1. Data controller and contact
The data controller responsible for processing your personal data in connection with this website and our training activities is:
Coursedepneus Growth Academy
Via Giovanni Battista Pirelli, 13
20024 Milano MI, Italy
Phone: +39 02 8239 8854
For privacy-related questions, please use the contact form on our Contact page and mention “Privacy request” in your message.
2. Scope of this Privacy Policy
This Privacy Policy applies to personal data we process when you:
- visit or use our website at Coursedepneus.com,
- request information about our training on strategies for business growth through financial consulting,
- register for or participate in a cohort, executive intensive or in-company program, or
- receive emails or other communications from us in a B2B context.
3. Categories of personal data we collect
The specific data we process depends on how you interact with us. We may collect the following categories of personal data:
- Identification data such as your name, role, organisation and country.
- Contact details such as your business email address and phone number.
- Professional information such as your industry, size of your organisation and key responsibilities.
- Training-related data such as modules attended, dates, feedback you choose to provide and materials we share with you.
- Communication data such as messages sent via contact forms and notes from our conversations.
- Technical and usage data such as IP address, browser type, device information and basic analytics about how you use our website.
4. How we obtain personal data
We collect personal data from the following sources:
- Directly from you when you complete forms on our website, register for training, participate in sessions or contact us by phone or email.
- From your organisation if they enrol you in an in-company or group program and share participant details with us.
- Automatically through cookies and similar technologies when you visit our website (for more details see the cookies section and our separate Cookie Policy).
5. Purposes and legal bases for processing
We process your personal data only where we have a valid legal basis under the GDPR. Depending on the situation, we rely on the following legal bases:
- Contract performance – to prepare, deliver and manage your participation in our training programs, including registration, scheduling and issuing certificates or confirmations.
- Legitimate interests – for example, to respond to enquiries, maintain relationships with B2B contacts, improve our programs, protect our rights and prevent misuse of our services. When we rely on legitimate interests, we balance our interests with your rights and expectations.
- Consent – for certain optional activities such as sending newsletters or using non-essential cookies that track behaviour across websites. You can withdraw your consent at any time with future effect.
- Legal obligations – to comply with regulatory, tax and accounting requirements that apply to us in Italy and the European Union.
6. How we use your personal data
In practice, we use personal data for purposes such as:
- answering your questions and providing requested details;
- planning and delivering training sessions, including sending pre-work, materials and follow-up notes;
- adapting program content to the needs of participants and their organisations;
- sending B2B communications and invitations that we believe may be relevant for your role;
- improving our website, materials and processes based on aggregated and anonymised insights;
- fulfilling contractual and legal obligations, including bookkeeping and record keeping.
7. Data sharing and recipients
We do not sell your personal data. We share data only where it is necessary for the purposes described above, for example:
- with carefully selected service providers who host our systems, send emails, provide collaboration tools or help us manage registrations;
- with co-facilitators or external experts involved in a specific program, where needed for preparation and delivery;
- with your employer or commissioning organisation, if they enrol you in a program and require attendance reports or aggregated feedback, subject to clear agreements;
- with authorities or legal advisors where we are required or allowed to do so by law.
We require our service providers to handle personal data in line with data protection laws and our instructions.
8. International data transfers
Our primary operations are based in Italy. Some of our service providers may be located in other countries, including outside the European Economic Area (EEA).
Where personal data is transferred to a country without an adequacy decision from the European Commission, we implement appropriate safeguards, such as Standard Contractual Clauses or equivalent measures, and assess whether additional protections are needed.
You can contact us for more information about the safeguards applied to specific transfers that concern you.
9. Data retention
We keep personal data only for as long as it is necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.
- Enquiry and contact data is usually retained for up to 24 months after our last meaningful interaction, unless you become a participant.
- Participant data related to training contracts is typically retained for the duration of the engagement plus the period required by Italian tax and accounting rules.
- Newsletter subscription data is retained until you unsubscribe or we stop sending such communications.
Where possible, we anonymise data so that it no longer identifies you and may be used in aggregated form to improve our programs.
10. Your rights under the GDPR
As a data subject, you have the following rights, subject to conditions and exceptions set out in the GDPR:
- right of access to your personal data;
- right to rectification of inaccurate or incomplete data;
- right to erasure (“right to be forgotten”) in certain cases;
- right to restriction of processing;
- right to data portability, where applicable;
- right to object to processing based on our legitimate interests;
- right to withdraw consent at any time, where processing is based on consent.
To exercise your rights, please contact us using the details provided in the “Data controller and contact” section. We may ask for additional information to verify your identity before responding.
11. Cookies and similar technologies
Our website uses cookies and similar technologies to ensure basic functionality, understand how visitors use our pages and, where you agree, to improve the experience over time.
We distinguish between:
- Essential cookies that are necessary for the secure and proper functioning of the site.
- Preference and analytics cookies that help us understand which content is most useful and how visitors move through the site.
- Optional cookies that may be used for more advanced analytics or marketing, only with your consent.
You can learn more and manage your preferences in our Cookie Policy.
12. Security of your data
We implement technical and organisational measures appropriate to the risks associated with the personal data we process. These measures aim to protect data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.
- restricted access to personal data on a need-to-know basis;
- use of secure communication channels where appropriate;
- careful selection and supervision of service providers who process data on our behalf;
- regular review of our practices as our programs and tools evolve.
No system can be completely secure, but we are committed to continuously improving our safeguards and responding promptly to any potential incidents.
13. Training participants and corporate clients
When we work with participants as part of a cohort, executive intensive or in-company program, we may process additional information such as:
- attendance lists and group allocations;
- responses to exercises, case work and reflection questions, to the extent they are linked to identifiable individuals;
- feedback forms and follow-up notes that you choose to share.
Where programs are commissioned by your organisation, we agree in advance what information will be shared with them (for example, aggregated feedback versus named attendance). We encourage corporate clients to share this arrangement transparently with participants.
14. B2B communications and newsletters
We may use your business contact details to send you communications about upcoming cohorts, executive intensives, resources and events related to financial consulting and business growth.
Depending on your country and the context in which your details were collected, we may rely on consent or on our legitimate interests in maintaining B2B relationships. In every case, you can opt out at any time by using the unsubscribe option in our messages or by contacting us directly.
Opting out of such communications does not affect important service messages, for example information strictly necessary to deliver a program you are enrolled in.
15. Right to lodge a complaint
If you believe that our processing of your personal data violates data protection laws, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement.
In Italy, the competent authority is the Garante per la protezione dei dati personali. We would, however, appreciate the opportunity to address your concerns directly before you contact an authority.
16. Changes to this Privacy Policy
We may update this Privacy Policy from time to time, for example to reflect changes in our services, applicable laws or guidance from authorities.
The “Last updated” date at the bottom of this page indicates the most recent version. We encourage you to review the policy periodically to stay informed about how we protect your data.
If we make material changes that significantly affect your rights, we will provide additional notice where reasonably possible.
Last updated: 15 March 2025