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PRIVACY AND DATA PROTECTION POLICY

COOKIE POLICY

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A: PRIVACY AND DATA PROTECTION POLICY

This Privacy Policy describes how InItalia (hereinafter, "the Academy") collects, uses, and protects the personal information of its students and prospects.

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1. Data Controller

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2. Processing of Data for Adults and Adolescents Over 15 Years of Age

At InItalia, we process the personal data of our students, ensuring their privacy and security. In accordance with Ecuador's Organic Law on Personal Data Protection (LOPDP), we recognize the capacity of adults and adolescents over fifteen (15) years of age to directly exercise their data protection rights before this academy. In the case of adolescents between 15 and 17 years old, although they have legal autonomy over their personal information, consent for processing such data is understood to be linked to the formal academic relationship established by their legal representative at the time of pre-enrollment. In all cases, data is collected solely for the purpose of providing educational services, conducting pedagogical monitoring, and complying with the academy's administrative obligations, applying the same confidentiality standards to all our users.

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3. Data We Collect

To provide our educational services, we process the following data:

  • Identification: First name, last name, ID card or passport number.

  • Contact: Email address, WhatsApp number, street address, city, country.

  • Academic: Italian proficiency level, attendance, and grades, managed through our Moodle platform and the Blinklearning digital environment.

  • Multimedia: Voice and image recordings of classes conducted via videoconference.

  • Financial: Billing data.

The Academy does not collect or store sensitive debit/credit card data. This data is processed exclusively by PayPhone/dLocalgo/PayPal and other payment gateways, which hold PCI-DSS certification.

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4. Purpose of Processing

Your data will be used exclusively to:

  • Manage enrollment and access to the educational platform.

  • Conduct online classes.

  • Issue legal invoices and process payments.

  • Send course-related communications (schedule changes, Zoom links).

  • Optional: Send promotions and new course offerings (only if expressly authorized by the user).

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5. Legal Basis for Processing

We process your data based on:

  • Execution of a contract: We need your data to deliver classes to you.

  • Consent: For the use of your image/voice in class recordings.

  • Legal obligation: To comply with tax regulations.

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6. Transfer of Data

As part of our educational model, your data may be shared with:

  • Teachers: For delivering classes and conducting evaluations.

  • Technology Service Providers: Wix (web hosting and registration forms), Namecheap (domain and corporate email management), Meta (WhatsApp Business), Zoom (videoconferencing), Moodle (virtual classroom), BlinkLearning (digital learning materials), and payment gateways (PayPhone/dLocalgo/PayPal). These providers ensure high levels of data protection.

  • Social Networks / Marketing / Outreach: Meta (WhatsApp Business, Facebook, and Instagram), TikTok, and LinkedIn, for community management, customer support, and ad campaign analytics.

Our providers are international companies that may store information on servers located outside Ecuador, always guaranteeing international standards of security and data protection.

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7. Data Retention

Personal data will be retained for the duration of the academic relationship and, subsequently, for the statutory periods required by Ecuadorian tax authorities (generally 7 years).

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8. Class Recording

The student or their legal representative acknowledges and accepts that classes are recorded for the exclusive use of the Academy. Recordings are the property of the institution and, to prevent any detriment to users, will not be made available to students or third parties under any circumstances.

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9. Your Rights

You have the right to:

  • Access your personal data.

  • Rectify inaccurate data.

  • Delete your data when it is no longer necessary.

  • Object to the use of your data for marketing purposes.

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B: COOKIE POLICY

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1. Technical and Functional Cookies (Mandatory)

These cookies are essential for the website to function properly and to enable us to process your requests.

  • Wix Infrastructure: Enables secure browsing, site stability, and proper display of all academy elements.

  • Forms and Enrollment: Ensures that your inquiries and registration data are submitted correctly and securely.

  • Security: Ensures that any registration or interaction takes place under data protection protocols.

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2. Personalization Cookies and Widgets

Allow integrated interactive tools on our website (such as calendars or direct contact buttons) to function properly and facilitate your use of our services.

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3. Analytics and Performance Cookies

We use Wix Analytics to obtain anonymous statistical data regarding website usage (most visited sections, countries of origin), helping us improve the learning experience.

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4. Third-Party and Social Media Cookies

Our website includes links and tools from external platforms:

  • Social Networks: TikTok, Meta, and Instagram buttons may allow these platforms to place cookies if you interact with them or have an active session logged in.

  • Multimedia Content: Embedded video playback (such as YouTube) may generate third-party cookies to track video views.

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5. Consent and Cookie Management

By continuing to browse our website, you accept the use of the aforementioned cookies for the purposes described. If you wish to restrict or block cookies, you may do so at any time by adjusting your browser settings. Please note that disabling certain technical cookies may affect the functionality of enrollment forms and the proper performance of the academy's interactive tools.

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Document Code: PPR-COO-001

Version: 1.0

Publication Date: April 20, 2026

Quito-Ecuador

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