Medicor Tutor Limited (hereinafter “Medicor Tutor”) has for many years considered the protection of the personal data of its customers and/or prospective customers and users to be of fundamental importance, ensuring that the processing of personal data, carried out by any means, whether automated or manual, takes place in full compliance with the safeguards and rights recognised by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the “Regulation”) and by the other applicable legislation on the protection of personal data.
The term personal data refers to the definition contained in Article 4(1) of the Regulation, namely “any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person” (hereinafter “Personal Data”).
The Regulation provides that, before any processing of Personal Data takes place – the term processing being understood, in accordance with the relevant definition contained in Article 4(2) of the Regulation, as “any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction” – the person to whom such Personal Data belong must be informed of the reasons for which such data are requested and of how they will be used.
In this regard, the purpose of this document is to provide the user, in a simple and intuitive manner, with all the useful and necessary information to enable him or her to provide his or her Personal Data in a conscious and informed manner and, at any time, to request and obtain clarifications and/or rectifications.
This privacy notice has therefore been drawn up on the basis of the principle of transparency and of all the elements required by Article 13 of the Regulation, and is divided into individual sections, each of which deals with a specific topic, so as to make it quicker, easier and simpler to read and understand.
Where necessary, this privacy notice may be accompanied by a specific consent form, as provided for by Article 7 of the Regulation, structured according to the further type of use that we intend to make of the user’s Personal Data.
In general, the user may browse the Medicor Tutor website without providing any kind of personal information. Personal Data are collected and processed when this is necessary for Medicor Tutor in connection with the performance of services requested by the user, or when the user decides to disclose his or her Personal Data.
With regard to the latter cases, this privacy policy sets out the methods and characteristics of the collection and processing of the user’s Personal Data. Medicor Tutor processes the Personal Data provided by users in compliance with the legislation in force.
Personal Data means any information that may be used to identify an individual, a company or another entity. By way of example only and without limitation, the data collected include first name and surname, email address, telephone number, address, a postal or other physical contact address, other information necessary to contact the user, job title, date of birth, gender, occupation, business activity, personal interests, educational qualification, data relating to the course/qualification, area of study of interest and other information necessary for the provision of the services requested by the user.
Browsing on the Medicor Tutor website takes place anonymously. Medicor Tutor does not collect user data by automatic means, including the email address. Medicor Tutor records the user’s IP address (Internet Protocol, i.e. the Internet address of the user’s computer) in order to have an idea of the area of the website that the user visits and of the duration of the visit, in compliance with the legislation in force on the protection of Personal Data. However, Medicor Tutor does not link the user’s IP address with other personal information relating to the user unless it has first duly informed the user of the relevant processing and obtained his or her consent to the processing, and only in respect of users registered on the Medicor Tutor website. Like many other websites with a service-oriented nature and content, the Medicor Tutor website may use a standard technology called “cookies” to collect information on how the user uses the website. For further information, the user is invited to consult the “Cookies” section below.
Medicor Tutor collects the user’s Personal Data when the user completes the registration forms provided at the collection points on the Medicor Tutor website.
In order to enable Medicor Tutor to carry out the processing activities for the purposes set out in this privacy notice, it will be necessary to provide the Personal Data marked with the symbol *. If even one of the marked data items is not provided, it will not be possible to process the user’s Personal Data and, consequently, the user will not be able to complete his or her registration on the Medicor Tutor website and/or to benefit from the services provided by Medicor Tutor for which the provision of Personal Data is required.
In particular, completion of the aforementioned registration forms is necessary for the user to receive informative newsletters and commercial communications regarding the activities and services carried out by Medicor Tutor. Users are asked to provide data concerning them, such as first name, surname and contact details for getting in touch with the user (email address and telephone number). Medicor Tutor also collects data concerning users from posts published on social media channels (Facebook, Instagram, Youtube) or from messages sent to Medicor Tutor by email or via social media channels (Facebook and Instagram, Youtube).
The provision of data is, in any event, optional, and a refusal to provide such data will in no way prejudice the user’s rights, for example the right to consult all the information available on the Medicor Tutor website.
The provisions of this privacy notice concerning the collection and use of users’ data also apply where Medicor Tutor’s information and/or services are accessed through mobile digital channels such as, by way of example and without limitation, mobile phones, tablets or any other device or technology, including mobile applications.
Where Personal Data are collected, Medicor Tutor will inform the user of the purposes of the collection at the time of collection and, where necessary, will request the user’s consent.
The user’s Personal Data may be disclosed to specific parties considered to be recipients of such Personal Data. Indeed, Article 4(9) of the Regulation defines the recipient of Personal Data as “a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not”.
Accordingly, in order to carry out properly all the processing activities necessary to pursue the purposes set out in this privacy notice, the following recipients may be in a position to process the user’s Personal Data:
One of the principles applicable to the processing of the user’s Personal Data concerns storage limitation, governed by Article 5(1)(e) of the Regulation, which states that “Personal Data shall be kept in a form which permits identification of Data Subjects for no longer than is necessary for the purposes for which they are processed; Personal Data may be stored for longer periods insofar as they will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1), subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the Data Subject”.
In light of this principle, the user’s Personal Data will be processed by Medicor Tutor only to the extent necessary for the pursuit of the purposes set out in this privacy notice. In particular, the user’s Personal Data will be processed for the minimum period of time necessary, as indicated in Recital 39 of the Regulation, namely until the termination of the contractual relationship in place between the user and Medicor Tutor, without prejudice to any further retention period that may be imposed by law, as also provided for in Recital 65 of the Regulation.
Medicor Tutor uses cookies to improve the quality of the Medicor Tutor website and of the related service, and to try to make the user’s browsing experience meaningful.
When the user accesses the website, the Medicor Tutor web server sends a cookie to the user’s computer; this allows Medicor Tutor to recognise the computer, but not the person using it. However, by associating the identification numbers contained in cookies with other customer information, for example when the user logs in to the website, Medicor Tutor may know that the cookie information relates to that user.
By continuing beyond this page and browsing the website, for example by accessing an area of the website or by clicking on a link or image on the website, the user consents to the use of cookies in the manner defined by Medicor Tutor and declares that he or she has understood this Cookie Policy, which describes how the user can manage his or her choices and preferences regarding the use of cookies.
Cookies are small text strings sent to the user’s computer when the user visits a website, which store, and sometimes track, information relating to the user’s use of the website. Medicor Tutor does not use cookies for user profiling activities. The website uses technical cookies and “third-party” cookies.
The cookies used on the Website are those described below:
In accordance with the classification provided by the Italian Data Protection Authority (Garante per la protezione dei dati personali) in general decision No. 229 of 8 May 2014 on the “Identification of simplified arrangements for providing information and obtaining consent for the use of cookies”, “technical cookies” means browsing or session cookies and analytical cookies (analytics).
The use of such cookies does not require the user’s consent. The technical cookies used by Medicor Tutor are listed below:
A.1. Browsing or session cookies
These session cookies are necessary to enable the user to use the essential functions of the website. Disabling them may compromise the use of the website.
A.2. Analytical cookies
These cookies are also known as performance cookies and are used to collect information on how users use the website, so that Medicor Tutor can improve the quality of the website and of the service.
The analytical cookies used by Medicor Tutor do not collect information that could identify the user. All the information collected by these cookies is aggregated and anonymous information used by Medicor Tutor to:
When visiting a website, one may receive cookies managed by parties other than the owner of the website visited (“third parties”). The management of the information collected by “third parties” is governed by their respective privacy notices.
“Third-party” cookies allow the third parties that use them to obtain more comprehensive surveys and statistics on users’ browsing habits. Such cookies can be disabled without any loss of functionality.
How the user can manage his or her cookie preferences
Some of the cookies used on the website are served by Medicor Tutor, while others are sent by third parties providing services on behalf of Medicor Tutor.
The user may choose to enable or disable cookies by changing the settings of his or her web browser in accordance with the instructions made available by the respective providers. Since each browser has slightly different functions, check the “help” menu of your browser to find out how to change the cookie settings correctly.
You can therefore change your browser settings so that cookies are deleted or are not saved on your computer or mobile device without your explicit consent. The following links will help you better understand how to configure your browser:
- Internet Explorer:
- Mozilla Firefox:
- Google Chrome:
- Safari:
- Opera:
If you disable cookies, you will not have access to many features that make this website more efficient and some of our services will not function properly.
Medicor Tutor processes the user’s Personal Data in order to allow:
In certain cases, where appropriate and possibly also at a later time, the user may express his or her preferences regarding the use of his or her data in accordance with the provisions of this privacy notice and exercise this option through the means chosen for using the services, for example via mobile phone, mobile applications or any other representation of the website.
The processing of the user’s Personal Data for the purposes referred to in points (4) and (5) is conditional upon obtaining the user’s consent, which must necessarily satisfy the conditions set out in Article 7 of the Regulation, thereby establishing the lawfulness of the processing of the user’s Personal Data.
With regard to the direct marketing purpose referred to in point (4), it should be noted that, pursuant to Article 6(1)(f) of the Regulation, Medicor Tutor may carry out such activity on the basis of its legitimate interest, irrespective of the user’s consent and in any event until the user objects to such processing, as further explained in Recital 47 of the Regulation, according to which “the processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest”. This will also be possible following the assessments carried out by Medicor Tutor as to whether the interests, fundamental rights and freedoms of the user which require the protection of Personal Data may override its legitimate interest in sending direct marketing communications.
The means of contact used for the direct and indirect marketing activities referred to in points (4) and (5) above may be either automated (email, SMS, MMS, fax, calls without an operator) or traditional (calls with an operator, postal mailings). In any event, the user may withdraw his or her consent, including partially, for example by consenting only to traditional means of contact.
With regard to means of contact involving the use of the user’s telephone details, we remind the user that direct marketing activities by Medicor Tutor will be carried out after checking whether the user is registered in the Public Opt-Out Register (Registro delle Opposizioni) established pursuant to and for the purposes of Presidential Decree (D.P.R.) No. 178 of 7 September 2010, as subsequently amended.
The provision of data is not mandatory, but it is essential for the proper fulfilment of pre-contractual or contractual obligations and, in general, for carrying out all the formalities required by law. Any refusal to provide Personal Data, or to give consent to their processing or to their disclosure to parties belonging to the aforementioned categories, will result in difficulties in the performance of any contractual relationships between the user and Medicor Tutor, as well as in the use of the related services.
As provided for by the Regulation, where the user has given his or her consent to the processing of his or her Personal Data for one or more of the purposes for which it was requested, the user may, at any time, withdraw it in whole and/or in part without affecting the lawfulness of processing based on consent given before its withdrawal. The procedure for withdrawing consent is very simple and intuitive: the user need only contact the Medicor Tutor Privacy Office using the contact channels set out in this privacy notice.
In addition to the above and for the sake of simplicity, should the user receive advertising emails from Medicor Tutor that are no longer of interest to him or her, it will be sufficient to click on the unsubscribe button at the bottom of such emails in order to stop receiving any further communications, including through other contact channels for which his or her consent had been obtained (SMS, MMS, post, fax, telephone calls).
As provided for by Article 15 of the Regulation, the user may access his or her Personal Data, request their rectification and updating if incomplete or incorrect, request their erasure where they have been collected in breach of a law or regulation, and object to the processing on legitimate and specific grounds.
In particular, set out below are all the rights that the user may exercise, at any time, vis-à-vis Medicor Tutor:
To exercise all the rights identified above, the user need only contact Medicor Tutor in the following ways:
The user’s information is protected so as to guarantee the user’s confidentiality and security. Medicor Tutor adopts all the security measures and the physical, electronic and organisational procedures required by the legislation in force. The Medicor Tutor website uses standard SSL encryption systems to increase the security of data transmission. Although Medicor Tutor does everything reasonably possible to protect the user’s Personal Data, Medicor Tutor cannot guarantee the complete and total security of the data transmitted by users during communication; Medicor Tutor therefore strongly encourages the user to take all precautionary measures to protect his or her Personal Data when browsing the Internet. For example, the user is invited to use a secure browser.
The Medicor Tutor website contains links to other websites. Medicor Tutor does not share the user’s Personal Data with these websites and is not responsible for their practices with regard to the protection and processing of Personal Data. Medicor Tutor invites the user to read the privacy policies of such websites in order to understand how such third-party websites process and collect his or her Personal Data.
Medicor Tutor will amend this Privacy Policy from time to time. Should Medicor Tutor substantially change the manner in which it processes the user’s Personal Data, it will make such information available by publishing a specific notice on its website.
The Data Controller of the Personal Data for the purposes set out in this privacy notice, which will therefore act as Data Controller in accordance with the relevant definition contained in Article 4(7) of the Regulation, namely “the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data”, is Medicor Tutor Limited, a company registered in Hong Kong, No 2517208, with its registered office at Wing Hing Commercial Building Unit 25A, 25/F, 139 Wing Lok Street - Sheung Wan.
This website is operated by Medicor Tutor; the Data Processor is Medicor Tutor Limited, a company registered in Hong Kong, No 2517208, with its registered office at Wing Hing Commercial Building Unit 25A, 25/F, 139 Wing Lok Street - Sheung Wan. The list of Data Processors is kept up to date and will be sent to you upon request.
The user’s Personal Data will be processed by Medicor Tutor within the territory of the European Union.
Should it become necessary, for technical and/or operational reasons, to engage parties located outside the European Union, we hereby inform the user that such parties will be appointed as Data Processors pursuant to and for the purposes of Article 28 of the Regulation, and that the transfer of Personal Data to such parties, limited to the performance of specific processing activities, will be governed in accordance with Chapter V of the Regulation. All necessary precautions will therefore be taken in order to ensure the fullest protection of the user’s Personal Data, basing such transfer: (a) on adequacy decisions concerning the recipient third countries adopted by the European Commission; (b) on appropriate safeguards provided by the recipient third party pursuant to Article 46 of the Regulation; (c) on the adoption of binding corporate rules (so-called corporate binding rules).
In any event, the user may request further details from Medicor Tutor where his or her Personal Data have been processed outside the European Union, by requesting evidence of the specific safeguards adopted.
Should the user have any questions or concerns regarding the collection, use, processing, disclosure or dissemination of his or her Personal Data, the user may send an email to the email address info@medicortutor.com for the kind attention of the Medicor Tutor Privacy Office.
This document was updated on 20/05/2018
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