Pursuant to European Regulation No. 679 of 2016 (hereinafter, the “GDPR”) and Legislative Decree No. 196 of June 30, 2003, as amended by Legislative Decree No. 101 of August 10, 2018 (hereinafter, the “Privacy Code”), Fondazione Dignitas Curae – ETS wishes to inform you—and all adult users and/or visitors of the website www.fondazionedignitascurae.org (hereinafter, respectively, the “Users” and the “Site”)—regarding the use of personal data, log files, and cookies collected through the Site itself.
- Data Controller and Data Processors
The Data Controller for personal data is Fondazione Dignitas Curae – ETS (hereinafter, the “Foundation” or the “Controller”), based in Rome (0168) at Largo Agostino Gemelli No. 8 (c/o Policlinico Agostino Gemelli); Tax Code 97750570588; telephone 06-30154639; fax 06-30154108; e-mail info@fondazionedignitascurae.org.
An updated list of designated Data Processors can be provided upon request by Users.
The contact e-mail address for the Data Protection Officer (pursuant to Art. 37 of the GDPR) appointed by the Foundation is: abriganti@grimaldialliance.com.
- Information automatically collected by the Site – Cookies
a) Information automatically collected
Like all websites, our Site also uses log files, in which information collected automatically during your visits is stored. The IT systems and software procedures responsible for the operation of the Site automatically acquire certain information during use, the transmission of which is inherent in the use of Internet communication protocols.
The information collected is as follows:
Internet Protocol (IP) address or domain name of the device you use;
browser type and parameters of the device used to connect to the Site;
URI (Uniform Resource Identifier) addresses of the requested resources or the method used to submit the request to the server;
name of the Internet Service Provider (ISP);
date and time of the visit;
web page of origin (referral) and exit page of the User;
potentially the number of clicks;
size of the file obtained in response;
numerical code indicating the status of the server response (success, error, etc.);
other parameters relating to the operating system and IT environment of your device;
age.
b) Minimum age for browsing the Site
Users must be at least 14 (fourteen) years old to browse the Site. For further information, please refer to our Terms of Service. Therefore, browsing the Site and subsequently registering for it by providing false personal details constitutes a violation of our Terms of Service; likewise, registering an account on behalf of a minor under the age of fourteen constitutes a violation of our Terms of Service.
c) Cookies
Cookies are used on the Site. Cookies are text files stored on a digital medium that allow certain parameters and data communicated to the IT system—via the browser you use—to be recorded. These tools therefore enable an analysis of your usage habits on the Site for various purposes: performing IT authentication, session monitoring, storing information regarding specific configurations of users accessing the server, saving preferences, etc.
Cookies are categorized as follows:
a. Necessary cookies: these help make the Site usable by enabling basic functions such as page navigation and access to secure areas of the Site. The Site cannot function properly without these cookies.
b. Preference cookies: these allow the Site to remember information that changes the way the Site behaves or looks, such as your preferred language or the region in which you are located.
c. Statistical cookies: these help the Site owner understand how Users interact with the Site by collecting and reporting information anonymously.
d. Marketing cookies: these are used to track Users across the Site. The aim is to display ads that are relevant and engaging for the individual User and thereby more valuable for publishers and third-party advertisers.
Our website uses: i) necessary cookies, which do not require User consent for installation; and ii) statistical cookies—specifically Google Analytics—which require User consent before they can be activated.
While browsing the Site, you may also receive cookies on your device that are sent by different websites or web servers (hereinafter, “Third Parties”).
To receive further and more specific information regarding the regarding the cookies actually used on the Site, the User is invited to read the cookie policy—which constitutes a document separate from this notice—found at the bottom of the Site itself at the following link […].
- Personal data you provide when using the Site: purposes of processing
Registration is not required for simple browsing of the Site; however, in order to access the Site’s restricted area or to provide you with the newsletter service (if requested), the Foundation must collect certain information about you through your registration. Before completing the registration process for the Site’s restricted area, you will be provided with a specific, separate privacy notice. Similarly, if you request to subscribe to the newsletter service, you will be provided with another specific, separate privacy notice.
In any event, the Foundation undertakes to use your personal data solely in the manner, under the terms, and for the purposes specified below:
(i) to enable browsing of the Site;
(ii) to comply with legal obligations;
(iii) to manage the technical operation of the Site.
The data you provide will be processed primarily using electronic tools under the authority of the Data Controller, by individuals specifically designated and instructed to carry out the processing, pursuant to Art. 29 of the GDPR and Art. 2-quaterdecies of the Privacy Code. Please be advised that appropriate security measures are implemented—in accordance with Arts. 5 and 32 of the GDPR—to prevent data loss, illicit or improper use, and unauthorized access. 4. Nature of data provision and legal basis for processing
For the purposes referred to in paragraph 3 above, the provision of your personal data occurs automatically and is necessary to enable navigation of the Site.
While the Foundation does not retain navigation data beyond the strictly necessary duration, you may at any time request the Data Controller to delete such data by means of a simple communication sent—without specific formalities—to the contact details provided in paragraph 1 above.
With regard to the purposes referred to in points (i) and (iii) of paragraph 3 above, the legal basis for processing is the performance of the services provided through the Site and requested by you, pursuant to Art. 6, paragraph 1, letter b) of the GDPR. Conversely, regarding the purpose referred to in point (ii) of paragraph 3 above, the legal basis is compliance—by the Foundation—with legal obligations, pursuant to Art. 6, paragraph 1, letter c) of the GDPR.
- To whom and in what context we may transmit your data
Your data may be disclosed, within Italy and the EU, in full compliance with the GDPR and the Privacy Code, to the following parties:
(i) public bodies and/or authorities, where required by law or upon their request;
(ii) external entities, parties, and companies engaged by the Data Controller to carry out activities connected, instrumental, or consequent to the use of the Site and the provision of any services requested therein;
(iii) external consultants, unless they have been designated in writing as Data Processors.
- Your rights
You may at any time exercise the rights referred to in Arts. Articles 15 et seq. of the GDPR, regarding access, rectification, transformation, blocking, erasure, and restriction of processing, in the manner established by Art. 12 of the GDPR and subject to the limitations set forth in Art. 2-undecies of the Privacy Code.
In the event of a failure to respond in a timely manner or an inadequate response from the Foundation, or if you believe there has been a violation of the GDPR and/or the Privacy Code, you may lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) at the following contact details: registered office: Piazza Venezia 11, 00187 Rome; website: www.gpdp.it or www.garanteprivacy.it; email: garante@gpdp.it; fax: (+39) 06-696773785; switchboard: (+39) 06-696771.
- Duration of Processing
Subject to statutory obligations, your personal data will be retained for a period not exceeding that necessary to achieve the purposes for which they are processed (the so-called “storage limitation principle” referred to in Art. 5 of the GDPR). A periodic review is conducted to assess whether stored data have become obsolete in relation to the purposes for which they were collected.
Notwithstanding the foregoing, the Foundation may retain certain personal data of yours solely to defend or assert its rights, in cases provided for by law, or pursuant to an order from a judicial or administrative authority.
- Security Measures
Through the Site, your data will be processed in compliance with applicable law and using appropriate security measures—in accordance with regulations in force, including pursuant to Articles 5 and 32 of the GDPR—aimed at to prevent unauthorized access to, or the theft, disclosure, alteration, or unauthorized destruction of, your data.
- Changes to the Privacy Policy
This policy is subject to modification by the Data Controller; in this regard, the Foundation will notify you of any changes on the Website, providing at least 15 (fifteen) days’ notice prior to the date the new policy takes effect.