Privacy Policy

1. Introduction

D F & A SRL ("we," "us," or "our"), a company registered in Italy with its offices at Via Gian Battista Bazzoni, 12, 20123 Milano, Italy, is committed to protecting the privacy and personal data of all individuals who visit our website and use our services. This Privacy Policy explains how we collect, use, store, share, and protect your personal information in accordance with applicable data protection laws, including the General Data Protection Regulation (EU Regulation 2016/679, "GDPR") and Italian Legislative Decree 196/2003 (as amended by Legislative Decree 101/2018).

By using our website or submitting information through our forms, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described herein, please do not use our website or submit any personal data.

Our coaching and personal development education programs are offered to participants throughout Canada. This Privacy Policy applies to all users of our website, regardless of their geographic location.

2. Data Controller

The data controller responsible for the processing of your personal data is:

For any questions or requests regarding the processing of your personal data, please contact us using the email address above.

3. What Personal Information We Collect

We may collect and process the following categories of personal information:

3.1 Information You Provide Directly

When you complete our contact or inquiry form, you may provide us with:

• Full name
• Email address
• Phone number
• Selected program of interest
• Preferred learning format
• Message or comment content

3.2 Information Collected Automatically

When you visit our website, we may automatically collect certain technical information, including:

• IP address
• Browser type and version
• Operating system
• Device type
• Pages visited and time spent on each page
• Referring website or URL
• Date and time of access
• Language preferences

3.3 Cookie Data

We may use cookies and similar tracking technologies to collect information about your browsing behaviour. For detailed information about cookies, please refer to our Cookie Policy.

4. Why We Collect Your Information

We collect and process personal information for the following purposes:

• To respond to inquiries: When you submit a contact form, we use the information provided to respond to your request and provide relevant information about our coaching education programs.
• To provide educational services: To deliver, administer, and manage the coaching and personal development programs you have expressed interest in.
• To improve our website: To analyze website usage patterns and improve the functionality, content, and user experience of our website.
• To ensure security: To protect our website from unauthorized access, abuse, fraud, and other security threats.
• To comply with legal obligations: To meet our obligations under applicable Italian and European Union laws and regulations.
• To communicate with you: To send you educational information related to the program you have expressed interest in, only where you have provided explicit consent.

5. Legal Basis for Processing

Under the GDPR, we rely on the following legal bases for processing your personal data:

• Consent (Article 6(1)(a) GDPR): When you submit a form on our website, you explicitly consent to the processing of your personal data for the stated purposes. You may withdraw your consent at any time.
• Legitimate Interest (Article 6(1)(f) GDPR): We may process certain data based on our legitimate interest in maintaining the security and proper functioning of our website, and in improving our educational services.
• Legal Obligation (Article 6(1)(c) GDPR): We may process your data when required to comply with applicable laws and regulations.
• Contractual Necessity (Article 6(1)(b) GDPR): When processing is necessary for the performance of a contract or to take steps at your request before entering into a contract related to our educational programs.

6. How We Store and Protect Your Information

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• SSL/TLS encryption for data transmitted through our website
• Secure server infrastructure with access controls
• Regular security assessments and updates
• Restricted access to personal data on a need-to-know basis
• Secure form processing with server-side validation

While we take all reasonable precautions to protect your data, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security of your personal data.

7. Data Retention

We retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable laws and regulations. Specifically:

• Contact form submissions: Retained for up to 24 months from the date of submission, unless a longer retention period is required by law or for ongoing communication regarding our educational programs.
• Website usage data: Retained for up to 12 months for analytics and security purposes.
• Cookie data: Retention periods vary by cookie type. See our Cookie Policy for specific details.

8. Sharing of Personal Information

We do not sell, trade, or rent your personal information to third parties. We may share your data only in the following limited circumstances:

• Service providers: We may share data with trusted third-party service providers who assist us in operating our website, processing form submissions, or delivering our educational services. These providers are contractually obligated to process your data only on our behalf and in accordance with our instructions.
• Legal requirements: We may disclose personal data when required by law, in response to valid legal processes, or to protect the rights, property, or safety of D F & A SRL, our users, or the public.
• Business transfers: In the event of a merger, acquisition, reorganization, or sale of assets, your personal data may be transferred as part of that transaction. We will notify you of any such transfer and any changes to this Privacy Policy.

9. International Data Transfers

As our company is registered in Italy and serves participants in Canada, your personal data may be transferred to and processed in countries outside your country of residence, including Italy and other countries within the European Economic Area (EEA).

When personal data is transferred outside the EEA, we ensure that appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by the European Commission, or other legally recognized transfer mechanisms, to ensure that your data is adequately protected.

10. Your Rights Under GDPR

Under the GDPR and applicable Italian data protection law, you have the following rights regarding your personal data:

• Right of Access: You have the right to request a copy of the personal data we hold about you.
• Right to Rectification: You have the right to request the correction of inaccurate or incomplete personal data.
• Right to Erasure: You have the right to request the deletion of your personal data, subject to certain legal exceptions.
• Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal data in certain circumstances.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another data controller.
• Right to Object: You have the right to object to the processing of your personal data based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) or another competent supervisory authority.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days of receipt.

11. How Form Submissions Are Processed

When you submit a form on our website (such as the contact or inquiry form), the following applies:

• The information you provide is transmitted securely using SSL/TLS encryption.
• Your data is processed for the purpose of responding to your inquiry and providing information about our coaching education programs.
• We will only contact you using the information you have provided and only for purposes related to your inquiry.
• Your data will not be used for unrelated marketing purposes without your explicit consent.
• Form submissions are processed by our team and may be stored in our secure systems for the purpose of managing communications.

12. How Consent Is Collected Through Forms

Before submitting any form on our website, you are required to provide explicit consent by checking a consent checkbox. This checkbox is not pre-checked, and you must actively indicate your agreement before the form can be submitted.

By checking the consent checkbox and submitting the form, you confirm that:

• You have read and understood this Privacy Policy.
• You consent to the collection, processing, and storage of the personal data you have provided for the purposes stated in this policy.
• You consent to being contacted by D F & A SRL using the information you have provided in response to your inquiry.

13. Cookies

Our website uses cookies and similar technologies to enhance your browsing experience, analyze website traffic, and understand how visitors interact with our site. Cookies are small text files stored on your device when you visit our website.

We use the following types of cookies:

• Essential cookies: Necessary for the basic functioning of our website and cannot be disabled.
• Analytics cookies: Help us understand how visitors interact with our website by collecting anonymous usage data.
• Preference cookies: Remember your settings and preferences for a better user experience.

For complete information about our use of cookies, including how to manage and disable cookies, please refer to our Cookie Policy.

14. Children's Privacy

Our website and services are intended for adults only. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete such information from our records. If you believe that we may have collected information from a minor, please contact us at [email protected].

15. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those third-party websites. We encourage you to review the privacy policies of any third-party website before providing any personal information.

16. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time. Any changes will be posted on this page with an updated "Last updated" date. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Continued use of our website after any changes constitutes your acceptance of the updated Privacy Policy.

17. Supervisory Authority

If you believe that the processing of your personal data violates applicable data protection laws, you have the right to lodge a complaint with the competent supervisory authority. For Italy, the relevant authority is:

18. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact us: