Privacy Policy
Privacy policy
Pursuant to Art. 13 of EU Regulation No. 679/2016
fashiongraduateitalia.it – Users
In order to conduct a correct and transparent processing, Associazione Piattaforma Sistema Formativo Moda ETS, or, for short, Piattaforma ETS, provides the following privacy policy – drafted pursuant to Article 13 of Regulation (EU) No. 679/2016 on the “General Data Protection Regulation” (“GDPR”), to Legislative Decree 196/2003 (the “Privacy Code”), as amended by Legislative Decree 101/2018 – intended for all those who, as users, interact with the Website of the Fashion Graduate Italia event that can be found at fashiongraduateitalia.it (“Website”).
- Data Controller – Who processes your data?
The Data Controller is Piattaforma ETS, with registered office in Milan (MI), Via Giosuè Carducci, n. 32 – 20123, CF and P.IVA 06112310963 (“Controller”).
For any request relating to the processing of his/her personal data, the user of the Website (“User” or “Data Subject”) may contact the Controller by post at the registered office, or by e-mail at the following address: info@piattaformamoda.it .
- Types of Data Subject to the processing, collection and processing procedures – What personal data do we process? How do we collect them?
The personal data collected and processed by the Controller include:
- Personal data directly provided by the User: personal, identification and contact data (such as, for example, name, surname, e-mail address), any further data optionally provided by the User;
- Personal data not directly provided by the User: data automatically collected while browsing the Website (such as, for example, page accesses, amount of data transferred, session ID numbers, IP addresses, URL addresses, cookies, etc.); – click here to view our Cookie Policy.
- Purpose and legal basis of the processing – Why do we process your personal data?
The Controller collects and uses Users’ personal data, also through the use of computerised, telematic and analogue systems, for the following purposes:
- To enable navigation on the Website, through the use of cookies: during navigation on the Website, some personal data may be automatically collected, the processing of which is further detailed in our Cookie Policy.
The legal basis of such processing is: (i) for some of these data (e.g. technical cookies) the legitimate interest of the Controller (art. 6, c. 1, lett. f) of the GDPR) to ensure the secure navigation of the Portal and its regular operation and, in this case, the collection of the data is necessary; (ii) for others of these data (e.g. analytical and/or profiling cookies) the consent (art. 6, c. 1, lett. a) of the GDPR) of the User and, in this case, the collection of the data is only optional.
The personal data of Users who are mere navigators of the Website are subject to this sole processing;
- Handling contacts requests: the collection of personal data for this purpose is necessary and any refusal on the part of the User to provide such data will prevent the contact request from being completed. The legal basis of this processing is the legitimate interest (art. 6, c. 1, lett. f) of the GDPR) of the Controller to manage the contact requests of Users who, by filling in the contact form on the Website, have expressed their interest in receiving information from Piattaforma ETS. This legitimate interest of the Controller coincides, moreover, with the legitimate interest of the Users themselves who make the requests and who, therefore, within the context of their relationship with the Controller, can be reasonably expected to have their requests taken care of and processed by the Controller. The legitimate interest of the Controller thus identified may therefore be deemed to prevail over the fundamental rights and freedoms of the Data Subject, also because of such reasonable expectations.
- Responding to requests for contact, information, assistance or other requests: the collection of personal data for this purpose is necessary and any refusal on the part of the User to provide such data will result in the impossibility of receiving a response to the request. The legal basis of such processing is the legitimate interest (art. 6, c. 1, lett. f) of the GDPR) of the Controller to respond to the contact requests of Users who, by filling in the contact form on the Website, have made requests for information, assistance, or any other type of request to Piattaforma ETS. This legitimate interest of the Controller also coincides with the legitimate interest of the Users themselves who make the requests and who, therefore, in the context of their relationship with the Controller, may be reasonably expected to expect their personal data to be used by the Controller in order to receive a response. The legitimate interest of the Controller thus identified may therefore be deemed to prevail over the fundamental rights and freedoms of the Data Subject, also because of such reasonable expectations.
- Handling of Users’ requests for registration to Fashion Graduate Italia’s event activities: the collection of personal data for this purpose is necessary and any refusal by the User to provide such data will make it impossible to complete registration to the activities. The legal basis of this processing is the necessity to take steps at the request of the Data Subject prior to entering into a contract (art. 6, c. 1, letter b) of the GDPR). In fact, the User, by registering from the appropriate section on the Website, has expressly manifested the desire to sign up to one or more of the activities of the Fashion Graduate Italia event organised and realised by Piattaforma ETS.
- Including the Data Subject among the participants to one or more of the activities of the Fashion Graduate Italia event: the collection of personal data for this purpose is necessary to allow Piattaforma ETS to manage the registration of the participant to one or more of the activities of the Fashion Graduate Italia event. The legal basis of this processing is the necessity to take steps at the request of the Data Subject prior to entering into a contract (art. 6, c. 1, letter b) of the GDPR).
- Sending to the participant the confirmation of successful registration to one or more of the activities of the Fashion Graduate Italia event: the collection of personal data for this purpose is necessary to allow the Controller to contact the participant and to send him/her the confirmation of successful registration to one or more of the activities of the Fashion Graduate Italia event, together with the instructions for participation. The legal basis of this processing is the performance of a contract to which the Data Subject is party (art. 6, c. 1, letter b) of the GDPR).
- Perform statistical analysis, improve the presentation and use of the Website – where possible, to achieve this purpose we use anonymous personal data (personal data that does not identify or make identifiable Users): the collection of personal data for this purpose is only optional, but the User’s refusal to provide it prevents the User from benefiting from an offer that is more akin to his / her preferences, without any prejudice to the use of the Website. The legal basis of such processing is the legitimate interest (art. 6, c. 1, lett. f) of the GDPR) of the Controller represented by the benefit that Piattaforma ETS can obtain from the presentation of a website and an offer more akin to the preferences manifested by its Users while browsing it, which the Controller considers to be prevailing over the Users’ right to privacy.
- Sending information and promotional communications by e-mail about initiatives or events similar to those offered and promoted on the Website (so-called soft spam): the collection of personal data for this purpose is only possible, but the User’s refusal to provide such data prevents the latter from being updated on initiatives and events identical or similar to those already held and promoted, such as subsequent editions of Fashion Graduate Italia. The legal basis of this processing is the legitimate interest (art. 6, c. 1, lett. f) of the GDPR) of the Controller represented by the benefit that Piattaforma ETS can obtain from the sending of informative and promotional communications that favour the presentation of the offer to Users, involving them in the growth and development path of Fashion Graduate Italia, which the latter considers to be prevailing over the Users’ right to privacy (who, moreover, can reasonably expect to receive such communications). This legitimate interest of the Controller also coincides with the legitimate interest of the Users themselves who express their interest in Fashion Graduate Italia and who, therefore, in the context of their relationship with the Controller, may reasonably expect their personal data to be used by the Controller to receive communications about related initiatives or events, or subsequent editions of Fashion Graduate Italia. The legitimate interest of the Controller thus identified may therefore be deemed to prevail over the fundamental rights and freedoms of the Data Subject, also because of such reasonable expectations.
- Allowing the User to exercise his/her rights: the collection of personal data for this purpose is necessary and in the event of a refusal to provide such data, the Controller will not be able to receive and respond to requests to exercise his/her rights in relation to the protection of personal data under the GDPR and carry out the consequent activities. The legal basis of such processing is the compliance with a legal obligation to which the Controller is subject (art. 6, c. 1, letter c) of the GDPR).
- Exercising our rights: the collection of personal data for this purpose is necessary and in case of refusal to provide them for this specific purpose, the User will not be able to benefit from the services offered by the Controller. The legal basis of this processing is the legitimate interest (art. 6, c. 1, lett. f) of the GDPR) of the Controller to pursue remedies to ensure compliance with its contractual rights or to demonstrate that it has fulfilled its obligations arising from the contract with the Data Subject or imposed on the Controller by law. This legitimate interest is, in turn, based on the constitutionally protected right to defence. It may therefore be deemed to prevail over the fundamental rights and freedoms of the Data Subject.
- Possible categories of recipients of personal data – To whom are your data communicated?
Personal data are processed exclusively by employees and collaborators of the Controller, specifically authorised in accordance with Articles 29 of the GDPR and 2-quaterdecies of the Privacy Code, or by companies expressly appointed as data processors, in accordance with Article 28 of the GDPR.
In particular, personal data may be processed by, and/or communicated to:
- employees and/or collaborators of the Controller;
- third party service providers necessary to ensure the operation of the Website (by way of example, companies that provide hosting services);
- third parties who provide consultancy, assistance or support services in the organization and management of Fashion Graduate Italia’s events;
- authorities responsible for carrying out checks or investigations into fraud or abusive behaviour on the Website;
- third parties who provide services for the analysis of navigation data on the Website;
- third parties that provide automatic soft-spam and/or other information communication services;
- third parties who provide services to support profiling.
The User may request from the Controller, at any time, an updated list of the data processors that perform processing operations on his/her personal data.
Personal data will not be disclosed under any circumstances, i.e. it will not be communicated to unspecified persons, in any form whatsoever, even by simply making it available or consulting it.
- Transfer of data – To whom are your data transferred?
In general, the Controller does not transfer the personal data of Data Subjects to countries outside the European Union or to international organisations.
Should this occur, the Controller guarantees that all transfers will be subject to the safeguards set out in Article 45 of the GDPR and/or the appropriate protections described in Article 46 of the GDPR.
- Retention period of personal data (or criteria for determination) – How long do we keep your data?
Personal data are retained by the Controller for the period of time strictly necessary to achieve the purpose for which they were collected, as indicated in point 3 above. In particular, unless the right to object is exercised in accordance with point 7 below, the Controller retains Users’ personal data for the following duration periods:
- cookies: for the purpose referred to in point 3 letter a) above, we recommend that you read the information on Cookies, available at the following link [];
- personal data for the management and response to contact requests: for the purposes referred to in point 3 letters b) and c), for a period of 12 months from receipt of the contact request sent by the User. By derogation to this term, in case of sending by means of the “contact” form of a complaint or grievance, the User’s personal data shall be kept for the period referred to in letter f) below;
- personal data for (i) the management of Users’ registration requests to Fashion Graduate Italia’s event activities; (ii) to include the interested party among the participants to one or more of Fashion Graduate Italia’s event activities; (iii) to send the participant the confirmation of the correct registration to one or more of Fashion Graduate Italia’s event activities: for the purposes stated in point 3 letter d), e) and f), for a period of 18 months from the receipt of the request for registration to one or more of Fashion Graduate Italia’s event activities;
- personal data for the execution of statistical analysis and the improvement of the presentation and use of the Website, processed anonymously where possible: for the purposes set out in point 3 letter g), for a period of 12 months from receipt of the User’s first contact request;
- personal data for the sending by e-mail of information and promotional communications about initiatives or events similar to those offered and promoted on the Website (so-called soft spam): for the purpose referred to in point 3 letter h), for a period of 18 months following the User’s last interaction with the Controller, suitable for demonstrating an interest in the activities of Piattaforma ETS;
- personal data for the possible establishment, exercise and defence of rights, including in court: for the purposes set out in point 3 letter i), and j), the Controller is authorised to store all or part of the personal data for a maximum period of 10 years.
Once these terms have expired, the Controller shall automatically delete the personal data or irreversibly transform them into anonymous form.
- User Rights – What are your rights?
Pursuant to and for the purposes of the GDPR, for the period referred to in point 6 of this Policy, each User has the right to:
- request from the Controller access to personal data and information of the relevant processing and any copy thereof in electronic format, unless specifically requested otherwise by the User (Article 15 of the GDPR);
- request rectification and/or integration of personal data, without undue delay (art. 16 of the GDPR);
- for specific reasons (e.g. unlawful processing, non-existence of the purpose of the Processing), request the erasure of personal data, without undue delay (art. 17 of the GDPR);
- in the event of specific cases (e.g. inaccuracy of the personal data, unlawful processing, exercise of a right in court), request the restriction of the processing (Art. 18 of the GDPR);
- in case of automated processing, receive the personal data in a readable format, for the purpose of its communication to a third party, or, where technically feasible, request the transmission of the personal data by the Controller directly to such third party (so called right to portability – Art. 20 of the GDPR);
- for the purposes referred to in point 3, letters a), b), c), g), h) and j), object at any time to the processing of personal data that has as its legal basis the legitimate interest of the Controller (Art. 21 of the GDPR). If the right to object is exercised, the Controller shall refrain from further processing the personal data, unless it demonstrates the existence of compelling legitimate grounds for processing that override the interests, fundamental rights and freedoms of the Data Subject or for the establishment, exercise or defence of legal claims;
- to be informed by the Controller without undue delay of any breach or unauthorised access by third parties to its systems containing personal data (so-called data breach – Article 34 GDPR)
- to lodge a complaint with the supervisory authority of the EU country where he/she resides, works or where he/she believes that a breach of his/her rights has occurred (Art. 77 of the GDPR).
For further information on the terms and conditions for the exercise of the rights granted to the User, the latter may consult the text of the GDPR published on the Website of the Italian Data Protection Authority (www.garanteprivacy.it), or contact the Controller in the forms provided for in point 2 of this Policy.
- Changes and updates
Also, in consideration of future changes that may occur in the applicable privacy legislation, the Controller reserves the right to update and/or supplement, in whole or in part, this policy. Any changes will be promptly communicated to the User.
SPECIAL SECTION
FASHION GRADUATE ITALIA – THE CONTEST
This special section exclusively regulates the processing of personal data carried out by the Controller for the organisation, management and practical implementation of the contest called “The Contest: Young voices for fashion”.
Recipients of this special section are exclusively the participants in The Contest. In particular, only students of Technical and Professional Institutes and Arts High Schools with Fashion address who are attending the last year of their course (“Participants”) can take part in the contest.
Unless otherwise specified, the information in the “Ordinary Section” also applies to the processing of the Participants’ personal data.
The personal data collected and processed by the Controller in the context of The Contest include:
- Personal data directly provided by the User: identification and personal data (first name, surname, date of birth and school attended) and contact data (e-mail address and mobile phone number), as well as any further data optionally provided by the User when sending the participation;
- Personal data not directly provided by the User: data automatically collected while browsing the Website (such as, for example, page accesses, amount of data transferred, session ID numbers, IP addresses, URL addresses, cookies, etc. – click here to view our Cookie Policy).
In addition to the processing referred to in the Ordinary Section, the Controller collects and uses the personal data of the Participants, also with the aid of computer, telematic and analogue systems, for the achievement of the following purposes:
- Management of participation in “The Contest”: the collection of data for this purpose is necessary and any refusal of the Participant to provide such data will result in the impossibility to participate in The Contest.
The legal basis of this processing is the performance of a contract to which the Data Subject is party (art. 6, c. 1, letter b) of the GDPR). For this purpose, the Controller will retain the Participant’s personal data for the duration of 6 months after the conclusion of The Contest.
- Communication of the names and further personal data possibly included in the Participant’s project to the members of the Jury of Quality: the collection of data for this purpose is necessary and any refusal of the Participant to provide such data will result in the impossibility to participate in The Contest.
The legal basis of this processing is the necessity to take steps at the request of the Data Subject prior to entering into a contract (art. 6, c. 1, letter b) of the GDPR). For this purpose, the Controller will retain the Participant’s personal data for the duration of 6 months after the conclusion of The Contest.
- Sharing of the name and further personal data that may be part of the project on the Website and on the social media channels of Piattaforma ETS: the collection of data for this purpose is necessary and any refusal of the Participant to provide it will result in the impossibility of sharing said personal data on the social media channels of Piattaforma ETS.
The legal basis for this processing is the legitimate interest (Art. 6, c. 1, lett. f) of the GDPR) of the Controller, constituted by the interest of Piattaforma ETS to share the project realised by the Participant on its social media channels, so as to give media resonance to the same, while promoting The Contest and the statutory activity of the same. This legitimate interest of the Controller also coincides with the legitimate interest of the Participants themselves who express their interest in The Contest and who, therefore, in the context of their relationship with the Controller, can be reasonably expected to have their personal data used by the Controller to promote the projects that are part of The Contest in order to give them media exposure. For this purpose, the Controller will retain the Participant’s personal data for the duration of 5 years after the conclusion of The Contest.
- Handling of/response to any requests for information and/or clarifications sent by the Participant to the Controller: the collection of personal data for this purpose is necessary and any refusal by the Participant to provide such data will result in the impossibility of receiving a response to the request made by the same.
The legal basis for this processing is the legitimate interest (Art. 6, c. 1, lett. f) of the GDPR) of the Controller to respond to the contact requests of Participants who have made requests for information, assistance, or other requests to Piattaforma ETS. This legitimate interest of the Controller also coincides with the legitimate interest of the Participants themselves who make the requests and who, therefore, in the context of their relationship with the Controller, may reasonably be deemed to expect that their personal data will be used by the Controller to receive feedback. The legitimate interest of the Controller thus identified may therefore be deemed to prevail over the fundamental rights and freedoms of the Data Subject, also because of such reasonable expectations. For this purpose, the Controller will retain the Participant’s personal data for the duration of 6 months after the conclusion of The Contest.
Last update: 14th July 2023.