Privacy Policy

This policy describes the processing of personal data of visitors and users (collectively, "Users") of the website https://bs.h-farm.com/ (the "Site") by H-FARM Education S.r.l. with registered office in Via Sile 41, 31056 – Roncade (TV), Tax Code and VAT No. 04594110266 (hereinafter "H-FARM Education").

H-FARM Education may amend this policy to adapt it to future additions or changes to the Website or the services offered. In the event of substantial changes, H-FARM Education will publish a notice on the Website and/or send an email notification to report the changes and collect any requests to exercise the rights recognized by the legislation on the protection of personal data.

1. DATA CONTROLLER
   The data controller for Users' personal data collected through the Website (the "Data") is H-FARM Education.
2. DATA COLLECTED AND PURPOSES OF PROCESSING
   2.1 Browsing data
   Each time you access the Website, the systems automatically record and analyze access data (e.g., IP address of the provider, information on the browser used, pages visited, date, time, and duration of each visit). The information is collected automatically by the Website and does not require any action on the part of the User.

With regard to the processing of browsing data, please refer to the Website's cookie policy, which can be consulted at the following link: https://h-farmbusinessschool.com/cookie-policy/

2.2 Data communicated by Users
By filling in the "Contact Us" forms on the Website, or by sending a request to H-FARM Education using the contact details provided on the Website, Users communicate certain personal data to H-FARM Education, such as, for example: name, last name, email address, telephone number (optional), origin (optional), age, and any other information voluntarily entered by the User in the message box.

The data that is absolutely necessary in order to perform the activities requested from time to time is marked with an asterisk.

Users are asked not to disclose third-party personal data to H-FARM Education unless necessary (for example, if the User is a parent requesting further information about courses/schools/labs on behalf of their minor child): in this case, we remind you that it is the User's responsibility to comply with the legal requirements regarding the protection of personal data and, in particular, to inform third parties of the communication and, where applicable, to obtain their consent.

2.3 Data required for purchasing courses/school/lab
When purchasing a course and/or lab, as well as when transmitting specific requests from Users, the Website requires Users to provide specific personal data of the purchaser, such as:

• (a) first name, last name, email address, telephone number, residential address, date of birth, and tax identification number (the "Billing Information");
• (b) first name, last name, gender, age (or age range), and date of birth of the participant in the course/school/lab (the "Participant Data");
• (c) Furthermore, H-FARM Education, where necessary, also requests the communication of data relating to the health of the participant in the course/school/lab, and, in particular, information about dietary and/or medical requirements and/or the existence of certified educational needs (e.g., dyslexia) (the "Sensitive Data").

Data marked with an asterisk is required in order to complete the User's course registration request.

We recommend that Users only provide up-to-date, relevant Data that does not exceed the specific purposes of the processing.
Any unnecessary Data will be immediately deleted or anonymized.

3. PURPOSE OF PROCESSING AND RECIPIENTS OF DATA
   The data of Website Users may be processed by H-FARM Education, in strict compliance with applicable legislation and the guidelines of the Italian Data Protection Authority, for the following purposes.

3.1 Browsing data
Browsing data will be used:

• (i) to monitor the proper functioning of the Website;
• (ii) in anonymous and aggregated form, for statistical purposes related to understanding how the Site is used by Users, to improve ease of access and increase its attractiveness,
• (iii) as well as to detect any technical problems as soon as possible.

These processing operations have their legal basis in H-FARM Education's legitimate interest in improving its digital services, especially in relation to the use of the Website.

3.2 Responding to contact requests
The Data provided by sending a request to H-FARM Education by filling out the form in the "Contact Us" section of the Website will be processed to respond to requests for information about courses sent by the User and, if necessary, to provide assistance to H-FARM Education Users.

Such data, if marked with an asterisk, are necessary in order to follow up and respond to User requests.

The processing therefore has its legal basis in the need to implement pre-contractual measures at the request of the data subject.

3.3 Purchase and attendance of courses
The Data collected through the completion of the form on the Website (Billing Data and Participant Data) will be processed for the purchase of courses by the User. 

The provision of Data is necessary to complete the purchase of courses: therefore, in case of refusal or failure to provide the requested Data, it will not be possible for H-FARM Education to follow up on the User's requests, including that of registering an account.

This processing has its legal basis in the need to execute a contract to which the data subject is party (the contract signed between H-FARM Education and the User upon acceptance of the Terms and Conditions relating to participation in the course), in pre-contractual measures taken at the request of the data subject, and in compliance with legal obligations.

Personal data collected through the completion of the form on the Website (Billing Data and Participant Data) will then be communicated to the "Glide" software application owned by Glide S.r.l. / S.p.A,https://www.glideapps.com/– hello@glideapps.com and licensed to H-FARM Education under the name H-FARM Business School ("App"). This Data will be stored on the App in order to provide Users/Participants with an easy and accessible tool to have organizational information and staff contact details at their fingertips, and to receive photos, projects, and final certificates of the experience. For information on the use of cookies and how personal data is processed through the App, please refer to the App's privacy policy.

With particular reference to Sensitive Data, such data will be collected via a different platform to which the User will be redirected from the App in order to finalize their enrollment in the Course. This platform is the Zoho platform ("Zoho Platform"), owned by the Zoho Group, which includes all the companies listed here ("Zoho"). After being redirected to the Zoho Platform, the User will receive an email (at the address provided during registration on the Website) containing a form to be completed, in which they will be asked to enter, after accepting Zoho's privacy policy, some additional personal data necessary for H-FARM Education to ensure the best use of the Course and the safety of the User. In particular, after accepting Zoho's privacy policy, the Zoho Platform will collect information relating to the dietary, medical, and educational needs of the User enrolled in the Course and other data contained in the documents that must be uploaded to complete the registration, such as, by way of example, medical certificates, specific dietary requirements, etc.

Sensitive Data collected through the Zoho Platform will be processed solely to enable course participants to take part in a meaningful way and to allow H-FARM Education to provide them with adequate learning support and any related services (e.g., cafeteria) in accordance with the participant's health, depending on the specific needs reported at the time of purchase.

With regard to the processing of Sensitive Data, including the communication of such data to the third parties mentioned above, the legal basis for this is the need to protect the vital interests of the participant, as well as the explicit consent of the adult participant, or of the person exercising parental responsibility in the case of a minor participant, at the time of purchase of the course and/or workshop.

In this context, the Data, including Sensitive Data, may be disclosed to the following categories of subjects:

• (A) the company that owns and manages the App and its employees and collaborators who are duly trained to process personal data in accordance with applicable legislation;
• (B) educators, employees, and/or collaborators of H-FARM Education directly involved in the organization and management of courses/workshops in order to meet the educational and personal needs of the registered Participant;
• (C) with reference also to Sensitive Data, public and private entities involved in the related organizational and management activities and/or providers of ancillary services necessary to protect the specific needs of participants (e.g., dietary requirements).

These parties will process the Data, as applicable, as independent data controllers or as data processors; in the latter case, these parties will act on the basis of a specific written assignment given to them by H-FARM Education.

The complete list of Data recipients is kept at the H-FARM Education headquarters and is available upon request, which can be sent to the contact details indicated in point 5 below.

3.4 Receiving newsletters
The data provided by sending a request to H-FARM Education by filling out the appropriate form may be used, with the user's consent, to allow the user to benefit from the newsletter service and, therefore, to send newsletters with commercial and promotional content (which will be sent via email) concerning the activities of H-FARM Education and the most important news related to it, the courses offered by H-FARM Education, as well as fairs and events in which H-FARM Education will participate.

For the same purpose, the Data will be communicated to Zoho Corporation B.V., with registered office at Beneluxlaan 4B, 3527 HT UTRECHT, The Netherlands ("Zoho"), which includes all the companies listed here ("Zoho Group") and, for this reason, will process the Data under a specific assignment conferred by H-FARM Education. In this context and within the Zoho Group companies, the User's name, last name, and email address may be transferred outside the European Union, based on the adoption by H-FARM Education, as data controller, of appropriate measures in accordance with applicable laws and regulations to ensure that the Data is adequately protected, such as, in particular, the signing of standard contractual clauses as required by the European Commission.

The provision of Data is voluntary: any refusal will make it impossible for H-FARM Education to send the newsletter to the User but will not affect navigation on the Website and/or the purchase of courses/school/lab.

The Data will be stored and processed for up to 24 months from receipt of the last contact request and, if the User has consented to receiving the newsletter, from the date of consent.

The legal basis for processing data for the purpose of sending newsletters with commercial content is the consent of the data subject (user).

Users may revoke their consent and unsubscribe from the newsletter service at any time by following the procedure indicated in each newsletter or by sending a specific communication to H-FARM Education, at the address indicated in Article 5 below, expressing their wish to unsubscribe from the newsletter service and delete the Data held by H-FARM Education.

4. METHOD OF PROCESSING AND DATA RETENTION PERIODS
   The Data will be processed using manual and computerized tools by personnel and collaborators of H-FARM Education and/or companies expressly appointed as data processors, to whom H-FARM Education has given detailed operating instructions with particular reference to the adoption of adequate technical and organizational security measures.

Browsing data is not stored for more than 7 (seven) days and is deleted immediately after aggregation (except where necessary for the investigation of crimes by the competent judicial authorities).

Billing Data will be stored on Zoho and processed for the period necessary to fulfill tax, accounting, and regulatory obligations related to the sale of H-FARM Education courses/schools/labs.

Participant Data and Sensitive Data will be stored on Zoho and processed for the duration of the course and/or workshop and for 24 months after the end of the course and/or workshop for archiving purposes.

The account will be deactivated if there is no access for a period exceeding 36 months from the date of the last purchase.

5. USER RIGHTS AND CONTACT INFORMATION
The User may, at any time and within the limits of applicable rights:

1. obtain access to your personal data;
   2. request the rectification, erasure, or restriction of the processing of your personal data;
   3. where applicable, receive your personal data provided to H-FARM Education in a structured, commonly used, and machine-readable format, as well as request that such data be transmitted to another data controller (right to data portability);
   4. where applicable, withdraw consent at any time without prejudice to the lawfulness of processing based on consent previously given;
   5. lodge a complaint with the Data Protection Authority or appeal to the competent judicial authority.

Requests to exercise the above rights should be sent to one of the following addresses:

• by email, at the following address: info.education@h-farm.com;
• by registered mail with return receipt, to H-FARM Education S.r.l., 31056 – Roncade (TV), Via Sile 41.

Requests regarding the recipients of the Data, as well as requests for clarification on this policy, may also be sent to the same addresses.

6. LINKS TO OTHER WEBSITES
   This privacy policy is provided exclusively in relation to the Data collected through the Website and with reference to the purposes identified in point 3, and not for any other websites consulted and/or accessible via links and/or widgets (e.g., social networks): these additional websites will process the Data as independent data controllers and in accordance with their respective policies, which Users are expressly recommended to consult.