Privacy Policy

Last update: 26/06/2025

This Privacy Policy explains how personal data is collected, used, and protected when you use the website www.harmoniccircleacademy.org, in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR) and other applicable data protection laws.

1. Data Controller

The data controller is:

Harmonic Circle Academy

Email: info@harmoniccircleacademy.org

2. Types of Data Collected

We may collect the following personal data:

• Email address and first name, when you subscribe to our newsletter

• Technical data such as IP address, browser type, and device information

• Usage data such as pages visited and time spent on the site (collected via cookies and analytics tools)

3. Purpose and Legal Basis of Processing

We process your personal data for the following purposes:

• To send newsletters and updates about our courses, events, and initiatives (based on your explicit consent – Art. 6.1.a GDPR)

• To manage user preferences and improve website performance (based on legitimate interest – Art. 6.1.f GDPR)

• To comply with legal obligations, if required

4. Newsletter and Data Processing via Brevo

We use Brevo (Sendinblue) to manage email subscriptions and send newsletters. When you subscribe, your data (name and email) is stored on Brevo’s servers.

Brevo may transfer data outside the European Economic Area (EEA). In such cases, it ensures appropriate safeguards, such as Standard Contractual Clauses approved by the European Commission.

You can unsubscribe at any time using the link provided in each newsletter or by contacting us directly.

5. Cookie Use and Consent

We use cookies to:

• Ensure proper website functionality (technical cookies)

• Analyze site usage (analytical cookies)

• Personalize user experience (only if consented)

We use the Complianz GDPR/CCPA Cookie Consent tool to manage your cookie preferences and obtain valid consent before setting non-essential cookies.

You may modify or withdraw your consent at any time via the Cookie Settings banner or through your browser preferences.

For more details, see our Cookie Policy (link alla tua cookie policy completa).

6. Third-Party Tools

The website uses:

• Google Analytics (with IP anonymization) for aggregated and anonymous traffic statistics

  These services may collect data via cookies and similar technologies. Consent is required before their activation.

7. Data Retention

We retain your personal data:

• As long as your subscription remains active

• Or until you withdraw your consent or request deletion

8. Your Rights (Art. 15–22 GDPR)

As a data subject, you have the right to:

• Access your personal data

• Request rectification or erasure

• Restrict or object to processing

• Withdraw your consent at any time

• Data portability (if applicable)

• Lodge a complaint with the Garante per la Protezione dei Dati Personali (www.garanteprivacy.it)

To exercise any of these rights, please contact us at:

📧 info@harmoniccircleacademy.org

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction.

10. Changes to this Policy

We may update this policy from time to time. Any changes will be published on this page.

Last revision: 10/06/2025

11. Contact

If you have any questions or concerns regarding this Privacy Policy or the way your data is handled, please contact:

📧 Email: info@harmoniccircleacademy.org