Pursuant to the terms and conditions of Section 13 of D.Lgs. n. 196 of 30th June 2003 (“Codice in materia di protezione dei dati personali” – Personal Data Protection Law, hereinafter “the Law”) and to the provisions of Regulation (EU) 2016/679 (“Regulation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data”, hereinafter “the EU GDPR”), we hereby inform you that Study Abroad Italy, Inc., DBA SAI Programs (hereinafter referred to as “SAI”), in its capacity as Data Controller in Italy, pursuant to Section 29 of the above Law, of the processing of your personal data and information, is required to provide you with the following information:
1. All personal data you have provided to SAI, as well as any entity from whom personal data are collected, and all the further data provided in order to allow the planning and organization of the SAI study abroad programs with host schools in Italy, and thereof aimed at the performance of the academic services to be provided to you, will be processed and handled by SAI in accordance with its policies and with the aforementioned Law and EU GDPR, and with the principles of fairness, lawfulness, transparency, purpose limitation, accuracy, storage limitation, integrity and confidentiality and accountability, as well as the utmost protection of your privacy; sensitive data processing will only take place in relation to data regarding your health condition (such as diseases, allergies, food intolerances) or judicial data.
2. Data is collected from you, your respective school, and relevant parties upon your request. This data shall be processed exclusively for SAI purposes, connected or related to the activities carried out by SAI, such as study programs in partnership with Italian schools, the accomplishment of bureaucratic practices for your entry in Italy, the performance of the contractual obligations of SAI in connection with your study abroad stay with host schools in Italy. In particular the data supplied or collected will be processed for the following purposes:
a. to fulfill the obligations established by any applicable law, including the regulations or the European Union Law;
b. to execute the contractual obligations with reference to your enrollment with the SAI study abroad programs organized with host schools in Italy (such as, but not limited to, course enrollment, grades, students health and safety protection);
c. with reference to data provided by public authorities or by hospitals should an accident or aggression occur to the student, in order to take the necessary actions.
Sensitive data regarding your health conditions and food habits will only be processed for the purpose of protecting student safety or of fulfilling the obligations established by law, by regulations or by the European Union Law; sensitive data regarding judicial measures which may have been provided to SAI by public bodies will be processed only for purposes relating to a health or safety emergency and complying with any applicable mandatory provision of Italian or European Union law.
3. Submittal and processing of personal data is necessary in order to achieve the purposes above specified.
4. Any refusal will make it impossible to carry out the necessary activities and the correct administrative and didactic management of student programs necessary to accomplish the contractual obligations of SAI in connection with your study abroad stay with host schools in Italy, as well as the obligations imposed by law.
5. Data of common nature will be collected and processed automatically and/or manually in compliance with the provisions of Article 11 and 31 of the Italian Personal Data Protection Code and by adopting the related minimum safety measures, securing strictly monitored access; the collecting and processing of sensitive data will be carried out in compliance with the provisions of Art 11 and 31 of the Italian Personal Data Protection Code and by adopting the related minimum safety measures.
6. Data processing will take place, according to the aforementioned points, within those offices of SAI premises which are exclusively dedicated to SAI study abroad programs; the data will be handled only by the persons who are in charge of and responsible for SAI activities and by other persons working on the same areas as specified in internal communications, and who process data for your course enrollment, posting of grades, and processing of your transcripts by the SAI host school; sensitive data will be handled only within those offices of SAI premises which are exclusively dedicated to SAI study abroad programs, for the purposes above specified, by persons officially appointed to this task. Your personal data you have provided, with the exception of sensitive data, may be transferred overseas pursuant to the terms, conditions and limits specified by Title VII of Part I of Legislative Decree n. 196/2003.
7. In particular, your data may be communicated, in compliance with the rules above indicated, to public or private subjects to whom they may necessary in order to fulfill obligations set forth by laws, regulations or EU laws; sensitive data may be communicated to public bodies and authorities (such as Aziende USL or public hospitals, public safety authorities, police offices, courts, magistrates and the like) and to private subjects (such as private hospitals and clinics, security supervisors, insurance companies) only for purposes relating to health and safety emergency and for the purposes of fulfilling obligations set forth by laws, regulations and EU laws.
8. The Data Controller, under the law and with particular reference to the safety obligations related to the automatic processing of your data, is SAI.
9. All data will be processed by SAI in its capacity as Data Controller with the supervision of Marco Minuti, Data Manager, available in compliance with art. 7 of Legislative Decree 196/2003, who can be reached at the following telephone number/email: +39 371 168 0025 / email@example.com.
10. You will be able to exercise any and all other rights foreseen by Art. 7 of Legislative Decree n. 196/2003 reproduced hereunder in its entirety:
“1. The data subject has the right to obtain confirmation of the existence or not of personal data regarding him or her, even if not yet recorded, and their communication in intelligible form.
2. The data subject has the right to obtain indication: a) of the origin of the personal data; b) of the ends and methods of its processing; c) of the logics applied in the event of processing being carried out with the aid of electronic equipment; d) of the identification data of the controller, of those responsible and the appointed representative as per Art. 5 paragraph 2; e) of the organizations and categories of organizations to whom personal data can be communicated or who are likely to get to know them in their capacity of designated representative in any area of the country, of officers and appointees.
3. The data subject has the right to obtain: a) the update, the rectification or, if he or she as interest to, the integration of the data; b) the cancellation, transformation in anonymous form or the blockage of any data processed unlawfully, including those whose storage is not necessary in relation to the aims for which the data were collected or later processed; c) a statement that the operations indicated in letters a) and b), including their content, have been made known to those to whom the data have been communicated or released, except in the case of this being found to be impossible or requiring the use of means which are clearly disproportionate to the protected right.
4. the data subject has the right to completely or partially oppose: a) for legitimate reasons, the processing of personal data regarding him/her even if relevant to the aims of their collection; b) the processing of personal data regarding him/her for the purpose of sending publicity material, direct sales or for carrying out market research or commercial communications.”
The data subject can exercise the rights as per Art. 7 of Legislative Decree 196/2003, (updating, rectification, integration, cancellation, transformation, anonymously or blockage of data processed illegally, opposition, request for information as per section 1 and as per letters a), b), c), d) and 2) 2nd section, by contacting SAI, 7160 Keating Avenue, Sebastopol, CA 95472, USA - or sending an e-mail to the following address: firstname.lastname@example.org.
You can read Regulation (EU) 2016/679 at: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf
11. Please be also informed that:
a. the period for which your personal data will be stored will be from now until 20 years after your study abroad program is complete.
b. you can withdraw your consent, if granted below, at any time and even only orally, but this will not affect the lawfulness of processing your personal data based on your consent before withdrawal.
c. you have legal rights and remedies against any breach of your personal privacy according to articles from 77 to 84 of the EU GDPR.