DIFC, United Arab Emirates
INFORMATION PURSUANT TO DIFC DATA PROTECTION LAW NO. 5 of 2020
Istituto Marangoni Middle East Limited as the Data Controller wants to inform you about what data it collects and how, so as to ensure that your fundamental rights and freedoms are respected, with particular reference to the confidentiality and security with which the data are processed.
Istituto Marangoni Middle East Limited collects and stores your data:
Data are collected at the time of enrollment and/or subsequently, through the following channels:
a) Web form completion.
b) Forms collected at the time of accreditation to the Istituto Marangoni Open Day.
c) Others events organized at our campus or other locations.
We may ask social channels to send information about our courses based on the profiles of their users and in accordance with their data processing policy, but we are not aware of your name.
Istituto Marangoni Middle East Limited uses your data for the following purposes:
In relation to the purpose under d), processing is necessary for the pursuit of legitimate interest (Art. 10 (f) of the DIFC Data Protection Law).
In relation to the purposes in (d), (e) (f) the legal basis for processing is your consent (Art. 10(a) of the DIFC Data Protection Law).
For the purposes under 3 (a), (b), (c), we keep your personal data for the duration of the contractual relationship being established and also beyond the six (6) year limitation period from the termination of the relationship in order to fulfil legal obligations as well as for the purposes of legal protection.
In the event that the registration process is not completed for any reason, Istituto Marangoni will retain your data for a period not exceeding 12 months after collection.
For the purposes of (d), (e) and (f) we will keep your data for up to 3 years, without prejudice to your right to revoke your consent at any time.
Once the retention period has expired, the data will be destroyed or made anonymous.
Please note: If, in the event of litigation, it is necessary to ascertain, exercise or defend the rights of the Data Controller, the retention period of the data collected, for the above-mentioned purposes, may be extended due to the possibility that it may be necessary to prepare defensive elements within this timeframe. In this case, the data will only be kept until the conclusion of the litigation.
The processing of your data will be carried out by means suitable to guarantee its confidentiality, integrity and availability. The processing is carried out by means of information systems and/or automated systems and will include all the operations or set of operations provided for under the definition of “Processing” in the DIFC Data Protection Law and necessary for the processing in question, including communication to the persons in charge of the processing itself. The data in question will not be subject to dissemination; instead, it will or may be communicated to public or private entities operating within the scope of the purposes described above.
Only authorized persons within the scope of the tasks assigned by Istituto Marangoni Middle East Limited, including those located outside the Dubai International Financial Centre (“DIFC”) , can access your data.
Istituto Marangoni Middle East Limited is part of Galileo Global Education Italia. Employees of Galileo Global Education Italia, as well as employees of NABA (Nuova Accademia Middle East Limited) and Domus Academy, belonging to the same Galileo Global Education Italia Group, may also have access to some of your data.
Non-economic public entities (e.g. MIUR, Lombardy Region) may also have access to some of your data when the communication is necessary for the performance of the institutional functions of the requesting entity.
Personal data will not be disclosed in any way, it may also be communicated to and processed by third parties duly appointed as Data Processors, such as external collaborators and companies that provide specific instrumental services.
Personal data may also be accessible or may be communicated to parties whose right to access your personal data is recognized by provisions of applicable laws or regulations.
Your personal data will be managed and stored on servers located within the European Economic Area (EEA) and belonging to the Data Controller and/or to third party companies appointed and duly identified as Data Processors.
Your data may also be processed by the other companies belonging to the Istituto Marangoni group, located outside the DIFC area, adopting appropriate security measures to ensure an adequate level of protection.
In addition, some third-party companies appointed as Data Processors may transfer your personal data to servers located in other jurisdictions outside the DIFC area by using appropriate safeguards to ensure protection. All transfers of your personal data to Data Controllers or Data Processors outside of the DIFC will be done in accordance with either Art. 26 or Art 27 of the DIFC Data Protection Law, where applicable. Further information on these safeguards can be obtained from the Controller.
The provision of your data under point 3 a), b) and c) is necessary to enter into and execute the contract. For the purposes of point 3 d), e) and f) is optional, if you do not consent you will not be able to learn about our initiatives, events, courses that we will activate.
In accordance with the provisions of the DIFC Data Protection Law, Istituto Marangoni Middle East Limited guarantees you the following rights:
- to obtain confirmation of whether or not your personal data is being processed and, if so, obtain access to such data without charge and within one (1) month of the request (Art. 33, Right of access);
- to obtain, without undue delay, without charge and within one (1) month of the request the rectification of inaccurate personal data concerning you (Art. 33, Right to rectification);
- to obtain the erasure of personal data concerning you without undue delay, without charge and within one (1) month of the request Istituto Marangoni Middle East Limited is obliged to erase personal data without undue delay, provided certain conditions apply Art 33, ‘Right to be forgotten’); (
- to obtain the restriction of processing in certain cases (Article 35, Right to restriction of processing);
- to receive, in a structured format, in common use and readable by an automatic device, the personal data that you have provided to us and where applicable to transmit it to another Controller (Art. 37, Right to data portability”); - to object at any time, for reasons connected with your particular situation, to the processing of personal data concerning you (Art. 34, Right to object);
- to object at any time, to decisions based solely on automated Processing, including Profiling, which produces legal consequences concerning you or other seriously impactful consequences and to require such decision to be reviewed manually (Art. 38, Right to object to Automated Processing).
- to receive, without undue delay, communication of any personal data breach suffered by Istituto Marangoni Middle East Limited (Art. 42, Notification of Personal Data Breaches to the Data Subject);
-to not be discriminated against by the Data Controller for the exercise of any of your rights under the DIFC Data Protection Law whether through denial of goods or services, charging different prices or rates, or by providing or suggesting a less favorable level or quality of goods or services (Article 39, Non-discrimination)
- to withdraw your expressed consent at any time (Article 32, Right to withdraw consent).
If you believe that we have not complied with your rights regarding the protection of personal data, you can contact the DIFC Commissioner of Data Protection. Alternatively, if you live in another country, you can contact your local Data Protection Authority.
The Data Controller is: Istituto Marangoni Middle East Limited – Gate Village 8, Level 4, DIFC, Dubai, U.A.E.
Mail: privacy@istitutomarangoni.com
The Data Protection Officer can be contacted at the following e-mail address: dpo@istitutomarangoni.com
This policy is subject to change. Any substantial changes will be communicated to you by email or through our website.