Privacy Policy and terms of sale

1 - CATEGORIES OF PERSONAL DATA.

The company collects the following categories of personal data: identification data; professional contact data and, where applicable, data relating to your position within the end-customer company; data relating to your professional and commercial profile, such as role, experience, company, country and geographical area; data relating to access to and use of the platform; answers provided while completing EnneaSales™ Test; results and indicators derived from processing the test, including primary and secondary EnneaSales™ Type, Customer Approach, Growth Mindset and the contents of the individual report; purchase and transaction data, where applicable; and data you may provide through the contact form.

EnneaSales™ Test is a behavioural assessment tool applied to the commercial context and does not have diagnostic or clinical purposes. The service is not designed to collect special categories of personal data under Article 9 GDPR.

2 - PURPOSE AND LEGAL BASIS OF PROCESSING.

The data collected will be processed to allow you to access the platform, use the access code, complete the test, save your progress, process your answers, generate your EnneaSales™ profile and make the related individual report available.

The answers provided are processed using predetermined rules and algorithms to determine, among other things, primary and secondary EnneaSales™ Type, Customer Approach and Sales Growth Mindset.

For users who purchase the test directly, processing is also necessary to manage the purchase and payment, issue and send the access code, and comply with any administrative and tax requirements.

Where the test is supplied as part of a corporate programme, data may also be processed to enable the customer organisation to view, in accordance with the service arrangements, individual and/or aggregate information relating to assessment results and team dynamics.

This information may be used to support development, training, coaching, mentoring, team composition and talent-management activities. EnneaSales™ Test is not designed to autonomously make decisions concerning recruitment, promotion, termination of employment or other decisions that produce legal or similarly significant effects on the data subject.

Depending on the circumstances, the legal basis for processing is the performance of a contract or pre-contractual measures under Article 6(1)(b) GDPR, as well as the legitimate interest of A21CONSULTING and, in corporate programmes, of the customer organisation in correctly providing the service and managing assessment and development activities under Article 6(1)(f) GDPR.

3 - PROCESSING METHODS, PROFILING AND RETENTION PERIOD.

Data is collected, processed and stored mainly using IT and digital tools. A21CONSULTING uses processing tools and methods that ensure compliance with personal-data security and protection measures, according to procedures strictly related to the purposes stated above.

Test answers are processed automatically through a scoring model based on predetermined rules. This processing generates the user’s behavioural-commercial profile and related indicators. Its sole purpose is to provide a structured interpretation of commercial behaviour and the related areas of effectiveness and development.

The system does not autonomously make decisions that produce legal or similarly significant effects on the data subject within the meaning of Article 22 GDPR.

Personal data may be processed on behalf of A21CONSULTING by authorised collaborators and technology providers appointed, where necessary, as processors under Article 28 GDPR.

The personal data you provide will be retained for the time necessary to achieve the purposes described above, without prejudice to any further retention required for legal claims or by statutory obligations to which A21CONSULTING is subject.

In particular:

• assessment data and related results will be retained for the period necessary to provide the service and make the report available, unless deleted earlier or subject to further contractual obligations;
• purchase and tax-compliance data will be retained for the period required by applicable law;
• data received through the contact form will be retained for the time needed to handle the request and any subsequent relationship;
• technical logs, security data and backups will be retained for periods proportionate to security, business-continuity and service-protection needs.

Retention periods may be further specified on the basis of the Controller’s internal procedures.

4 - DISCLOSURE, RECIPIENTS AND TRANSFER OF DATA.

Your data will not be made public. It may be processed on behalf of the Controller by the technology providers described below.

In corporate programmes, individual and/or aggregate results may also be made available to the organisation that supplied the access code, in accordance with the service arrangements and the agreements in place with A21CONSULTING.

Where the services used involve a transfer outside the European Economic Area (EEA), the transfer will be subject to the safeguards required by applicable data-protection law, such as adequacy decisions, the European Commission’s Standard Contractual Clauses or other instruments provided for by Articles 44 et seq. GDPR.

5 - NATURE OF THE PROVISION OF DATA.

Providing your personal data is necessary to allow the Controller to identify you, validate the access code, enable completion of the test, save your answers, process the profile and generate the related report.

Refusal to provide mandatory data may make it impossible to access or use EnneaSales™ Test, complete the assessment, obtain the report or use the requested functions.

Providing data marked as optional is not necessary to use the main functions, unless it is required for a specific function or service.

6 - DATA SUBJECT RIGHTS.

Subject to the conditions set out in the GDPR, you may exercise the following rights: right of access (Article 15); right to rectification (Article 16); right to erasure (Article 17); right to restriction of processing (Article 18); right to data portability (Article 20); right to object (Article 21); and rights relating to automated decision-making and profiling (Article 22), where applicable.

Where processing is based on consent, you also have the right to withdraw it at any time, without affecting the lawfulness of processing carried out before withdrawal.

7 - IDENTITY AND CONTACT DETAILS OF THE DATA CONTROLLER.

The Data Controller is A21CONSULTING di Mirko Veratti, with registered office at Via San Cristoforo 28, staircase A, 41121 Modena (MO), Italy, VAT number 04003170364, email mirko.veratti@a21consulting.com.

Requests concerning the processing of personal data and the exercise of rights under the GDPR may be sent to the contact address above.

Where EnneaSales™ Test is used as part of a programme promoted by an employer or another customer organisation, that organisation may view the results in accordance with the service arrangements.

The company dashboard may include individual results and aggregate information concerning, among other things, the distribution of EnneaSales™ Type, Customer Approach and Sales Growth Mindset.

The customer organisation is responsible for informing the data subject about its own purposes for using the results and its role in processing personal data. A21CONSULTING and the customer organisation define their respective privacy roles and responsibilities according to the characteristics of the service and the agreements between the parties.

EnneaSales™ Test results must be used as one of the elements supporting the evaluation and development of people and not as the sole decision-making criterion.