INFORMATION ABOUT THE PROCESSING OF PERSONAL DATA PURSUANT TO ART. 13 OF REGULATION (EU) 679/2016
ISTITUTO ITALIANO PER LA PRIVACY – Italian Institute for Privacy and Data Valorization, Piazza San Salvatore in Lauro 13, 00186 – Rome, VAT Number 11129771009 , Tax Code 97506750583 , as Data Controller (hereinafter, “ISTITUTO ITALIANO PRIVACY“, “IIP“), under the EU Regulation 679/2016 (from now on:” Regulation“) – takes the privacy and data protection as the main focus of its business.
IIP can be contacted at: firstname.lastname@example.org .
The information and data supplied by you or otherwise acquired as part of the use of the ISTITUTO ITALIANO PRIVACY services (e.g. organization of events or consultancy in the field of privacy) will be processed in compliance with the provisions of the Regulation.
According to the rules of the Regulation, the processing carried out by the ISTITUTO ITALIANO PRIVACY will be based on the principles of lawfulness, fairness, transparency, purpose and storage limitation, data minimization, accuracy, integrity and confidentiality.
The personal data processed through the Website are the following:
Contact details such as name, surname, email and telephone.
Particular data could be processed if freely given by you sending e-mail requests.
a. Navigation data
The computer systems and software procedures used to operate the Site acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified data subjects, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of the computers used by users who connect to the site, the addresses in the Uniform Resource Identifier (URI) notation of the requested resources, at the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (success, error, etc.) and other parameters related to the operating system and the user’s computer environment. This data is used for the sole purpose of obtaining anonymous statistical information on the use of the website and to check its correct functioning to identify anomalies and/or abuse and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes to the detriment of the site or third parties: except for this possibility, the data on web contacts do not persist for more than seven days.
b . Special categories of personal data
In the use of the “Contacts” section of the Site, it may be possible to provide personal data included in the category referred to in art. 9 of the Regulation: the “data […] suitable to reveal the racial or ethnic origin, political opinions, religious or philosophical convictions, union membership, as well as to process genetic data, biometric data intended to uniquely identify a physical person, data relating to the health or sex life or sexual orientation of the person” . We invite you to communicate such data only when strictly necessary. It is paramount to remember that in in case of the transmission of your special categories of data, in the absence of specific manifestation of consent to process such data (eventuality that however obviously allows you to send a curriculum vitae), ISTITUTO ITALIANO PRIVACY can not be held responsible in any way, nor can receive disputes of any kind, since in this case the processing will be allowed as having data object made manifestly public by the data subject, in accordance with the art. 9 (1)(e) of the Regulation. However, we specify the importance, as mentioned above – to express the explicit consent for the processing of the special categories of personal data where you decide to share such information.
c . Data Provided Voluntarily by the Data Subject
In using some Site Services, personal data may be processed by third parties sent by you to ISTITUTO ITALIANO PRIVACY. With respect to these hypotheses, you act as autonomous data controller, assuming all the obligations and responsibilities of the law. In this sense, you will be charged of any objection, claim or request for compensation expressed to IIP by third parties whose personal data were processed through your use the Site in violation of the rules on data protection. In any case, if you provide or otherwise process personal data of third parties when using the Site, guarantees from now – and taking any related liability – that this particular hypothesis of processing is based on a suitable legal basis under Art. 6 of the Regulation that legitimizes the processing of the information in question.
The processing that we intend to carry, behind your specific consent where necessary, has the following purposes:
a) Allow and provide the services you requested such as:
registration to the site;
newsletter subscription via email
sharing of content on the site;
generic request for information;
registration for events and initiatives organized by the IIP
promotion and management of IIP donations and sponsorships, or subscriptions to its editorial and scientific initiatives and products;
analysis of curriculum vitae for purposes of collaboration or affiliation with the Institute.
b) responds to requests for assistance or information;
c) fulfilling any legal, accounting and tax obligations.
The legal basis for personal data processing for the purposes set out in section 3a-b is art. 6 (1)(b) of the Regulation as the processing is necessary for the supply of the services or for the response of requests by the data subject. The provision of personal data for these purposes is optional, but if you do not provide it would make impossible to activate the services provided by the Site. The purpose of section 3c represents a legitimate processing of personal data pursuant to art. 6 (1)(c) of the Regulation. Once the personal data has been provided, the processing is actually necessary to fulfill a legal obligation to which ISTITUTO ITALIANO PRIVACY is subject.
For the processing carried out for the purpose of sending direct advertising material or direct sales or for carrying out market research or commercial communications in relation to products or services of ISTITUTO ITALIANO PRIVACY similar to those you requested, ISTITUTO ITALIANO PRIVACY may use, without your consent, e-mail and paper mail addresses pursuant to and within the limits allowed by the provision of the Data Protection Authority of 19 June 2008; the legal basis of the processing of your data for this purpose is art. 6(1)(f) of the Regulation.
In any case, pursuant to art. 21 of the Regulation, you have the possibility to oppose this processing at any time, initially or during subsequent communications, in an easy and free way also by writing to the data controller or the DPO at the addresses indicated above, as well as obtaining immediate confirmation that you confirm the interruption of this processing (Article 15 of the Regulation).
Your personal data may be shared, for the purposes referred to in Section 3 above, with:
a . subjects that typically act as data controllers pursuant to art. 28 of the Regulation, namely: i) persons, companies or professional firms that provide assistance and advice to ISTITUTO ITALIANO PRIVACY in accounting, administrative, legal, tax, financial and debt collection matters relating to the supply of services; ii) subjects with whom it is necessary to interact for the supply of services (for example hosting providers) iii) or subjects delegated to perform technical maintenance activities (including maintenance of network equipment and electronic communications networks); (collectively “recipients”); the list of data processors who process data can be requested from the data controller.
b . subjects, bodies or authorities, autonomous data controllers, to whom it is mandatory to communicate your personal data under the provisions of law or orders of the authorities;
c . persons authorized by ISTITUTO ITALIANO PRIVACY to the processing of Personal Data pursuant to art. 29 of the Regulation necessary to carry out activities strictly related to the supply of services, which are committed to confidentiality or have an appropriate legal obligation of confidentiality (e.g. employees of ISTITUTO ITALIANO PRIVACY ).
6 . Data Retention
Personal Data processed for the purposes referred to in section 3a-b will be kept for the time strictly necessary to achieve those same purposes in compliance with the principles of minimization and storage limitation, ex art. 5(1)(e) of the Regulation. In any case, the data controller will process personal data for the time necessary to fulfill contractual and legal obligations.
Further information about the data retention period and the criteria used to determine this period can be requested by writing to the data controller.
Pursuant to articles 15 and following of the Regulation, you have the right to ask at any time for access to your personal data; the correction or cancellation of the same, the restriction of the processing in the cases provided by art. 18; obtaining, in a structured format, in common use and readable by automatic device, the data concerning you, in the cases provided for by art. 20. At any time, you can withdraw (ex art. 7) the consent given; lodge a complaint to the competent authority pursuant to article 77, if you consider that the processing of your data is contrary to the law in force. You can make a request to object to the processing of your data pursuant to Article 21 in which you have to give evidence of the reasons that justify the objection: the data controller reserves the right to evaluate the application, which would not be accepted in case of legitimate reasons to proceed with the processing that prevail over your interests, rights and freedom.
Requests must be made in writing to the data controller.
a. Definitions, characteristics and application of the legislation
There are various types of cookies, depending on their characteristics and functions, and these can remain in the user’s computer or mobile device for different periods of time: e.g. session cookies are automatically deleted when the browser is closed; e.g. persistent cookies remain on the user’s equipment until a predetermined deadline.
Ø “cookie analytics ” when used directly by the site operator to collect information, in aggregate form, on the number of users and how they visit the site,
Ø browsing or session cookies that guarantee the normal navigation and use of the website (allowing, for example, to make a purchase or authenticate to access restricted areas);
Ø functional cookies, which allow the user to navigate according to a series of selected criteria (for example, the language, the products selected for purchase) in order to improve the service provided.
For “profiling cookies”, vice versa, i.e. those aimed at creating profiles related to the user and used to send advertising messages in line with the preferences expressed by the same in the context of surfing the net, a prior consent of the user is required.
b. Types of cookies used by the site
The website uses the following types of cookies, and offers the possibility to de-select the same, except for third-party cookies for which the user must refer directly to the relative methods of selection and de-selection of the respective cookies, indicated by links:
Ø Technical cookies – navigation or session – strictly necessary for the operation of the site or to allow the user to take advantage of the contents and services requested by them.
Ø Cookie analytics , which allow the site manager to understand how this is used by users. With these cookies are not collected information about the user’s identity or any personal data. The information is processed in aggregate and anonymous form.
Ø Functionality cookies, used to activate specific functions of the site and a series of selected criteria (for example, language, products selected for purchase) in order to improve the service rendered.
Ø Profiling cookies, aimed at creating profiles related to the user and used to send advertising messages in line with the preferences expressed by the same in the context of surfing the net.
WARNING: by disabling technical and/or functional cookies, the site may not be available for consultation or certain services or certain functions of the site. They may be unavailable or not working properly, and you may be forced to change or manually insert some information or preferences each time you visit the site.
IIP uses third-party cookies, i.e. cookies of sites or web servers other than that of the owner, used for the purposes of these third parties, including analytical cookies and profiling . It should be noted that these third parties, listed below with the relative hypertext links to the privacy policies, act as independent data controllers collected through the cookies sent by them therefore, the user must refer to their data processing policies personal, informative and possible forms of consent collection (selection and de-selection of the respective cookies).
Google: https://www.google.it/intl/it/policies/technologies/types/ Google Analytics: https://tools.google.com/dlpage/gaoptout?hl=en-GB
In detail, cookies sent directly through the website are shown below:
Cookies on the Site:
At present there are no cookies on the website.
There are two trackers both referable to the social network Twitter :
d. How to view and modify cookies through your browser
the user can select which cookies to authorize through the appropriate procedure in the sectionSettings related to cookies, as well as authorize, block or delete (in whole or in part) cookies through the specific functions of your browser (browser): however, in the event that all or some of the cookies are disabled, it is possible that the site can not be consulted or that certain services or certain functions of the Website are not available or do not work properly and / or the user may be forced to modify or manually enter some information or preferences each time you visit the site.
Below it is possible for the user to make a choice and to indicate specifically which cookies to authorize.
The user is informed that not allowing technical cookies may make it impossible to use the website, view its contents and take advantage of the related services. Inhibiting cookies of functionality could mean that some services or certain functions of the website are not available or do not work properly and the user may be forced to change or manually insert some information or preferences each time he visits the website.
The lack of authorization with respect to other cookies indicated by third parties will not affect the operation of the site; however, being such types of cookies sent exclusively by third parties, and not being able to control the site manager to send these cookies to the user’s terminal, the relative opposition can be exercised only by accessing the consent forms prepared by the aforementioned third parties, if any, or through the settings of your browser. The links to the privacy policies and any consent collection forms for the receipt of cookies prepared by the third parties that send cookies through the website are provided in the section Types of Cookies Used by the Site.
As for cookies directly sent by the site operator, as well as through the procedure made available on this page, the user can block or delete (in whole or in part) cookies through the specific functions of your browser (in this regard, see the above).
The choices made by the user in relation to cookies on the site will in return be recorded in a special technical cookie, having the characteristics shown in the table of cookies. This cookie may, however, in some circumstances not work properly: in such cases, we recommend that you delete unwanted cookies and inhibit their use through the functionality of your browser.
Your preferences in relation to cookies will be reset if you use different devices or browsers to access the site.