Privacy & Cookie Policy

Note: this document is an informational template provided as a working basis. Before final publication it must be reviewed and adapted by a legal professional in light of actual operations and applicable law (EU Reg. 2016/679 – GDPR and Italian Legislative Decree 196/2003 as amended by Legislative Decree 101/2018).

1. Data controller

The controller of personal data is EULE Institute S.r.l. (hereinafter also "EULE Institute", "we" or the "Controller").

For any request regarding data processing or to exercise the rights provided by the GDPR, you can write to [email protected].

2. Types of data collected

Depending on your interaction with the site and the services, we may process the following categories of personal data:

• Contact and enrollment data: first name, last name, email address, phone number and course of interest, provided through the contact form on the site.
• Account and course-usage data: credentials, learning-progress data and interactions with the mentor, managed through the Eduspera e-learning platform (LMS).
• Payment data: course payments are handled through Stripe; EULE Institute does not store full payment-card details, which are processed directly by the service provider.
• Browsing and usage data: IP address, browser and device type, pages visited and data collected through cookies and similar technologies (see the Cookie section).

3. Purposes and legal basis of processing

• Responding to requests via the contact form — legal basis: performance of pre-contractual measures and legitimate interest in responding to requests (Art. 6.1 lett. b and f GDPR).
• Enrollment, course delivery and mentor support — legal basis: performance of the contract (Art. 6.1 lett. b GDPR).
• Payment processing — legal basis: performance of the contract and legal obligations, including tax and accounting obligations (Art. 6.1 lett. b and c GDPR).
• Newsletter and promotional communications (where enabled) — legal basis: consent of the data subject, revocable at any time (Art. 6.1 lett. a GDPR).
• Statistics and site improvement through analytics cookies — legal basis: consent of the data subject (Art. 6.1 lett. a GDPR).

4. Recipients and data processors

Data may be shared with third parties acting as data processors, on the basis of specific agreements pursuant to Art. 28 GDPR. In particular:

• Eduspera — LMS platform for course delivery and student-account management (master.euleinstitute.com).
• Stripe — provider of payment-processing services.
• Google — traffic analysis and measurement services (Google Analytics 4 and Google Tag Manager).
• Hosting and infrastructure providers — the site is hosted on infrastructure managed through Coolify and delivered through the Cloudflare network.

Data is not disseminated or sold to third parties.

5. Transfers outside the EU

Some providers (in particular Stripe and Google) may also process data outside the European Economic Area. In such cases the transfer takes place in compliance with the GDPR, on the basis of adequacy decisions of the European Commission or of Standard Contractual Clauses and additional appropriate safeguards.

6. Retention period

Data is kept for the time strictly necessary for the purposes for which it was collected. In particular: contact data is kept for the time needed to handle the request and, in the event of enrollment, for the duration of the contractual relationship; accounting and tax data is kept for the legally required terms (as a rule 10 years); data processed on the basis of consent is kept until that consent is withdrawn.

7. Rights of the data subject (Art. 15–22 GDPR)

As a data subject, you have the right to:

• access your personal data (Art. 15);
• request its rectification (Art. 16);
• request its erasure ("right to be forgotten", Art. 17);
• obtain the restriction of processing (Art. 18);
• receive your data in a structured and portable format (Art. 20);
• object to processing (Art. 21);
• not be subject to automated decisions (Art. 22);
• withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise your rights you can write to [email protected]. You also have the right to lodge a complaint with the competent supervisory authority (in Italy, the Garante per la protezione dei dati personali).

8. Cookies and tracking technologies

Cookies are small text files stored on your device that allow the site to work properly and, subject to consent, to collect statistical information.

Technical cookies (necessary)

These are essential for the operation of the site (for example to store the language, the light/dark theme and consent preferences) and do not require the user's consent.

Analytics cookies (statistical)

We use Google Analytics 4 and Google Tag Manager to understand how the site is used and to improve its content. These tools are activated only with the user's consent and, as things stand, may not yet be active. Consent can be given or withdrawn at any time through the cookie banner or your browser settings.

For more details on the categories, duration and management of cookies, see our dedicated Cookie Policy.

9. Changes to this notice

The Controller reserves the right to update this notice to align it with regulatory or organizational changes. The updated version will always be available on this page, indicating the date it was last updated.

10. Contacts

For any question regarding the processing of personal data: EULE Institute S.r.l. — [email protected].