I – INFORMATION REGARDING THE SITE’S PRIVACY POLICY

1. This section contains information about the management of edifyeduproject.eu regarding the processing of user data from edifyeduproject.eu.
2. This policy is also valid pursuant to Article 13 of Legislative Decree No. 196/2003, the Personal Data Protection Code, and Article 13 of EU Regulation 2016/679 concerning the protection of natural persons with regard to the processing of personal data and the free movement of such data, for users interacting with edifyeduproject.eu and accessible at the address corresponding to the homepage: https://edifyeduproject.eu.
3. This policy applies only to edifyeduproject.eu and not to other websites that may be accessed by the user via links contained herein.
4. The purpose of this document is to provide guidance on the methods, timing, and nature of the information that data controllers must provide to users when connecting to the web pages of edifyeduproject.eu, regardless of the purpose of the connection, in accordance with Italian and European legislation.
5. This policy may be amended due to the introduction of new regulations. Users are therefore advised to check this page periodically.
6. If the user is under 16 years of age, pursuant to Article 8(1) of EU Regulation 2016/679, they must legitimize their consent through parental authorization or the authorization of their legal guardian.

II – DATA PROCESSING

1 – Data Controller

1. The data controller is the natural or legal person, public authority, service, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data. They are also responsible for security matters.
2. For this website, the data controller is: Altheo Valentini. For clarifications or to exercise user rights, you may contact them at the following email address: info@edifyeduproject.eu.

2 – Data Processor

1. The data processor is the natural or legal person, public authority, service, or other body that processes personal data on behalf of the data controller.
2. Pursuant to Article 28 of EU Regulation 2016/679, the data processor for edifyeduproject.eu is: Altheo Valentini.

3 – Location of Data Processing

1. Data processing generated by the use of edifyeduproject.eu takes place at EGInA s.r.l. – Via A. Vici, 8/b – 06034 Foligno (PG).
2. If necessary, data related to the newsletter service may be processed by the data processor or persons appointed for this purpose at their respective offices.

III – COOKIES

1 – Types of Cookies

1. The website edifyeduproject.eu uses cookies to make the user’s browsing experience easier and more intuitive. Cookies are small text strings used to store certain information, which may concern the user, their preferences, or their internet access device (computer, tablet, or mobile). They are primarily used to adapt the site’s operation to the user’s expectations, offering a more personalized browsing experience and storing previous choices.
2. A cookie consists of a small set of data transferred to the user’s browser by a web server and can only be read by the server that made the transfer. It is not executable code and does not transmit viruses.
3. Cookies do not record personal information, and no identifiable data will be stored. If desired, users may block some or all cookies. However, doing so may compromise the use of the site and its services. To continue without changing cookie settings, simply proceed with navigation.

2 – Technical Cookies

1. There are numerous technologies used to store information on the user’s computer, which are then collected by websites. Among these, the most well-known and widely used is HTML cookies. They are used for navigation and to facilitate access to and use of the site by the user. They are necessary for transmitting communications over electronic networks or to the provider to deliver the service requested by the user.
2. Settings to manage or disable cookies may vary depending on the internet browser used. However, users may manage or request general deactivation/deletion of cookies by modifying their browser settings. This deactivation may slow down or prevent access to certain parts of the site.
3. The use of technical cookies allows for the safe and efficient use of the site.
4. Cookies placed in the browser and retransmitted via Google Analytics or through the blogger statistics service (or similar) are considered technical only if used for site optimization purposes directly by the site owner. They may collect aggregate information about the number of users and how they visit the site. Under these conditions, the same rules for technical cookies apply to analytics cookies regarding information and consent.
5. Regarding duration, cookies may be temporary session cookies (automatically deleted at the end of the browsing session) used to identify the user and avoid logging in on each visited page, or permanent cookies (active until expiration or deletion by the user).
6. Session cookies may be installed to allow access to and stay in the restricted area of the portal as an authenticated user.
7. They are not stored persistently but only for the duration of the browsing session until the browser is closed. Their use is strictly limited to transmitting session identifiers (random numbers generated by the server) necessary for secure and efficient site navigation.

3 – Third-Party Cookies

1. Regarding origin, cookies may be sent to the browser directly from the site being visited or from third-party sites (not the one being visited).
2. Most third-party cookies are tracking cookies used to identify online behavior, understand interests, and customize advertising offers.
3. Third-party analytical cookies may be installed. These are sent from domains of the aforementioned third parties external to the site.
4. Third-party analytical cookies are used to detect information about user behavior on edifyeduproject.eu. Detection occurs anonymously to monitor performance and improve site usability. Third-party profiling cookies create user profiles to deliver targeted advertising based on user preferences.
5. The use of these cookies is governed by rules set by the third parties themselves. Users are encouraged to review the privacy policies and cookie management instructions published on the respective third-party websites.

IV – PROCESSED DATA

1 – Data Processing Methods

1. Like all websites, this site uses log files that automatically store information collected during user visits. This information may include:
   • Internet Protocol (IP) address;
   • Browser type and device parameters used to connect to the site;
   • Internet Service Provider (ISP) name;
   • Date and time of visit;
   • Referral webpage (origin) and exit page;
   • Number of clicks (if applicable).
2. This information is processed automatically and collected in aggregate form to verify site functionality and for security purposes. It is processed based on the controller’s legitimate interests.
3. For security purposes (anti-spam filters, firewalls, virus detection), automatically recorded data may include personal data such as the IP address, which could be used to block attempts to damage the site or harm other users. Such data are never used to identify or profile users and are processed based on the controller’s legitimate interests.
4. If the site allows comments or specific services requested by the user (e.g., submitting a CV for job opportunities), the site automatically records user identification data, including email address. Such data is voluntarily provided by the user when requesting the service. By submitting comments or other information, the user expressly accepts this privacy policy and agrees to the dissemination of their content to third parties. Data received will be used exclusively to provide the requested service and only for the duration required.
5. Information that users intend to make public through the site’s services/tools is provided knowingly and voluntarily, exempting the site from liability for any violations of laws. Users must verify that they have permission to enter personal data of third parties or content protected by national/international regulations.

2 – Purpose of Data Processing

1. Data collected during the site’s operation is used exclusively for the purposes stated above and stored for the time strictly necessary to carry out the specified activities. Under no circumstances will data be retained for more than 2 years.
2. Data used for security purposes (e.g., blocking damaging attempts) are retained for the time strictly necessary to achieve the stated purpose.

3 – Data Provided by the User

1. As indicated above, optional, explicit, and voluntary emails sent to addresses listed on this site result in the subsequent acquisition of the sender’s address (required to respond) and any other personal data included in the message.
2. Specific summary information will be progressively displayed or linked on pages dedicated to particular services on request.

4 – Browser Configuration Support

1. Users can manage cookies through their browser settings. However, deleting cookies may remove preferences set for the site.
2. For further information and support, visit the help page of your browser:
   • • Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
     • Firefox: https://support.mozilla.org/en-us/kb/enable-and-disable-cookies-website-preferences
     • Safari: http://www.apple.com/legal/privacy/it/
     • Chrome: https://support.google.com/accounts/answer/61416?hl=it
     • Opera: http://www.opera.com/help/tutorials/security/cookies/

V. USER RIGHTS

1. Article 13(2) of EU Regulation 2016/679 lists user rights.
2. This site aims to inform users of the following rights:
   • The right to request access to personal data (Article 15 EU Regulation), their updating (Article 7(3)(a) of Legislative Decree 196/2003), rectification (Article 16 EU Regulation), integration (Article 7(3)(a) Legislative Decree 196/2003), or restriction of processing (Article 18 EU Regulation), or to object to processing for legitimate reasons (Article 21 EU Regulation), as well as the right to data portability (Article 20 EU Regulation);
   • The right to request deletion (Article 17 EU Regulation), anonymization, or blocking of unlawfully processed data, including data whose retention is unnecessary for the purposes for which they were collected or processed (Article 7(3)(b) Legislative Decree 196/2003);
   • The right to obtain certification that update, rectification, integration, deletion, blocking, or transformation operations have been notified to those to whom data were communicated/disseminated, unless this proves impossible or involves disproportionate effort (Article 7(3)(c) Legislative Decree 196/2003).

• Requests may be sent to the data controller without formalities or via the template provided by the Italian Data Protection Authority (Garante), or by email to: info@edifyeduproject.eu.
• If processing is based on Article 6(1)(a) (explicit consent) or Article 9(2)(a) (consent for genetic, biometric, health, religious, philosophical, or trade union-related data, racial/ethnic origin, or political opinions), users may withdraw consent at any time without affecting the lawfulness of processing based on prior consent.
• Users may lodge a complaint with the Italian Data Protection Authority (Garante) if they believe their rights have been violated under EU Regulation 2016/679.
• For a detailed review of user rights, see Articles 15-22 of EU Regulation 2016/679 and Article 7 of Legislative Decree 196/2003.

VI. TRANSFER OF DATA TO NON-EU COUNTRIES

1. This site may share collected data with services located outside the EU (e.g., Google, Facebook, Microsoft/LinkedIn via social plugins or Google Analytics). Such transfers comply with Article 45(1) of EU Regulation 2016/679 (adequacy decisions) and require no further consent. The aforementioned companies adhere to the Privacy Shield framework.
2. Data will never be transferred to third countries that do not comply with Article 45 and subsequent provisions of the EU Regulation.

VII. DATA SECURITY

1. This site processes user data lawfully and securely, adopting measures to prevent unauthorized access, disclosure, modification, or destruction. Processing is carried out via IT/telematics tools, with organizational methods and logic strictly related to the stated purposes.
2. In addition to the controller, authorized personnel (administrative, commercial, marketing, legal, system administrators) or external parties (e.g., third-party technical service providers, hosting providers, IT companies, communication agencies) may access data.

VIII. CHANGES TO THIS DOCUMENT

1. This document, published at: https://edifyeduproject.eu/privacy-policy , constitutes the privacy policy of this site.
2. It may be amended or updated. Users are encouraged to check this page periodically to stay informed about legal updates.
3. Previous versions of the document will remain accessible on this page.
4. This document was updated on 14/11/2022 to comply with relevant regulations, including EU Regulation 2016/679 (GDPR).