1. Our core beliefs regarding user privacy and data protection

• User privacy and data protection are human rights
• We have a duty of care to the people within our data
• Data is a liability, it should only be collected and processed when absolutely necessary
• We loathe spam as much as you do!
• We will never sell, rent or otherwise distribute or make public your personal information

2. Relevant legislation

Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:

• Bulgarian law on protection of personal data – Закон за защита на личните данни 2002
• EU Data Protection Directive 1995 (DPD)
• EU General Data Protection Regulation 2018 (GDPR)

This site’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well.

3. Personal information that this website collects and why we collect it

This website collects and uses personal information for the following reasons:

3.1. Site visitation tracking

Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor.
GA makes use of cookies, details of which can be found on Google’s developer guides. Our website uses the analytics.js implementation of GA.
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.

3.2. Contact forms and email links

Should you choose to contact us using the contact form on our contact page or via an email link, none of the data that you supply will be stored by this website or passed to / be processed by any of the third party data processors defined in section 6.0. Instead the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our own SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices. However, not all mail servers are secured in such a way. Therefore, we would suggest that you always consider email as an insecure medium and not include personal, confidential or otherwise sensitive information within an email.

4. How we store your personal information

If you submit a comment to a blog post published on this website some personal information will be stored within this website’s database. This is currently the only occasion where personal data will be stored on this website. This data is currently stored in an identifiable fashion; a limitation of the content management system that this website is build on (WordPress). In the near future we aim to change the storage of this data to a pseudonymous fashion meaning that the data would require additional processing using a separately stored ‘key’ before it could be used to identify an individual.
Pseudonymisation is a recent requirement of the GDPR which many web application developers are currently working to fully implement. We are committed to keeping it as a high priority and will implement it on this website as soon as we are able to.

5. About this website’s server

This website is hosted by SIM – SCUOLA ITALIANA DI MENTORING BY AUDEO CFR SAS DI M. PERCHIAZZI within an ITALIAN data centre.
Some of the data centre’s more notable security features are as follows:

• SSL Certificate
• SPAM protection
• Ensuring interruptibility of service by using the DDoS defense system.
• Websites protection against any malicious access that can modify or compromise such sites or steal data.
• Mailbox protection against unauthorized access.
• Protection for the entire infrastructure by applying the latest versions of the system software used.

All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.

6. Our third party data processors

We use 1 third party to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2.0. This third party is based in the USA and are EU-U.S Privacy Shield compliant.

• Google (Privacy policy)

7. Data breaches

We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.

8. Data controller

The data controller of this website is:
SIM – Italian School Mentoring

9. Data protection officer

Dr. Matteo PERCHIAZZI
CEO
Email: mperchiazzi@scuolaitalianadimentoring.com

10. Changes to our privacy policy

This privacy policy may change from time to time, inline with legislation or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes. Specific policy changes and updates are mentioned in the change log below.

10.1. Change log

• 01/05/2018 – version 1.2
  • Added a paragraph to section 3.2 (Contact forms and email links) about email not being secure and that confidential information should not be sent over email
  • Added version numbers to the change log
• 01/04/2018 – version 1.0
  • Privacy policy instigated