DATA PROTECTION NOTICE
Pursuant to Articles 13 and 14 of the European Regulation 2016/679 'GDPR'.
With this document ("Notice"), Davines S.p.A. and the subsidiaries of the Davines Group, each to the extent of its competence, provide information on the collection and processing of users' personal data carried out within the framework of Websites and/or related platforms of the [comfortzone] brand listed below, specifying the purposes for which the data is used and the rights of the data subject ("Data Subject" or "User"):
- Comfortzone e-learning:
- https://professionalacademy.comfortzoneprofessional.com: dedicated to Davines business clients [comfortzone] (where individually referred to as 'Professional Academy');
- https://educatoracademy.comfortzoneprofessional.com: dedicated to Davines trainers [comfortzone] (where individually referred to as 'EAcademy');
- https://salesacademy.comfortzoneprofessional.com: dedicated to Davines [comfortzone] dealer agents and Sales Department personnel ('Sales Academy');
This Privacy Notice does not refer to processing performed or described as a result of browsing Internet sites that can be reached through links that may be found on the Websites.
The following is an index of the structure of this Policy and the contents in each paragraph, which all users should be aware of and examine in detail in the sections of interest.
I. GENERAL INFORMATION
In this section, we explain who are the entities that process Users' personal data and specify their responsibilities in the area of data protection.
1. Data Controller
The Data Controller is Davines S.p.A., in the person of its legal representative, with registered office in Via Don Angelo Calzolari 55/A - Roncopascolo, 43126 - Parma - PR (hereinafter, also 'Davines' or 'Data Controller').
The Data Controller can be contacted at the following addresses:
- telephone number 0521-965611;
- e-mail: gdpr@davines.it.
2. Davines Group
Depending on the localisation of the user and the processing carried out, the Davines Group subsidiary with territorial jurisdiction, as well as Davines S.p.A. may access the User's Personal Data, as defined below, acting as autonomous data controllers or in a relationship between Data Processor and Data Controller or as joint-controllers of Davines S.p.A. The contact details of all the companies in the Davines Group can be found at: Governance | Davines Group .
For more information on the B2B services provided by the subsidiaries, the related processing operations and the privacy roles of the involved companies, please refer to the subsidiaries’ data contacts listed at Governance | Davines Group .
3. Data Protection Officer (DPO)
Davines S.p.A. has appointed a Data Protection Officer who can be contacted at the e-mail address privacydpo@davines.it whenever it is clear and/or suspected that data processing is not carried out in compliance with the relevant regulations or violates the rights and/or freedoms of the Data Subject.
4. Collection and Processing of Personal Data
The processing of personal data shall be carried out by authorised and specifically trained Davines Group's internal resources, by means of manual as well as computerised and telematic tools, with logics strictly related to the purposes themselves and, in any case, by adopting technical and organisational measures such as to guarantee a level of security adequate to prevent the risk of destruction, loss, modification and unauthorised disclosure of data or access, accidental or unlawful, to such personal data.
5. Persons Authorized to Process and Communicate Personal Data
Without prejudice to what may be indicated in the specific sections dedicated to the individual Websites, in order to achieve the aforementioned purposes, we may need to communicate your data to the following categories of persons, other than Davines' authorised in-house personnel:
- Davines S.p.A. Group branches: in order to allow users to use services at all Group branches by the competence determined on the basis of the territory to which the user belongs (for example, in the case of a French user, the data may be processed, jointly or severally, both by Davines S.p.A. and by the French subsidiary for one or more of the purposes set out in this Notice and in the related privacy policy of the competent subsidiary);
- Davines' suppliers (e.g. suppliers of IT services and platforms, including e-learning platforms, consultants, etc.) who collaborate with us for consultancy, assistance, maintenance services and who may use the data in their capacity as "Data Processors" appointed under a specific contract;
- Shipping and transport companies, which act as autonomous data controllers, and their involvement is necessary to execute purchases and correctly process orders (e.g. deliver products purchased online, etc.).
The data may be made available to parties who are entitled to by law, regulations or European legislation, within the limits and for the purposes provided for by applicable provisions (debt collection companies, insurance agencies, public authorities).
In no the data will be spread.
6. Transfer of Data to Countries Outside the European Union
Davines does not regularly transfer users' personal data outside the European Union. However, should it become necessary to transfer personal data to non-EU countries, in order to carry out online purchases or to guarantee the services offered, this will be done in accordance with Articles 44 et seq. of the GDPR, providing appropriate instruments that guarantee adequate data protection guarantees. For further information on any possible transfer of data outside the EU, users are invited to contact the Data Controller at the contact details provided in Article 1 above, and/or the territorially competent subsidiary whose contact details can be found in the privacy notices referred to in Article 2 above.
II. USER RIGHTS
This section sets out the methods and rights of Users according to the GDPR, such as access, rectification, deletion of personal data, restriction of processing and portability of personal data. Information is also provided on how to revoke any consents given and how to object to processing.
User Rights
The Data Subject may exercise the rights that the GDPR guarantees regarding personal data by writing to gdpr@davines.it. Davines undertakes to respond to the request as soon as possible and in any event no later than thirty days from receipt of the report. If it is necessary to verify the identity of the sender, a copy of an identification document may be requested. In particular, the data subject may exercise the following rights, where applicable:
- Right of access, i.e. the right to know whether personal data relating to him or her is being processed and, if confirmed, to obtain a copy of such data and to be informed about: the source of the data, the categories of personal data processed, the recipients of the data, the purposes of the processing, the existence of automated decision making (including profiling), the data retention period, the rights under the GDPR;
- Right to rectification or integration, i.e. the right to have inaccurate data corrected or supplemented;
- Right to obtain the erasure of personal data if such data are no longer necessary for the purposes for which they were collected, or if the Data Controller uis no longer authorised to process them;
- Right to obtain the restriction of processing of personal data in the following cases: i) the accuracy of the personal data is contested. In this case, the data subject may request a restriction of the processing for the period necessary to verify the accuracy of the data; ii) he processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; iii) the data controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; iv) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject;
- Right to data portability, i.e. the right to receive personal data concerning the data subject in a structured, commonly used and machine-readable format, as well as the right to request that such data be transmitted to another Data Controller;
- Right to withdraw consent, for processing based on it;
- Right to object at any time to the processing of personal data based on the Data Controller’s legitimate interest.
III. INFORMATION ON 'BASIC' PROCESSING COMMON TO DIGITAL SERVICES ACCESSIBLE THROUGH THE WEBSITES
The digital services offered through the Websites are accessible for the most part after authentication. Once logged in, the User shall access the digital services which are the subject-matter of the service package(s) purchased, possibly also at one of the Davines Group’s subsidiary and/or a distributor and/or agents of Davines S.p.A. or of one of the subsidiary.
Below, we describe the 'basic' processing operations related to the Websites, which apply independently of the Website and/or related platform considered.
The Websites carry out some processing of personal data that are homogeneous and that apply without distinction to all the Websites referred to in this Privacy Notice.
These processing operations are better described in this Chapter III) and concern personal data collected during browsing, data required for the login/registration of an online account and/or collected through customer care contact. For each processing operation, the categories of personal data involved, the purposes and legal basis, and the storage period are defined.
In the event of a conflict between the contents of this Chapter III) describing the processing operations present and common to the Websites and the contents of the specific sections dedicated to each Website, the provisions of the specific sections shall prevail.
1. Website Navigation
Type of data processed: the IP addresses or domain names of the computers used to connect to the Websites, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user's operating system and computer environment.
Purpose and legal basis: data are automatically acquired by technical and necessary cookies installed to enable web browsing, carry out aggregate statistical analyses aimed at measuring the proper functioning of web pages and, in the event of computer crimes against the platforms, ascertain any liability.
The legal basis legitimising the processing of this data is the legitimate interest of the Data Controller in ensuring the proper functioning of the platforms and services available, as well as in the investigation of possible offences.
In any case, failure to provide data will preclude the possibility of using the navigability and services of the Websites.
Data retention time: data are normally retained for short periods of time, as set out in more detail in the Cookie Policy, with the exception of possible extensions related to survey activities.
In addition to the cookies necessary for browsing, other types of cookies that will enable the Data Controler to capture additional data relating to Users’ browsing experience can be installed. In this case, however, the processing is subject to the User’s consent, provided via the cookie panel. For more details, please read the Cookie Policy.
2. Login - Online Account Registration
Type of data processed: first name, surname, e-mail, country, and/or any other data to be specifically indicated in the reference form. The data provided as mandatory are indicated with an asterisk (*), the others are optional.
The log-in data will be used by Davines in association with further information in the client databases (e.g. role, service package purchased, etc.) to determine the contents of the Websites that can be viewed by the User.
Purpose and legal basis: personal data are required in order to fulfil registration requests and allow access to content related to the services/products and/or courses purchased and, where applicable, to be redirected to the site in your country.
The processing is necessary in order to take steps at the request of the user prior to entering into a contract or perform a contract to which the user is party and/or, in any case, to follow up a request by the User, and failure to provide the data will not allow the User to take advantage of the digital services purchased.
Data retention time: Account data is retained until a request for deletion is received.
3. Customer Care
Type of data processed: all types of data indicated in the request received via telephone, messaging chat (Whatsapp) or e-mail and/or entered in the dedicated forms present on each Website. In the case of forms, the list of data requested will be directly specified in the form. The data provided as mandatory are indicated with an asterisk (*), the others are optional and do not preclude the possibility of sending the request for contact and/or assistance. Any other information spontaneously inserted by the user in the message text, where present, may also be processed; Davines, therefore, invites Users to provide only the information that is actually necessary. Without prejudice to the foregoing, please refer to the specific sections dedicated to each Website for further information.
Purposes and legal basis: personal data is acquired to enable Davines to collect and manage Users' requests relating both to an order and/or products purchased and/or to be purchased (information relating to the status of purchases made, their delivery, any returns/refunds, defects in products received, etc.) and more general requests for information (relating, for example, to initiatives and events, product characteristics, etc.) and, therefore, to offer the best pre- and post-sales support to Users. Based on the request, Davines might forward it to the territorially competent subsidiary.
The processing of data, which is carried out on the basis of a request by the Data Subject, is therefore necessary to perform the contract of sale and/or purchase of a service and/or partnership or to take steps at the request of the User.
In any case, the processing of the mandatory personal data is necessary for the performance of a contract or a contract-like situation and, therefore, failure to provide the data will preclude the possibility of sending the contact request itself and, therefore, of using the service described.
Data retention time: the data collected is usually kept for short periods of time and, in any case, for as long as is strictly necessary to process requests and provide the requested services.
4. Commercial Communications - Marketing
Davines, pursuant to law, wishes to keep its Users up-to-date with news from the world of Davines, as indicated below and without prejudice to any different and further indications given in the specific sections dedicated to each Website.
For further information on the processing of personal data carried out by the local subsidiary for marketing purposes, please refer to the applicable Privacy Notice se out tin the list in Article 2 above.
Type of data processed: identification and contact data (name, surname, e-mail address), purchase data.
Purpose and legal basis: to send commercial communications - via the newsletter service - regarding products/services, discounts, offers, promotions and/or events relating to the brands of Davines S.p.A. Group (Davines and Comfort Zone) and via any other channel that Davines usually adopts and/or will adopt as part of its marketing campaigns; to carry out market research and satisfaction survey activities regarding products relating to the brands of Davines S.p.A. Group (Davines and Comfort Zone). In order to be able to process this data, consent is required, which the user may revoke at any time by clicking on the unsubscribe link present in each communication that the user will receive or, alternatively, by accessing the reserved area of the user's Account or by writing to the email address gdpr@davines.it.
Marketing, remarketing/retargeting campaigns through social channels and third-party platforms may also be carried out. This depends, of course, on the consents given with regard to Cookies and other tracking tools. For further details, users are invited to read the following paragraph and the Cookie Policy.
In general, failure to provide data for the purpose in question will not preclude the use of the Websites and related services, but it will not allow the user to be kept up-to-date on news and promotions relating to products/services in the Davines world.
Data retention period: Identification and contact details are used to reach users with Davines' promotional communications for twenty-four (24) months after the last interaction.
Purchase data will be used for marketing purposes for a period of twenty-four (24) months after collection.
IV. INFORMATION ON SPECIFIC AND RELATED PROCESSING OF DIGITAL SERVICES ACCESSIBLE THROUGH INDIVIDUAL WEBSITES
Each Website offers specific digital services. Therefore, in this Chapter IV), Users can examine the details of the processing carried out within each Website. In this way, the user can obtain detailed information on the data processed, the purposes of the processing, the legal basis and the retention periods, applicable to the case at hand.
Depending on the user's localization and the type of digital services purchased, only some of the provisions of this Policy may apply (for example, the provisions set out in the Professional Store section will only apply to those users whose reference Davines Subsidiary has an active Store).
1. Basic Treatments of the Platform
Recipients: all users of Comfortzone E-Learning
Type of data processed: first name, last name, email address, country of origin and/or any other data specifically indicated in the following sections of Comfortzone E-Learning.
Purpose and legal basis: in general and except as further provided for in the following sections, the processing operations of the Personal Data of users of Comfortzone E-Learning take place for:
- to grant access to the digital platform of Comfortzone E-Learning and carry out any related and/or consequent operation, or in any case to perform one or more contractual obligations;
- manage the personal access and connection credentials to Comfortzone E-Learning assigned to each user;
- enable the use of the training content and issue certificates of attendance;
- fulfil internal operational and management requirements inherent to the service provided;
- carry out the necessary maintenance and monitoring activities of the Comfortzone E-Learning platform, with regard to technical and system management of the data and hardware structure.
Without prejudice to what is further stated below, data are also collected to enable the provision of any digital services purchased by the user.
In general, failure to provide personal data will preclude access to the purchased digital services and will therefore make it impossible for the Data Controller to implement the contractual provisions in force between the parties, without this resulting in a breach of contract on the part of the Data Controller.
Disclosure of data: for the purpose of proper functionality and management of this service, data are disclosed and processed by the e-learning platform provider. For more information, please feel free to consult the following webpage: https://www.absorblms.com/support/compliance/gdpr/.
Data retention period: the retention period of data acquired via Comfortzone E-Learning (and the resulting accessibility of content) is determined according to the training package activated and/or purchased and in accordance with the relevant contractual and regulatory obligations (e.g. ten years for tax-accounting regulations).
As a general rule and unless more specific provisions under the terms&conditions applicable, the validity of the training packages activated and/or purchased is one year. Therefore, once the period of validity of the training package has expired, it will no longer be possible to access Comfortzone E-Learning. Relevant personal data may however be stored - in databases different and separate from the environment dedicated to the platform - for administrative-accounting and/or tax purposes, in the context of the aforementioned contractual obligations between the parties and/or applicable laws.
For further information and for anything not expressly set out in this policy text, users are invited to consult the main privacy notice applicable from time to time according to the main legal relationship existing between the user and the Data Controller (e.g. sales contract, service contract, collaboration contract, partnership contract, etc.).
2. Focus: Professional Academy
Recipients: business clients of Davines[comfortzone] (Clients).
Type of data processed: name, surname, email address and/or any other data specifically indicated in the dedicated sections of the Professional Academy.
Purpose and legal basis: data are collected to enable the provision of digital services purchased by the Client through the Davines[comfortzone] sales network and, in particular, to enable the Client to access the training content purchased (e.g. ppt, excel, video, etc.).
The data is also used to carry out all activities related to the purchased service, e.g. sending (by email) service communications related to the purchased course (e.g. course start reminder) and/or sending automatic messages of successful enrolment or completion of a course.
The processing of this data is necessary to perform the sales contract and to fulfil accounting and tax obligations. Without the provision of the data, it is not possible to use the functionality of the Website.
3. Focus: E-Academy
Recipients: trainers of Davines [comfortzone] and/or distributors of Davines [comfortzone] ("Trainers").
Type of data processed: first name, surname, email address, name and/or company name, and/or any other data specifically indicated in the dedicated sections of the EAcademy.
Purposes and legal basis: data is collected in order to offer Trainers the opportunity to carry out e-learning experiences that are functional and strictly related to the execution of the existing collaboration contract with Davines [comfortzone] and also aimed at recovering, deepening and enhancing knowledge, using methodologies that favour collaboration and the sharing of materials and content through the web; EAcadamy also enables trainers to make available a series of information, documents and multimedia materials (e.g. ppt, excel, videos, etc.) for training purposes.
The data is also used to carry out all activities related to the training service provided, e.g. sending (by email) service communications relating to the course activated (e.g. reminder of the start of the course) and/or sending automatic messages of successful enrolment or completion of a course.
The processing of this data is necessary in order to execute the collaboration contract, as an intrinsically connected activity, and to fulfil accounting and tax obligations. Without the provision of the data, it is not possible to use the functionality of the Website.
V. FURTHER USEFUL INFORMATION
In this section, we inform Users that the Websites include social buttons that allow direct redirection to social networks. We also inform the user that Davines does not process personal data of minors through the Websites and promotes the safe use of the Internet for this category. Finally, the user is informed that the use of cookies is governed by the respective cookie policies of the Websites.
1. Social Network
On our Websites there may be social buttons/widgets, i.e. those particular "buttons" representing the icons of social networks (e.g. Facebook, Linkedin, Instagram, Youtube). These 'buttons' allow users browsing the Websites to be directed directly to the social network by simply clicking on the desired 'button'. If the user then logs in to the selected social network, the latter will acquire the data relating to the visit made by the user on the Website.
2. Minors
Through the Websites, Davines does not process the personal data of minors. Therefore, despite the fact that the contents of the Websites are potentially and partially viewable by minors, it is specified that when filling in any forms on the Websites, no personal data should be entered by minors and/or in relation to minors without the prior consent of their parents or guardians. Davines encourages all parents and guardians to instruct minors in the safe and responsible use of their personal data on the Internet. Davines does not retain and does not process any personal data that may be entered into the form by minors for any purpose.
3. Cookie
The Websites use cookies as referred to in their respective cookie policies, which you are invited to review by clicking on the items below:
- Cookie Policy Comfortzone Professional;
- Cookie Policy Comfortzone e-learning.
4. Updates
The Users are also informed that Davines reserves the right to periodically update the content of this Information Notice. Therefore, the Users are invited to regularly consult this Information Notice in order to be kept up-to-date with respect to any changes that have occurred since the date of the last consultation. For the purposes of this paragraph, the date of:
Last updated: 29 January 2025