A. Responsible data processing body

The responsible body for the processing of personal data within the scope of this website and in accordance with the provisions of the General Data Protection Regulation (GDPR) is:

NORTHSUN EDUCATION GROUP S.R.L.
Viale della Carriera 109,
63900 Fermo, Italy
Tel: +39 0734217365
Email: info@northsun.education  

Our data protection officer is:

Steen Kirkby , email: info@northsun.education

In this data protection declaration, we would like to inform you about the extent to which your personal data (hereinafter referred to as "Data") is processed.

B. Data processing

We process Data for the operation of our website. The processing of this Data also includes the disclosure of the Data by transferring it to other companies.

The transfer of data to the USA is governed by an adequacy decision of the European Commission, i.e. the EU-US Privacy Shield. In this decision, the Commission attests that the guarantees applicable to the transfer of data to the USA on the basis of the EU-US Privacy Shield correspond to the data protection standards in the EU. Where we transfer Data to the USA, we shall specify the participation of our service providers in the EU-US Privacy Shield.

The Data affected in such cases, the processing purposes, legal bases, recipients and transfers to third countries are listed below:

a) Log file

We record your visit to our webpages in a log file. In doing so, the following Data is processed: the name of each accessed webpage, the date and time of access, the data volume transferred, the browser type and version, the operating system used by you, the referrer URL (the previously visited website), your IP address and the access requesting provider. This is necessary in order to ensure website security. We process the Data accordingly on the basis of our legitimate interests pursuant to Art. 6 (1) f) GDPR. The log file will be deleted after the expiration of seven days, unless it is required for the clarification of or as evidence for specific infringements which have emerged during the retention period.

b) Hosting

Within the scope of web hosting, all Data processed in connection with the operation of this website will be stored. This is necessary to ensure the operation of the website. We process the Data accordingly on the basis of our legitimate interests pursuant to Art. 6 (1) f) GDPR. We use the services of web hosting service providers, to whom we transfer the aforementioned data, for the operation of our website.

c) How to contact us

When contacting us, your Data (name, contact details, to the extent provided by you) and your message will be used solely for the purpose of the processing and handling of your request. The Data will be used for the processing of your request on the basis of Art. 6 (1) b) GDPR or Art. 6 (1) f) GDPR. For processing your contact requests, we work with service providers, to whom we transfer the aforementioned Data.

d) Newsletter

In order to be able to regularly provide you with information on our company and our services, you can subscribe to our newsletter. When subscribing to our newsletter, we will process the Data entered by you (email address and other additional voluntarily provided data).

To do this, we require your consent, as follows:

"[ ] I would like to subscribe to the newsletter of NORTHSUN EDUCATION GROUP S.R.L. I can withdraw my consent at any time by sending an email to info@northsun.education or by using the unsubscribe link provided in the newsletter."

Based on your consent, our newsletter is then sent to you pursuant to Art. 6 (1) a) GDPR upon registration. Subscriptions to our newsletter are subject to the "double-opt-in process". In order to prevent abuse, we will send you an email upon receipt of your registration, requesting you to confirm your subscription. In order to be able to document the subscription process in accordance with the legal requirements, your subscription will be logged. Specifically, this means we will store the time of receipt of your registration and your subscription confirmation as well as your IP address. The newsletter is sent on our behalf by service providers, to whom we transfer the above mentioned data.

e) Customer account

When opening a customer account, you automatically consent to the storage of your contact details (name, address, email address, bank details) and your usage data (user name and password). In doing so, we are able to identify you as a customer and you are able to manage your orders. In this context, we will obtain the following consent from you:

"[ ] I would like to create a customer account. Please save my data for this purpose. I can withdraw my consent at any time by sending an email to info@northsun.education."

Based on this consent, your Data will be processed pursuant to Art. 6 (1) a) GDPR.

f) Purchase transaction

We process your order data for the fulfillment of the purchase contract. The Data is processed on the basis of Art. 6 (1) b) GDPR.

We will transfer your address data to the company assigned with dispatching the goods. Where required for the fulfillment of the contract, we will also forward your email address or your telephone number to agree a delivery date (advice note) with the dispatcher.

We will transfer your transaction data (name, order date, payment method, date of dispatch and/or receipt, payment amount and recipient and, where applicable, bank details or credit card details) to the payment services provider entrusted with processing the payment.

g) Prize draws

Your Data (name and contact details and company name and role in the event of participation on behalf of a company) must be disclosed if you want to take part in our prize draws and quizzes. To process the prize draw, we work together with service providers, to whom we transfer the specified Data. The Data is processed on the basis of your consent given pursuant to Art. 6 (1) a) GDPR or on the basis of our legitimate interests in the marketing of our services pursuant to Art. 6 (1) f) GDPR.

h) Career section

When contacting us in order to send us your job application, for example via our ReachMee platform, your Data (e.g. name, email address, preferred workplace, if provided), your message and the submitted application documents will be used solely for the purpose of processing and handling your job application request. Here, the primary legal basis for processing your data is Section 26 GDPR. According to this, it is permitted to process Data that is required in connection with a decision on or the conclusion of an employment relationship.

If the Data are still required after the completion of the application procedure, for instance for prosecution purposes, we are permitted to process the Data for the protection of our legitimate interests pursuant to Art. 6 (1) f) GDPR, i.e. for the assertion or defence of claims.

i) Salesforce

For purposes of providing efficient customer support, we use the Salesforce customer management system. We use Salesforce to collect, link and evaluate form data (contact details, customer account, order data, etc.) processed on our website. This data is transferred to Salesforce’s servers in the course of processing. Processing in this context is performed on the basis of our compelling interest in improving our customer service in accordance with Art. 6(1)(f) GDPR. Salesforce is a cloud-based service. This means that services are provided via the Internet using servers that are distributed worldwide. Accordingly, it is possible that your data will be transferred to non-EU countries.
Salesforce ensures appropriate levels of data protection for transfers to third countries by means of binding corporate rules; in the case of transfers to the United States, this is accomplished through participation in the EU-US privacy shield, and through EU standard contract clauses.
Salesforce’s certification in the EU-US-Privacy-Shield can be found here:
https://www.privacyshield.gov/...
Further information on data privacy can be found at: https://www.salesforce.com/com... ‍

j) Website analysis and marketing

We use "cookies" to enable the use of certain functions. Cookies are small data packages which are installed on your device and exchanged with other service providers. Some of the cookies used by us will be deleted as soon as you close your browser ("session cookies"). Other cookies remain on your device and will enable us to identify your browser again on your next visit ("persistent cookies").

You can delete all cookies saved on your device and adjust the settings of your browser to prevent the installation of cookies.

In this case, you may have to readjust some settings each time you visit our website and accept the impairment of some of the provided functions. We use cookies in connection with the following functionality:

aa) Google Analytics

We use Google Analytics which is a service of Google LLC 1600 Amphitheatre Parkway Mountain View, CA 94043 USA. For the provision of its services, Google uses certain cookies. The information on your use of this website (including your IP address) generated by the cookies, is transferred to a Google server in the USA, where they are stored. We use the stored information to analyse your use of our website, to prepare reports on website activities for the website operator and to provide additional services in connection with the use of the website. We process the Data obtained with your consent pursuant to Art.6 (1) a) GDPR. Under no circumstances will Google link your IP address to other Google data.

We would like to point out that this website uses Google Analytics with the "anonymizeIp()" expansion. This means that IP addresses are truncated prior to being transferred to the USA. Direct personal identification in connection with the saved Data is therefore generally not possible. Only in exceptional cases, will a complete IP address be transferred to a server in the USA and truncated there.

You can object to the collection of your Data at any time with future effect by applying the Google Analytics deactivation add-on for browsers at http://tools.google.com/dlpage... or by clicking this opt-out link.
Please also note the information on the use of data by Google available in the Google Partner network at: http://www.google.com/intl/de/...
‍www.google.de/privacy_ads.html
Google is certified at:
‍https://www.privacyshield.gov/...
Additional information on data privacy is also available at: 
‍https://policies.google.com/pr...

cc) Facebook Remarketing/Retargeting: Facebook Custom Audiences (Pixel/Cookies)

We are using a so called tracking pixel on our website, which means that a cookie will be saved on your device when you visit certain pages. This cookies will be permanently saved on your device. We use those cookies in order to understand which advertisements or which third party websites redirected users onto our website. Those information are further utilized in order to optimize our website by analyzing the statistical data provided by the cookie. The data we receive is processed by us for the purposes of legitimate interest in the optimal marketing of our website content according to par.6 subpar 1 f) GDPR.
The cookies are not used for the personal identification of users. The data is anonymous and cannot be used to draw any conclusions about users’ identities. The information about your website usage gathered by this cookie (including your IP-address) will be stored and processed by a Facebook server in the United States.
Facebook is certified:
https://www.privacyshield.gov/...
More information regarding your data protection can be found here:
https://www.facebook.com/help/...
You can revoke your consent to the collection and storage of data at any time with effect for the future by clicking this opt-out link.

dd) Optimizely

In order to continuously improve our website, we use the Optimizely web analysis service on our website provided by Optimizely Inc. 631 Howard Street, Suite 100, San Francisco, CA 94105, USA (“Optimizely”). Optimizely uses cookies. They process information about the page accessed, the date and time of access, the referrer URL (the previously visited website), your browser, your use of the website and your IP address. Please note that Optimizely is used on our website with IP anonymisation. This shortens IP addresses before they are sent to a server in the USA. A direct personal reference in connection with the stored data is thus usually excluded. Only in exceptional cases is the full IP address transmitted to a server in the USA and shortened there. Processing in this manner is performed on the basis of our compelling legitimate interest in the optimum marketing of our website in accordance with Art. 6(1)(f) GDPR.
Optimizely is certified under:
https://www.privacyshield.gov/...
Further information on Optimizely’s Privacy Policy can be found at:
https://www.optimizely.com/de/...
You can object to having Optimizely process your data at any time with future effect by setting an opt-out cookie available via the following link: https://www.optimizely.com/opt. Please note that you must click on the link again if you delete the cookies in your browser.

ee) FullStory

We use the FullStory analysis service, provided by FullStory Inc., 120 Ottley Dr NE Ste 100, Atlanta, GA 30324, USA (“FullStory”), to analyse user behaviour on our website. FullStory records information about the behaviour of website visitors, enabling us to analyse this behaviour and to improve the user experience on our website. FullStory processes information such as clicks, mouse movements, input (with the exception of sensitive information), scroll movements, type of browser used, device type, IP address, pages visited and session duration.
FullStory uses cookies to collect this information. The information generated by the cookie about your use of the website is transmitted to, and stored by, FullStory on servers in the United States.
We process the data we receive when using FullStory in accordance with Art. 6(1)(f) GDPR on the basis of our compelling legitimate interest in the optimum marketing of our website.
You may object to data collection at any time with future effect by clicking the following opt-out link: https://www.fullstory.com/opto...
FullStory is certified under: https://www.privacyshield.gov/...
You can find further information about FullStory’s Privacy Policy at:
https://www.fullstory.com/lega...

C. Term of Data storage

We will only store personal Data for as long as is required for the purpose for which it is processed or until you withdraw your consent to the processing of such Data. Where statutory retention obligations must be complied with, the storage period for certain Data may be up to 10 years, regardless of the processing purposes.

D. Your rights as the affected party

a) Right to information

On request, we will provide you with information on the personal Data stored on you, at any time and free of charge.

b) Correction, deletion, processing restrictions (blocking), objection

If you no longer consent to the storage of your personal Data or if your personal Data is no longer accurate, we will initiate the deletion or blocking of your Data at your request or ensure that your Data is updated accordingly (to the extent possible in accordance with the applicable laws and regulations). The same applies if you want your Data only to be processed subject to certain restrictions in the future.

c) Data portability

On request, we will provide you with your Data in a common, structured and machine-readable format so that you can transfer the Data to another competent party, where required.

d) Right of appeal

You have a right of appeal to your competent supervisory authority:
(https://www.datainspektionen.se/)

e) Right to withdraw consent with future effect

You can withdraw your given consent at any time with future effect. The withdrawal of your consent will, however, in no way affect the lawfulness of the processing of your Data before the time of withdrawal.

f) Restrictions

Data which cannot be used to identify the affected party, for example which has been anonymised for analysis purposes, are not affected by the above rights. The provision of information, deletion, blocking, correction or transfer of Data to another company may be possible if you provide us with additional information which enable an identification by us.

g) Exercise of your rights as an affected party

If you have any questions regarding your personal Data, the provision of information, corrections, blocking, objections or the deletion of Data or want your Data to be transferred to another company, please contact info@northsun.education.

h) Salesforce

For purposes of providing efficient customer support, we use the Salesforce customer management system, represented in Germany by Salesforce.com Germany GmbH, Erika-Mann-Str., 63, 80636 Munich, Germany (“Salesforce”). We use Salesforce to collect, link and evaluate form data (contact details, customer account, order data, etc.) processed on our website. This data is transferred to Salesforce’s servers in the course of processing. Processing in this context is performed on the basis of our compelling interest in improving our customer service in accordance with Art. 6(1)(f) GDPR. Salesforce is a cloud-based service. This means that services are provided via the Internet using servers that are distributed worldwide. Accordingly, it is possible that your data will be transferred to non-EU countries.
Salesforce ensures appropriate levels of data protection for transfers to third countries by means of binding corporate rules; in the case of transfers to the United States, this is accomplished through participation in the EU-US privacy shield, and through EU standard contract clauses.
Salesforce’s certification in the EU-US-Privacy-Shield can be found here:
https://www.privacyshield.gov/...
Further information on data privacy can be found at: https://www.salesforce.com/com...

i. Facebook Remarketing/Retargeting: Facebook Custom Audiences (Pixel/Cookies)

We are using a so called tracking pixel on our website, which means that a cookie will be saved on your device when you visit certain pages. This cookies will be permanently saved on your device. We use those cookies in order to understand which advertisements or which third party websites redirected users onto our website. Those information are further utilized in order to optimize our website by analyzing the statistical data provided by the cookie. The data we receive is processed by us for the purposes of legitimate interest in the optimal marketing of our website content according to par.6 subpar 1 f) GDPR.
The cookies are not used for the personal identification of users. The data is anonymous and cannot be used to draw any conclusions about users’ identities. The information about your website usage gathered by this cookie (including your IP-address) will be stored and processed by a Facebook server in the United States.
Facebook is certified:
https://www.privacyshield.gov/...
More information regarding your data protection can be found here:
https://www.facebook.com/help/...
You can revoke your consent to the collection and storage of data at any time with effect for the future by clicking this opt-out link.

j. FullStory

We use the FullStory analysis service, provided by FullStory Inc., 120 Ottley Dr NE Ste 100, Atlanta, GA 30324, USA (“FullStory”), to analyse user behaviour on our website. FullStory records information about the behaviour of website visitors, enabling us to analyse this behaviour and to improve the user experience on our website. FullStory processes information such as clicks, mouse movements, input (with the exception of sensitive information), scroll movements, type of browser used, device type, IP address, pages visited and session duration.
FullStory uses cookies to collect this information. The information generated by the cookie about your use of the website is transmitted to, and stored by, FullStory on servers in the United States.
We process the data we receive when using FullStory in accordance with Art. 6(1)(f) GDPR on the basis of our compelling legitimate interest in the optimum marketing of our website.
You may object to data collection at any time with future effect by clicking the following opt-out link: https://www.fullstory.com/opto...
FullStory is certified under: https://www.privacyshield.gov/...
You can find further information about FullStory’s Privacy Policy at:
https://www.fullstory.com/lega... ‍

k. Optimizely

In order to continuously improve our website, we use the Optimizely web analysis service on our website provided by Optimizely Inc. 631 Howard Street, Suite 100, San Francisco, CA 94105, USA (“Optimizely”). Optimizely uses cookies. They process information about the page accessed, the date and time of access, the referrer URL (the previously visited website), your browser, your use of the website and your IP address. Please note that Optimizely is used on our website with IP anonymisation. This shortens IP addresses before they are sent to a server in the USA. A direct personal reference in connection with the stored data is thus usually excluded. Only in exceptional cases is the full IP address transmitted to a server in the USA and shortened there. Processing in this manner is performed on the basis of our compelling legitimate interest in the optimum marketing of our website in accordance with Art. 6(1)(f) GDPR.
Optimizely is certified under:
https://www.privacyshield.gov/...
Further information on Optimizely’s Privacy Policy can be found at:
https://www.optimizely.com/de/...
You can object to having Optimizely process your data at any time with future effect by setting an opt-out cookie available via the following link: https://www.optimizely.com/opt. Please note that you must click on the link again if you delete the cookies in your browser.