professional firms that provide services or activities of assistance and consulting in favor of the Data Controller or that are partners of the same for marketing purposes; associations or professional firms that provide services or activities of assistance and consulting in favor of the Data Controller in order to protect its own right (for example, accountants, lawyers, tax consultants, auditors, consultants within the scope of auditing or due diligence operations, etc. ); subjects to whom the right to access personal data is recognized by provisions of the law and/or secondary regulations or provisions issued by Authorities empowered to do so by law; document archiving companies; third-party technical service providers, postal couriers, telematic and computer services, hosting providers, management software, technological platforms to deliver webinars (free online mini-courses). In addition, your data may be communicated to employees and collaborators of Hi-Performance, as authorized processors and other third parties responsible for processing or autonomous data controllers (professionals and/or external companies for the provision of support services, certification, consulting, control, marketing, data processing, IT services, for printing, call-center management, specializing in market research or commercial information and mailing etc.). Your data may also be shared with third parties where required by legal obligation or as a result of a judicial or administrative determination. Your data may be shared with other companies for which Hi Performarce has signed joint controllers agreements or companies appointed as data processors under Article 28 GDPR. Lists of third-party data processors under Art. 28 GDPR as well as joint controllers under Art. 26 GPDR are available upon request to the Data Controller.

    5.1 Processing, disclosure or communication of personal data outside of the EU
    Your personal data are stored on servers within the European Union (EU) where European Regulation (EU) 2016/679 applies. It may happen that some of our suppliers, partners or professionals, data controllers or joint controllers may be located outside the EU. In such cases, it is our care that such transfer takes place in compliance with EU privacy regulations, putting in place safeguards and precautions for the protection of your data equivalent to those in the EU. We therefore inform you that your data may be communicated to and processed, for all the purposes set out in this privacy notice, by partner companies located outside the EU or even to other companies, which may therefore be located in countries where data protection laws may not be equivalent to those applied in the EU.
    Therefore, we inform you that: your data, subject to extra-EU transfer primarily, and in any case where possible, are subject to pseudonymization; processing will take place provided that certain conditions set forth in the applicable legislation are met and in any case the limits provided for, specified and indicated in the privacy notice and for the purposes indicated therein; in case of communication of data outside the EU, the Data Controller requires guarantees of an adequate level of protection of personal data, as well as requires that adequate technical and organizational security measures are in place to protect personal data against accidental or unlawful deletion, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing; only in the cases and within the specified limits, the data may be transmitted and processed, however in compliance with Reg. (EU) 2016/679, also outside Italy or the European Union; this way, the data processed for the purposes referred to in point 3.c) - subject to prior consent - may also be processed, within the limits of the above, outside Italy or the European Union; at any time you may request and obtain the list of the data processors appointed by the Data Controller and/or the companies with which an agreement has been entered into by means of standard clauses. You have the right to exercise your data protection rights with the Italian national authorities and specifically with the Italian Data Protection Authority; for further information on the security measures in force, please contact the Data Controller or the DPO.
  6. nature of data provision – Providing and consenting to the processing of personal data is obligatory since refusal, to the limits indicated in the preceding points, or even refusal to provide them in whole or in part, could result in the inability of the Data Controller to execute the request for information on the products offered or to fulfill a legal obligation to which it is subject or even for the pursuit of the legitimate interest of the data controller or third parties.
  7. Duration and retention of personal data – In accordance with the principles of proportionality and minimization of processing, the duration of processing is equal to the duration of the relationship necessary to process your request. We inform you that your personal data will be kept for 120 months from the filling of the form in order to receive marketing, advertising, information material about courses, services and digital products of Hi-Performance. Such terms are provided in light of the type of service provided by the Data Controller in that training, education, and updating activities can sometimes be placed in a broad temporal context and, consequently, marketing strategies, advertising, or any treatment provided for purposes, in general, of information about the services offered must be consistently appropriate. We also inform you that the storage of your personal data may also be extended after the indicated term and thus for the time necessary for the purpose of fulfilling legal obligations and/or for the legitimate interest of the Data Controller. However, these data will be kept, commensurate with the degree of indispensability, only for the time necessary to achieve the purpose of the activity.
  8. Rights of the data subject – Pursuant to Art. 12 et seq. EU Reg. 679/2016, data subjects have the right to contact the Data Controller and/or the data processors in order to access processed personal data concerning them. In particular, pursuant to Art. 15 EU Regulation 2016/679, the data subject, where he/she is in any case identifiable, has the right to obtain confirmation of the existence or non-existence of personal data concerning him/her, their communication in an intelligible form and thus access to his/her personal data as well as to obtain information concerning: (a) the purposes̀ of the processing; (b) the categories of personal data concerned; (c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular if recipients in third countries or international organizations; (d) when possible, the period for which the personal data are to be retained or, if this is not possible, the criteria used to determine that period  (e) the existence of the data subject's right to request from the controller the rectification or erasure of personal data or the restriction of processing of personal data concerning him or her or to object to their processing; (f) the right to lodge a complaint with a supervisory authority; (g) where the data are not collected from the data subject, all available information about their origin; (h) the existence of an automated decision-making process, including profiling as referred to in Article 22(1) and (4), and, at least in such cases, meaningful information on the logic used, as well as the importance and expected consequences of such processing for the data subject. The information shall be provided free of charge; pursuant to Article 12 paragraph 5 Reg (EU) 2016/679, in the event of manifestly unfounded, excessive and/or repetitive requests, the data controller may charge a fee inherent in the costs incurred in providing the information, communication or taking the requested action or refuse to comply with the request. The interested party may obtain the cancellation, rectification, transformation into anonymous form or blocking of data processed in violation of the law or may also exercise the right to data portability. For the purposes of what is indicated by this privacy notice or for the above mentioned requests / communications, the Data Controller and the DPO can be contacted at the email address [email protected] or by registered mail addressed to Hi Performance S.r.l., Via Cesare Fracassini, 4 - 00196 Rome.
  9. Complaint – The data subject has the right to lodge a complaint with the Data Protection Authority in the manner provided by the Authority, which can be found at www.garanteprivacy.it. For more information regarding your privacy rights, we invite you to visit the website of the Data Protection Authority at www.garanteprivacy.it.