Privacy policy pursuant to art. 13 of Regulation (EU) 2016/679 (GDPR)
Please be informed that the processing of personal data provided by you through accessing this Platform and/or App, whether via Corporate Login and/or corporate Gmail or by creating a username and password, will be carried out by the Max Mara Group company, or its affiliate, with which you have an employment relationship, and whose identifying data are already known to you (hereinafter also the “Company” and/or the “Data Controller”).
The Company acts as the data controller. The processing will be managed through Max Mara Fashion Group S.r.l. with registered office in Via Pietro Giannone 10, 10121 Turin, as the data processor of the Company, where applicable, pursuant to art. 28 of the General Data Protection Regulation (EU) 2016/679 (hereinafter “GDPR”).
The personal data provided by you may be used by the Company, by Max Mara Fashion Group S.r.l., by the companies of the Max Mara Group and by their affiliates and/or partners who offer services to support such processing, also through authorized persons, to allow access to the E-learning platform (hereinafter “Platform”) and the Edu-Hub App (hereinafter “App”) for the use of content dedicated to personnel training.
Through accessing the Platform and the App, the e-mail address and/or tax code provided by the user will be acquired, and data on training activities used and monitoring data necessary to verify the completion of courses will also be acquired. For some content available on the Platform and the App, the user may also optionally, explicitly and voluntarily send additional personal data (e.g., image) which will be processed only for the performance of specific training activities and processed in accordance with what is indicated in this privacy policy.
Purpose and methods of processing​
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The collection and processing of data within the Platform and the App are aimed solely at providing training courses in the various ways they are presented (e.g., webinars and/or social learning) for monitoring the training activities used to verify the completion of courses, for verifying over time the correct learning of the training contents also through forms of direct interaction with the user (e.g., through gamification or simulation of training scenarios), the fulfillment of legal obligations in relation to mandatory personnel training, where applicable, incumbent on the Company, as well as for the processing of anonymous and aggregate statistics and analyses functional to verifying the sustainability and effectiveness of training projects; the processing is in any case minimal and limited to operational purposes only.
It is understood that your participation in the gamification activities that will be submitted to you, also in the form of simulation, according to the regulations that will be made available to you from time to time, is optional and your adherence or non-adherence to them does not determine any element of evaluation of your work performance, being exclusively aimed at verifying the effectiveness of the awareness and training activities provided.
The collection and processing of your personal data concern personal and contact data (name, surname, e-mail address, tax code), the company of belonging, any scores obtained in simulation and gamification activities and, for social learning activities also images, will be processed limited to the operations indispensable to allow you to use the content dedicated to personnel training and, if you have activated push notifications using the App, for sending communications relating to the publication of new training content on the Platform and finally, for the Company's fulfillment of specific obligations provided for by community law, laws and/or regulations.
All your data will be processed in Europe, will be stored in specific electronic and/or paper archives, or in any other suitable support, and kept under constant control with adequate operating procedures and security measures, pursuant to art. 32 of Regulation (EU) 2016/679, to guarantee the security and confidentiality of your personal data, from illicit or incorrect uses and unauthorized access and in order to prevent the loss of the data themselves.
Legal basis and lawfulness of processing​
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The processing of personal data for the aforementioned purposes is necessary to allow participation in the content dedicated to personnel training available through the Platform. The legal bases for the processing of personal data provided by you to the Data Controller are the performance of a contract to which the data subject is party (Article 6.1.b Regulation 679/2016/EU) and the fulfillment of a legal obligation to which the Data Controller is subject (Article 6.1.c Regulation 679/2016/EU).
Your personal data will be kept by the Company for the entire duration of your employment relationship and upon its termination for the period required by law in cases where training is functional to the fulfillment of legal obligations. With regard to the content and training projects established by the Company and the Max Mara Group for internal needs, the data will be kept for the period of use of the dedicated content and for a short subsequent period (up to a maximum of 12 months after the date of termination of your employment relationship) functional to the statistical processing and analyses indicated above and their subsequent anonymization or deletion.
Scope of communication and processing​
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Your data will not be disseminated, will be collected in paper and digital archives only to the necessary extent (according to the principle of necessity sanctioned by art. 5, paragraph 1, letter c of the GDPR) and processed with methods appropriate to the declared purposes; furthermore, they may be processed by employees or collaborators of the Company appointed for processing and possibly by third-party companies – carefully selected and appointed Data Processors pursuant to art. 28 GDPR, – including group HR functions, the Max Mara Group companies to which the Company belongs for technical-IT support services in the management of the Platform and the App – who need to access the data to perform precise services necessary or functional to the performance of training activities (e.g., Docebo SpA).
In the event of any transfer of data to third countries with legislation different from that of Europe, measures will be adopted to ensure that this occurs in compliance with European legislation, including the adoption of Standard Contractual Clauses, if applicable. Furthermore, to the extent permitted by law, the Company may communicate personal data to third parties in the event of reports relating to the use of the Platform and/or the App, where deemed necessary to investigate, prevent or take action regarding illegal activities, suspected fraud or in cases where the Company, at its sole discretion, deems that the use of the Platform and/or the App by the user is incompatible with the terms of use of the Platform or the App.
Cookie Policy and similar processes​
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For further general information on the use of cookies on this Platform and their enabling and disabling, please refer to the Cookie Policy section. The Platform and the App primarily use technical cookies strictly necessary for its operation, as well as similar cookies, pursuant to the Guidelines of the Italian Data Protection Authority on cookies and other tracking tools of 10 June 2021, aimed at measuring traffic and analyzing user behavior to improve the use of the Platform and/or the App, subject to the activation of the necessary masking mechanisms and without the use of direct and unique identifiers as provided for by the aforementioned Guidelines.
Data subject rights​
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You will be granted the rights referred to in Chapter III of Regulation (EU) 2016/679 and, in particular, at any time you will have the right to access your personal data, to request their rectification, updating and deletion, if incomplete, erroneous or collected in violation of the law, as well as to object to their processing for legitimate reasons by writing to the Data Controller who can be contacted at the following addresses: Via Pietro Giannone 10, 10121- Turin (Italy); email: ref_privacy@mmfg.it.
You will also have the right to lodge a complaint with the Italian Data Protection Authority pursuant to art. 77 of the GDPR.
Finally, we inform you that Max Mara Fashion Group S.r.l. has appointed its Data Protection Officer who can be contacted at the following addresses: Via Pietro Giannone 10, Turin (Italy); e-mail: dpo@mmfg.it.
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Last update: June 2025