Privacy Policy

Protecting your privacy is one of our primary objectives

“iCONS – Innovative Consulting srl,” with its registered office at Galleria J.F. Kennedy 10/A, Seregno, ZIP 20831 (hereinafter “iCONS”), is committed to safeguarding the privacy of its users. This document allows you to understand our privacy policy, how your personal information is handled when you use our services, and, if applicable, to provide consent for the processing of your personal data pursuant to Article 13 of EU Regulation 2016/679 (hereinafter: the “Regulation”). Any information and data you provide, or that are otherwise collected in the context of iCONS services, will be processed in compliance with the provisions of the Regulation and the confidentiality obligations guiding iCONS’ operations.

In accordance with the principles of the Regulation, iCONS processes personal data in a manner that is lawful, fair, transparent, purpose-limited, data-minimizing, accurate, and secure.

More information and details about Data Processing: Controllers, Personal Data, Purposes, Legal Basis, Rights, and More

TABLE OF CONTENTS

1. Data Controller
2. Personal Data Subject to Processing
3. Purpose of Processing
4. Legal Basis and Mandatory or Optional Nature of Processing
5. Recipients of Personal Data
6. Transfers of Personal Data
7. Data Retention
8. Data Subject Rights
9. Amendments

1. Data Controller

The data controller of the processing carried out through the Sites is iCONS, as defined above. The Controller is available for any information regarding the processing of personal data by iCONS, including the list of data processors. You may contact the Controller by writing to: This email address is being protected from spambots. You need JavaScript enabled to view it..

2. Personal Data Subject to Processing

“Processing” of personal data refers to any operation or set of operations carried out with or without automated means and applied to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or any other form of making available, comparison or interconnection, restriction, erasure, or destruction.

Personal data processed may include, depending on your use of the Services, identifiers such as your name, email address, identification number, location data, online identifiers, purchases made, and other data capable of identifying you directly or indirectly (hereinafter “Personal Data”). Specifically, the Personal Data processed within the context of training services includes:

a. Data voluntarily provided by the data subject

When using the requested Services (e.g., an online course, online exam, or subscription to an application), you may process Personal Data of third parties (e.g., course participants or application administrators) that you submit. In such cases, you act as an independent data controller, assuming all legal obligations and responsibilities. You hereby fully indemnify iCONS against any claim, dispute, or damage arising from such third-party data processing in relation to the Services.

You also guarantee that any third-party Personal Data you provide or process in the use of the Service is based on an appropriate legal basis (e.g., the consent of the data subject) pursuant to Article 6 of the Regulation, legitimizing the processing of such information.

b. Cookie (in the context of the requested Services)

Cookies are small text files sent and stored on your computer or mobile device by the websites you visit, and retransmitted on subsequent visits. Cookies allow websites to remember your actions and preferences (e.g., login data, language, display settings) so that you do not have to re-enter them. Cookies are also used for authentication, session monitoring, and recording user activities, and may contain unique identifiers for statistical or advertising purposes.

During your navigation, you may also receive cookies from third-party websites (“third-party cookies”). Some functions of a website may not operate without cookies, which in some cases are technically necessary for the website’s functioning.

Different types of cookies exist: session cookies (deleted upon closing the browser) and persistent cookies (stored until a predetermined expiration date).

Under Italian law, explicit consent is not always required for technical cookies necessary for transmitting communications or providing a service explicitly requested by the user. The cookies used on iCONS websites and applications are exclusively technical.

WARNING: Disabling technical or functional cookies may render the Sites partially or completely inaccessible, or some features may not function correctly. You may need to manually re-enter information or preferences each time you visit the Sites.

3. Purpose of the data processing

iCONS processes Personal Data for the following purposes:

1. To provide the Services requested and to manage your user profile within the application, including data collection, storage, and processing necessary for operational, technical, and administrative management of the Services and related communications.
2. To respond to requests for assistance or information received via email, telephone, or chat through the “Contact Us” page (calls will not be recorded).
3. To comply with legal, accounting, and tax obligations.
4. To provide personalized commercial offers based on the products or services you purchased.
5. For security and fraud-prevention purposes, iCONS may use automatic systems to monitor user behavior on the website, including IP addresses, and may take measures to prevent fraudulent activities such as unauthorized sharing of online course access.

4. Legal basis and mandatory or optional nature of the processing

The legal basis for processing Personal Data for purposes under Section 3(a-b) is Article 6(1)(b) of the Regulation, as processing is necessary for the performance of contractual services. Providing Personal Data for these purposes is optional, but failure to do so prevents activation of the requested Services.

Processing under Section 3(c) is based on Article 6(1)(c) of the Regulation, as it is necessary to comply with legal obligations.

Processing under Section 3(d) (email marketing) is based on iCONS’ legitimate interest under Article 6(1)(f), and you may object at any time. Processing under Section 3(e) is also based on legitimate interest for fraud prevention under Article 6(1)(f). You may object by writing to This email address is being protected from spambots. You need JavaScript enabled to view it.   

5. Recipients of personal data

Personal Data may be shared for the purposes in Section 3 with:

1. Data processors assisting iCONS, including professional advisors, service providers, and technical maintenance personnel.
2. Authorities or entities to whom disclosure is legally required.
3. iCONS employees authorized to process Personal Data under confidentiality obligations.

A full list of data processors is available upon request at This email address is being protected from spambots. You need JavaScript enabled to view it.

6. Transfers of personal data

Some of the Services you purchase may be provided by iCONS partners. In such cases, in addition to processing carried out by iCONS under this Privacy Policy, your data will also be processed by the partner as an independent data controller.

The summary table below provides, for third-party products, the link to the partner’s privacy policy governing the processing of personal data.

 

 

7. Data retention

Personal Data processed for the purposes set out in Section 3(a-b) will be retained only for as long as strictly necessary to achieve those purposes. In any case, as such processing is carried out for the provision of Services, iCONS will process Personal Data for the duration permitted under Italian law to protect its legitimate interests (Arts. 2946 et seq. of the Civil Code).

Personal Data processed for the purposes set out in Section 3(c) will be retained for the period required by the specific legal or regulatory obligation.

In any case, iCONS reserves the right to retain your Personal Data for the period permitted under Italian law to protect its legitimate interests (Arts. 2947(1) and (3) of the Civil Code). Further information regarding the retention period and the criteria used to determine it may be requested by contacting the Data Controller.

8. Data Subject Rights

You have the right to request from iCONS, at any time, access to your Personal Data, correction or deletion of the same, or to object to their processing in the cases provided for under Article 20 of the Regulation. You also have the right to request the restriction of processing in the cases provided for under Article 18 of the Regulation, as well as to receive your data in a structured, commonly used, and machine-readable format (data portability), in the cases provided for under Article 20 of the Regulation.

Article 20 of the Regulation establishes the right to data portability, which allows you to receive the personal data you have provided to iCONS in a structured, commonly used, and machine-readable format, and to transmit it to another data controller.

All requests must be submitted in writing to This email address is being protected from spambots. You need JavaScript enabled to view it.

You also have the right to lodge a complaint with the competent supervisory authority (Italian Data Protection Authority), pursuant to Article 77 of the Regulation, if you believe that the processing of your data violates applicable law.

9. Amendments

This Privacy Policy is effective as of 23 October 2025. iCONS reserves the right to modify or update its content, in whole or in part, including due to changes in applicable laws and regulations. Should any amendments involve substantial changes to the processing of personal data or otherwise have a significant impact on data subjects, iCONS will take care to notify the data subjects appropriately.