This privacy notice is provided by H-International School S.r.l., with its registered office at Via Olivetti 1, 31056 – Roncade (TV), Tax Code and VAT Number 03888620261 (hereinafter “H-IS”), to describe the processing of personal data of visitors and users (collectively, “Users”) of the website https://courses.h-farm.com (the “Website”) owned by H-IS, as well as - in case of enrollment in the services offered by H-IS - the processing of personal data through the App Summer Academy (hereinafter “App”). The information contained in this document is provided in compliance with EU Regulation 2016/679 – GDPR, Legislative Decree 196/2003 as amended, and the measures issued by the competent Authorities regarding the personal data protection.

H-IS may modify this privacy notice to adapt it to future expansions or future changes of the Site, the App, and/or the services offered. In the event of substantial modifications, H-IS will publish a notice on the Site and/or will send a notification by e-mail to notify the variations and to collect possible request to exercise the rights recognised by the legislation on the protection of personal data. 

1. DATA CONTROLLER 

The controller of the personal data of Users collected through the Website is H-IS. The controller can be contacted at the following addresses: summeracademy@h-farm.com or at the H-IS registered office at Via Olivetti 1, Roncade - 31056 (TV).

2. DATA COLLECTED AND PURPOSE OF PROCESSING

2.1 Browsing data 

Each time the Site is accessed, the systems automatically record and analyse the access data (e.g. IP address of the provider, information on the used browser, pages visited, date, time, and duration of each visit). The information is automatically collected by the Site and does not require any action by the User. 

With regard to the processing of browsing data, please refer to the Site's cookie policy, available at the following link https://courses.h-farm.com/cookies/.

2.2 Data communicated by Users 

By filling in the "Contact us" forms on the Site, or by sending a request to H-IS through the contact information indicated on the Site, Users communicate to H-IS some personal data such as, for example: name, surname, e-mail address, phone number (optional), country of origin (optional), age and any other information voluntarily inserted by the User in the message box. 

Data that are absolutely necessary in order to perform the activities requested from time to time are marked with an asterisk. 

Users are requested not to communicate personal data of third parties to H-IS, unless it is necessary (for example, in the event that the User is a parent requesting more information on courses/school/labs in the interest of their minor child): in this case, we remind you that it is the User's responsibility to fulfil the legal requirements concerning the protection of personal data and, in particular, to inform third parties of the communication and to obtain their consent, if necessary. 

2.3 Data required for the purchase of courses/school/lab. 

The Site, in the event of the purchase of a course, school and/or workshop as well as in the case of transmission of specific requests from Users, requires the latter to communicate specific personal data of the purchaser, such as: 

1. first name, surname, e-mail, phone number, residential address, date of birth and social security number of the User making the purchase (the "Billing Data");
2. first name, surname, gender, age (or age bracket) and date of birth of the course/school/lab participant (the "Participant Data");
3. in addition, H-IS, where necessary, also requests the disclosure of data relating to the health of the course/school/lab participant, and, in particular, information regarding dietary and/or medical needs and/or the existence of certified educational needs (e.g. dyslexia) or other information useful/needed to make the participant’s stay as pleasant as possible (the "Sensitive Data").

Data, if marked with an asterisk, are necessary in order to finalise the User's request for enrolment in the course/school/lab. 

We recommend that Users only communicate Data that are up-to-date, relevant, and not exceeding the specific processing’s purposes. 

Any unnecessary Data will be immediately deleted or anonymised. 

The browsing data (par. 2.1), the data provided by Users (par. 2.2), and the data required for the purchase of courses/schools/labs (par. 2.3) are collectively referred to below as “Data.”

3. PURPOSE OF PROCESSING AND RECIPIENTS OF DATA 

The Data will be processed by H-IS, in strict compliance with applicable legislation and the guidance of the Data Protection Authority, for the following purposes.

3.1 Navigation data   

Navigation data will be used:

1. in order to monitor the proper functioning of the Site;
2. in an anonymous and aggregate form, for statistical purposes related to understanding how Users use the Site, to improve the ease of access and increase its attractiveness,
3. as well as to detect technical problems as soon as possible. 

Such processing has its legal basis in the legitimate interest of H-IS in improving its digital services, especially in relation to the use of the Site. 

3.2 Responding to contact requests 

The Data provided by sending a request to H-IS by filling in the appropriate form in the "Contact Us" section of the Site will be processed to respond to requests for information on courses/schools/labs transmitted by the User and, if necessary, to provide assistance to H-IS Users. 

These data, if marked with an asterisk, are necessary in order to follow up and answer requests from Users. 

The processing, therefore, finds its legal basis in the need to implement pre-contractual measures at the request of the data subject.

3.3 Purchase and attendance of courses 

The Billing Data collected during the checkout on the selected payment gateway (see par. 4, letter A of the Terms and Conditions of Use of the H-IS service) will be processed to complete the purchase of the H-IS course/school/lab and to enable the payment of the fees required from the User.

For each provider, please refer to the Terms and Conditions of Use of the respective platform and the information regarding the processing of personal data by each provider.

The Participant Data collected through the completion of the required fields during the purchase of courses/schools/labs on the Website will be processed upon acceptance of the Terms and Conditions of Use of the H-IS service and the Summer Academy 2025 Camper Code of Conduct. Additional information necessary to enable the best use of the service by the participant will be collected afterwards to finalize the enrollment and contracting phase on the App.

The provision of such data is necessary to complete the purchase of courses/schools/labs, therefore, in the event of refusal or failure to provide the requested data, H-IS will be unable to process the User’s requests and provide the requested service.

This processing has its legal basis in the need to execute a contract to which the data subject is a party (the contract signed between H-IS and the User with the acceptance of the Terms and Conditions relating to participation in the course/school/lab), pre-contractual measures taken at the request of the data subject and in compliance with legal obligations. 

The Sensitive Data collected through the registration form is processed solely to enable the participant to attend the course/school/lab effectively and to allow H-IS to provide appropriate learning support as well as any related services (e.g., canteen) while ensuring the participant’s health is respected, based on the specific needs reported.

The Sensitive Data, along with the Purchase Data and Participant Data, will then be stored on the App; the App is managed by Zoho company and is owned by the Zoho Group which includes all the companies listed herein (“Zoho”). The Data will be processed and stored on the App, subject to acceptance of Zoho’s privacy policy, to allow H-IS to manage the participant’s dietary, medical, and educational needs, as well as to upload other relevant documents, such as, for example, medical certificates or specific dietary requirements.

For information regarding the use of cookies and the processing of personal data through the App, please refer to the App’s privacy policy (Zoho’s privacy policy).

The Sensitive Data collected through the App has its legal basis in the need to protect a vital interest of the participant, as well as in the explicit consent of the major participant, or of the exercising parental responsibility in the case of a minor participant, at the time of purchase of the course and/or workshop. 

3.4 Receipt of newsletters 

The Data provided in order to subscribe to the H-IS newsletter, by filling in the appropriate form in the "Subscribe to our newsletter" section will be processed, subject to the User’s consent, to allow the User to benefit from the newsletter service and, therefore, to send the newsletter with commercial and promotional contents (which will be transmitted by e-mail) concerning the activity of H-IS and its most important news, courses/schools/labs offered by  the latter, as well as fairs and events in which H-IS will participate. 

Data communication occurs on a voluntary basis: any refusal will result in the impossibility for H-IS to send the newsletter to the User but will not affect the navigation on the Site and/or the purchase of courses/school/lab. The processing of Data for sending newsletters with commercial content has its legal basis in the consent of the interested party (User). 

Users may revoke their consent at any time and cancel their subscription to the newsletter service by following the procedure indicated in each newsletter or by sending a specific communication to H-IS, at the address indicated in article 6 below, expressing their intention to unsubscribe from the newsletter service and to cancel the Data held by H-IS. 

4. DISCLOSURE AND RECIPIENTS OF DATA

The Data may be accessed and disclosed, for specific purposes, to the following categories of subjects:

1. employees and/or collaborators specifically designated as authorized personnel for data processing (e.g., administrative, accounting, and IT staff);
2. educators and other collaborators working for H-IS who are directly involved in the organization and management of the courses/schools/labs to provide appropriate support to participants, respecting their educational and personal needs;
3. for newsletter distribution, if consent is provided, and to enable access to and use of the features of the H-IS App, by the company Zoho Corporation B.V., headquartered at Beneluxlaan 4B, 3527 HT UTRECHT, The Netherlands, which includes all the companies listed here (“Zoho Group”). Zoho operates as a data processor under Article 28 GDPR, with its employees and collaborators appropriately trained to process personal data in compliance with applicable regulations;
4. regarding Sensitive Data, public and private entities involved in organizational and management activities and/or providers of ancillary services necessary to meet the specific needs of participants (e.g., dietary requirements).

These subjects —  except for the persons referred to in subparagraph A who act, on behalf of the owner, as data processors —will process the Data either as independent data controllers, or as data processors; In the latter case, these subjects will act by virtue of specific written assignment given to them by H-IS.

The complete list of Data recipients is kept at the H-IS headquarters and is available upon request, which can be submitted to the contacts provided in Section 6 below.

5. DATA PROCESSING METHODS AND RETENTION PERIODS

The Data will be processed using manual and electronic tools, in compliance with the technical, IT, and organizational security measures adopted by H-IS.

Browsing Data will not persist for more than 7 (seven) days and will be deleted immediately after their aggregation (except in cases where judicial authorities require data for crime investigation purposes).

Billing Data will be stored on Zoho and processed for the period necessary to comply with tax, accounting, and regulatory obligations related to the sale of H-IS courses/schools/labs, which is 10 years from the date of collection by H-IS.

Participant Data and Sensitive Data will be stored on Zoho and processed for the duration of the course/school/lab and for 24 months following the conclusion of the educational/training activities for archival purposes. The account will be deactivated if no access is made for a period exceeding 36 months from the date of the last purchase.

Data collected to respond to User requests and for newsletter distribution will be stored and processed for up to 24 months from the receipt of the last contact request and, in the case the User has consented to receive the newsletter, from the provision of such consent.

6. USER RIGHTS AND CONTACT DETAILS 

The User may, at any time and to the limits to which the rights are applicable: 

1. obtain access to their personal data; 
2. request the rectification, deletion or restriction of the processing of personal data; 
3. where applicable, receive in a structured, commonly used and machine-readable format the personal data concerning him/her that he/she has provided to H-IS, as well as request that such data be transmitted to another data controller (right to data portability); 
4. where applicable, withdraw consent, at any time and without prejudice to the lawfulness of the processing based on the consent previously given; 
5. file a complaint with the Data Protection Authority, or appeal to the competent judicial authority. 

Requests to exercise the above rights should be sent to one of the following addresses: 

• via e-mail, to: summeracademy@h-farm.com; 
• via registered letter with return receipt, to H-International School S.r.l., 31056 - Roncade (TV), Via Olivetti 1. 

Requests concerning the recipients of the Data, as well as requests for clarification of this information notice, may also be addressed to the same addresses.

7. LINKS TO OTHER WEBSITES 

This information on the processing of personal data is provided exclusively in relation to the Data collected through the Site and with reference to the purposes identified in point 3, and not also for any other websites consulted and/or consultable through links and/or widgets (e.g. social networks): these additional websites will process the Data as autonomous controllers and in accordance with their respective disclosures, the consultation of which by Users is expressly recommended.