Last update: September 17, 2025

1. Data Controller
The Data Controller is Dr. David Palombo, Corso Cristoforo Colombo 1, Milan, Italy, VAT no. IT09336410965, (hereinafter, the “Data Controller”), owner of the educational platform “dpalombo_perio Academy” and the website www.dpalombo-perio.academy.

2. Privacy Policy
This privacy policy on the processing of personal data (hereinafter, the “Privacy Policy”) governs the processing of personal data and information collected by Dr. David Palombo (hereinafter, the “Data Controller”), in its capacity as data controller, for the purposes and in the manner specified below, in accordance with the provisions of Article 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data (hereinafter, the “Regulation”) and implementing legislation.This Privacy Policy also provides guidance regarding cookies and their use by Dr. David Palombo. For detailed information regarding cookies use, please visit our cookie policy.

3. Personal data collected
Personal data about you is directly provided by you when  you register with the dpalombo_perio Academy’s platform through the website www.dpalombo-perio.academy or its related opt-in and landing pages (collectively, the “Platform”) and/or use the products and services provided by the dpalombo_perio Academy on its websites.

The data collected and processed by dpalombo_perio Academy include:

• Identifying data voluntarily provided by the user: name, surname, email, phone number, taxpayer number, residential address and billing data (necessary for the purchase of online courses), and any information submitted through contact forms (eg. occupation, date of birth, professional interests).
• Newsletter subscription data: email address and phone number.
• Browsing data: IP address, logs, technical and profiling cookies (see Cookie Policy).
• Payment data: payment details related to the credit card you used for purchasing from the Platform are not stored on the Website but securely managed by certified payment providers (e.g., PayPal, Stripe).
• Data related with One-to-One Tutoring service: all data related to the video call, including the date and time of the video call, as well as its duration, the call title, names and surnames of the trainee enrolled in the call, and the session end date and time.
• Additional data:
  – Any personal information you provide when contacting customer service;
  – The data you provide when visiting or interacting with dpalombo_perio Academy’s social network pages;
  – Automatically received data such as browser type and version, mobile device and unique device identifier, software and hardware characteristics, as well as information collected through cookies;
  – Data about your use of the Platform, such as the content you view, how often you use the Platform, and your viewing preferences.

4. Processing purposes and legal basis

Personal data referred to in Section 2 above shall be processed by Dr. David Palombo for the following purposes:
a) management of Platform registration, use of related products, services and features, and provision of support in case of requests submitted to the dpalombo_perio Academy’s customer service;
b) fulfillments related to the management of Platform subscription payments and related billing;
c) profiling purposes;
d) statistical purposes on anonymized data;
e) delivery by dpalombo_perio Academy of periodic updates on its activities and commercial and promotional communications about discounts, offers, services or events. Commercial and promotional communications may be sent via both e-mail and text messages and WhatsApp;
f) receiving commercial and promotional communications by telephone call via operator;

The legal basis for the processing of personal data is:
– the performance of a contract for the purposes referred to in letters a) and b) above. Such processing is therefore lawful in accordance with Article 6.1(b) of the Regulation; and
– your consent for the purposes referred to in letters c), e), f) above. You may withdraw your consent at any time; however, this will not affect the lawfulness of the processing based on the consent you gave before such withdrawal.
Please note that any consent given by you for the purposes referred to in letter e) above extends to marketing and promotional communications transmitted via e-mail, text messages and WhatsApp.

You may at your option withdraw the consent previously given in order to no longer receive any marketing communications on any of the aforementioned channels (e-mail, text messages and WhatsApp), or revoke it only partially for specific methods of transmission. To withdraw your consent, you can send a notice to info@dpalombo-perio.academy
The provision of data is optional. However, any refusal to provide the data necessary for registration on the Platform, for the possible use of paid services (such as the One-to-One Training service), for billing, for support through customer service and for the management of the related payments referred to in this Section 4) letters a) and b), will result in the inability to register on the Platform and take advantage of all or part of the services (including paid ones) offered by Dr. David Palombo through the dpalombo_perio Academy.

Any subsequent opposition or revocation to the processing of personal data for the aforementioned purposes will also result in the immediate suspension of the use of the relevant services.Any refusal to consent to the processing for the additional purposes of profiling, delivering periodic updates and sending marketing and promotional communications, as well as receiving commercial and promotional communications by telephone call via operator, referred to in this Section 4), letters c), e) and f), will not entail any consequences, except for the impossibility of being informed about marketing and promo-advertising communications, as well as receiving marketing communications and/or advertising content likely to be of interest.

In case you give your consent to the profiling activity indicated in letter c) above, this means your information will the subject of an automated activity in order to place you in a category of persons with homogeneous characteristics on the basis of the services you will have used, your use habits on the Platform, the content you view and the appreciation you express by liking or disliking such content found on the Platform or on Dr. David Palombo’s social media channels. On the basis of this categorisation, we will personalise certain content and marketing materials (if you have consented to receive them).

5. How personal data are processed
The processing of your data for the purposes referred to in Section 3 above, will take place either by paper, digitally, automated or through online hosting. Processing will take place in compliance with all the necessary measures to ensure the security and confidentiality of the information in accordance with the GDPR requirements.

6. Disclosure of personal data
In carrying out its activities, dpalombo_perio Academy may disclose personal data about you to the following third parties:

• Technical and hosting service providers
• Payment service providers (e.g., PayPal, Stripe),
• Newsletter management platforms (e.g., Brevo, MailerLite),
• Video delivery platforms (e.g., VdoCipher, Loom),
• Analytics and tracking tools (e.g., Google Analytics, Meta Pixel).
• Partners and suppliers who may provide services on behalf of the dpalombo_perio Academy,
• Data Controller’s consultants and call centers.

Some of these providers may be located outside the European Economic Area (e.g., in the USA). In such cases, data transfers will be based on Standard Contractual Clauses approved by the European Commission or other safeguards required by the GDPR.

These parties shall be appointed by Dr. David Palombo as data processors for purposes of registration and payment management, provision of related services or for such other purposes for which you have given your consent.

A complete list of the Data Processors appointed by dpalombo_perio Academy can be easily and freely known by sending a request to the address indicated in Section 9 of this Privacy Policy.

Finally, Dr. David Palombo Academy may disclose your data to judicial authorities in order to respond to subpoenas, comply with orders issued by courts or other lawful requests from competent authorities; to enforce or exercise his rights or defend himself in court; for purposes of investigation, crime prevention or combating; and in any other case required by law.

Dr. David Palombo may also disclose only anonymized data collected through cookies to our customers, business partners, and companies with whom he has collaborative relationships.

Without prejudice to the above, your data will not be disclosed to other third parties or otherwise disseminated.

7. Retention of personal data
Personal data collected for the processing purposes indicated in Section 4), letters a) and b) above will be retained for the duration of your registration on the Platform. Thereafter, personal data will be retained for a period not exceeding the period of limitation provided by law for the purpose of possibly asserting or defending a legal claim against you or third parties.

The data collected for the processing purposes indicated in Section 4), letters c), e) and f) above will be retained until you have withdrawn your consent to profiling activities and the receipt of marketing and promotional communications, or to the transfer of your data, or you request the deletion of the data, except for the exceptional need to retain the data in order to defend the rights of the Data Controller in relation to disputes outstanding at the time of the request, or upon an order from public authorities.

8. Your rights
Finally, pursuant to Articles 15-21 of the Regulation, we remind you that you have the right:
a) to obtain information in relation to the purposes for which your personal data are processed, the period of processing and the persons to whom the data are disclosed (so-called right of access);
b) to obtain the rectification or supplementation of inaccurate personal data concerning you (so- called right to rectification);
c) to obtain the deletion of personal data concerning you in the following cases: (i) the data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you have withdrawn your consent on which the data processing is based; (iii) you have objected to the processing of personal data concerning you where they are processed for a legitimate interest of Dr. David Palombo; or (iv) the processing of your personal data does not comply with the law. However, please note that the retention of personal data by Dr. David Palombo is lawful whenever it is necessary to enable it to comply with a legal obligation or to establish, exercise or defend a right in court (so-called right to erasure);
d) to ensure that personal data concerning you are only retained without any other use of them in the following cases: (i) you have contested the accuracy of the personal data, for the period necessary to allow the Data Controller to verify the accuracy of such personal data; (ii) the processing is unlawful but you still object to the deletion of the personal data by the Data Controller; (iii) the personal data is necessary to you for the establishment, exercise or defense of legal claims; (iv) you have objected to the processing and verification is pending as to whether the Data Controller’s legitimate grounds for processing override yours (so-called right to restriction of processing);
e) to obtain the cessation of the processing in cases where your personal data are processed for the legitimate interest of the Data Controller and you contest the existence of this interest (so-called, right of opposition);
f) to receive in a commonly used, machine-readable and interoperable format the personal data concerning you processed by automated means, if they are processed under a contract or on the basis of your consent (socalled right to data portability).

Please note that you also have the right to appeal to the competent supervisory authority in order to assert your rights in relation to the processing of your personal data.

For the purposes of this Section 8, you may send a request to the Data Controller by email to info@dpalombo-perio.academy or by registered letter to the Data Controller’s address indicated in Section 10 below.

9. Cookies
The dpalombo_perio Academy website uses technical and analytical cookies in order to collect and access information stored on your device. For more information, please visit dpalombo_perio Academy’s Cookie Policy.

10. Data controller contacts
The data controller is Dr. David Palombo, Corso Cristoforo Colombo 1, Milan, Italy, VAT no. IT09336410965. The data controller can be contacted for requests or reports at the following e-mail address: info@dpalombo-perio.academy