Your information is processed using primarily electronic means and is used, without limitation, for the following purposes  

• Service Offerings. We use information collected to provide our services and to follow up with you about your satisfaction with the same. 
• Account Activity. We may use information collected to maintain your account with us (e.g., account verification), including administering any programs associated with such accounts, to communicate with you regarding your account and for customer support purposes. 
• Customization. We may use information collected to monitor and analyze trends, usage, and activities in connection with our products and services. Further, we may use the information collected to provide you with recommendations and offers that are tailored to your interests, and to target advertisements to you on third-party platforms and websites.  We may use also information collected to personalize your experience when you visit our Sites (e.g., by remembering your login ID and password).    
• Marketing. If you have signed up to receive our newsletter, we may use this information to send you marketing communications, such as email communications and mobile messages (including text and/or push notifications). These communications may inform you about new products, services, special discounts and other news and special offers.  
• Product and Site Development. We may use personal information to create non-identifiable information that we may use, alone or in the aggregate, with information obtained from other sources, in order to help us optimally deliver our existing products and services or develop new products and services.  From time to time, Davines may perform research (online and offline) via surveys (directly or through third parties) to help us better serve our customers by learning more about their needs and the quality of the services we provide. Anonymized and aggregated information is used for a variety of functions, including the measurement of Sites visitors’ interest in and use of various portions or features of the Sites.  
• Events, Contests and Promotions. We may use information collected to host events, facilitate contests, sweepstakes, giveaways, competitions, or other similar marketing campaign or promotion. To comply with sweepstakes laws, we may publish or share limited information about promotion winners (such as name and city of residence). For more information about our contests and other promotions, please see the official rules or details that will be posted with each promotion. 
• Customer Service. If you have requested a quote or further information or to start a collaboration, contacted customer service or in any other way requested that we contact you, we will use your personal information to respond to such a request.  We may also use your information to ensure we are providing the highest level of customer service, and to identify any potential gaps or potential improvements to the same. 
• E-Learning Services.  We may use information collected to grant you access to our e-learning platforms, to perform contractual obligations, to manage the credentials assigned to each user for access and connection to the e-learning platforms, to enable the access and use of the training content, to allow trainers to provide e-learning services and make available training content, to carry out all activities related to the e-learning services, e.g., sending service communications via email related to the training content, such as course start reminders and sending automatic messages of successful enrollment and/or completion of a course, to issue certificates of attendance, to administer tests, to assess the satisfaction with the e-learning services through a customer satisfaction questionnaire, survey, or similar tool, to fulfil internal operational and management requirements inherent to the e-learning services provided, and to carry out the necessary maintenance and monitoring activities of the e-learning platforms, with regard to technical and system management of the data and hardware structure. 
• General Business Purposes. We may use information collected for other general business purposes, such as to maintain the day-to-day operation and security of our Sites, to ensure that our Sites are working as intended, to protect the integrity of our business, and for analytics, auditing and technical assistance purposes. 
• Corporate Reasons. We may use information collected to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Davines’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Davines about our Sites’ users is among the assets transferred.
• Legal Purposes. We may collect and use personal information to enforce our contracts, including our Sites Policies, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties.  We also collect information in order to comply with certain legal rules and regulations that we are subject to, and as required by law enforcement.

The Sites use Secure Socket Layer (SSL) / Transport Layer Security (TLS) software and similar encrypting systems to protect your information. Only employees, contractors and agents of the Sites operator may access user information on a need-to-know basis and only for the purposes set forth in this Privacy Policy.   

While we make reasonable efforts to ensure your information is processed and stored in a secure manner, we cannot guarantee the security of data transferred over the Internet and you assume the risk of any such transfer.

Your information will be collected and stored in the United States and European Union.

If you provide your personal information to us, your information may be processed in a foreign country, where privacy regulations may be different from the ones in your home country. By submitting your personal information to us, you consent to the transfer, storage, and processing of your data in a country other than your country of residence, including, but not limited to, the United States and any country in the European Union.

We will not sell or otherwise disclose your information, except as described in this section and other relevant sections of this Privacy Policy.  

Generally, we share your personal information as necessary to provide the services you request.  We also may share your personal information when required by law, to protect your rights and safety, and with your consent.  Specifically, we may share your personal information with third parties, including: 

• Authorized Service Providers.  We may retain third-party service providers in order to process your data in connection with the services provided on the Sites. These services may include but are not limited to IT support, websites hosting, customer service, marketing communications, e-learning platform providers, analytics, logistics, and financing. Third parties who perform these operations are only permitted to use the information provided to them to perform their function and for no other purpose.   
• Social Media. We may share your information with social media providers, who may re-use your personal information for their independent activities in compliance with their respective privacy policies.
• Data Aggregators. We may disclose aggregated or de-identified information that cannot reasonably be used to identify you, to data aggregators. We process, maintain, and use this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law.
• Successors in Interest.  In the event there is a change in the corporate structure of Davines including, without limitation, by merger, consolidation, sale, liquidation, transfer of substantial assets, or in the unlikely event of bankruptcy, we may, in our sole discretion, transfer, sell or assign users’ information collected on and through the Sites to one or more affiliated or unaffiliated third parties or successor in interest.  
• Professional Advisors. We may disclose personal information to our legal, financial, insurance and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests. 
• Law Enforcement.  We may disclose a user’s information when required to do so to comply with applicable law or legal process or to respond to a request from law enforcement and/or regulatory authorities.  We may also provide your information in situations where we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing, to protect and defend the rights, property, or safety of our company, our consumers, our employees, or others, or to enforce our Sites Policies or other agreements or policies. 

Davines retains your personal information for as long as necessary to fulfill the purpose(s) for which it was collected, provide our services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. When we are no longer required to retain the personal information as described above, we will destroy, erase, or de-identify it, unless we are legally required to maintain it for longer. 

The Sites may contain links to third-party websites. We do not operate, control, monitor, endorse or guarantee those third-party websites. This Privacy Policy does not apply to the collection and use of information by such third-party websites. We suggest that you carefully read the privacy policy and other policies of all third-party websites.  

We may provide hyperlinks to third-party websites only for the convenience of our users and it is not a recommendation that users access such third-party websites.  We do not guarantee the services or goods provided and sold by such third-party websites to Internet users. YOU AGREE THAT YOUR USE OF ANY THIRD-PARTY WEBSITE IS AT YOUR SOLE RISK AND WITHOUT WARRANTIES OF ANY KIND BY DAVINES, EXPRESS, IMPLIED OR OTHERWISE, INCLUDING, BUT NOT LIMITED TO, WARRANTIES OF TITLE, FITNESS FOR A PARTICULAR PURPOSE, MERCHANTABILITY OR NONINFRINGEMENT. UNDER NO CIRCUMSTANCES SHALL DAVINES BE LIABLE FOR DAMAGES ARISING FROM ANY TRANSACTION BETWEEN YOU AND ANY THIRD-PARTY WEBSITE OR FOR ANY INFORMATION APPEARING ON THIRD-PARTY WEBSITES.

You may update, correct or remove your personal information at any time and free of charge by emailing us at gdpr@davines.it. We may ask that you identify yourself and the information you wish to access, change or delete for security purposes, and we will comply with your request as soon as reasonably practicable.  By removing some of your information, you may not be able to access some of the Sites’ features.  We may keep some of your personal information if required by law and/or for recordkeeping purposes.

Email.  You may unsubscribe from any marketing email communications by clicking on the “Unsubscribe” button included in all of our marketing communications or by contacting us at gdpr@davines.it. Note that you will continue to receive transaction-related emails regarding products or services you have requested.  We may also send you certain non-promotional communications regarding Davines and our Services and, to the extent permitted by law, you will not be able to opt out of those communications (e.g., communications regarding updates to our Sites Policies). 

Text. To stop receiving text messages, reply “STOP” to any text message you have received from us. Note that you will continue to receive transaction-related emails regarding services you have requested. We may also send you certain non-promotional communications regarding Davines and our services and, to the extent permitted by law, you will not be able to opt out of those communications (e.g., communications regarding updates to our Website Policies). 

Our Sites do not recognize Do Not Track signals. Some third parties may collect aggregate information about the users’ online activities over time and across websites when they use the Sites. While this information does not include personally identifiable information, certain processing activities that combine aggregate information with other information in possession of such third parties could result in the identification of users.

If you are a California resident, please read our Privacy Notice for California Residents for additional information concerning the collection and processing of your personal information and the rights granted to you with respect to such information. 

We do not provide services to children. If you are under 18 years old, you may use the Sites only under the supervision of a parent or guardian.  In accordance with the Federal Children’s Online Privacy Protection Act of 1998 (COPPA), we do not knowingly collect, solicit or use personal information of children under the age of 13 provided without parental consent. Should we become aware that a user under the age of 13 has registered without verifiable parental consent, any such information will be deleted.

Davines may amend or update all or any portion of this Privacy Policy, at any time, without notice, in its sole discretion.  Please access this section regularly to verify if any changes have been made to our Privacy Policy and to review the updated Privacy Policy. 

If you have any questions or comments about this notice, the ways in which Davines collects and uses your information described above, your choices and rights regarding such use, please do not hesitate to contact us at gdpr@davines.it or +1 212 924 2470 ext.12.