Everything you need to know
in line with EU Regulation 2016/679

In effect as of 25th of May, 2018
updated at the 28th of July, 2021

  1. Data Controller

The Data Controller is Holden S.r.l. (hereafter referred to as “Scuola Holden”, “the School” or “Holden”). Its registered office is in Piazza Borgo Dora, 49 – 10152 Turin, Italy.
The Data Protection Officer can be contacted by email at dpo@lafeltrinelli.it.

2. How Holden collects or receives your personal data

Holden collects and receives personal data directly from users (i.e. from those of you reading this). In most cases, we collect it electronically when you register on our website scuolaholden.it (via the Application Form page and the Email Us link). Alternatively, your personal data may be requested by employees of the school or by our collaborators.

Naturally, you can decide whether or not to give us your personal data. If you decide not to do so, however, you will not be able to register on our site. You will therefore be unable to perform various actions that require the creation of an account (for example, you will not be able to purchase courses or receive our newsletter), nor will you be able to sign a contract with Holden (in most cases, “signing a contract” with us simply means signing up for a course).

2.1 Cookies

Holden also collects data through cookies and similar technology, as well as allowing others to use cookies on our site (take a look at this fascinating page that explains our Cookie Policy).

Cookies are used to recognise you and the devices with which you connect to the site and attempt to access the various online services offered by Scuola Holden.

You can control your cookies by changing your browser settings and using other tools; should you wish to do so, you can even prohibit Holden from using cookies and similar technology.

3. Types of personal data

When you register as a user, we ask you a few questions. The answers that you type into these tedious forms allow us to work and deal with you.

Here’s what we ask for:

  • personal information (name, surname, residence, domicile, date of birth);
  • your email address, fax number and telephone number;
  • your qualifications and the marks you achieved;
  • images (e.g. a photograph of you or a copy of your ID);
  • payment information (e.g. your current account number or credit card number).

If you wish, you can also provide other data: this can happen when we have specific requests or if you wish to leave comments.

Holden does not request or handle sensitive personal data on its own initiative. For example, we will never ask you anything about: racial or ethnic origin; political opinions; religious or philosophical beliefs; union membership; genetic data; biometric data; data concerning your health, your lifestyle or your sexual orientation; or any other information that could specifically identify you as opposed to just any other guy.

However, in some special cases, Holden may have to handle such data. We can neither ask you for nor refuse to receive this data (if you want to give it to us). However, you must also send us your written consent allowing us to manage this sensitive information. It is understood that it will be used solely and exclusively to manage your specific requests and for matters related to the contract you have entered into with us.

4. Data recipients or categories of data recipients

Who will know about your data?

The natural and legal persons appointed as Data Processors and the natural persons authorised to do so in order to carry out their work: those who work at the School and our collaborators, interns and external consultants.

Your personal data may be communicated to shipping agents and carriers in order to make deliveries to you or to other persons indicated by you. It will also be disclosed to third parties if necessary in order to comply with the contractual agreements between you and Holden (in other words, to allow you to attend courses or use our online services).

Without your consent, Holden may pass on your personal data to those responsible for compliance with legal obligations, regulations or EU legislation.

5. How we use the personal data collected

Once you enter into a contract with Holden, your data will be added to electronic databases owned by the School: this allows us to manage registrations, accounts, takings and payments, issue tax documents, handle orders and contracts, process internal statistics, and send information, commercial and promotional messages and advertising material, including to your email address.

Let’s be clear on one thing: Holden does not sell, rent or market your personal data.

6. How long do we keep your personal data for?

For the duration of the contract and for the period needed to complete the work that we have promised to do.

When the relationship between you and Holden ends (yes, sadly, it will happen eventually), your data is retained in compliance with the terms set out by law. In particular, we are required to keep accounting data on record for 10 years.

In the event of a legal dispute, the data will be retained for the entire duration of the dispute, until the appeal period has expired (i.e. until the matter is definitively resolved).

7. Rights of data subjects

In accordance with EU regulations, you have the right to:

  • request access to your personal data, rectify it, complete it if it’s incomplete, or have it erased if one of the conditions set out in Art. 17, Section 1 of the GDPR is met (in accordance with the exceptions provided for in Section 3 of the same article);
  • you have the right to restrict the processing of your personal data if one of the conditions set out in Art. 18, Section 1 of the GDPR is met;
  • you have the right to data portability;
  • you have the right to change your mind and withdraw your consent to our processing of your personal data at any time. However, everything that Holden does with your data before you withdraw your consent will remain valid and lawful. If you do change your mind, we advise you to submit a written request;
  • you have the right to lodge a complaint with a supervisory authority (the Italian Data Protection Authority – garanteprivacy.it).

8. Updates to the website’s privacy policy

Holden has the right to modify the website’s privacy policy at any time. If changes are made, we will update the date from which the new rules are valid (you can find this at the top of the page), and these changes will take effect once the updated page is published.

For this reason, we suggest that you take a look at this page every now and then to see if anything has changed.

9. Links to other websites

The Scuola Holden website may contain links to external sites whose privacy rules may differ from ours. We are not responsible for the actions of others, so please read their privacy statements before browsing their sites or sending them your personal data and other information.

Our contact details

If you have any comments or questions about our website’s privacy policy, or if you wish to update the information you have sent us or exercise your rights, you can send an email to dpo@lafeltrinelli.it or write a letter to Holden S.r.l., Piazza Borgo Dora 49 – 10152 Turin, Italy.

Any doubts?