Privacy Policy

This Privacy Policy (“Privacy Policy”) explains how Adhoc Academy, with address at Via Eraclito 15/3, Milan, (MI) 20128, Italy (hereinafter “Adhoc Academy,” “We” or “Us”) collect, use and share personally identifiable information of visitors of our web site (the “Site”) and users of our products and services (the “Services”).
In accordance with the provisions of current legislation on the Protection of Personal Data, the General Data Protection Regulation (GDPR) (EU) 2016/679, we inform you your data will be incorporated into the processing system owned by Adhoc Academy and will be treated on mixed files with your personal data, stored and managed in accordance with the GDPR.

1. Purpose

The collection and processing of personal data, incorporated into these files, is intended to allow you to enroll in and take online courses on a variety of topics or other sellable material (“Products”), to provide you with information of your interest, as well as to send you commercial communications, including commercial messages via SMS, email, and postal mail, etc., from the study and segmentation of the data collected during navigation through the website, the data provided by filling in any form, as well as those derived from the contractual relationship with you.

The information that you provide through the Site can be in one of two categories: information relating to your use of the Site or the Services, including, without limitation, enrollment information for Products, is referred to as “Site Information,” while information relating to taking the Products, including, without limitation, interchanges with the Course instructors (“Instructors”), other students (“Users”), answers, essays and other items submitted to satisfy Course requirements, is referred to as “Course Information”. When this Privacy Policy uses the generic term “information” it is intended to address the general use of information, and not your specific Site Information or Course Information. By using the Site, Services, or Products you consent to the collection, use and disclosure of your personally identifiable Site Information and Course Information, as applicable, in accordance with this Privacy Policy.

2. Personally Identifiable Information We Collect and How We Use It

2.1. Browsing the website

You can generally visit the Site without revealing any personally identifiable information about yourself. We do not collect personal information from our Site visitors without the Site visitor providing us with this information as set forth in this Privacy Policy.

2.2. Personal information within your account

If you request to receive company or product information, or request information about specific Services, or provide comments about Services, you will be asked to provide contact information so that we can complete your request after you agreed to this Privacy Policy. We use this Site Information to fulfill your request. We may also use this Site Information to send you additional information about our Services or Products on the Site that you may be interested in, upon your consent.

Some of the Services require that you become a registered user and create a user account. This will require that you provide certain personally identifiable information, that may include (but not be limited to) your name, surname, username, nickname, company’s name, e-mail address, biographical as well as telephone, address information.

You allow Us to use this personally identifiable Site Information to register you to use the Services, enroll in Products, and otherwise provide you with the Services; verify your authority to enter the Site and access the Products and Services; notify you of updates via email; improve the content and general administration of the Site and the Services; provide you with notices regarding the Services and other services that you have purchased or may wish to purchase in the future.

2.3. Accessing personal information via newsletter subscription

To subscribe our newsletter service We will require that You provide certain personally identifiable information, that may include as mandatory fields email address, your name, surname, current job title, current company’s name, current Country, Current city e-mail address. You agree at the Opt-in to let Adhoc Academy to send you emails on Products updates.

3. Other information we collect and how we use it

Adhoc Academy may also automatically collect and analyze Site Information about your general usage of the Site, Services and Products. We might track your usage patterns to see what features of the Site, Services and Products you commonly use, Site traffic volume, frequency of visits, type and time of transactions, type of browser, browser language, IP address and operating system, and statistical information about how you use the Services and Products. We only collect, track and analyze such Site Information in an aggregate manner that does not personally identify you. This aggregate data may be used to assist us in operating the Site and the Services and provided to other third parties to enable them to better understand the operation of the Services, and improve their Course offerings, but such information will be in aggregate form only and it will not contain personally identifiable data.

4. Legitimacy

You, as the owner of the data, must explicitly agree you accept your data may be incorporated into these files, giving your explicit consent once your data has been filled in on any of the forms available on this website, in which any personal data is obligatorily required and before it is sent. The legal basis for the processing of your data is the provision of your consent, which may be withdrawn upon request.

5. Duty of Secrecy

Adhoc Academy undertakes to comply with the obligation of secrecy with regard to the personal data You provide. We may share your personally identifiable Site Information with third parties only in the ways that are described in this privacy policy. These include, but are not limited to, sharing Site Information with service providers to allow them to fulfill your requests, to Instructors (in which case this will become Course Information), and to your employer if you are enrolled through the Adhoc Academy for Instructor Program as an employee. Please refer to the sections on personally identifiable and other Course Information for how Course Information may be used.

5.1. Data Processors

Your data can be passed on to third parties including vendors and service providers only when they constitute Data Processors with whom we have signed a confidentiality clause guaranteeing that your personal data will be protected under the same conditions of this Privacy Policy. These Data Processors must abide by this Privacy Policy and keep nonpublic information confidential and use it only for its intended purpose.

Your personal data will not be transferred to third parties based outside the European Union, unless we have requested your express consent for this purpose and for specific purposes at the time of the request.

5.2. Instructors

Part of your personal data may be shared with Instructors as part of the Course Information when you enroll in a Course. Instructors will just use this Course Information to provide the Course to you. Instructors may have other users for Course Information.

Instructors may have access to non-personally identifiable Course Information in connection with your participation in Products. This Course Information may include, but not be limited to, your interaction with the Instructor and other Users, comments you leave on Course forums, answers or essays you submit to satisfy Course requirements, and so forth. All instructors must agree to the Data Processors confidentiality clauses in order to access your personal information.

5.3. Legally required data transfer

We may also disclose your personally identifiable information: (a) if we are required to do so by law, regulation or other government authority or otherwise in cooperation with an investigation of a governmental authority, (b) to enforce these Terms and Conditions, or (c) to protect the safety of Users of our Site and our Services and Products. In addition, we may transfer your personally identifiable information to a successor entity upon a merger, consolidation or other corporate reorganization.

5.4. Social Networks

If you choose to follow our company profile in any social network, included but not limited to Facebook, Twitter, Instagram or Linkedin, we will treat your personal data to according to the functionalities and policies of each social network. This data will be used to inform you about our company, its latest news, activities and other information of your interest. When signing up to any of those social networks, you agree to their terms, conditions and privacy policies. All communications between Adhoc Academy and You through those social networks will be ruled by their policies, and it is your responsibility to learn how your personal data will be processed by them.

In no event will we treat your information for any other purpose, nor will we use it outside the social networks without your consent. If at any time you would like us to stop processing your data, simply unfollow our profile page in the social networks.
Any changes to the data related to your profile in a social network must be made through your account settings page in that social network.

6. Security

The security of your personal information is important to Us. Adhoc Academy complies with the duty to safeguard it by adopting reasonably designed and appropriate technical, organizational and security measures necessary to prevent its alteration, loss, processing, unauthorized access or disclosure.
Among these measures, We use software, secure socket layer technology (SSL) encryption, password protection, firewalls, internal restrictions and other security measures to help prevent unauthorized access to your personally identifiable information. However, Adhoc Academy cannot guarantee that unauthorized third parties will never be able to defeat these measures or use your personally identifiable information for improper purposes. Therefore, you should be aware that when you voluntarily display or distribute personally identifiable information to any website, that information might be collected and used by others. Adhoc Academy is not responsible for the unauthorized use by third parties of information you post or otherwise make available publicly.

6.1. Children

We recognize the privacy interests of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. We do not knowingly collect personal information from people under 18. If we learn that we have collected personal information from a child under 18, we will delete such information. Children under the age of 18 must  not register for an account or purchase Products. Individuals under the age of 18 may only use the Services with the involvement, supervision, and approval or a parent or legal guardian.

6.2. Links to Other Websites

The Site, Services and in particular the Products, may provide links to third party web sites or resources not associated with us and over which we do not have control (“External Web Sites”). Such links do not constitute an endorsement by Adhoc Academy of the External Web Sites, the content displayed therein, or the persons or entities associated therewith. You acknowledge that Adhoc Academy is only providing these links as a convenience, and cannot be responsible for the content of such External Web Sites neither for any personal information you provide to those sites.

In no event will we treat your information for any other purpose, nor will we use it outside the social networks without your consent. If at any time you would like us to stop processing your data, simply unfollow our profile page in the social networks.

Any changes to the data related to your profile in a social network must be made through your account settings page in that social network.

7. Data Retention

Your data will be kept for the time strictly necessary to fulfill the purpose for which it was collected and for as long as your consent persists and has not been expressly revoked.

We will also retain and use this personal Site Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements with Users, and/or the period required by laws in applicable jurisdictions.

8. Rights

You have the right to obtain confirmation if we are processing personal data concerning you, to access your personal data, as well as to request the rectification of inaccurate data or, where appropriate, to request their deletion when, among other reasons, the data are no longer necessary for the purposes for which they were collected. In certain circumstances, you may request a restriction on the processing of your data, in which case we will only retain them for the purpose of exercising or defending claims. For reasons related to your particular situation, you may object to the processing of your data. You have the right to portability where technically possible. You may contact the above postal address or the e-mail address [email protected] to exercise your rights.

9. Privacy Policy changes

Adhoc Academy reserves the right to change this Privacy Policy from time to time. We will post the revised Privacy Policy on this Site located at www.adhoc.academy will either send a notice to the e-mail address that you specified in your registration and/or post notice of the change so it is visible when users log-in for the first time prior to said changes taking effect so that you are always aware of what personal information we may collect and how we may use this information. We encourage you to review this Privacy Policy regularly for any changes. Your continued use of the Site and/or Services will be subject to the then-current Privacy Policy.

This Privacy Policy was last updated on April 6, 2020

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