The protection of your Personal Data is important to us.
We are committed to processing your Personal Data lawfully, fairly and transparently.
Please take the time to read this privacy notice on the processing of personal data.
PRIVACY NOTICE ON THE PROCESSING OF PERSONAL DATA PURSUANT TO ARTICLE 13 OF REGULATION (EU) NO. 2016/679
Pursuant to Article 13 of Regulation (EU) No. 2016/679 (hereinafter, the “GDPR”), Daikin Applied Europe S.p.A. (hereinafter, “DAE” or the “Controller”), a company belonging to the Daikin Group, wishes to inform you about the processing of Personal Data collected from you (hereinafter, the “User” or “You”) through the “Applied Academy” training platform, accessible at the following link https://daikinapplied.learnworlds.com (hereinafter, the “E-Learning Platform”).
1. Definitions
Data Controller or Controller: means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its designation may be provided for by Union or Member State law;
Data Processor or Processor: means the natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the data Controller;
Data Subject: means an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to that person’s physical, physiological, genetic, mental, economic, cultural or social identity;
Personal Data (or, in the plural, “Personal Data”): means any information relating to an identified or identifiable natural person (“data subject”);
Processing of Personal Data: means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or any other form of making available, alignment or combination, restriction, erasure or destruction;
Special Categories of Personal Data: means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data processed for the purpose of uniquely identifying a natural person, data concerning health and data concerning a natural person’s sex life or sexual orientation.
E-Learning Platform: means the Applied Academy website of Daikin Applied Europe S.p.A. available at the following link: https://www.daikinapplied.eu/
2. Data Controller and Data Protection Officer
The Data Controller is Daikin Applied Europe S.p.A., with registered office in Ariccia (Rome), 00072, Via Piani di S. Maria No. 72, VAT No. 01318801006, telephone 06-937311, fax 06-9374014, email: dataprivacy@daikinapplied.eu.
The Data Protection Officer (Data Protection Officer or DPO) may be contacted at the following addresses: Daikin Industries, Ltd. Osaka Umeda Twin Towers South, 1-13-1 Umeda, Kita-ku, 530-0001 Osaka, Japan; telephone: +81 6-6147-3321, email address: euprivacy@daikin.co.jp, by writing to Daikin’s registered office.
3. Categories of
Personal Data processed
DAE will process the following categories of Personal Data provided by the User:
- Browsing data, such as, by way of example, the hardware model, operating system, mobile network information and the country from which access takes place, request time, access time, IP address, cookies, etc.
Browsing data are Personal Data whose transmission is implicit in the use of internet communication protocols. In particular, this information is not collected in order to be directly associated with identified data subjects, but by its very nature could, in theory, through processing and association with other Personal Data transmitted by third parties (e.g. third-party internet connectivity service providers), allow users to be identified.
With regard to the use of cookies, DAE informs you that the Cookie Policy of the E-Learning Platform, containing all useful information to understand, identify, use or delete the cookies used on the E-Learning Platform, is available at the following link.
- Data actively provided by the User, meaning information provided by the User on an optional and voluntary basis, for example by completing online registration forms in the profile.
Such data may include, by way of example, name, surname, email address, country, etc.
- Data relating to the use of the e-learning platform, such as course participation, training progress, results and access to the E-Learning Platform.
DAE will not process Special Categories of Personal Data.
4. Purposes and legal basis of processing
The Personal Data made available to DAE may be processed for the following purposes:
a) Registration and access to the Applied Academy
DAE will process the Personal Data provided by You through the completion of specific online forms in order to allow registration, access to the E-Learning Platform and use of the training content.
DAE may disclose to Your Affiliate or company of reference the Personal Data relating to Your participation in courses, webinars and other training activities, so that such entities may update the information relating to Your training path within the Applied Academy.
The processing of Personal Data for this purpose is necessary for the performance of a contract or for the implementation of pre-contractual measures taken at Your request, pursuant to Article 6(1)(b) of the GDPR.
b) Management of training activities and service communications relating to the Applied Academy
DAE will process the User’s Personal Data for the organisational and operational management of training activities, including by sending service communications relating to the account and the use of the E-Learning Platform, communications on new courses, training content, webinars and Applied Academy events, updates relating to the training offering and course catalogue, as well as for technical and administrative support connected with the use of the E-Learning Platform. These communications are functional to the use of the Applied Academy and are sent for training, informational, organisational or service purposes, without independent promotional purposes.
The processing of Personal Data for this purpose does not require Your consent, as it is necessary for the pursuit of the legitimate interest of the Data Controller in ensuring the management, updating and proper use of the Applied Academy, pursuant to Article 6(1)(f) of the GDPR.
The User may at any time limit the receipt of communications that are not essential to the provision of the training service, according to the methods indicated in Section 11 of this Privacy Notice.
c) Legal obligations
DAE may process Personal Data in order to comply with the legal obligations to which it is subject.
The processing of Personal Data for this purpose does not require Your consent, as it is necessary to comply with a legal obligation to which the Data Controller is subject pursuant to Article 6(1)(c) of the GDPR.
d) Requirements connected with the use of the E-Learning Platform
DAE may process the User’s Personal Data to ensure the proper functioning, technical management, support and security of the E-Learning Platform and of the services available through it.
The processing of Personal Data for this purpose does not require Your consent, as it is necessary for the pursuit of the legitimate interest of the Data Controller in ensuring the proper functioning of the E-Learning Platform, pursuant to Article 6(1)(f) of the GDPR.
5. Provision of Personal Data. Consequences in case of failure to provide Personal Data
The provision of Personal Data for the purposes referred to under letter a) is necessary to implement pre-contractual measures taken at Your request or to perform a contract to which You are a party. In such case, any refusal or the provision of inaccurate data may prevent DAE from allowing You to register, access the E-Learning Platform and participate in training activities.
The provision of Personal Data for the purpose referred to under letter b) is necessary for the pursuit of the legitimate interest of the Data Controller in ensuring the proper functioning and updating of the service. In such case, any refusal or the provision of inaccurate data may prevent DAE from adequately providing You with the services connected with the Applied Academy.
The provision of Personal Data for the purpose referred to under letter c) is necessary to comply with a legal obligation to which the Data Controller is subject. In such case, any refusal or the provision of inaccurate data may prevent DAE from complying with the legal obligations to which it is subject.
The provision of Personal Data for the purpose referred to under letter d) is necessary for the pursuit of the legitimate interest of the Data Controller in ensuring the security and proper functioning of the E-Learning Platform. In such case, any refusal or the provision of inaccurate data may prevent DAE from ensuring the technical management, support and security of the E-Learning Platform and of the services available through it.
6. Methods of processing
The Personal Data provided by You will be processed mainly by electronic means under the authority of the Controller, by persons specifically appointed and authorised to process the data pursuant to Articles 28 and 29 of the GDPR. Appropriate security measures will also be observed pursuant to Article 32 of the GDPR to prevent the loss of Personal Data, destruction, unlawful or incorrect use and unauthorised access.
7. Recipients or categories of recipients of Users’ Personal Data
Your Personal Data may be transferred and/or disclosed to the following parties, in their capacity as independent controllers, processors, persons in charge of processing or authorised persons, specifically designated for this purpose by the Data Controller:
- third parties, natural or legal persons, that provide DAE with services or activities instrumental to the purposes indicated above, including, by way of example, Daikin Group companies and Affiliates, data hosting, e-learning platform providers (such as LearnWorlds), subcontractors and internet service providers;
- Police Forces or the Judicial Authority in the context of investigations or judicial police inquiries for the purposes of preventing, detecting or prosecuting criminal offences;
- public authorities, where required by law or upon their request;
- any other party to whom the Personal Data must be disclosed pursuant to an express provision of law.
Whenever a third party acts as Data Processor, DAE will ensure that it has entered into a contract with such party pursuant to Article 28 of the GDPR, binding the Data Processor to the Data Controller and specifying the subject matter and duration of the processing, the nature and purpose of the processing, the type of Personal Data and categories of data subjects, and the obligations and rights of the Controller.
8. Transfer of Personal Data to Third Countries
Within the scope of the purposes described above, DAE may transmit Personal Data to other companies of the Daikin Group also in countries outside the European Union, in accordance with the provisions of applicable legislation.
In any case of transfer of Personal Data to a non-EU country, Daikin undertakes to ensure an adequate level of protection by establishing appropriate safeguards and complying with the provisions of Chapter V of the GDPR.
In particular, transfers to non-EU countries, in addition to cases where such transfers are guaranteed by Adequacy Decisions of the European Commission, will be carried out in such a way as to provide appropriate and suitable safeguards pursuant to Articles 46, 47 or 49 of the GDPR.
9. Duration of processing and Personal Data retention period
We will process Your Personal Data to the extent and for the period of time necessary to pursue the purposes described above.
The Personal Data retention periods are listed below:
- In the event of account inactivity for a period of 12 months, DAE will send the User, where possible, prior notice to the email address associated with the account, indicating the expected date for account closure and deletion of the related Personal Data.
- The User may keep the account active by accessing the E-Learning Platform or by carrying out the action indicated in the communication within the following 30 days. If this period expires without action, DAE will proceed with account closure and deletion of the associated Personal Data. Account closure entails the deactivation of the access credentials to the E-Learning Platform and the deletion or anonymisation of all Personal Data associated with the account, except for data that must be retained separately for specific legal obligations, security needs or the need to establish, exercise or defend a legal claim;
- Personal Data processed to comply with legal obligations will be retained for the period necessary to fulfil those obligations, as indicated by the applicable legislation;
- Personal Data processed to carry out requirements connected with the use of the E-Learning Platform will be retained for the time strictly necessary to pursue those purposes.
Upon expiry, Personal Data will be deleted or anonymised, unless further obligations exist for their retention pursuant to applicable legislation.
For specific information on cookies and other tracking tools that may be used within the E-Learning Platform, please refer to the Cookie Policy of the E-Learning Platform.
10. Minors
Through the E-Learning Platform, DAE does not knowingly process any Personal Data of minors below the age required for parental consent under applicable local laws.
If DAE accidentally processes Personal Data of minors without obtaining the consent of the holder of parental responsibility, DAE will delete the information as soon as possible after becoming aware of it.
11. Your rights as Data Subject
We inform You that, at any time and in relation to Your Personal Data, You may exercise the rights provided for, within the limits and under the conditions set out in Articles 7 and 15-22 of the GDPR.
To exercise these rights, described below, please contact the Data Controller at any time,
- by writing to Daikin Applied Europe S.p.A. and sending the request to exercise Your rights by post to the following address: Ariccia (Rome), 00072, Via Piani di S. Maria No. 72 or via email sending the request to exercise Your rights at dataprivacy@daikinapplied.eu
In order to allow You to exercise Your rights and to prevent anyone else from attempting to exercise Your rights, DAE will need to verify Your identity as accurately as possible. Therefore, You will be asked to provide a valid identity document at the time of the request.
Right of access to Your Personal Data
As Data Subject, You have the right to obtain from the Data Controller confirmation as to whether or not Personal Data concerning You are being processed and, where that is the case, to obtain access to the Personal Data and to the following information:
• the purposes of the processing;
• the categories of Personal Data concerned;
• the categories to whom the Personal Data have been or will be disclosed;
• the envisaged retention period or the criteria used to determine that period;
• the rights You may exercise in relation to our processing;
• the existence of automated decision-making processes, including profiling, and, at least in such cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the Data Subject.
Right to rectification, erasure and restriction of the processing of Personal Data
It may happen that some Personal Data processed by DAE are not, or are no longer, accurate, or that You wish to supplement, delete or restrict the Personal Data You have provided to us.
As Data Subject, You have the right to obtain from the Data Controller the rectification of inaccurate Personal Data concerning You without undue delay. Taking into account the purposes of the processing, You also have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.
Furthermore, where the requirements set out in Article 17 of the GDPR are met, You have the right to obtain from the Data Controller the erasure of Personal Data concerning You without undue delay, and the Data Controller is obliged to erase such Personal Data without undue delay.
Finally, You have the right to obtain restriction of the processing of Personal Data at any time, where the conditions set out in Article 18 of the GDPR apply.
You may also request the deletion of Your account at any time.
Right to data portability
As Data Subject, You have the right to receive the Personal Data concerning You, which You have provided to a controller, in a structured, commonly used and machine-readable format, and You have the right to transmit those Personal Data to another controller without hindrance, where the conditions set out in Article 20 of the GDPR are met.
Right to withdraw consent to the processing of Personal Data
Whenever You provide Your consent to the processing of Your Personal Data, You may subsequently withdraw that consent without affecting the lawfulness of processing based on consent before its withdrawal.
Right to object
As Data Subject, You have the right to object at any time to the processing of Your Personal Data carried out for the pursuit of a legitimate interest of the Data Controller. In the event of objection, Your Personal Data will no longer be processed, unless there are compelling legitimate grounds for the processing which override Your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
Right to lodge a complaint with the competent Authority
Finally, pursuant to Article 77 of the GDPR, we remind You that, as Data Subject, You have the right to lodge a complaint with the competent data protection Authority if You believe that the rights You hold under the GDPR have been infringed.
12. Changes to the Privacy Policy
This Privacy Policy will be subject to updates.
The Data Controller therefore invites Users who wish to know how the Personal Data collected are processed to visit this page periodically.
Last modified: August 2026
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