Privacy Notice

INFORMATION NOTICE FOR THE PROCESSING OF PERSONAL DATA
pursuant to EU Regulation no. 2016/679 (“GDPR”), Articles 13 and 14 for the use of the Docebo on learn platform

Dear User,
Benetton Group Srl (hereinafter the “Data Controller” and/or “the Writer”), pursuant to European Regulation no. 2016/679 (“GDPR”) and for the effects of Law, intends to inform you of the following methods of processing of Your personal data in relation to the training service of the Docebo platform.

DATA CONTROLLER
The Data Controller (pursuant to EU Reg. no. 2016/679, Articles 24 et seq.) is Benetton Group Srl (C.F./VAT no. 03490770264) with registered office in Via Villa Minelli, 1 – 31050 Ponzano Veneto (TV) and operational headquarters in Via della Cartiera, 1 – 31020 Castrette di Villorba (TV); telephone: +39 0422 519111 - fax: +39 0422 969501.


DATA PROTECTION OFFICER (DPO/RPD)
The Controller has appointed the Data Protection Officer (pursuant to EU Reg. no. 2016/679, Articles 37 et seq.), available at the e-mail address: rpd@benetton.it

CATEGORY OF PERSONAL DATA PROCESSED
The subject of the processing (paper/electronic/digital) of personal data by

Docebo includes:
common personal data (pursuant to EU Reg. no. 2016/679, art. 6)

✓ User identification: name, surname, e-mail, password (in case of non-use of the SSO system) and, for the Employees of the Writer registered in the Company Systems, the data relating to the employment relationship (classification, company, company office, etc.);

✓ User tracking (visible by the respective Managers): assignment of courses and completion percentages;

✓ forum comments: in case of activation of the forum mode in the assigned course;

sources of the aforementioned data

✓ User Interested in training;

✓ Information Systems of Benetton Group Srl.

PURPOSE OF PROCESSING
Your personal data (acquired beforehand/during/at the end of the employment relationship) are processed exclusively for the following purposes:

• to provide Interested Users with a training service through the Docebo platform;

• to make company contents detected available in sharing, also deferred (example: training courses, company training material, etc.).

LEGAL BASIS OF PROCESSING
The processing of Your personal data is considered lawful pursuant to EU Reg. no. 2016/679, art. 6, par. 1, lett. b), as it is necessary for the contractual execution of the provision of the training service through the Docebo platform (with relative tracking of performance/completion of the assigned courses).

NATURE OF THE PROVISION OF DATA
The provision of Your personal data constitutes the necessary requirement for the use of the training tool; failure to provide them therefore determines the impossibility of using the Docebo platform.

METHODS AND TIMES OF DATA RETENTION
Your personal data are processed in compliance with the fundamental principles that regulate the matter (cf. EU Reg. no. 2016/679, Articles 5 and 6) and, consequently, may be
• acquired by manual (paper) and/or IT tools with the technical-organizational measures compliant with the purposes indicated for collection (example: historicization for company reporting);
• retained for the entire duration of Your employment relationship with the Writer and also subsequently (within the limits of the applicable regulatory provisions, where necessary): in any case, data retention is specified for 24 months from the date of termination of the relationship.

COMMUNICATION OF DATA TO THIRD PARTIES
Your personal data may be communicated
• to the company Personnel of the Data Controller, authorized by specific act in relation to the tasks performed and operationally instructed in this regard);
• to external Subjects acting as independent Data Controllers (example: Authorities and Supervisory and Control Bodies, public and private Subjects legitimized in the request);
• to Data Processors who carry out, on behalf of the Controller, specific activities (example: Suppliers of IT applications).

TRANSFER OF DATA TO THIRD COUNTRIES
Your personal data will not normally be subject to transfer either to Third Countries or to International Organizations. However, the Controller makes use of some information services (hosting and/or assistance in the maintenance of the Docebo platform) outside the EU; therefore, Your personal data may be transferred outside the European Union in application of European Regulation no. 2016/679 (it is specified, in such circumstance, that: the destination Countries are equipped with privacy legislation that the European Commission considers protective for the Interested parties, the destination Companies are bound by rules approved by the competent Supervisory Authority, the Subjects operating in the U.S.A. adhere to the Personal Data Processing Agreement, the Subjects who do not comply with the previous conditions have signed the contractual clauses – so-called standards – prepared by the European Commission to protect the Interested parties).

RIGHTS OF THE DATA SUBJECT
As a Data Subject in the processing of personal data, you may exercise, at any time, the rights recognized by European Regulation no. 2016/679, art. 13 par. 2 lett. b) (that is: access to personal data and rectification or erasure thereof or restriction of processing of personal data concerning him/her or to object to their processing, in addition to the right to data portability) within the limits of the relative procedures expressed through:

• written request to be sent to the e-mail address infoprivacy@benetton.it
• complaint to a Supervisory Authority