PRIVACY POLICY

Please read V4CP’s privacy policy. Your privacy is important to Value4Capital Partners S.r.l.s. (“V4CP”). This Privacy Policy explains how V4CP collects, uses, discloses, and retains personal information, including information collected through websites, blogs, apps (including but not limited to messaging services), and our correspondence with you (for example, by e-mail) and when providing you with our products and services. 

1) Your Consent
If you are located in Italy or another country within the European Economic Area (EEA) or the European Union (EU), by providing V4CP with your personal information, you consent to the collection, use, disclosure, and retention of that information by V4CP in accordance with this Privacy Policy and applicable EU and Italian law. Where we rely on consent, you may withdraw your consent at any time, subject to legal or contractual restrictions and on reasonable notice to V4CP, but then you might not be able to proceed with your intended interactions or transactions with V4CP or otherwise receive the full benefit of V4CP’s products and services.

2) Data Controller
For purposes of the General Data Protection Regulation (the “GDPR”), we are the data controller for the purpose of data protection law, in respect of your personal information collected and used through your use of the website, products, and services. This is because we dictate the purpose for which your personal information is used and how we use your personal information.

3) Personal Information Defined
In this Privacy Policy, “personal information” means information about you and which identifies you, such as your name and email address, but does not include (to the extent permitted by law) information that is publicly available in a telephone directory or that is the business contact information that enables an individual to be contacted at a place of business.

4) Personal Information V4CP Collects
We collect personal information about you in the course of providing the websites, blogs, apps (including but not limited to messaging services), products and services, and our correspondence with you. The information may include the following:

 

Category	Description
Personal contact information	Name, personal address, personal email address, and personal telephone number
Business contact information	Name, business address, business email address, and business telephone number
Account information	Username and account preferences
Payment information	Payment card number (credit or debit card), bank account number, billing address, or other financial account numbers and account details
Financial aid application information	Contact information, link to social media profile, education and employment information, annual income, country of residence, aid preferences, and answers about your financial situation, and academic or professional achievements
Course and enrolment information	Online registration information, record of attendance information, and assessments
Social Media	Information relating to your social media profiles, including (but not limited to) LinkedIn
Marketing preferences, marketing activities, and customer feedback	Marketing preferences or responses to voluntary customer satisfaction surveys, interaction with and responses to our marketing communications, reviews, and endorsements of our courses
Other information you provide to us	For example, if you write a review of our products, submit a “Contact Us” form, or provide other information to us in the course of your use of our websites, products, or services

5) How V4CP Collects Information

(a) Information You Provide
You may be asked to voluntarily give your personal information to V4CP when you interact with V4CP. This information may be provided:

• in the course of communications between you and us (including by phone, email, chat, in person, via social media, website, or otherwise);
• when you register for an account;
• when you request information about or use a product or service provided by us;
• when you subscribe to a newsletter;
• when you attend tradeshows and other events; and
• when you report a problem with our websites, products, or services.

In certain circumstances, you can choose not to provide certain requested personal information, but then you might not be able to proceed with your intended interaction or transaction with V4CP or otherwise receive the full benefit of the desired product or service.

If you give V4CP the personal information of another individual, then you are solely responsible for complying with all applicable laws, including obtaining the individual’s valid consent, regarding your collection and disclosure of the personal information to V4CP and to V4CP’s use, disclosure, and retention of the personal information.

(b) Automated Collection
V4CP may automatically collect certain information regarding your use of V4CP’s websites, such as the dates and times that you use the websites, the browsers, operating systems, software and devices that you use to access the websites, and details of your use of the websites.

V4CP’s websites, email messages, and advertisements may use technologies (e.g. cookies, web beacons, tokens, pixels, or tags) to collect information that assists V4CP to improve its products, services, customer communications, and advertising and to prevent fraud. V4CP may use information collected through technological means to recognize you as a user of V4CP’s websites, to facilitate and improve your use of V4CP’s websites, to confirm that messages have been delivered to and opened by you, and to provide you with targeted advertisements. You may choose to decline or disable cookies if your web browser or device permits, but doing so may affect your ability to access or use certain features of a website.

Some of the information automatically collected by technological means is non-personal information (because the information does not identify you), and V4CP will deal with that non-personal information as explained below in this Privacy Policy unless applicable law requires otherwise.

V4CP shall have a royalty-free, worldwide, transferable, sublicenseable, irrevocable, perpetual, unrestricted license to use or incorporate into the Services any suggestions, enhancement requests, recommendations, or other feedback provided by you relating to the operation of the Services, including but not limited to beta offerings, or products or features that are provided at no cost.

(c) Cookies
Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the website’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we may use cookies to help us remember and process the items in your shopping cart and to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We may also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. Find out more about how to manage cookies.

We use cookies to:

• help remember and process the items in the shopping cart;
• understand and save user’s preferences for future visits;
• keep track of advertisements; and
• compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

You may choose to decline or disable cookies if your web browser permits, but doing so may affect your ability to access or use certain features of V4CP’s websites. However, you will still be able to place orders.

(d) Internet-Based Advertising
V4CP may use interest-based advertising services (sometimes called “remarketing” or “retargeting”) provided by third-party vendors (such as Google, Bing, LinkedIn, and Facebook) to display advertisements on third-party websites and social media sites visited by users of a V4CP website. Advertising vendors (such as Google, Bing, LinkedIn, and Facebook) use cookies, pixels or tokens – unique identifiers of a web browser on a specific computer that are installed on the computer when it accesses V4CP websites – to display ads based on the computer’s past access to V4CP websites. You can opt out of Google’s use of cookies by visiting Google’s Ads Settings. You can also opt out of a remarketing vendor’s use of cookies by visiting the Network Advertising Initiative’s consumer opt-out page. For more information, including details of how to block these cookies specifically, please see https://support.google.com/analytics/answer/181881. We partner with Rakuten Advertising, who may collect personal information when you interact with our site. The collection and use of this information is subject to the Rakuten Advertising Privacy Policy.

(e) Information from Other Sources
V4CP may collect personal information from various publicly available sources and other third parties that are lawfully entitled to share your personal information with V4CP.

If V4CP refers you to an independent business (e.g. a sales partner) for a proposed transaction, then V4CP may collect from that independent business information regarding the transaction for use by V4CP to update your confidential profile for use by V4CP as set out in this Privacy Policy.

V4CP may combine your personal information collected by V4CP through various sources.

6) How V4CP Uses Personal Information

(a) General
Under data protection law, we can only use your personal information if we have a proper reason for doing so, for example:

• to comply with our legal and regulatory obligations;
• for our legitimate interests (see below) or those of a third party;
• for the performance of our contract with you or to take steps at your request before entering into a contract; or
• you have given consent.

A legitimate interest is when we have a business or commercial reason to use your personal information, so long as this is not overridden by your own rights and interests. Where we rely on our legitimate business interests or those legitimate interests of a third party to justify the purposes for using your personal information, this will include:

• pursuit of our commercial activities and objectives, or those of a third party;
• compliance with applicable legal and regulatory obligations and any codes of conduct;
• improvement and development of our business operations and service offering, or those of a third party; or
• protection of our business, shareholders, employees, and customers, or those of a third party.

(b) Purpose and Legal Basis
V4CP may use your personal information collected by V4CP for purposes relating to or arising from your relationship and transactions with V4CP and as otherwise set out in this Privacy Policy or permitted by applicable law. The table below explains what we use your personal information for and our reasons for doing so:

Purpose	Legal Basis
To administer your relationship with V4CP, including to contact and correspond with you regarding those matters	For our legitimate business interests (i.e. the provision of the websites, products, and services)
To facilitate your interactions and transactions with V4CP	For our legitimate business interests (i.e. the provision of the websites, products, and services)
To provide you with the websites, products, and services	For our legitimate business interests (i.e. the provision of the websites, products, and services), and depending on the circumstances, to perform a contract between you and us
To process your application for financial aid	For our legitimate business interests (i.e. the provision of our products and services)
To process and respond to your inquiries, requests, and other communications	For our legitimate business interests (i.e. the provision of the websites, products, and services)
To notify you about changes to the websites or the products and services	For our legitimate business interests (i.e. the provision of the websites, products, and services)
To audit and monitor the use of the websites	For our legitimate business interests (i.e. the provision of the websites, products, and services, as well as to improve and monitor security), or where required by law, with your consent
To maintain, protect and improve V4CP’s products and services and to develop new products and services	For our legitimate business interests (i.e. the provision and improvement of the products and our services)
To manage complaints, feedback, and queries	For our legitimate business interests (i.e. the provision and improvement of the websites, products, and services)
To administer and facilitate your participation in contests and promotions related to V4CP	For our legitimate business interests (i.e. the promotion of the websites, products, and services), and depending on the circumstances, to perform a contract between you and us
To carry out market research and analysis	For our legitimate business interests (i.e. the provision, improvement, and promotion of the websites, products, and our services)
To carry out satisfaction surveys and analysis	For our legitimate business interests (i.e. the provision, improvement, and promotion of the websites, products, and our services)
To provide you with information (including by email and other electronic messages) regarding V4CP and its business, products, and services and products and services offered by other businesses, to the extent permitted by applicable law and in accordance with your preferences	Depending on the method of communication, this processing may be carried out with your consent or in accordance with our legitimate business interests to process your information for direct marketing purposes
To comply with any legal or regulatory obligations and to protect and enforce V4CP’s legal rights, interests and remedies, to protect the business operations and customers of V4CP or other persons	For our legitimate business interests and for compliance with legal obligations to which we are subject
To enforce or apply the agreements concerning you (including agreements between you and us)	For our legitimate business interests and for compliance with legal obligations to which we are subject

(c) How We Use Automated Decision Making When We Process Your Personal Information to help us assess your suitability for financial aid, decisions will be made about you using automated computer software on a system. This is known as automated decision making.

The systems apply pre-defined logic programming and criteria to make a decision and these decisions do not require human input.

You have the right to challenge any automated decision with us directly. You can object to an automated decision, ask that we do not make automated decisions about you, and ask that a person reviews it. If you want to know more details about your rights, please see section 17(c) below.

1.  

7) How V4CP Discloses and Shares Personal Information

(a) General
V4CP discloses your personal information for purposes relating to or arising from your relationship and transactions with V4CP and as otherwise set out in this Privacy Policy or permitted by applicable law.

(b) Specific Consents
V4CP may disclose your personal information in accordance with express or implied consent that you give during your interactions and transactions with V4CP.

(c) Affiliates
Value4Capital Partners S.r.l. and its affiliates may share your personal information with each other and use it in connection with our relationship with you for the provision of our products and services, the whole in accordance with this Privacy Policy. When V4CP shares your personal information with its affiliates, V4CP may develop, maintain and share a confidential profile for you for use by V4CP to provide information, products, and services to you, to facilitate your dealings with V4CP and as otherwise set out in this Privacy Policy.

(d) Referred Transactions
If V4CP refers you to an independent business (e.g. a sales partner) for a proposed transaction, then V4CP may disclose your personal information to the independent business to facilitate the proposed transaction, and in those circumstances, V4CP has no control over, or responsibility or liability for, the use, disclosure or retention of your personal information by the independent business.

(e) Suppliers and Service Providers
V4CP may disclose your personal information to its suppliers and third-party service providers, such as our payments processor or our analytics provider, to assist V4CP in the provision of information, products, and services to you, to provide services to V4CP, to assist V4CP to use your personal information as set out in this Privacy Policy and as otherwise permitted by applicable law.

(f) Professional Advisers
V4CP may disclose your personal information to our professional advisers including accountants, lawyers, and other professional advisers that assist us in carrying out our business activities.

(g) Law Enforcement/Legal Disclosures
V4CP may disclose your personal information as required or authorized by applicable European Union or Italian law, including to comply with a subpoena, warrant, or court or arbitral order or litigation disclosure obligation. V4CP may disclose your personal information to law enforcement agencies or other independent organizations if V4CP reasonably believes the disclosure is necessary or appropriate in connection with national or public security, law enforcement, or other issues of public importance, or if V4CP reasonably believes the disclosure is necessary or appropriate to protect and enforce V4CP’s legal rights, interests and remedies or to protect the rights, interests, business, operations or customers of V4CP or other persons.

(h) Business Transactions
V4CP may disclose your personal information in connection with a proposed or actual business transaction in which V4CP is involved (e.g. a corporate amalgamation, reorganization, merger or acquisition, or the sale or transfer of some or all of V4CP’s business or assets), but V4CP will require the information recipient to agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy and applicable law.

(i) Information that You Share
You may use V4CP’s products and services (including membership in related forums or communities) to share your personal information and other information and content with other users of V4CP’s products and services. When you do so, the information and content that you share can be read, collected, used, retained, and disclosed by other users and may be publicly available on V4CP’s websites. You are solely responsible for the information and content that you choose to share. V4CP has no control over, or responsibility or liability for, the way in which the information or content that you share is collected, used, retained, or disclosed by other users. V4CP encourages you to be careful when you share information or content.

8) Location and Transfer of Personal Information
V4CP and its service providers may process, store, and use your personal information at facilities in various locations, including within Italy, the European Economic Area, and potentially outside the EEA if allowed by law. If we transfer your personal information outside the EEA, we will implement appropriate and suitable safeguards to ensure that such data will be protected as required by applicable data protection law. Such safeguards may include use of the European Commission approved standard contractual clauses or transfers to countries deemed adequate. For further information on the steps taken relating to such transfers and the safeguards in place, please contact our Privacy Officer using the details listed at the end of this Privacy Policy.

9) Retention of Personal Information
We will retain your personal information for the period reasonably necessary for the purposes set out or referenced in this Privacy Policy and to comply with V4CP’s legal obligations or enforce or protect V4CP’s legal rights, or a longer period required or permitted by applicable law. V4CP will delete or dispose of your personal information, or depersonalize the information when V4CP is no longer reasonably required to retain the information for the purposes set out in this Privacy Policy. Please note that all of the above retention periods may be extended where we need to preserve and use personal information for the purposes of bringing or defending a legal claim. In such cases, we will continue to hold and process your personal information for as long as is necessary to deal with the legal proceedings. For further information as to our retention periods, please contact our Privacy Officer using the contact details as set out at the end of this Privacy Policy.

10) Your Rights Under European (Including Italian) Data Protection Laws
If you are located in Italy or another EU/EEA member state, you have rights under the GDPR and applicable Italian and EU data protection laws. These include (as further explained in section 13) the right to request access to your personal information, the right to rectification, erasure, restriction, objection, and data portability, and the right to withdraw consent where we rely on it. You also have the right to lodge a complaint with your local data protection authority if you believe we have not used your personal information in accordance with data protection law. If other relevant jurisdictions enact laws similar to the GDPR, and we operate under those jurisdictions, this section will also apply to you if you reside in those jurisdictions.

11) Do Not Track Signals; Tracking Across Third Party Websites
Certain mechanisms may allow you to send web browser signals known as “Do Not Track” (“DNT”) signals, indicating your choice to disable tracking on our website. We do not respond to such signals at this time. We may not be aware of or able to honor and respond to every such mechanism. Third parties, other than our vendors (such as our website analytics provider), do not have authorization from us to track which websites you visited prior to and after visiting our website. That said, we cannot control third-party tracking and there may be some third-party tracking that occurs without our knowledge or consent.

12) Protection of Personal Information
V4CP uses reasonable safeguards – including administrative, physical, and technical security and safeguarding measures – appropriate to the sensitivity of the personal information in V4CP’s possession or under V4CP’s control to help protect the information from unauthorized access, collection, use, disclosure, deletion or similar risks. Nevertheless, security risks cannot be eliminated and V4CP cannot guarantee that your personal information will not be accessed, used, disclosed, or deleted in ways not otherwise described in this Privacy Policy.

13) Accuracy and Access to Personal Information
V4CP will rely on you to ensure that the personal information that you provide to V4CP is as accurate, complete and up to date as necessary for the purposes for which V4CP uses the personal information. You will promptly notify V4CP of any changes to the personal information that you provide to V4CP using the procedures made available for that purpose by V4CP or by contacting V4CP’s Privacy Officer using the contact information noted below. You have certain rights with respect to your personal information. The rights may only apply in certain circumstances and are subject to certain exemptions. Please see the table below for a summary of your rights. You can exercise these rights using the contact details at the end of this Privacy Policy.

Right	Summary of your rights
Right of access to your personal information	You have the right to receive a copy of your personal information that we hold about you, subject to certain exemptions.
Right to rectify your personal information	You have the right to ask us to correct your personal information that we hold where it is incorrect or incomplete.
Right to erasure of your personal information	You have the right to ask that your personal information be deleted in certain circumstances.
Right to restrict the use of your personal information	You have the right to suspend our use of your personal information in certain circumstances.
Right to data portability	You have the right to obtain personal information that you have provided to us in a structured, commonly used, and machine-readable format and for it to be transferred to you or another organization.
Right to object to the use of your personal information	You have the right to object to the use of your personal information in certain circumstances, for example where we rely on legitimate interests or direct marketing.
Right to withdraw consent	You have the right to withdraw your consent at any time where we rely on consent to use your personal information.
Right to complain to the relevant data protection authority	You have the right to complain to the relevant data protection authority if you believe we have not used your personal information in accordance with data protection law.

14) Non-Personal Information
V4CP may use personal information to create and collect non-personal information (information that is not about an identifiable individual), including personal information that has been aggregated or otherwise depersonalized so that the information no longer relates to an identifiable individual. V4CP may use, disclose, transfer, and retain non-personal information for any purpose and in any manner whatsoever. If non-personal information is combined with personal information, then V4CP will treat the combined information as personal information for the purposes of this Privacy Policy.

15) Other Websites and Businesses
V4CP’s websites and correspondence (including emails and messages) may include advertisements for products and services offered by independent businesses or links to websites operated by independent businesses. V4CP has no responsibility or liability for, or control over, those other websites, online services, or businesses, their products or services, or their collection, use, disclosure, or retention of your personal information. If you have questions about how those websites, online services, or independent businesses collect, use, disclose, or retain personal information, please contact the owner or operator of the website, service, or business.

16) Social Networking and Similar Situations
When you use certain aspects of V4CP’s websites or other services, or post information to other social networking sites (e.g. there may be links to V4CP’s LinkedIn or Facebook pages), the personal information that you post or share is visible to other persons and can be read, collected, used and disclosed by other persons, including to send unsolicited messages. Any information provided to such third-party social networking sites and other sites is governed by their own privacy policies. You are solely responsible for the personal information that you choose to post or share in those situations. V4CP has no control over, or responsibility or liability for, the use, disclosure, and retention of the personal information that you disclose in those situations.

17) Other Matters
(a) Disclaimers, Liability Exclusions/Limitations, and Disputes:
The agreements (including any website terms of use) that you accept when you apply, register for, order, or use V4CP’s products and services contain important provisions, including provisions disclaiming, limiting or excluding the liability of V4CP and other persons (including service providers) and provisions determining the applicable law and jurisdiction for the resolution of disputes. To the extent permitted by applicable law, each of those provisions applies to any dispute that may arise in relation to this Privacy Policy or V4CP’s collection, use, disclosure, and retention of your personal information, and are of the same force and effect as if they were reproduced directly in this Privacy Policy.

(b) Changes to this Policy:
V4CP may change this Privacy Policy as it applies to V4CP from time to time by posting a new version of this Privacy Policy on V4CP’s websites. V4CP’s collection, use, disclosure, and retention of your personal information will be governed by the version of this Privacy Policy in effect at that time. Your continued dealings with V4CP after any change to this Privacy Policy will signify your consent to the collection, use, disclosure, and retention of your personal information by V4CP as set out in the changed Privacy Policy. Accordingly, you should check the “Last Updated” date of this Privacy Policy (at the top) and review any changes since the last version.

(c) Contacting V4CP’s Privacy Officer:
If you have any comments or questions about this Privacy Policy or how V4CP deals with your personal information, please contact V4CP’s Privacy Officer by mail or email at:

Privacy Officer Value4Capital Partners – Ms. Liudmyla Slobodianiuk
Address: Ctr. Cupo Biancucci, 5/A – 64026 Roseto degli Abruzzi (TE), Italy
Email: info@v4cpartners.com 
Phone: (+380) 97 3498201

Read all of V4CP’s Legal Information.