Privacy Policy

Welcome to the Academy for Change Hub (https://www.academy4change.com/). Your privacy and the security of your personal data are of utmost importance to us.

This Privacy Policy explains how Associazione Framework (“we”, “us”, or “our”) collects, uses, shares, and protects your personal data when you visit our website, register for an account, enroll in our courses, become a hub member, or interact with our services, in accordance with the European General Data Protection Regulation (GDPR) and the Italian Data Protection Code.

1. Data Controller

The Data Controller responsible for your personal data under this website is:

• Organization Name: Associazione Framework
• Registered Address: Corso Vittorio Emanuele II 176, Turin, ITALY
• Email Contact: info@academy4change.com
• Telephone: +39 378 0650260

2. Types of Personal Data We Collect

We collect and process various types of information depending on how you interact with the Hub:

• Account Registration & Member Profiles: Full name, email address, password (encrypted), professional affiliation/organization, and any profile bio or photo you choose to submit when becoming a member.
• Course Enrollment & Hub Activities: Progression data, course completions, project submittals, and participation in shared collaboration tools or knowledge platforms.
• Contact Forms & Communications: Name, email address, telephone number, and the contents of any message you send us through inquiry or support channels.
• Technical & Usage Data (Log Files): IP address, browser type and version, operating system, timestamp of access, and pages visited.
• Cookies: Minimal essential technical cookies to manage secure login sessions and basic analytical data. (Please see our Cookie Policy for more details).

3. Purpose and Legal Bases for Processing Data

Under GDPR, we must have a lawful reason to handle your personal information. We process data for the following reasons:

Purpose for Processing	Type of Data	Legal Basis (GDPR Art. 6)
To manage your account, authenticate logins, and grant access to the training platform.	Identity, login credentials, and session logs.	Performance of a Contract: Necessary to provide the service you requested.
To deliver online training courses, monitor progress, and award certificates/evaluations.	Account data and educational metrics.	Performance of a Contract: To fulfill our educational service obligations.
To operate the Hub membership network, allowing networking and project visibility.	Profile details, organization, project submissions.	Consent / Performance of a Contract: Based on your explicit configuration of a member profile.
To respond to inquiries sent via our contact forms.	Name, email, and message content.	Legitimate Interest: To effectively handle customer service and inquiries.
To ensure platform security, monitor technical performance, and prevent fraud.	IP addresses, login timestamps, technical data.	Legitimate Interest: Keeping our services safe and stable for all network members.

4. Data Retention Period

We will only retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including satisfying any legal, accounting, or reporting requirements.

• Account and Member Data: Kept for as long as your account remains active. If you request account erasure, your data will be permanently removed or anonymized within 30 days.
• Contact Inquiries: Retained for up to 24 months from the last communication to ensure continuous support, unless a longer retention is required legally.
• Technical/Security Logs: Deleted or anonymized automatically within 6 months.

5. Sharing and Disclosure of Information

We value your trust and do not sell your personal data. We only share data with third parties under strict confidentiality terms in the following scenarios:

• Service Providers: Specialized cloud hosting providers, learning management system infrastructure, and IT security tools necessary to run our website.
• Hub Network Members: If you explicitly opt to share visibility of your projects, resources, or member profile to promote international replication and scaling of impactful practices, your public profile information will be visible to other authenticated network members.
• Legal Authorities: When required by applicable EU or Italian laws, court orders, or government regulations.

International Data Transfers: Because the Hub serves an international network, data may occasionally be accessed by partner organizations. If personal data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards (such as EU Standard Contractual Clauses – SCCs) are in place to preserve your rights.

6. Your Data Protection Rights

Under the GDPR, you have comprehensive rights regarding your personal information. You can exercise these at any time by contacting us:

• Right of Access: You can request a copy of the personal data we hold about you.
• Right to Rectification: You can request that we correct inaccurate or incomplete information.
• Right to Erasure (“Right to be Forgotten”): You can request that we delete your personal data under certain conditions.
• Right to Restrict or Object to Processing: You can object to our processing of your data, or ask us to restrict how we use it.
• Right to Data Portability: You can request that we transfer your data directly to another organization or to you in a machine-readable format.
• Right to Withdraw Consent: If we rely on your consent to process data (e.g., optional profiling), you can withdraw it at any time.

To exercise any of these rights, please contact us at info@academy4change.com. We respond to all legitimate requests within 30 days.

If you believe your data protection rights have been violated, you also have the right to lodge a formal complaint with a European supervisory authority, particularly the Italian Data Protection Authority (Garante per la protezione dei dati personali — www.garanteprivacy.it).

7. Security Measures

We implement rigorous technical and organizational security measures to protect your personal data against unauthorized access, loss, alteration, or disclosure. This includes SSL/TLS encryption for all transmitted data, secure hashed passwords, restricted staff access privileges, and routine security reviews of our servers.

8. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our organizational practices or legal obligations. We will notify you of any significant updates by updating the “Last Updated” date at the top of this page or via an in-app notice upon login.

Last Updated: May 23, 2026