DATA CONTROLLER:
GENIUS KID (“The School”)
Corso Plebisciti 15, 20129 Milano (MI)
Email address: info@geniuskiditaly.com

DATA PROCESSOR:
TEAM CONSULTING SRL
Corso Plebisciti 15, 20129 Milano (MI)

1. INTRODUCTION

This policy is drafted in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of personal data and on the free movement of such data (GDPR) and the Italian implementation by Legislative Decree n. 101 dated 10 August 2018. Our Data Protection Officer can be contacted by email at the address info@geniuskiditaly.com if you have any queries regarding the processing of your personal data.

2. TYPES OF PERSONAL DATA WE PROCESS

We process personal data from our students and their families and / or competent persons and from our employees, candidates, suppliers, contractors, prospective customers and third parties interested in finding out more about Genius Kid within the systems controlled by the school as Data Controller. The personal data processed are mainly the following:
• Names, addresses, telephone numbers, e-mail addresses and other contact details;
• Family details and siblings;
• Safeguarding information (such as court orders and professional involvement)
• Education and employment data;
• Financial information;
• Educational centres previously attended. Other types of data we may collect and process, according to the school purposes, are related to health condition, criminal records and other sensitive information related to an individual, such as:
• Information about health status or provision of health care linked to a specific individual;
• Behavioural information;
• Special educational needs
• Criminal records linked to a specific individual
• Biometric information;

3. HOW WE COLLECT AND PROCESS PERSONAL DATA

Genius Kid collects information in several ways, including:
• Personally and over the phone;
• Through our website, including information received through our website contact us form;
• From email and hand delivery paper documentation;
• Through online tools such as apps, educational platforms and other software used by the School;
• Through third parties, such as legal representatives, professionals or other authorities;

4. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA

Genius Kid processes personal data to carry out the School’s educational activity lawfully and legitimately. The School collects and keeps students’ and parents’ information when necessary to:
• Attend enquiries correctly;
• Provide educational services including the support of pupil learning, monitor and report on pupil progress;
• Make provision to the students of welfare and pastoral care services;
• Meet the educational, social, physical and emotional requirements of the student;
• Manage the Genius Kid Summer Camp;
• To enable parents/guardians to be contacted in the case of emergency or in the case of school closure, or to inform parents of their child’s educational progress or about GK events, etc.
• With the aim to celebrate school’s achievements and to keep a record of the history of the school, Genius Kid may take photographs and recorded images of students to be shared in, e.g., yearbooks, school website, etc, always based on informed consent from parents or students of legal age;
• To send commercial communications if previously requested and authorised by the data subject. You will be able to unsubscribe from the receipt of such commercial communications by clicking in the “unsubscribe” section found in all these kinds of e-mails sent by the School. In the case of a CV received through our website, we will process the information provided under the Legislative Decree 101/2018 and art.

5. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

As a School, we may be lawfully required to share personal information with relevant authorities or third parties as permitted on statutory grounds, to comply with legal obligations or based on a specific consent given by the individual concerned. We will ensure that, where relevant, contractual safeguards are implemented to ensure the protection of your personal data when disclosing your personal data to a third party.
For example, we will enter into data processing agreements with relevant parties (providing for restrictions on the use of your personal data and obligations with respect to the protection and security of your personal data). The parties to whom we may disclose your personal data as above referred may be located in countries outside Italy, including countries which may offer a lower level of data protection.
In such cases, we will implement appropriate measures to ensure adequate protection of your personal data in accordance with applicable data protection legislation. Your personal data shall be neither rented nor sold to third parties.

6. CONSERVATION OF DATA

Personal information will only be retained for the period required to fulfil the purpose for which it was collected unless for a longer time for public interest archiving, scientific or historical research, or statistical purposes. Once the personal information is no longer required or permitted to be retained for legal or business purposes, or you have withdrawn your consent, it will be destroyed or made anonymous.

7. YOUR RIGHTS

Under the data protection regulations, you have rights regarding the processing of your personal data. These rights are, however, subject to certain exemptions and limitations. You have the right to:
• Be informed, at the time when personal data is collected, about the data processing.

• Access the information we process and how we process it as well as to obtain a copy of the personal data considering the legal limitations and exceptions;
• Ask for the erasure of the personal data we hold about you without undue delay considering the legal limitations and exceptions;
• Obtain the rectification of your personal data providing a supplementary statement;
• Obtain restriction of processing of your personal data when it is inaccurate, illegal, unnecessary or not verified, considering the legal limitations and exceptions;
• Obtain data portability of your personal information in a structured, commonly used, and machine-readable format. This allows the right to transmit that data to another controller without hindrance from the controller to which the personal data has been provided;
• Object to processing for direct marketing purposes;
• Withdraw consent at any time and freely to the processing of your personal data. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
You can send a written request, along with a copy of your ID card, to the Data Protection Officer’s email address info@geniuskiditaly.com

8. CONSENT

You will have the right and possibility to withdraw your consent for any specific purpose granted at any given time without prejudice of the legality of processing according to the consent given before withdrawal.

9. MINORS

Genius Kid will not collect and process, under any concept, data from individuals under 14 years old. Consent from parents or legal representatives will be always required.

10. STORING AND SECURING INFORMATION

Genius Kid shall use the appropriate technical and organisational measures to ensure the security, confidentiality, integrity, and privacy of the personal data, preventing from unauthorised access or unlawful processing as well as accidental loss, destruction or damage of the files.

11. COOKIES USED IN OUR WEBSITE

We use cookies to provide you with a better experience in the use of our website, as well as to store information about our visitors. This information is related to your session ID and are a way of monitoring single user access.
The Web server is allowed to remember some data concerning the user, such as his preferences for visiting the pages of this server, name and password, products that are more interesting, etc.

12. COMPLAINTS

If you are not satisfied with our response, you would like to discuss anything regarding this privacy notice, or you believe we are processing your personal data disregarding the data protection regulations in force, please contact our Data Protection Officer at: info@geniuskiditaly.com or you can address your request for mediation to the Italian data protection authority,
Garante per la Protezione dei Dati Personali, addressed at Piazza Venezia 11, IT-00187, Roma, with email: rpd@gpdp.it or visiting the website: https://www.garanteprivacy.it/home/diritti/come-agire-per-tutelare-i-tuoidati-personali although it is recommended that previous steps are taken to resolve the matter with the school before involving the authority.

14. PRIVACY NOTICE UPDATES

Genius Kid may need to update this privacy notice periodically, so we recommend that you review this information from time to time. This version was last updated in January 2024 ___________