Savoy Swing Italy

Marketing Consent Policy

How we use your data to keep you in the loop — on your terms

Last Updated: May 2026

We love keeping our community informed about upcoming classes, events, workshops, and special offers. But we will never contact you for marketing purposes without your explicit consent, and we will never share your data with third parties for marketing. This page explains exactly how our internal marketing works, what laws govern it, and how you can control your preferences at any time.

Article 1

What Is Marketing Consent?

Marketing consent is your freely given, specific, informed, and unambiguous agreement (as defined by Article 4(11) GDPR) to receive promotional and informational communications from us. This is entirely separate from the processing of your data needed to deliver classes you have enrolled in — you may attend our school without ever giving marketing consent.

Important: Under Italian law and GDPR, consent to marketing must be unbundled — it cannot be a condition of service, pre-ticked, or buried in general terms. We always obtain marketing consent through a clear, separate, affirmative action.

Article 2

Legal Framework

Our marketing activities are governed by the following laws and regulations:

2.1 — EU / European Law

  • — GDPR — Regulation (EU) 2016/679: Articles 4(11), 6(1)(a), 7, 21 — governing consent to data processing
  • — ePrivacy Directive 2002/58/EC (as amended by 2009/136/EC): Article 13 — governing electronic direct marketing (email, SMS)
  • — EDPB Guidelines 05/2020 on Consent
  • — EDPB Guidelines 06/2021 on the Interaction between ePrivacy and GDPR

2.2 — Italian Law

  • — Codice del Consumo (D.Lgs. 206/2005): Consumer protection in commercial communications
  • — Codice Privacy (D.Lgs. 196/2003, as amended by D.Lgs. 101/2018): Italian implementation of GDPR
  • — D.Lgs. 70/2003: Electronic commerce and unsolicited commercial communications
  • — Provvedimento Garante — Linee guida in materia di attività promozionale e contrasto allo spam (4 July 2013, as updated): Garante guidelines on promotional communications and spam prevention

The Italian Garante has consistently held that marketing consent must be specific and separate for each marketing channel (email, SMS, phone call). We follow this interpretation and obtain channel-specific consent where applicable.

Article 3

What Our Marketing Communications Include

If you consent, we may send you communications about our own school's activities, including:

Type of Communication Channel Frequency
New class schedules and course openings Email Seasonal / as needed
Special workshops, visiting teachers, intensives Email Occasional
Social dances, parties, and school events Email / SMS Monthly or less
Early-bird offers and membership promotions Email Occasional
School news, community updates, blog content Email newsletter Monthly
Birthday or milestone messages Email Annual / occasion-based

We only do internal marketing. We do not market on behalf of third parties, do not sell advertising space in our communications, and do not share your data with any partner for their own marketing purposes. Every communication comes from Savoy Swing Italy about Savoy Swing Italy.

Article 4

What Data We Use for Marketing

For marketing purposes, we use only the following data that you have provided to us:

  • — Name — to personalise communications
  • — Email address — primary channel for marketing emails
  • — Phone number — only for SMS/WhatsApp communications, and only if you have separately consented to this channel
  • — Dance level / class history — to send you relevant, targeted content (e.g., advanced workshop invitations sent only to advanced students)
  • — Language preference — to communicate in your preferred language (Italian/English)

We do not use any profiling, automated decision-making, or third-party data enrichment for marketing. We do not track your behaviour on external websites.

Article 5

How We Obtain and Record Your Consent

We obtain marketing consent through a separate, unticked checkbox at the time of registration or as a standalone subscription form. Consent is never bundled with our terms and conditions or with enrolment.

Our Consent Standards — What We Require

✦

Consent is given by a clear, affirmative action (ticking an unticked box)

Never pre-ticked, implied, or bundled with another action

✦

The marketing purpose is clearly and plainly described before consent is given

No vague language like "partner communications" or "relevant offers"

✦

Consent is given separately for each channel (email, SMS) where applicable

Italian Garante requires channel-specific consent

✦

We record the time, date, and method of consent for every consent given

As required by Art. 7(1) GDPR — we can demonstrate consent at any time

✦

Consent is freely given — refusing marketing has no impact on your ability to enrol

Service provision is never conditional on marketing consent

We maintain a consent log that records: the identity of the data subject, the date and time consent was given, the form through which consent was collected, and the specific channels and purposes consented to. This log is our evidence of compliance under Article 7(1) GDPR.

Article 6

The "Soft Opt-In" Rule — Existing Students

Under Article 13 of the ePrivacy Directive (as implemented in Italy), and consistent with the Italian Garante's guidelines, we may contact existing students by email about our similar services without fresh consent, provided that:

  1. 1. You gave us your email address in the context of a purchase or enrolment for our services
  2. 2. The communication relates to our own similar dance classes, workshops, or events
  3. 3. You were clearly given the opportunity to opt out at the time your email was collected
  4. 4. You have not opted out or unsubscribed

The soft opt-in applies only to current or recent students (within 12 months of last attendance or transaction) and only for communications about our own, directly similar services. We do not interpret this rule broadly. If in doubt, we seek fresh consent.

Article 7

Withdrawing Your Consent — Unsubscribing

You have an absolute right to withdraw your marketing consent at any time, with no negative consequences. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal (Article 7(3) GDPR).

How to Unsubscribe

  • — Click the "Unsubscribe" link in any email we send you
  • — Email us at savoyswing.it@gmail.com with the subject line "Unsubscribe"
  • — Reply "STOP" to any SMS we send
  • — Speak to us in person at Reception or during any class

We will process your unsubscribe request within 5 business days. You will receive one final confirmation email, after which you will receive no further marketing from us.

Article 8

Right to Object to Direct Marketing

Under Article 21(2) GDPR, you have an absolute right to object to the processing of your personal data for direct marketing purposes. This right is unconditional — we cannot refuse this request or require you to justify it. Upon receiving your objection, we will immediately and permanently cease all marketing processing for your data.

This right extends to any profiling carried out in connection with direct marketing (Article 21(3) GDPR). Although we do not currently engage in profiling for marketing, any such objection will be honoured fully.

Article 9

Third-Party Email Platforms

We use a third-party email service provider to manage and send our marketing emails. These providers act as data processors under a signed Data Processing Agreement (Article 28 GDPR). They process your email address and name solely for the purpose of sending emails on our behalf — they do not use your data for their own purposes.

Our email platform may be located outside the EU. In such cases, we ensure appropriate safeguards under Chapter V GDPR (Standard Contractual Clauses or adequacy decision) are in place.

Article 10

Retention of Marketing Data

We retain your marketing consent and associated data for as long as you remain subscribed, or until you withdraw consent or object. Upon unsubscription, your data is:

  • — Removed from all active marketing lists within 5 business days
  • — Your consent record (name, email, date of consent/withdrawal) is retained for a further 2 years solely to document compliance, after which it is deleted
  • — All other marketing data (e.g., open history) is deleted upon unsubscription

Questions About Marketing Consent

To unsubscribe, update your preferences, or ask any questions about how we handle your data for marketing:

To lodge a complaint about our marketing practices:
Garante per la protezione dei dati personali
www.garanteprivacy.it — Piazza Venezia 11, 00187 Roma