Privacy policy

• The personal data you provide, or otherwise acquired in the course of our activity, may be processed using the Information System with or without the use of electronic means in compliance with the aforementioned legislation for the institutional purposes of our company, and in particular for:
  • executing a service or one or more contractually agreed operations
  • fulfilling obligations required by laws or regulations
  • protecting our rights in judicial proceedings Providing your data to our company is strictly functional to the execution of the contractual relationship. In relation to our data processing, you have the right to exercise your rights under Legislative Decree No. 196/03 as set out below. The data controller is Andrea Sergon, Owner of Meta Caraibica. They will be stored at via Rapicio 5, Trieste (TS). The data will be retained for the time prescribed by law. The processing of the data provided or otherwise acquired in the course of our activity may also be carried out by entities who are authorized to access your personal data by law or secondary/community regulations

Legislative Decree No. 196 of June 30, 2003, EU Regulation 2016/679 GDPR (General Data Protection Regulation) rights of the data subject:

In relation to the processing of personal data, the data subject has the right: a) to know, through free access to the register referred to in Article 31, paragraph 1, letter a), the existence of data processing that may concern him or her; b) to be informed as indicated in Article 7, paragraph 4, letters a), b), and h); c) to obtain, from the data controller or the data processor, without delay:

1. confirmation of the existence or otherwise of personal data concerning him or her, even if not yet recorded, and the communication in an intelligible form of the same data and their origin, as well as the logic and purposes on which the processing is based; the request may be renewed, except for justified reasons, at intervals of no less than ninety days;
2. the deletion, transformation into anonymous form, or blocking of data processed in violation of the law, including data that does not need to be kept for the purposes for which the data were collected or subsequently processed;
3. the updating, rectification, or, if interested, the integration of data;
4. the certification that the operations mentioned in numbers 2) and 3) have been made known, including as regards their content, to those to whom the data has been communicated or disseminated, except in cases where compliance proves impossible or involves a manifestly disproportionate use of means compared to the right protected; d) to object, in whole or in part, for legitimate reasons, to the processing of personal data concerning him or her, even if relevant to the purpose of the collection; e) to object, in whole or in part, to the processing of personal data concerning him or her for the purpose of commercial information or sending advertising material or direct selling or for conducting market research or interactive commercial communication and to be informed by the data controller, no later than the moment when the data is communicated or disseminated, of the possibility of exercising this right free of charge. For each request referred to in paragraph 1, letter c), number 1), the data subject may be asked, if the existence of data concerning him or her is not confirmed, to contribute to the costs, not exceeding the actual costs incurred, according to the procedures and within the limits established by the regulation referred to in Article 33, paragraph 3. The rights referred to in paragraph 1 relating to personal data concerning deceased persons may be exercised by anyone interested. In exercising the rights referred to in paragraph 1, the data subject may provide, in writing, power of attorney or delegation to individuals or associations. The provisions on professional secrecy of journalists, limited to the source of the news, remain unchanged.

Methods of Data Processing

The Data Controller processes personal data of users by adopting appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of personal data.

Processing is carried out using IT and/or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, categories of persons involved in the organization’s activities (collaborators, legal professionals, system administrators) or external subjects (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communication agencies, platforms for managing newsletters) may have access to the data, also appointed, if necessary, as Data Processors by the Data Controller.

Purpose of Data Processing

User Data is collected to allow the Data Controller to provide their services, as well as for the following purposes: Statistics, Advertising, Hosting and backend infrastructure, Interaction with social networks and external platforms, and Displaying content from external platforms.

The types of Personal Data used for each purpose are indicated in the specific sections of this document.

In particular, Browsing Data is processed exclusively for:

• the operational management of navigation;
• processing statistical data on access and consultation;
• managing data security.

Regarding Personal Data voluntarily provided by the User, they are processed for the following purposes, in addition to those indicated herein:

• processing anonymous and aggregated usage statistics;
• protecting or defending rights in court;
• fulfilling obligations required by current laws or regulations, including accounting and tax matters;
• meeting the specific purposes for which the data was provided by the User (e.g., providing a service, responding to specific queries sent via contact form, requests for discount coupons, information requests, etc.);
• sending newsletters to the User, with the latter’s consent;
• sending course departure notifications if the User expressed interest in a course but could not attend;
• User participation in initiatives, in compliance with the rules governing such activities or any regulations published on the site.

For the purpose of pursuing the above-described processing purposes, Meta Caraibica uses the following services, listed by processing purpose.

Hosting and back-end infrastructure These types of services have the function of hosting data and files that allow Meta Caraibica to function, distribute them, and provide an infrastructure ready to use for delivering specific functionalities of Meta Caraibica. Some of these services operate through geographically dispersed servers, making it difficult to determine the exact location where Personal Data is stored.

Interaction with social networks and external platforms These types of services allow for interactions with social networks, or other external platforms, directly from the pages of Meta Caraibica. The interactions and information acquired by Meta Caraibica are, in any case, subject to the User’s privacy settings for each social network.

In the case that a social network interaction service is installed, it is possible that even if Users do not use the service, it collects traffic data related to the pages where it is installed. “Like” button and social widgets of Facebook (Facebook, Inc.) The “Like” button and social widgets of Facebook are services for interaction with the social network Facebook, provided by Facebook, Inc. Personal Data collected: Cookies and Usage Data. Place of processing: USA – Privacy Policy

Advertising These types of services allow the use of User Data for commercial communication purposes in various advertising forms, such as banners, videos, etc. This does not mean that all Personal Data is used for this purpose. Data and conditions of use are indicated below.

Statistics The services contained in this section allow the Data Controller to monitor and analyze traffic data. Meta Caraibica uses this service to conduct aggregate analyses on its Users in an anonymous form, thereby improving the performance of the Meta Caraibica site. All statistics services used by Meta Caraibica through an integration that anonymizes the User’s IP address.

Google Analytics with anonymized IP (Google, Inc.) Google Analytics is a free statistics service provided by Google Inc.

Personal Data collected: Cookies and Usage Data. Data storage duration: 26 months. Place of processing: USA – Privacy Policy – Opt Out.

Displaying content from external platforms These types of services allow you to view content hosted on external platforms directly from the pages of Meta Caraibica and interact with them. In the case that a service of this type is installed, it is possible that even if Users do not use the service, it collects traffic data related to the pages where it is installed. YouTube Video Widget (Google Inc.) YouTube is a content viewing service managed by Google Inc. that allows Meta Caraibica to integrate such content within its pages. Personal Data collected: Cookies and Usage Data. Place of processing: USA – Privacy Policy Google Maps Widget (Google Inc.) Google Maps is a map viewing service managed by Google Inc. that allows Meta Caraibica to integrate such content within its pages. Personal Data collected: Cookies and Usage Data. Place of processing: USA – Privacy Policy

Additional information on Personal Data

Social network sharing features

On Meta Caraibica, the sharing feature through social networks is available. This feature allows Users to send invitations, news, or other types of communications and/or share content or actions undertaken by the User (e.g., sharing comments, etc.) on the Site in use, through external social networks (currently only sharing towards Facebook is active). In such cases, the User must be aware that any Personal Data provided may also be processed by third-party controllers of such social networks according to their privacy policies and without the ability for the Controller to exercise any control or influence over such subsequent processing methods.

The User is invited to read and accept the privacy policies of such third parties available for consultation at the links provided in the section dedicated to each of these services within this document.

Rights of the data subject

The User, as a data subject, may contact the Controller at any time, without any formalities, to enforce their rights, as provided by Article 7 of the Privacy Code, which for the convenience of the User is reproduced below in its entirety:

1. The data subject has the right to obtain confirmation of the existence or not of personal data concerning them, even if not yet registered, and their communication in an intelligible form.
2. The data subject has the right to obtain an indication of:
   • the origin of personal data;
   • the purposes and methods of processing;
   • the logic applied in case of processing carried out with the aid of electronic instruments;
   • the identifying details of the controller, the processors, and the designated representative according to Article 5, paragraph 2 (of the Privacy Code);
   • the subjects or categories of subjects to whom personal data may be communicated or who may become aware of them as designated representatives in the State’s territory, as processors or persons in charge.
3. The data subject has the right to obtain:
   • the updating, rectification, or, when interested, the integration of data;
   • the deletion, transformation into anonymous form, or blocking of data processed in violation of the law, including those that do not need to be kept for the purposes for which the data was collected or subsequently processed;
   • the certification that the operations mentioned in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data was communicated or disseminated, except in cases where this proves impossible or involves a manifestly disproportionate use of means compared to the protected right.
4. The data subject has the right to object, in whole or in part:
   • for legitimate reasons, to the processing of personal data concerning them, even if relevant to the purpose of the collection;
   • to the processing of personal data concerning them for the purpose of sending advertising material, direct selling, or conducting market research or commercial communication.

Cookies

To make this site work properly, sometimes we place small data files called “cookies” on your device. Most large websites do this too.

What are cookies? A cookie is a small text file that websites save on your computer or mobile device while you visit them. Thanks to cookies, the site remembers your actions and preferences (e.g., login, language, font sizes, and other display settings) so you don’t have to re-enter them whenever you return to the site or browse from one page to another.

How do we use cookies? Please refer to the dedicated cookie information page of our site by clicking on this link: Cookie Information

Data deletion possibility They can be removed at any time; just click here: Data Deletion

Stored data collection

The data collected will remain in our databases, then will be archived within and can be removed at any time; just click here: Data Deletion

In your browser, you can set privacy preferences so as not to store cookies, delete them after each visit or each time you close the browser, or even accept only metacaraibica.it cookies and not third-party ones; there is also a service, Your Online Choices, that shows you which cookies are installed by various services and how you can disable them one by one.

Contact pages

On these pages (like this one: Contact Page), there is a form where you enter your own data and required information. The data is used immediately to be contacted back by an administrator. Such data is not then used in any other way and is not transferred to anyone else for any reason.

However, it is possible to, through a request from the page Data Deletion, delete any trace of your data (for example, from the mailbox that stores sent and received emails).

“I’d like to try” request pages

In the “I’d like to try” type pages (like this one: I’d like to try Salsa and Bachata), the User enters their contact information to try one of the courses offered by the school.

Obviously, the data entered is used to recontact the User as soon as an edition of the course for which interest was expressed is started, and references such as time, location, and what to bring are sent. In case they are unable to attend the first starting edition of the course, Meta Caraibica can contact the User when other editions are scheduled.

The user’s data is sent via email to the site admin and then manually copied into a table on a password-protected Google Drive account, to be later transferred into the appropriate contact list in third-party software, MailChimp. Apart from the first reply received (sent through a normal mail program), subsequent emails are then sent through MailChimp. The data is not transferred to anyone else for any reason.

Every email received through MailChimp contains a direct link to unsubscribe from the database. Users who unsubscribe from the MailChimp database are subsequently deleted from other lists as well.

MailChimp

You can read MailChimp’s privacy policy and how they comply with GDPR requests here: MailChimp’s Data Management.

MailChimp provides information on who opens newsletters and clicks on links; this information is used to understand if people are still interested in the courses by opening the emails or not. For your information:

The data controller is the school director Andrea Sergon, via Biasoletto 8, Trieste (TS) info@metacaraibica.it; we do not share your email address with anyone else, for any reason; you can stop receiving email updates at any time via the link at the bottom of each message.

Discount code request pages

On these pages (like this one: Discount Code Redirection), the User can request a Discount Code via the form included in it. The code presented at the lesson entitles to a discount (usually 25%) on the course for which it was requested.

The data entered in the form is automatically saved in a mysql database within the same hosting on which the website operates; then manually extracted and entered into a password-protected Google Drive account table; finally, the data is transferred to a contact list in the external program MailChimp. The data is not shared with anyone else for any reason.

The first reply email is automatically sent by the system, which sends the essential course information for which the discount was requested. Other warning emails for the same course may follow (time changes, rescheduling trial lessons, etc.). Subsequently, if you did not manage to attend the mentioned course, emails will be sent at each main reedition of the same course for which the discount was requested (at least until the school director deems the requested discount valid). These emails are sent 3 to 5 times a year. At the bottom of each email, there is a link to delete your data, and a link to manage the email update service (which you can also just temporarily suspend); these settings are managed by MailChimp software.

Phone contact

Some contact or request forms include an optional phone contact field. At the moment, such contact is not used unless explicitly requested by the User (such as “please call me for information about your courses”). The data is still saved as indicated in the previous points, depending on the page of origin, and can be deleted along with all other data upon the User’s request.

Browsing the site

Like millions of other site owners, we are curious to know how many people visit the site, how many pages are opened, where readers come from, and similar information.

To get these data, we use Google Analytics, which is a great free service provided by Google; Google Analytics is set so that your IP address is anonymized, by zeroing out the last part of the address itself.

The information generated by the Google Analytics cookie about your use of the website (including the first part of your IP address) is transmitted to Google and stored on its servers in the United States. Google uses this information to track and examine the use of the site by visitors and provide these data, in aggregated form and never linked to your identity, through Analytics reports and its other information services (e.g., Google Trends).

Google may transfer this information to third parties if required by law or in the case of subjects who process this information on its behalf; the information on Google Analytics privacy and data use is here.

We use analytics data to understand better what you like and don’t like, and to improve the content of the site.

If you don’t want to be “tracked” by Google Analytics, you can download the add-on that works with the most popular browsers and is distributed by Google.

That’s all for Meta Caraibica’s privacy, I hope it was of interest to you. If you think any piece of information is missing or we overlooked something, do not hesitate to contact us for further clarifications.