PRIVACY POLICY

The “Data Controller”
ALMA – Academy for Leadership and Management in Medicine Srl
Via Francesco Giordani, 56 – 80122 Naples
VAT identification number 09724401212

Pursuant to Article 13 of EU Regulation no. 679/2016, ALMA – Academy for Leadership and Management in Medicine Srl (hereinafter also “Company”, and/or “Alma”), with headquarters in Naples, Via Francesco Giordani, 56, is the Data Controller, pursuant to Article 24 of EU Regulation no. 679/2016 of the processing of your personal data. The same therefore informs you that the personal data acquired, also with reference to existing legal relationships (Customer / interested party), are subject to processing in compliance with the above mentioned legislation. In relation to the aforementioned processing, the Data Controller provides, among other things, the following information.
“Processing”, (ex art. 4 Regulation no. 679/2016), means any operation or set of operations, carried out even without the aid of electronic instruments, concerning the collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, erasure and destruction of data, even if not registered in a database.
This treatment must be carried out in accordance with Article 1 of Legislative Decree 196/2003 as amended by Legislative Decree 101/2018 and based on the principles of correctness, lawfulness, transparency, protecting your privacy and your rights.

Personal data collected
The personal data collected are essentially inherent to:
– Identification data (first and last name, address, telephone, email, place of work, category, IP address);
– Banking, accounting and fiscal data strictly necessary for participation in the event.

Purposes of the treatment
The purposes of the processing of personal data are as follows:
1. Execution of contracts stipulated with you and related commitments;
2. Fulfillment of legal obligations related to the existing contractual relationship;
3. Organizational management of the contract;
4. Any external professional collaborations for the fulfillment of legal obligations;
5. Protection of contractual rights;
6. Internal anonymized statistical analysis;
7. Marketing activities through the sending of promotional material relating to products or services similar to those covered by the existing relationship;
8. Commercial, promotional and advertising communications by Alma;
9. Commercial, promotional and advertising communications relating to third party commercial companies in the health sector (for example, for products and services in the diagnostic-pharmaceutical sector);
10. Litigation management.

Nature of data conferment
The provision of data and its processing are mandatory in relation to the purposes n. 1, 2, 3, 4, 5 and 6 relating to the contractual, pre-contractual and scientific fulfillment: it follows that any refusal to provide data for these purposes will make it impossible for the Data Controller to implement the same contractual relationships and legal obligations.
For the purpose 7, the use of e-mail coordinates, provided in the context of previous purchases of services/products, in order to send commercial and promotional information of similar services/products, may be based on the legitimate interest of the Data Controller, without the need for express consent and unless your refusal to processing, opposable at any time.
The provision of data in relation to the purposes n. 8 and 9 is optional and subject to express consent. With reference to point 9, communications for marketing purposes from third party companies may also be sent through Alma. Any refusal to provide consent for purposes 8 and 9 will make it impossible for you to take advantage of the relative services.
Finally, the legal basis for the purpose nr. 10 is the need to ascertain, exercise or defend a right in court.

Treatment modalities
Personal data will be treated in paper, computerized and telematic form and inserted in the relevant databases (customers, suppliers, administration, etc.) which may be accessed, and therefore come to know, the employees expressly designated by the Data Controller as authorized / designated to the processing of personal data, which may perform consultation operations, use, processing, comparison and any other appropriate operation also automated in accordance with the provisions of the law necessary to ensure, among other things, the confidentiality and security of data as well as the accuracy, updating and relevance of the data in relation to the stated purposes.

Duration of treatment
The data will be processed for as long as is necessary for the performance of the existing relationship and for a period of 10 years after the closure of the relationship or the issuance of the last tax documentation for legal obligations and administrative-accounting purposes, except the greater holding for purposes of legal protection and defense in court.
For marketing purposes the data retention period is set at 24 months.
In case of failure to complete the contract or termination of the contractual relationship, the data will be kept for marketing purposes for 24 months from the termination of the relationship or from the last contact with Alma.
This is without prejudice to the interested party’s right to withdraw consent at any time.

Scope of communication and dissemination of data
In relation to the purposes indicated, the data may be communicated to the following subjects and/or categories of subjects indicated below, or it may be communicated to companies and/or persons, both in Italy and abroad, who provide services, including external services, on behalf of the Data Controller. We indicate, for greater clarity, their different types:
– CME provider;
– consulting companies
– professional firms;
– Competent authorities and/or Supervisory bodies for the fulfilment of legal obligations;
– Public Administrations for their institutional purposes;
– qualified professionals for the study and resolution of any legal and contractual problems;

The list of External Managers with further useful data for identification is available by making a request to the addresses of the Data Controller.

It is foreseen the communication of the data for their processing outside the Company, exclusively for the above mentioned purposes.
The diffusion of personal data is not foreseen.

Rights of the interested parties
In relation to the aforementioned processing operations, you may exercise the rights set forth in Chapter III of EU Regulation No. 679/2016 at Articles 15 – 22, which include:
– obtain confirmation as to whether or not data concerning you exists;
– to know the origin of the data, the logic and the purpose on which the processing is based;
– obtain access, cancellation, transformation into anonymous form or data blocking processed in violation of the law, updating, limitation, rectification, revocation, portability and integration of data
– to oppose, for legitimate reasons, the processing of the data itself;
– propose a complaint to a supervisory authority pursuant to art. 77 of EU Regulation no. 679/2016 (http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524),

by contacting Alma srl, with registered office in Naples, Via Francesco Giordani, 56, by sending an email to info@almacademy.net.
Further information regarding the processing and communication of data provided directly or otherwise acquired may be requested from the Data Controller at the above email address. This notice, of course, does not exclude that other information is also given orally to interested parties at the time of data collection.