DATA PRIVACY POLICY
Updated to EU Reg. 2016/679
(European Data Protection Regulation)
1. Introduction
The EUCENTRE Foundation takes your privacy seriously and is committed to respecting it. This privacy policy (“Privacy Policy”) describes the personal data processing activities carried out by the EUCENTRE Foundation through the website www.eucentre.it and the commitments made by the Company in this respect. The EUCENTRE Foundation may process your personal data when you visit the Site and use the services and functionalities present on the Site. In the sections of the Site where the user’s personal data are collected, a specific information notice pursuant to art. 13 /15 of EU Reg. 2016/679 is normally published.
Where required by EU Reg. 2016/679, the user’s consent will be required before processing his or her personal data. If you provide personal data of third parties, you must ensure that the communication of the data to the EUCENTRE Foundation and the subsequent processing for the purposes specified in the applicable privacy policy complies with EU Reg. 2016/679 and applicable legislation.
2. Identification details of the owner, manager and Privacy Officer
The data controller is the EUCENTRE Foundation
Pec: protocollo@pec.eucentre.it – E-mail: privacy@eucentre.it
3. Type of data processed
Visiting and consulting the Site does not generally entail the collection and processing of the user’s personal data except for navigation data and cookies as specified below. In addition to the so-called “surfing data” (see below), personal data voluntarily provided by the user when interacting with the functionalities of the Website or when requesting to use the services offered on the Website may be processed. In compliance with the Privacy Code, the EUCENTRE Foundation may also collect the user’s personal data from third parties in the performance of its activities.
4. Cookies and navigation data
The Site uses “cookies”. By using the Site, you consent to the use of cookies in accordance with this Privacy Policy. Cookies are small files stored on the hard disk of the user’s computer. There are two macro-categories of cookies: technical cookies and profiling cookies.
Technical cookies are necessary for the proper functioning of a website and to allow the user to navigate; without them, the user may not be able to view pages correctly or use certain services.
Profiling cookies have the task of creating user profiles in order to send advertising messages in line with the preferences expressed by the user while browsing.
Cookies can also be classified as:
- session’ cookies, which are deleted immediately when the browser is closed;
- persistent’ cookies, which remain in the browser for a set period. They are used, for example, to recognize the device connecting to a site by facilitating authentication operations for the user;
- own’ cookies, generated and managed directly by the operator of the website on which the user is browsing;
- third-party’ cookies, generated and managed by parties other than the operator of the website on which the user is browsing.
5. Cookies used on the site
The Site uses the following types of cookies:
- own, session and persistent cookies, necessary to enable navigation on the Site, for internal security and system administration purposes;
- third-party, session and persistent cookies, necessary to enable the user to use multimedia elements on the Site, such as images and videos;
- third-party, persistent cookies used by the Site to send statistical information to the Google Analytics system, through which the EUCENTRE Foundation can carry out statistical analysis of access/visits to the Site. The cookies used pursue exclusively statistical purposes and collect information in aggregate form. By means of a pair of cookies, one of which is persistent and the other a session cookie (which expires when the browser is closed), Google Analytics also saves a log with the start time of the visit to the Site and the exit time from the Site. You can prevent Google from collecting the data by means of cookies and the subsequent processing of the data by downloading and installing the browser plug-in at the following address: http://tools.google.com/dlpage/gaoptout?hl=it
- third-party, persistent cookies used by the Site to include buttons from certain social networks (Facebook, X and LinkedIn) on its pages. By selecting one of these buttons, the user can publish on their personal page of the relevant social network the contents of the web page of the Site they are visiting.
The Site may contain links to other sites (so-called third party sites). The EUCENTRE Foundation has no access to or control over cookies, web beacons and other user tracking technologies that may be used by third party sites that the user may access from the Site; the EUCENTRE Foundation has no control over the content and materials published by or obtained through third party sites, nor over the manner in which your personal data is processed, and it expressly disclaims any responsibility for such eventualities. The user is required to check the privacy policy of the third-party sites that he/she accesses through the Site and to inform him/herself of the conditions applicable to the processing of his/her personal data. This Privacy Policy applies only to the Site as defined above.
6. How to disable cookies in browsers
If you wish, you can also manage cookies directly through your browser settings. However, deleting cookies from your browser may remove the preferences you have set for the EUCENTRE website, so you should visit this page periodically to review your preferences.
For further information and support, you can also visit the specific help page of the web browser you are using:
- Internet Explorer;
- Edge;
- Firefox;
- Safari;
- Chrome;
- Opera.
7. Retention of personal data
Personal data are stored and processed through IT systems owned and operated by the EUCENTRE Foundation or by third party technical service providers; for further details please refer to the section “Scope of accessibility of personal data” below. The data is processed exclusively by specifically authorized personnel, including personnel in charge of extraordinary maintenance operations. Personal data will be kept for the duration of the contract and after the end of the contract to fulfil the legal obligation of the EUCENTRE Foundation, including claims, in accordance with applicable law, and will then be deleted or anonymized.
If we consent to the processing of our products and services for the purpose of direct marketing after the expiry of the contract, we will process the data until the consent is revoked.
8. Purposes and methods of data processing
The EUCENTRE Foundation may process the user’s common and sensitive personal data for the following purposes: use by users of services and functionalities present on the Site, management of requests and reports from its users, sending of newsletters, management of applications received through the Site, etc.
Furthermore, with the further and specific optional consent of the user, the EUCENTRE Foundation may process personal data for marketing purposes, i.e. to send the user promotional material and/or commercial communications relating to the services of the Company, at the addresses indicated, both through traditional methods and/or means of contact (such as, paper mail, telephone calls with operator, etc.) and automated means (such as, communications via internet, fax, e-mail, sms, applications for mobile devices such as smartphones and tablets -called APPS-, social network accounts -e.g. via Facebook, X or LinkedIn-, automated operator calls, etc.). APPS-, social network accounts -e.g. via Facebook, X or LinkedIn-, automated operator phone calls, etc.).
Personal data are processed both in paper and electronic form and entered into the company’s information system in full compliance with EU Reg 2016/679, including security and confidentiality profiles and inspired by the principles of fair and lawful processing. In accordance with EU Reg 2016/679 the data are kept and stored for as long as necessary to achieve the purposes for which they are processed and in any case for as long as you decide to be registered on our website.
9. Security and quality of personal data
The EUCENTRE Foundation is committed to protecting the security of the user’s personal data and complies with the security provisions set forth in the applicable regulations to avoid loss of data, illegitimate or unlawful use of data and unauthorized access to the same, with reference to the Technical Specifications on minimum security measures. Furthermore, the information systems and computer programs used by the EUCENTRE Foundation are configured in such a way as to minimize the use of personal and identification data; such data are processed only for the achievement of the specific purposes pursued from time to time. EUCENTRE Foundation uses a variety of advanced security technologies and procedures to help protect your personal information; for example, your personal information is stored on secure servers located in secure, controlled access locations. You can help the EUCENTRE Foundation update and keep your personal information correct by notifying us of any changes to your address, job title, contact information, etc.
10. Scope of data communication and access
Your personal data may be disclosed to:
- all persons to whom the right of access to such data is recognised by virtue of regulatory provisions;
- to our collaborators, employees, within the scope of their duties;
- to all those natural and/or legal, public and/or private persons when such communication is necessary or functional for the performance of our activity and in the manner and for the purposes set out above.
11. Nature of provision of personal data
The provision of certain personal data by the user is obligatory to allow the Company to manage communications, requests received from the user or to contact the user in order to follow up on his/her request. This type of data is marked with an asterisk symbol [*] and in this case the provision of such data is obligatory to allow the Company to follow up on the request, which, failing this, cannot be processed. On the contrary, the collection of other data not marked with an asterisk is optional: failure to provide such data will have no consequences for the user.
The provision of personal data by the user for marketing purposes, as specified in the section “Purposes and methods of processing” is optional and refusal to provide such data will have no consequences. The consent given for marketing purposes is understood to extend to the sending of communications carried out through both automated and traditional methods and/or means of contact, as exemplified above.
12. Rights of the data subject
12.1 Art. 15 (right of access), 16 (right of rectification) of EU Reg. 2016/679
The data subject has the right to obtain from the controller confirmation as to whether or not personal data relating to him are being processed and, if so, to obtain access to the personal data and the following information:
- the purposes of the processing;
- the categories of personal data in question;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular if they are recipients in third countries or international organizations;
- the intended period of retention of personal data or, if this is not possible, the criteria used to determine that period;
- the existence of the data subject’s right to request from the controller the rectification or erasure of personal data or the restriction of the processing of personal data concerning him or her or to object to their processing;
- the right to lodge a complaint with a supervisory authority;
- the existence of an automated decision-making process, including profiling, and, at least in such cases, meaningful information on the logic used, as well as the importance and expected consequences of such processing for the data subject.
12.2 Right under Article 17 of EU Reg. 2016/679 – right to erasure (“right to be forgotten”)
The data subject shall have the right to obtain from the controller the erasure of personal data concerning him/her without undue delay and the controller shall be obliged to erase the personal data without undue delay if one of the following grounds applies
- personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- the data subject withdraws the consent on which the processing is based in accordance with Article 6(1)(a) or Article 9(2)(a) and if there is no other legal basis for the processing;
- the data subject objects to the processing pursuant to Article 21(1) and there is no overriding legitimate ground for processing, or objects to the processing pursuant to Article 21(2);
- personal data have been unlawfully processed;
- personal data must be erased in order to comply with a legal obligation under Union or Member State law to which the data controller is subject;
- the personal data were collected in connection with the provision of information society services as referred to in Article 8(1) of EU Reg. 2016/679.
12.3 Right under Art. 18 Right to limit processing
The data subject has the right to obtain from the data controller the restriction of processing when one of the following cases occurs:
- the data subject contests the accuracy of the personal data, for the period necessary for the controller to verify the accuracy of such personal data;
- the processing is unlawful and the data subject objects to the deletion of the personal data and requests instead that their use be restricted;
- although the data controller no longer needs them for the purposes of processing, the personal data are necessary for the establishment, exercise or defence of a legal claim;
- the data subject has objected to the processing pursuant to Article 21(1) EU Reg 2016/679 pending verification as to whether the data controller’s legitimate reasons prevail over those of the data subject.
12.4 Right under Art. 20 Right to data portability
The data subject has the right to receive in a structured, commonly used and machine-readable format the personal data concerning him/her that have been provided to a data controller and has the right to transmit these data to another data controller without hindrance.
13. Withdrawal of consent to processing
The data subject has the right to revoke consent to the processing of his/her personal data by sending a registered letter with return receipt to the following address Fondazione EUCENTRE – via Adolfo Ferrata 1 – 27100 Pavia accompanied by a photocopy of your identity document, with the following text: “revocation of consent to the processing of all my personal data”, or by pec to the address protocollo@pec.eucentre.it. At the end of this operation, your personal data will be removed from the archives as soon as possible. If you wish to receive further information on the processing of your personal data, or if you wish to exercise the rights referred to in point 7 above, you may send a registered letter with acknowledgement of receipt to the following address Fondazione EUCENTRE – via Adolfo Ferrata 1 – 27100 Pavia accompanied by a photocopy of your identity document, with the following text: “evocation of consent to the processing of all my personal data”, or by pec to protocollo@pec.eucentre.it. Before being able to provide or modify any of the data subject’s information, it may be necessary to verify identity and answer a few questions. A reply will be provided as soon as possible.