PRIVACY AND COOKIE POLICY

This policy explains what personal data Hired and Promoted collects when you visit our website or buy our courses, why we collect it, who we share it with and what rights you have.

1. Who we are

Hired and Promoted is a brand of District-9 S.R.L., Via Arcivescovo Calabiana 6, c/o Talent Garden, 20139 Milan, Italy, VAT number IT10187710966 ("we", "us"). We are the data controller for the personal data described in this policy.

You can contact us about privacy at info@hiredandpromoted.com.

This policy covers hiredandpromoted.com and academy.hiredandpromoted.com (the "Website").

2. Data we collect

1. Account and purchase data. Name, email address, phone number, country, billing details, the courses you buy, order number, amount paid, coupon used and payment status. We do not receive or store your full card number; card details are handled by the payment providers.

2. Course usage data. Which lessons you open and complete, and your progress.

3. Communication data. Messages you send us and our replies.

4. Newsletter and lead data. Your email address and name when you subscribe to our newsletter or request a free resource, and whether you open or click our emails.

5. Website and device data. Pages visited, referring page or advertisement, approximate location derived from your IP address, browser and device type, and identifiers stored in cookies. Part of this data is collected only with your consent, as explained in section 7.

3. Why we use your data and on what legal basis

1. Create your account, deliver the courses you bought and provide support. Data: Account, purchase, usage and communication data. Legal basis: Performance of our contract with you.

2. Process payments, issue invoices and keep accounting records. Data: Purchase and billing data. Legal basis: Performance of the contract and legal obligation.

3. Send service emails, such as receipts and access instructions. Data: Account data. Legal basis: Performance of the contract.

4. Send our newsletter and promotional emails. Data: Email, name, email engagement. Legal basis: Your consent, or our legitimate interest in telling existing customers about similar courses; you can opt out at any time.

5. Understand how the Website is used and improve it. Data: Website and device data. Legal basis: Your consent.

6. Measure our advertising and show you relevant ads on other platforms. Data: Website and device data; purchase events. Legal basis: Your consent.

7. Prevent fraud and abuse, and defend legal claims. Data: Any relevant data. Legal basis: Our legitimate interest.

4. Who we share your data with

We do not sell your personal data. We share it only with the providers that help us run the business, each acting on our instructions or as an independent controller where the law says so:

1. TagMango, the platform that hosts the Website, the courses and the checkout, and its payment partners, which process your payment.

2. Google Ireland Limited (Google Analytics 4 and Google Tag Manager), for website statistics.

3. Meta Platforms Ireland Limited (Meta Pixel and Conversions API), for advertising measurement. With your consent the Meta Pixel in your browser records page visits. Purchase and registration events are sent to Meta from the platform's server, including contact details in hashed form, so that Meta can match them to its users.

4. Acumbamail, for promotional emails and email sequences.

5. Substack, for our newsletter.

6. Pabbly Connect, an automation service that passes data between the tools above.

7. SiteGround, for domain and email services.

8. Accountants, legal advisers and public authorities, when the law requires it.

5. Transfers outside the European Economic Area

Some of these providers are based in, or use servers in, countries outside the European Economic Area and the United Kingdom, including India and the United States. Where this happens we rely on an adequacy decision or on the Standard Contractual Clauses approved by the European Commission, or on the equivalent UK mechanism.

6. How long we keep your data

1. Purchase and billing data: 10 years, as required by Italian tax and accounting law.

2. Account and course usage data: for as long as your account is active, and up to 24 months after your last login if you ask us to close it or stop using it.

3. Newsletter and marketing data: until you unsubscribe or withdraw consent.

4. Website statistics in Google Analytics: 14 months.

5. Support messages: 24 months after the conversation ends.

7. Cookies and similar technologies

When you first visit the Website you see a banner where you can accept all cookies, reject non-essential ones or choose by category. You can change your choice at any time using the cookie icon at the bottom left of every page.

If you visit from the European Economic Area, the United Kingdom or Switzerland, analytics and marketing technologies stay off until you accept them. In other countries they are on by default and you can switch them off from the same banner.

1. Essential. Keeps you logged in, processes payments and remembers your cookie choice. Cannot be switched off. Technologies: TagMango session and login cookies; your consent choice saved in your browser's local storage by Silktide Consent Manager. Duration: Session, or until you clear your browser data.

2. Analytics. Counts visits and shows how the Website is used. Technologies: Google Analytics 4 cookies (_ga and _ga_ followed by an identifier). Duration: Up to 2 years.

3. Marketing. Measures our advertising and lets us show relevant ads on Meta platforms. Technologies: Meta Pixel cookies (_fbp and _fbc). Duration: Up to 90 days.

When analytics or marketing consent is not given, Google tags may still send limited signals that do not use cookies and do not identify you, as provided by Google Consent Mode.

You can also block or delete cookies in your browser settings. If you block essential cookies, login and checkout may not work.

8. Your rights

Depending on where you live, you have the right to:

1. access your personal data and receive a copy;

2. have inaccurate data corrected;

3. have your data deleted, where we have no legal reason to keep it;

4. restrict or object to our use of your data, including for direct marketing;

5. receive your data in a portable format;

6. withdraw your consent at any time, without affecting what we did before you withdrew it.

To exercise these rights, email info@hiredandpromoted.com. We reply within one month.

You also have the right to complain to a data protection authority. In Italy this is the Garante per la protezione dei dati personali (www.garanteprivacy.it). In the United Kingdom it is the Information Commissioner's Office (ico.org.uk).

9. Children

The Website and our courses are intended for adults. We do not knowingly collect data from anyone under 18. If you believe a minor has given us personal data, contact us and we will delete it.

10. Changes to this policy
We may update this policy when our tools or the law change. We will publish the new version on this page with a new date and, if the changes are significant, tell you by email or with a notice on the Website.