IED Istituto Europeo di Design S.p.A. (hereinafter even “IED”) a company registered in Italy, whose registered office is at Via Bezzecca no. 5, 20135 Milano, registered in the Business Registry of Milan, Registration Number, Tax Code and VAT No. 06525850969
The Service comprises a suite of online services provided by IED, including but not limited to
an online IED Community Directory
the Community Messaging Service class emailer,
Life-Long Email Forwarding Address service (“LEFA”),
a User-to-User Community Messaging service, and
the IED Community Clubs service.
for alumni Users > PEOPLE DIRECTORY (PROFILE, STORIES, PORTRAITS), WALL, GROUPS, MY BUSINESS
for companies/Employers Users> COMPANY SHOW CASE, JOB POSTS
IED Intellectual property and copyright.
Rules for Submission of User Content and license grant by Users.
You retain ownership of all of Your intellectual property rights in any content created, posted, or shared by You, on or through the Service and any personal data, job postings, resumes, responses or displaying any content, information, data, text, software, music, sound, photographs, graphics, video, messages or other materials (the “User Content”). IED does not claim ownership of Your User Content.
Without prejudice to the above, by using the Service and the Site, including without limitation by submitting any User Content to the Site or use relating to, in connection with or arising out of your use of the Site/Service, You grant IED a nonexclusive, irrevocable, worldwide, perpetual, unlimited, assignable, sublicensable, fully paid-up and royalty-free right to use, copy, prepare derivative works of, improve, distribute, publish, remove, retain, add, process, analyze, use and commercialize such User Content, and including after Your termination of Your account or the services, provided that if such User Content is your resume information, our right shall only be in connection to your job search through use of the Site/Service. You also grant a nonexclusive, worldwide, perpetual, unlimited, fully paid-up and royalty-free right to use and publish the name or any of the trademarks, service marks, designs, and logos, domain names, and other distinctive brand features of the entity that You are employed by, represent, are the agent of, associated with or are acting on behalf of (e.g., the university, college, or other institution, or as an employer or recruiter as the case may be) for promoting and redistributing part or all of the Site or the Services (and derivative works thereof) in any media formats and through any media channels (including, without limitation, on the Site, third party websites and feeds), and including after Your termination of Your account or the services. You also hereby do and shall grant each user of the Site who has access to your User Submitted Content, a non-exclusive, perpetual license to (i) access your User Content through the Site/Service, solely for internal employment and hiring purposes, and (ii) use, reproduce, distribute, prepare derivative works of, display and perform such User Content, solely for internal employment and hiring purposes, including after Your termination of Your account or the Services.
You also represent and warrant that You have all the rights, power and authority for yourself and your employer and/or the entity you represent, or are the agent of or associated with or acting on behalf of (e.g., university, college or other institution, or as an employer or recruiter) and that entity has authorized You to grant the licenses in this section. You acknowledge that all User Content, accessed by You using the Site/Service is at your own risk and You will be solely responsible for any damage or loss to You or any other party resulting therefrom. IED do not guarantee that any User Content You access on or through the Services/Site is or will continue to be accurate and IED make no representations or warranties as to the accuracy, truth, or security of candidate materials submitted through the Site/Service.
Limited use license grant by IED
Restrictions on use
You must respect IED’s ownership of the IED Content and Trademarks. You will not: (a) change or delete any proprietary notices from materials printed or downloaded from the Site/Service; (b) refer to or attribute any information to IED or its licensors in any public medium (e.g., press release, websites) for advertising or promotion purposes, or for the purpose of informing or influencing any third party; (c) use or reproduce any Trademark of, or imply any endorsement by or relationship with IED or its licensors; (d) modify, create derivative works of, decompile or otherwise attempt to extract source code from us, unless you are expressly permitted to do so under an open source license or we give you express written permission; (e) copy or adapt the HTML code used to generate web pages on the Site; (f) use or attempt to use engines, manual or automated software, tools, devices, agents, scripts robots or other means, devices, mechanisms or processes (including, but not limited to, browsers, spiders, robots, avatars or intelligent agents) to navigate, search, access, “scrape,” “crawl,” or “spider” any web pages or any services provided on the Sites other than the search engine and search agents available from IED on the Site and other than generally available third party web browsers (e.g., Internet Explorer, Firefox, Safari); or (g) aggregate, copy or duplicate in any manner any of the IED Content. Use, reproduction, modification, distribution or storage of any IED Content or User Content for other than purposes of using the Service/Site is expressly prohibited without prior written permission from IED. You shall not sell, license, rent, or otherwise use or exploit any IED Content or User Content for commercial use or in any way that violates any third party right.
IED’s reservation of rights
Users’ restrictions and responsibilities
Employers and Recruiters
All employers submitting User Content, including but not limited to all job postings, will only submit User Content that is accurate, true, not misleading or deceptive in any manner, and fully in compliance with all applicable laws (including laws prohibiting employment discrimination). All employer User Content that are job postings must be for actual job listings in compliance with all applicable laws and (i) may not contain any form of advertisement, promotion or endorsement, other than promotion of the job itself, (ii) require any form of upfront payment or referrals to other candidates or (iii) represent job postings that direct the user to a website other than the employer’s website. Employers will comply with any recruitment policies published by universities at which the employer wishes to recruit from, including but not limited to all non-discrimination policies adopted by such institution. All employers are solely responsible for their own hiring determinations: IED does not take any liability nor obligation in relation to this.
You agree to provide accurate and complete registration information, and it is Your responsibility to inform IED of any changes to that information. Each registration is for a single individual only, unless specifically designated otherwise on the registration page. You are responsible for preventing such unauthorized use and for maintaining the confidentiality of Your account. You must notify IED immediately if You believe there has been unauthorized use.
Rules of Conduct.
You may not post violent, nude, partially nude, discriminatory, unlawful, infringing, hateful, disturbing, pornographic, or sexually suggestive photos or other content via the Service.
You may not defame, stalk, bully, abuse, harass, threaten, impersonate or intimidate people or entities and You must not post private or confidential information via the Service, including, without limitation, Your or any other person's credit card information, social security or alternate national identity numbers, non-public phone numbers or non-public email addresses.
You may not use the Service for any illegal or unauthorized purpose. You agree to comply with all laws, rules and regulations (for example, state, local and provincial) applicable to Your use of the Service and Your User Content, including but not limited to, copyright laws.
You must not interfere with or disrupt the Service or servers or networks connected to the Service, including by transmitting any worms, viruses, spyware, malware or any other code of a destructive or disruptive nature.
You must not create accounts with the Service through unauthorized means, including but not limited to, by using an automated device, script, bot, spider, crawler or scraper.
You must not contact other users in any manner or for any purpose other than that which is expected, solicit login information or other personal information from any other user, or send unsolicited mail or email, make unsolicited phone calls or send unsolicited faxes to any user.
You may only make non-commercial uses of the Service and Service Content. Use of Service or the Service Content for any commercial, public or political purpose is strictly prohibited. Prohibited activities include, but are not limited to: (1) activities that are illegal or fraudulent; (2) use that inaccurately implies endorsement, approval, or sponsorship by IED (or any individual officer or employee of IED ); (3) use that can be confused with official communications of IED or its officers or employees;
and (4) print or electronic mass mailings (sometimes known as "spamming"), solicitations for commercial services.
Certain areas of the Service provide tools for the exchange of ideas and information between users, including in the form of direct messaging. IED is not responsible or liable for any content, including User Content, that is posted or distributed pursuant to such user to user exchanges. The views and opinions expressed by users are theirs alone, and are not endorsed by, and should not be ascribed to IED. You are solely responsible for all User Content You post, and You assume all risks relating to its use by others and others’ reliance on its accuracy.
No guarantee of results
Neither IED nor its partners are an employment agency or a recruiting firm, and neither makes any representations or guarantees regarding the effectiveness or timeliness of the Site/Service in meeting the employment objectives of Users. Neither IED nor its partners make any guarantee that employers will find suitable candidates, that documents posted by users will result in candidates being hired or positions being filled, and neither is responsible for any employment decisions, for whatever reason made, made by any User.
Unlawful Activities; Termination of access.
Third party content
IED disclaims all liability for any third party content or communications that may appear on the Site/Service, may be accessible via links from this Site/Service, or any communications directed to You from any third party directly or indirectly in connection with this Site/Service (collectively, “Third Party Content”), or any actions you may take or refrain from taking as a result of any Third Party Content. You are solely responsible for assessing and verifying the identity and trustworthiness of the source and content of any Third Party Content. IED assumes no responsibility for verifying, and makes no representations or warranties regarding the identity or trustworthiness of the source or content of any Third Party Content. IED shall not be responsible for and assumes no liability for any infringement, mistakes, misstatements of law, defamation, slander, libel, omissions, falsehood, obscenity, pornography or profanity in the statements, opinions, representations or any other form of content contained in any Third Party Content appearing on the Service/Site or elsewhere. You understand that the information and opinions in the Third Party Content is neither endorsed by nor does it reflect the belief or opinion of IED. Further, information and opinions provided by employees and agents of IED in interactive areas are not necessarily endorsed by IED and do not necessarily represent the beliefs and opinions of IED.
Linking to the site
You shall not distribute on or through this Site/Service any postings containing any advertising, promotion, solicitation for goods, services or solicitation for others to become members of any enterprise or organization without the express written permission of IED. Notwithstanding the foregoing, in any interactive areas of this Site/Service, where appropriate you (a) may list along with Your name, address and email address, Your own web site’s URL and (b) may recommend third party web sites, goods or services so long as You have no financial interest in and receive no direct or indirect benefit from such recommended web site, product or service or its recommendation. In no event may any person or entity solicit anyone with data retrieved from this Site/Service.
Nothing on the Site shall be considered an endorsement, representation, or warranty with respect to any user or third party, whether in regards to its web site, products, services, hiring, experience, employment or recruiting practices, or otherwise.
Limitation of Liability; Indemnification.
THIS SERVICE AND ALL ITS CONTENT ARE PROVIDED “AS IS” AND WITHOUT WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED.
IED DOES NOT APPROVE OR ENDORSE ANY USER CONTENT.
IED IS NOT LIABLE TO USERS OR VISITORS FOR ANY DAMAGES
OF ANY KIND ARISING OUT OF THE USE OF THE SERVICE, SERVICE CONTENT, OR USER CONTENT REGARDLESS OF WHETHER IED HAS BEEN ADVISED OF THE POSSIBILITY OF DAMAGES.
User Accounts; Account Termination Policy.
Links to Other Services. IED may provide links to websites operated by third parties, including but not limited to, websites operated by IED, as a convenience for our users. IED does not endorse or accept responsibility for the content or the use of third-party websites. If You use third-party sites, You do so solely at Your own risk. Links do not imply that IED is affiliated or associated with any linked site.
In compliance with Section 13 of European Data Protection Regulation no. 2016/679 (hereinafter also “GDPR”) setting provisions about data protections, we inform you that your collected data will be processed by the following data controllers:
• ISTITUTO EUROPEO DI DESIGN S.p.A., with registered office in Milano, Via Bezzecca 5, in the person of its legal representative pro tempore (also “IED”).
• I.L.E.M. S.r.l.,with registered office in Como, Via Petrarca 9, in the person of its legal representative pro tempore (also “ILEM”).
• ISTITUTO EUROPEO DI DESIGN SL, with registered office in C/ Flor Alta 8, Madrid 28-MADRID, in the person of its legal representative pro tempore.
• ISTITUTO EUROPEO DI DESIGN-BRASIL, with registered office in Rio de Janeiro, Avenida João Luís Alves. Nº 13, CEP 22.291-090, Urca, in the person of its legal representative pro tempore.
• ISTITUTO EUROPEO DI DESIGN – SÃO PAULO (IED-SÃO PAULO), with registered office in São Paulo, Brasil, Rua Maranhão, nº 617, CEP 01.240-001, Higienópolis, in the person of its legal representative pro tempore.
∙(hereafter, individually the “Company” or collectively “Companies”).
The Company offers a platform for networking, work opportunities and continuous learning called “IED Alumni Network” (hereafter, the “Platform”) to its users, which have subscribed on the Platform and as such have a user account (hereafter, the “Users”). The Platform is available at the following URL address www.iedalumni.com and https://ied.hivebrite.com/.
The Company uses a solution called “Hivebrite”, which enables the import and export of user lists and data, the management of content and events, the organization of emailing campaigns and opportunity research and sharing.
In this regard, as data controller, the Company is particularly aware and sensitive with regard to the respect of its Users privacy and personal data protection. The Company commits to ensure the compliance of the processing it carries out as data controller in accordance with the applicable provisions of the “D.Lgs. 196/2003” of Italian Law and the EU Regulation EU 2016/679 regarding data protection dated April 27, 2016.
IED and ILEM have appointed a Data Protection Officer than can be contact sending an email to [email protected]
COLLECTED PERSONAL DATA
1.1 When subscribing on the Platform
When subscribing on the Platform, the User is informed that its following personal data is collected:
for COMPANIES/EMPLOYERS USERS
Password (to be set up)
For ALUMNUS USER
IED school location
Password (to be set up)
The User commits to providing only accurate, exhaustive, and regularly updated data regarding its identity, its content and any information in general. Under no circumstances shall the Company be liable for any data that is illegal contrary to public order provisions.
In the event the User does not consent to the collection of the above-mentioned data, it shall be informed that it cannot have access to the Platform.
1.2 During the use of the Platform
The User may validly publish, at its own initiative and being aware that other Users may see them, any content on the Platform which shall be kept by the Company:
The User commits not to publish any content which contains, including but not limited to, any remarks/images/pictures, contrary to application legislation and regulations, to public order and good morals, or affecting the rights of third parties, including but not limited to:
Identity fraud of a third person;
Remarks/publish pictures or images that are violent, defamatory, offensive, malicious, obscene, inciting to discrimination or hatred, racist, xenophobic, anti-Semitic, condoning or approving war crimes, inciting to committing a crime, offense, act of terrorism, or contrary to the security of minors;
Counterfeiting the intellectual property rights of a third person;
Commercial canvassing or elements that could be qualified as unfair competition.
In any event, the Company shall not be liable for the content, accuracy, or up-to-date state of the information freely published by the User.
The User consents that, following the publication of the content, its information will become public on the Platform and that as such, same information will be published, modified, translated, reproduced in any form and accessible, saved and reproduced by other Users and the Company.
In most cases, Users post contents without previous moderation from the Company. The Company does not alter the content or information of the User, except under exceptional circumstances. The Company reserves its right to freely delete or amend the content or information of the User, without prejudice to the Users.
The User is informed that the Company does not collect any particularly sensitive data within the meaning of applicable legislation and regulations.
1.3 Cookie data
The Company informs the User that Hivebrite, as well as its subcontractors, uses a tracking technology on its terminal such as cookies whenever the User navigates on the Platform.
A cookie is a message that, subject to the User settings, is sent to its terminal when the User navigates on a website. The aim is to collect data regarding the internet navigation of the User to send tailor-made services to its terminal (computer, mobile phone or tablet).
THE PURPOSE OF THE DATA PROCESSING
The Company and its subcontractors collect, process and host personal data that are freely transferred by the User when accessing the services proposed by the Platform.
Purpose of the processing
When subscribing on the Platform:
When using the Platform:
The Company only collects and processes the User’s personal data for the purpose for the optimal implementation and use of the Platform that is put at its disposal.
USER’S CONSENT TO THE COLLECTION OF DATA
The Company informs the User that no personal data within the meaning of applicable legislation and regulations shall be collected without the prior explicit consent of the User.
The Company and its subcontractors commit to a lawful and fair collection of the User’s data, in full transparency and in compliance with the rights conferred to the User pursuant to applicable legislation and regulations.
LENGHT OF DATA RETENTION
The Company informs the User that the data is retained only during the length of the User’s subscription on the Platform.
Following the termination of said subscription, the data collected upon the subscription as well as the content published by the User on the Platform shall be deleted after a period no longer than 90 days.
In accordance with application legislation, cookie data will be automatically deleted thirteen (13) months following their placing on the User’s terminal.
OBLIGATIONS OF THE COMPANY
As data controller and in accordance with applicable legislation and regulations, the Company commits to:
Keep a processing register;
Put in place all necessary technical and organizational appropriate measures in order to ensure the security, confidentiality, integrity, availability and the resilience of the process systems and services;
Limit the access to the Users’ data to the persons duly authorized to this effect;
Increase awareness and train staff members regarding the processing of personal data;
Guarantee to the Users their rights regarding the access, portability, erasure, rectification and opposition in relation to the collection and processing of their data;
Notify the competent supervisory authority of any security breach presenting a serious risk regarding the rights and liberties of the Users within the terms provided for under the applicable laws and regulations;
Only subcontract the processing of the Users’ data to Hivebrite which, as subcontractor, has put all necessary technical and organizational measures in order to guarantee the security, confidentiality, integrity, availability and resilience of the processing systems and services.
For any additional information on Hivebrite, you can consult the webpage available at the following address: www.hivebrite.com.
EXERCISE OF THE USERS’ RIGHTS
The User is duly informed that it disposes at any time, meaning prior to, during or following the processing of data, to a right to access, copy, rectify, oppose, port, limit and delete its data, as stated from art. 15 to 22 of the GDPR.
The User can exercise its rights by sending an email to the following address [email protected] provided that the User justifies its identity.
In addition, in the event the User considers that its rights have not been respected, the User of which the personal data is collected can file a reclamation before the competent supervisory authority. For any additional information, you can review your rights on the websites of the competent authorities.
The competent supervisory authority is defined on the following website:
HOSTING OF THE USERS’ PERSONAL DATA
The personal data collected by the Company is hosted by the following service providers:
Nature of the hosting
Microsoft Azure Cloud
Hosting of all data and content produced / provided by the User, as well as images, profile pictures and backups
In case of breach of its systems, or theft, deletion, loss, alteration, disclosure, unauthorized access, or any other malicious act, the Company commits to treat the breach accordingly to sections 33, 34 of GDPR.
The malicious act presenting a serious risk regarding the rights and freedoms of the Users shall be notified to the competent supervisory authority.
The User is duly informed that the Company shall not be liable in case of breach of IT security which can cause damages to computer equipment, as well as in case of breach or malicious act by a third party targeting the system or the Platform.
COOKIE MANAGEMENT CONFIGURATION AND OTHER DATA
The User’s consent is requested through a banner at the bottom of the Platform homepage.
In case of consent, the User’s internet navigator shall automatically transmit to the Company the data collected and detailed under Article 1.2.
The User is informed that the cookies and trackers will be automatically deleted following a period of thirteen (13) months.
The User may at all times configure its navigator in order to prevent the creation of cookie files.
However, certain functionalities of the services proposed by the Platform may not function properly without cookies. In addition, even if most navigators are configured by default and accept the creation of cookie files, the User has the possibility to choose to accept the creation of all cookies other than the functional cookies or to systematically decline them or to choose the cookies it accepts depending on the issuer by configuring the following settings:
Click on the settings menu, followed by “Internet Options”;
Under the “General” tab on the upper-left hand side, scroll down to “Browsing history”;
Check the "Temporary Internet files and website files," "Cookies and website data," "History," and "Download History" boxes;
Click on “Delete”;
Close out of Internet Explorer and reopen it for changes to take effect.
Click on your Tools bar;
Click on “Preferences”;
On the menu to the right, select "Privacy";
Under the “history option”, there is a shortcut titled "clear your recent history", click on that;
Select only the top four options and hit clear now.
Click on “Safari” in the top left corner of the finer bar;
Click on “Preferences”;
Click on the “Privacy” tab;
Click on “Manage Website Data”;
Click on “Remove All”;
Click “Remove Now”.
Click the Tools menu;
Click on “More tools”;
Clear browsing data;
At the top, choose a time range.
To delete everything, select “All time”;
Next to "Cookies and other site data" and "Cached images and files", check the boxes;
Click on “Clear data”.
In order to configure the data settings, please find below the recommendations of the Company:
Data collected for the following purposes:
General data enabling the proper functioning of the Platform and the improvement of the services proposed by the Platform.
Data that is essential for the provision of services by the Company, non-configurable.
Data regarding the management of payment services proposed by the Platform, delinquencies and litigation.
Data that is essential for the provision of services by the Company, non-configurable.
Data enabling the creation of User files;
Mailing of commercial offers, advertisements or newsletters of the Company and/or its commercial partners if this has been accepted by the User.
Management by the User in its login area;
Unsubscribing to newsletters / commercial offers by clicking on the appropriate link;
Compilation of statistics with the purpose of improving the functioning of the Platform notably by analysing the traffic of the Platform (modules which are more or less consulted, preferred routes, level of activity depending on the day of the week et hour of the day, etc.) and by adapting the Platform according to the needs and tastes of the Users (recognition of the User when it accesses the Platform).
Clearance of cookie history in the navigator pursuant to the above instructions;
Using the “incognito mode” whilst navigating;
Management of requests to access, rectify, delete, limit and oppose.
PERSONS AUTHORIZED TO ACCESS THE USERS’ DATA
The data of the Users are accessible only to the persons duly authorized to do so by the Company for administrative or maintenance purposes of the Platform to the exclusion of any commercial use, and if applicable, in order to enforce the rights exercised by the Users regarding their data (in particular the right to access, rectify, oppose, port and to be forgotten).
The Company informs the User that, outside of hosting services, it uses the following subcontractor:
The company KIT UNITED for its HIVEBRITE solution, a French société par actions simplifiée with a capital of 284.280,00 Euros, registered with the Paris Companies register under the number 75339171300017, having its registered office at 8, rue de la Grande Chaumière, 75008 – Paris.