Personal Data Protection

  1. Why is this Charter important?
  2. Glossary of the main legal terms used in this charter
  3. Who is responsible for use of your data in the framework of your relationship with our departments?
  4. Why do we collect your personal data and on what grounds?
  5. What personal data do we collect?
  6. Who do we share your personal data with?
    1. Sharing your personal data with NOVARIC® Academy affiliates
    2. Sharing of your personal data with our partners
    3. Other sharing
  7. How long do we keep your personal data?
  8. Hyperlinks to external sites
  9. What are your rights over your personal data and how can you exercise them?
    1. Access right
    2. Correction right
    3. Deletion right
    4. Right to be forgotten
    5. Right to restrict processing
    6. Objection right
    7. Right to digital death
    8. Portability right
  10. Is your personal data sent abroad?
    1. Data transfer within Europe
    2. Data transfer outside Europe
  11. Data security
  12. Do you wish to contact us about this Personal Data Protection and/or make a complaint to a personal data protection authority?
    1. Do you have a question or suggestion concerning this Personal Data Protection Charter?
    2. Do you feel that we are not adequately protecting your personal data?
    3. Submitting a complaint to Information and Data Protection Commissioner, the Albanian data protection authority
  13. How do you know if this Personal Data Protection has been amended?

1- Why is this Personal Data Protection important?

Your privacy is a priority for NOVARIC® Academy. We are committed to protecting the personal data of our customers, prospects and online users (hereinafter “you”), to processing it with the utmost care and ensuring it has the best level of protection in accordance with Law No. 9887 dated 10.03.2008 as amended by the Law No. 48/2012, date 26.04.2012 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“the GDPR”) (hereinafter “Albanian law”).

This informs you about:

NOVARIC® Academy operates this website, accessible to the public at the URL address https://www.novaric.edu.al (hereinafter “the Site”). The Site is designed to make available to web-users (i.e. any natural person or legal entity that visits or uses the Site, hereinafter “the users” or “you”) information presenting the training programmes and services offered by NOVARIC® Academy as well as its news (events, publications, etc.).

The Site also offers functionalities allowing users to contact NOVARIC® Academy: contact request, request for brochures, registration for an event or newsletter, speculative application or response to a job offer, etc. The Site also offers users the possibility of submitting an application form online for a training programme offered by NOVARIC® Academy and makes available to them a personal space on an online platform (https://novaric.sharepoint.com/sites/NOVARIC-TUNON) allowing users to complete their application and track its progress and completion.

During your browsing and interaction with the Site or with NOVARIC® Academy, NOVARIC® Academy may need to collect and process personal data about you, in the capacity of data controller.

2- Glossary of the main legal terms used in this Document

For example, use of your data for the purposes of order management, delivery, sending newsletters, etc.

Terms frequently used in this Charter Definitions provided by the GDPR Explanations of terms in everyday language
Personal data (hereinafter “personal data”) Any information relating to an identified or identifiable natural person (hereinafter a "data subject"); an "identifiable natural person" is considered to be a natural person who can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, location data, an online identifier or one or more elements specific to his/her physical, physiological, genetic, psychic, economic, cultural or social identity. All types of information relating to a natural person, i.e. an individual, directly or indirectly identifiable as a person distinct from other persons.
For example: a name, a photo, a finger print, an email address, a telephone number, a social security number, an IP address, a voice recording, your browsing data on a website, data linked to an online purchase, etc.
Data protection officer The notion of data protection officer is not defined by the GDPR. The data protection officer (DPO) is responsible within the company for compliance with the GDPR and applicable national laws as well as our policies and practices for managing your personal data. He/she is also responsible for liaising with the supervisory authorities. The DPO is your first point of contact for any request concerning your personal data.
Processing Any operation or group of operations whether or not they are carried out with the aid of automated processes and applied to data or personal data sets, such as the collection, recording, organisation, structuring, conservation, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction. Any use of personal data, regardless of the process used (recording, organising, conservation, modification, reconciliation with other data, transmission, etc. of personal data).

For example, use of your data for the purposes of order management, delivery, sending newsletters, etc.

Data controller The natural person or legal entity, the public authority, the agency or other body which, alone or in conjunction with others, determines the processing purposes and methods. The person, public authority, company or organisation which manages your data and decides how it is used, including deciding whether to create or delete a process and determining why your data will be processed and to whom it will be transmitted. The data controller is the main party responsible for compliant protection of your data.
Subcontractor The natural person or legal entity, public authority, agency or other body which processes personal data on behalf of the controller. Any natural person or legal entity that carries out processing tasks on the instructions and under the responsibility of the data controller.

3- Who is responsible for use of your data in the framework of your relationship with our departments?

The data controller responsible for processing your personal data is NOVARIC® Academy, an Academy (An education business activity of NOVARIC® Sh.A. registered under Albanian law) and a private vocationalhigher education institution whose registered office is at NOVARIC Building, Nd2 H6, Rruga Studenti, Shkoder 4001, Albania declared to the prefecture of Shkoder, Albania, under number 'LN-1845-02-2021' on 09/02/2021, tel: +355 (0) 222 55 999, email address: legal.department@novaric.edu.al (hereinafter “NOVARIC® Academy” or “us”).

NOVARIC® Academy has appointed a data protection officer in the person of Ms Fjoralba HYSAJ. She is particularly responsible for independently ensuring internal application of the rules governing protection and management of your data and liaison with the supervisory authorities. Here are the contact details for Ms Fjoralba HYSAJ:

Ms Fjoralba HYSAJ
NOVARIC Building, 
Nd2 H6, 
Rruga Studenti, 
Shkoder 4001,
Albania.

4- Why do we collect your personal data and on what grounds?

We collect personal data about you for various reasons.

In general terms, NOVARIC® Academy collects and uses your personal data to function effectively and optimise your experience with its departments. Generally, this processing is necessary for:

You should also be aware that we can only collect and use your personal data if that use is based on one of the legal grounds determined by the GDPR (e.g. your consent or performance of a contract concluded with us).

The table below specifically lists the purposes for use of your personal data by NOVARIC® Academy, based on one or more of the following legal grounds:

Purposes of collecting your personal data

1. Information exchange

Management, processing and monitoring of your requests and exchanges with NOVARIC® Academy by means of or initiated via the Site (request for contact, information or brochures, registration for an event, reservation for a training session, recommendation of a training programme, job application, etc.) and NOVARIC® Academy's relations with its contacts (prospects, students, alumni, web-users, etc.) generally.

2. Applications and admissions

Management, processing, study and monitoring of applications and admissions for our training programmes, including provision of a personal space on the online platform (https://novaric.sharepoint.com/sites/NOVARIC-TUNON) allowing users to complete their application file and track its progress and completion, or assess and select applications.

3. Prospecting & Marketing

Carrying out prospecting, canvassing loyalty-building, communication and marketing operations in a broad sense, by email, letter or telemarketing (newsletters, invitations to events, reminders to training programme applicants, meeting proposals, etc.), including associated technical operations (e.g. segmentation and targeting in order to personalise exchanges, enhancement, targeted advertising etc.).

4. Human resources

Management, processing and monitoring of applications and pre-recruitment procedures, including assessment of professional profiles and selection of applications, particularly using recruitment assistance methods and techniques, as well as the creation of an application file (or CV library) in order to fill certain positions (offers corresponding to your profile which could also be sent to you for that purpose if you have applied on our Site).

5. Site management

Management of the Site, including:

  • access to and benefit of the Site functionalities
  • understanding and study of users’ use of the Site and their browsing behaviour in order to improve our online communications
  • improvement of optimisation of Site content quality and functionalities
  • Site administration, particularly for the purposes of security, and for identification and diagnostic of problems which may affect Site servers
  • completion and preparation of studies, analyses, reports and statistics, particularly concerning the Site audience or users’ browsing of the Site
  • management and processing of requests from Site users and, more generally, NOVARIC® Academy's contacts, in order to exercise their personal data protection rights

6. Laws and regulations

Compliance with legal and regulatory obligations, particularly resulting from NOVARIC® Academy's activity.

7. Campus Management and Security

Collection, use and storage of data relating to campus management and security, including:

  • Campus logistics and general services
  • Video surveillance
  • Registration of visitors (i.e. students, staff, service providers and other visitors)
  • Physical access control, including monitoring the implementation of measures to limit the spread of disease and ensure institutional safety

5- What personal data do we collect?

Your personal data is particularly collected and processed, entirely or partially, when you browse the Site and enter information in its data collection forms (brochure requests, registration for events, applications for our training programmes, etc.) and, more generally, in the framework of your relations and exchanges via the Site and subsequent (online or offline) communication with NOVARIC® Academy.

Generally, your data is therefore collected directly from you under the circumstances mentioned below.

In addition to that information, you are informed that the data we collect and process about you may be enhanced by us via information sources (other web platforms provided by NOVARIC® Academy, rental of files, recommendations or information from third parties, etc.).

Furthermore, more specifically in relation to the information processed in this respect by our recruitment operations, we use the information you send us by email to incorporate into our file of applicants (CV library). However, we may also contact third parties (e.g. recruitment agencies, previous employers, internship supervisors or clients you have worked with in previous roles) to collect information about you in order to study your application.

Within the Site, you are informed of the compulsory nature of providing your personal data on each collection form by the presence of an asterisk alongside the relevant field(s). Where no asterisk is present, the requested information is optional.

If the compulsory information is not entered, the request associated with that collection of personal data (e.g. brochure request, registration for an event, application for a training programme, etc.) may not be able to be processed or its processing may be delayed.

In respect of optional information requested, they are generally designed to provide us with a better knowledge of Site users and their preferences. NOVARIC® Academy encourages users to provide this information in order to help ensure that the contents of our Site remain relevant to your interests and needs.

6- Who do we share your personal data with?

In the course of our activities, we may need to share your personal data. Obviously, whenever we do so we always ensure optimal protection of your personal data.

6.1- Sharing your personal data with NOVARIC® Academy affiliates

We may transmit your personal data to  NOVARIC® Academy affiliates. Since we wish to be as transparent as possible, below you will find a list of  NOVARIC® Academy affiliates with whom we share your data and their locations.

Recipients involved in sharing your personal data Location of recipients
Representatives and branches of  NOVARIC® Academy in Albania and E.U. Albania and E.U.
Representatives and branches of  NOVARIC® Academy around the world NOVARIC® Ltd., Greystone, Valley Road, Msida MSD9021, Malta.

NOVARIC® Sh.A. Zyra 4, Kati 5, Sky Tower,  Rruga Ibrahim Rugova, Tirane 1019, Albania.

6.2- Sharing of your personal data with our partners

Any of our service providers and contractual and commercial partners that may be involved in processing the above-mentioned personal data may have access to your personal data. We may also share your data with external institutions for the purpose of participating in university/school rankings.

6.3- Other sharing

With public authorities, in response to legal requests, including to respond to national security requirements or application of the law.

In the context of a transaction, such as a merger, acquisition, consolidation or sale of assets, we may need to share your personal data with buyers or sellers.

7- How long do we keep your personal data?

NOVARIC® Academy has determined precise rules concerning how long we retain your personal data. This length of time varies depending on the different purposes and must take into account any legal obligations to retain some of your data.

The retention time within NOVARIC® Academy has been defined to allow us to process your requests (brochures, contacts, registration for an event, job application or registration for a training programme, etc.), manage and monitor them and/or complete our prospecting, canvassing loyalty-building, communication and marketing operations, while complying with the principle of proportionality according to which personal data must not be retained for longer than necessary to fulfil the purpose for which it was collected.

It is nevertheless specified that all of this data may be retained for longer than the lengths of time mentioned in this article:

8- Hyperlinks to external sites

This Site includes links to third-party websites. Those sites are not managed or updated by NOVARIC® Academy and are therefore not covered by this charter. NOVARIC® Academy does not have any control over the content of those websites, nor over their confidentiality policies, their use of personal data, use of cookies, or the way in which they collect, process and store that data. You are therefore advised to consult the terms and conditions for collecting and using personal data established by those external sites before sending them any information.

9- What are your rights over your personal data and how can you exercise them?

We wish to inform you as clearly as possible of your rights over your personal data. We would also like to make it as easy as possible for you to exercise those rights.

Below you will find a summary of your rights with a description of how to exercise them.

9.1- Access right

You can ask us to access all of the following information concerning:

To do this, please simply contact us via email at the address contact@novaric.edu.al, with the subject line “access right: personal data”, attaching a copy of your identity document showing your signature as well as a brief description of the information you want to access. Unless you indicate otherwise, you will receive the information requested free of charge in electronic format within one month of receipt of the request, two months in the case of a request requiring more in-depth research

If you are unable to access your information by email, you can send us your request by post at the following address:

Legal Department,
NOVARIC® Sh.A. 
Zyra 4, Kati 5, 
Sky Tower, 
Rruga Ibrahim Rugova, 
Tirane 1019, 
Albania.

In the case of a written request, it must be signed and accompanied by a copy of your identity document bearing your signature. The request must specify the address to which the response should be sent. A response will then be sent to you within one month following receipt of the request, two months in the event of a request requiring more in-depth research or in the event that NOVARIC® Academy receives an excessive number of requests.

9.2- Correction right

You can ask NOVARIC® Academy to correct and/or update your personal data.

You simply need to send an email to contact@novaric.edu.al stating your full name and with the subject line “correction right: personal data”, along with a copy of your identity document showing your signature.

Also do not forget to indicate the reason for contacting us in the body of your email, i.e. correction of inaccurate information and the information to modify, with proof of the correct information where relevant and if you have it.

You can also exercise this right by sending us a letter to the following address:

Legal Department,  NOVARIC® Sh.A.  Zyra 4, Kati 5, Sky Tower,  Rruga Ibrahim Rugova,  Tirane 1019,  Albania.

Your written request must be signed and accompanied by a copy of your identity document bearing your signature. The request must specify the address to which the response should be sent. A response will then be sent to you within one month following receipt of the request, two months in the event of a request requiring more in-depth research or in the event that NOVARIC® Academy receives an excessive number of requests.  

9.3- Deletion right

You can also contact us at any time to ask us to delete your personal data held by us, in one of the following situations:

You simply need to send an email to contact@novaric.edu.al stating your full name and with the subject line “deletion right: personal data”, attaching a copy of your identity document showing your signature. Also do not forget to indicate the reason for contacting us in the body of your email (e.g. deletion of your data when you have withdrawn the consent you provided as a basis for processing your personal data).

You can also exercisethis right by sending us a letter to the following address: 

Legal Department,
NOVARIC® Sh.A. 
Zyra 4, Kati 5, 
Sky Tower, 
Rruga Ibrahim Rugova, 
Tirane 1019, 
Albania.

Your written request must be signed and accompanied by a photocopy of your identity document bearing your signature. The request must specify the address to which the should be sent. A response will then be sent to you within one month following receipt of the request, two months in the event of a request requiring more in-depth research or in the event that NOVARIC® Academy receives an excessive number of requests.
 

However, it may be that we are unable to accede to your request to be forgotten. It should be remembered that this right is not absolute. We need to weigh it against other important rights and values, such as freedom of expression, compliance with a legal obligation applicable to us or important public interest reasons.

9.4- Right to be forgotten

Our Site may contain personal data concerning you. If you no longer wish for it to be displayed, you can ask us to delete it in one of the following situations:

We are also obliged to take reasonable measures to inform other companies (data controllers) that process the personal data for which you have asked for all links and copies to be deleted.

To have information about you on our website deleted, simply send an email to contact@novaric.edu.al stating your full name and with the subject line “right to be forgotten: personal data”, attaching a copy of your identity document showing your signature. Also do not forget to indicate the reason for contacting us in the body of your email, along with the precise web address (URL) of the page in question.

You can also exercise this right by sending us a letter to the following address: 

Legal Department,
NOVARIC® Sh.A. 
Zyra 4, Kati 5, 
Sky Tower, 
Rruga Ibrahim Rugova, 
Tirane 1019, 
Albania.

Your written request must be signed and accompanied by a photocopy of your identity document bearing your signature. The request must specify the address to which the response should be sent. A response will then be sent to you within one month following receipt of the request, two months in the event of a request requiring more in-depth research or in the event that NOVARIC® Academy receives an excessive number of requests.

However, it may be that we are unable to accede to your request to be forgotten. It should be remembered that this right is not absolute. We need to weigh it against other important rights and values, such as freedom of expression, compliance with a legal obligation applicable to us or important public interest reasons.

9.5- Right to restrict processing

You have the right to ask us to restrict your data, i.e. marking your personal data held by us (e.g. b y temporarily moving your data to another processing system or locking your data to make it inaccessible), in order to restrict its future use.

You can exercise this right when:

In the case of a restriction on processing, your personal data shall no longer be subject to any processing without your prior agreement, with the exception of its retention (storage).

Your personal data may still be processed for the purpose of official recording, the exercise or defence of your rights in legal proceedings, or to protect the rights of another natural person or legal entity, or else on important grounds of public interest in the European Union or Member State.

In the case of a restriction on processing of some of your personal data, we will keep you informed of the date when the measure will be lifted.

You simply need to send an email to contact@novaric.edu.al stating your full name and with the subject line “restriction right: personal data”, along with a copy of your identity document.

Also do not forget to indicate the reason for contacting us in the body of your email.

You can also exercise this right by sending us a letter to the following address: 

Legal Department,
NOVARIC® Sh.A. 
Zyra 4, Kati 5, 
Sky Tower, 
Rruga Ibrahim Rugova, 
Tirane 1019, 
Albania.

Your written request must be signed and accompanied by a copy of your identity document. The request must specify the address to which the response should be sent. A response will then be sent to you within one month following receipt of the request, two months in the event of a request requiring more in-depth research or in the event that NOVARIC® Academy receives an excessive number of requests.

9.6- Objection right

You have the right to object to us processing your personal data if, for your own reasons, you consider that one of the forms of processing infringes your privacy and causes you excessive harm. You cannot prevent us from processing your data:

You can object to the use of your personal data for the purposes of marketing communications and particularly advertising. You can also object to profiling if it is linked to marketing communications (e.g. when we send you personalised content).

You simply need to send an email to contact@novaric.edu.al with the subject line “objection right: personal data”, attaching a copy of your identity document showing your signature.

It is important to include the reasons for your objection request.

You can also exercise this right by sending us a letter to the following address: 

Legal Department,
NOVARIC® Sh.A. 
Zyra 4, Kati 5, 
Sky Tower, 
Rruga Ibrahim Rugova, 
Tirane 1019, 
Albania.

Your written request must be signed and accompanied by a photocopy of your identity document bearing your signature. The request must specify the address to which the response should be sent.
 

NOVARIC® Academy has two months to respond to your objection request. If your request is imprecise or does not include all the information enabling us to fulfil your request, we will contact you to ask for further information within that time.

However, it may be that we are able to accede to your request. In that case, we will of course provide you with as clear a response as possible.

Furthermore, any emails and newsletters which may be sent to you will contain a link you can click on to stop receiving promotional information from us.

Specifically in relation to your right to object to marketing communications, we remind you that our marketing partners are responsible for their use of your personal data and taking into account your rights, including to no longer receive offers from them.

9.7- Right to digital death

You have the option to send us instructions relating to the retention, deletion and communication of your personal data after your death. Those instructions may also be recorded with a “certified digital trusted third party”. Those instructions, a sort of “digital will”, may appoint a person responsible for their execution or, failing, that your heirs will be appointed.

In the absence of any instructions, your heirs may contact us to:

In any case, you have the option of informing us, at any time, that you do not want your personal data to be communicated to a third party after your death.

9.8- Portability right

This right gives you the possibility of more easily managing your personal data yourself, specifically:

That right covers both your actively and knowingly declared data, such as your data supplied to create your online account (e.g. email address, username, age) and the information collected by NOVARIC® Academy.

Conversely, personal data derived, calculated or inferred from data you have supplied, e.g. the results of a medical examination, is excluded from the portability right since it has been created by NOVARIC® Academy .

You simply need to send an email to contact@novaric.edu.al stating your full name and with the subject line “portability right: personal data”, attaching a copy of your identity document showing your signature. Do not forget to indicate in your email the files concerned and the type of request (data retrieval and/or transfer to a new service provider).

You can also exercise this right by sending us a letter to the following address: 

Legal Department,
NOVARIC® Sh.A. 
Zyra 4, Kati 5, 
Sky Tower, 
Rruga Ibrahim Rugova, 
Tirane 1019, 
Albania.

Your written request must be signed and accompanied by a photocopy of your identity document bearing your signature. The request must specify the address to which the response should be sent. A response will then be sent to you within one month following receipt of the request, two months in the event of a request requiring more in-depth research or in the event that NOVARIC® Academy receives an excessive number of requests.

You should be aware, however, that NOVARIC® Academy is entitled to refuse your portability request. In fact, this right only applies to personal data based on your consent or performance of a contract concluded with us (for more details of personal data covered by the portability right: click on the Purposes and Grounds section). Similarly, this right may not infringe on third-party rights and freedoms, whose data may be contained in the data transmitted following a portability request.
 

10- Is your personal data sent abroad?

10.1- Data transfer within Europe

Personal data benefits from the same level of protection within the European Economic Area.

We process your personal data on IT servers located in the EEA.

10.2- Data transfer outside Europe

NOVARIC® Academytransfers, processes and stores your information on IT servers located in a number of countries outside Europe as set out in section 6 above.

You should be aware that protection of privacy and rules allowing authorities to access your personal data in those countries are not necessarily equivalent to those in Europe.

In order to ensure standards are adhered to in terms of data and privacy protection, we impose technical and legal guarantees on all our partners.

11- Data security

NOVARIC® Academy takes all useful and appropriate physical, logical, technical, functional, administrative and organisational precautions and measures to guarantee the security of your personal data, with regard to the state of the art, implementation costs and the nature, extent, context and purposes of the processing, as well as the risks, whose degree of likelihood and severity vary, to the rights and freedoms of natural persons, to preserve data security and confidentiality and guarantee a level of security appropriate to the risks, and particularly to prevent the data being distorted, damaged or accessed by unauthorised third parties.

Due to the difficulties inherent in exercising an activity on the internet and the risks, of which you are aware, resulting from the electronic transmission of data, NOVARIC® Academy may not be bound by a performance obligation.

In the event that difficulties occur, NOVARIC® Academy shall do its utmost to circumvent the risks and shall take all adequate measures, in accordance with its legal and regulatory obligations (corrective actions, informing the national authority responsible for personal data protection and, where relevant, data subjects, etc.).

In the event that all or part of the personal data processing is subcontracted, NOVARIC® Academy contractually imposes security guarantees on its subcontractors, particularly in terms of confidentiality in respect of the personal data to which they may have access (appropriate technical and organisational measures to protect that data).

12- Do you wish to contact us about this Personal Data Protection and/or make a complaint to a personal data protection authority?

12.1- Do you have a question or suggestion concerning this Personal Data Protection?

Please let us know by contacting us here (legal.department@novaric.edu.al) or by post at:

Legal Department
NOVARIC® Sh.A. 
Zyra 4, Kati 5, 
Sky Tower, 
Rruga Ibrahim Rugova, 
Tirane 1019, 
Albania.

We would be delighted to hear from you and it will be a pleasure to respond as soon as possible.

12.2- Do you feel that we are not adequately protecting your personal data?

If you believe that NOVARIC® Academy does not process your personal data in accordance with the GDPR and Albanian law, you are entitled to complain to:

12.3- Submitting a complaint to IDP, the Albanian data protection authority

You can submit a complaint directly via the IDP.

Or by writing to the following address:

Information and Data Protection Commissioner
Address: Rr. “Abdi Toptani”, Nd. 5, Kodi postar 1001, Tirana
Tel: +355 4 2237200
Fax: +355 4 22 33977
Green Number: 0800 2050
E-mail: info@idp.al
 

13- How do you know if this Personal Data Protection has been amended?

This Personal Data Protection may be amended at any time, particularly to take account of any changes to the law or regulations or changes to our services.

Major changes made will be notified via our Site or by email, as soon as possible and at least 30 days before they come into force.

When we publish changes to this, we will revise the “last updated on” date at the bottom of this Privacy Policy.

We encourage you to regularly consult this Privacy Policy to find out how NOVARIC® Academy is protecting your personal data.

Last update: 28 February 2022