Introduction
Pursuant to Article 13 of European Regulation No. 679 of 2016 (hereinafter, the “Privacy Regulation”), the Data Controller, Fondazione Dignitas Curae – ETS (hereinafter, the “Controller” or the “Foundation” or “Dignitas Curae”), represented by its incumbent legal representative Prof. Massimo Massetti, wishes to inform you (hereinafter, the “Data Subject”)—as a party adhering to the “Dignitas Curae Manifesto” (hereinafter, the “Manifesto”)—that your personal data will be processed in compliance with the aforementioned legislation.
An updated list of Data Processors, where appointed, is available at the Foundation.
The Data Protection Officer (appointed pursuant to Article 37 of the Privacy Regulation) designated by Dignitas Curae may be contacted at the following email address: abriganti@ga-alliance.eu.
- Purposes and methods of processing.
The Data Subject’s personal data are processed within the scope of the Foundation’s institutional activities for the following purposes:
- the Data Subject’s adherence to the Manifesto;
- compliance with specific obligations laid down by law, regulations, or EU legislation;
- subject to the Data Subject’s specific consent, the publication, disclosure, and dissemination of their full name on the Foundation’s website and/or social media channels, as well as in any other initiative and/or project (digital, audio, audiovisual, print, or similar) undertaken by Dignitas Curae to publicize and raise awareness among the general public, industry professionals, public authorities, and all interested parties regarding the purpose and content of the Manifesto; 4. subject to the Data Subject’s specific consent, sending the Foundation’s documentation to provide updates on all other future projects, initiatives, and events promoted by the Foundation, using both automated means (e.g., newsletters, emails, SMS, MMS, automated calls, etc.) and traditional contact methods (postal mail and/or direct calls by an operator).
Personal data processing is carried out under the authority of the Data Controller by individuals specifically designated, authorized, and instructed to process data pursuant to Art. 2-quaterdecies of Legislative Decree no. 196 of June 30, 2003, as amended by Legislative Decree no. 101 of August 10, 2018 (hereinafter, the “Privacy Code”), and Art. 29 of the Privacy Regulation. Processing is performed using manual, electronic, or automated tools, applying logic strictly related to the purposes and in a manner that ensures the confidentiality and security of personal data.
Legal basis for processing, nature of data provision, and consequences of any refusal of consent by the Data Subject.
With regard to the purpose referred to in paragraph 1, point 1 above, the provision of personal data is optional; however, failure to provide such data means the Data Subject will be unable to subscribe to the Foundation’s Manifesto. Therefore, the legal basis for the relevant processing is Art. 6, paragraph 1, letter a) of the Privacy Regulation. Furthermore, regarding the purposes referred to in paragraph 1, points 3 and 4 above, the provision of personal data is optional; however, failure to provide such data means that, respectively: i) the Data Subject’s first and last name cannot be published, disclosed, or disseminated on the Foundation’s website and/or social media channels, nor in any other initiative and/or project (digital, audio, audiovisual, print, or similar) undertaken by Dignitas Curae to publicize and raise awareness among the general public regarding the purpose and content of the Manifesto; ii) the Data Subject cannot receive documentation from the Foundation concerning all future projects, initiatives, and events promoted by it; therefore, the legal basis for the relevant processing is the Data Subject’s express consent pursuant to Art. 6, paragraph 1, letter a) of the Privacy Regulation. Finally, once the Data Subject has given their consent to adhere to the Manifesto, regarding the purpose referred to in paragraph 1, point 2 above, the provision of personal data is mandatory, and the legal basis for processing is compliance with legal obligations incumbent upon the Data Controller, pursuant to Art. 6, paragraph 1, letter c) of the Privacy Regulation.
- Recipients or categories of recipients to whom personal data may be disclosed and scope of disclosure.
In relation to the processing purposes indicated above, and within the limits strictly relevant thereto, the Data Subject’s personal data—excluding data that will be published subject to their specific consent—will be disclosed, in Italy or within the EU, to the following parties:
(i) Public Authorities, where required by law or upon their request; (ii) to external entities and/or companies engaged by Dignitas Curae to carry out activities connected with, instrumental to, or resulting from the enrollment and of the Data Subject who has signed the Manifesto, to the publication of their full name (subject to their consent), as well as to the sending of Foundation documentation to keep them updated on all other future projects, initiatives, and events promoted by the Foundation (subject to their consent);
(iii) to external consultants, provided they have not been designated in writing as Data Processors;
(iv) to other parties adhering to the Manifesto, upon their request.
The aforementioned parties, to whom the Data Subject’s personal data will or may be communicated (as they have not been designated in writing as Data Processors), shall process the personal data as Data Controllers pursuant to the Privacy Regulation, acting with full autonomy and independently of the original processing carried out by Dignitas Curae.
A detailed and constantly updated list of these parties, including their registered office addresses, is available at all times at the registered office of Dignitas Curae.
- Rights of the Data Subject.
Articles 15 et seq. of the Privacy Regulation grant the Data Subject the right to obtain:
– confirmation as to whether or not personal data concerning them exist, even if not yet recorded, and communication thereof in an intelligible form;
– information regarding the source of the personal data, the purposes and methods of processing, the logic applied in the event of processing carried out with the aid of electronic tools, and the identification details of the Data Controller; – the updating, rectification, supplementation, erasure, anonymization, or blocking of data processed in violation of the law—including data whose retention is unnecessary in relation to the purposes for which the data were collected or subsequently processed—and confirmation that these operations have been notified, including regarding their content, to those to whom the data were communicated or disseminated, unless this proves impossible or involves an effort manifestly disproportionate to the right being protected.
The Data Subject also has the right:
– to withdraw consent (where given) to the processing of personal data at any time (without affecting the lawfulness of processing based on consent given prior to withdrawal);
– to object, in whole or in part, on legitimate grounds, to the processing of personal data concerning them, even if relevant to the purpose of collection;
– to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) in the cases provided for by the Privacy Regulation.
Given that any consent provided by the Data Subject to be contacted for promotional purposes via automated means (as referred to in point 4 of the preceding paragraph 1) also extends to traditional means of contact, the Data Subject may at any time contact Dignitas Curae at the contact details indicated above to exercise their right to object—including partially, i.e., with regard to one or the other of the contact methods specified above.
To obtain the detailed and constantly updated list of parties to whom the Data Subject’s personal data may be communicated, and to exercise the rights set forth in Articles 15 et seq. of the Privacy Regulation—in the manner provided for by Article 12 of the Privacy Regulation and within the limits established by Article 2-undecies of the Privacy Code, the Data Subject may contact the Data Controller at the following addresses:
Fondazione Dignitas Curae – ETS, based in Rome (00168), Largo Agostino Gemelli no. 8, c/o Policlinico Agostino Gemelli, Tax Code 97750570588, e-mail info@fondazionedignitascurae.org.
Duration of Processing.
Subject to legal obligations and instances of consent withdrawal, the Data Subject’s personal data—other than data that has been published—shall be retained for the entire duration of their adherence to the Manifesto. Regarding the receipt of updates from Dignitas Curae—subject to specific consent—concerning all future projects, initiatives, and events promoted by the Foundation, the processing shall last no longer than 5 (five) years from the date such updates are provided, unless the Data Subjects have previously requested their deletion. Notwithstanding the foregoing, Dignitas Curae may retain certain personal data of the Data Subjects even after the processing has ceased, solely for the purpose of defending or asserting its rights, or in cases provided for by law or pursuant to an order from a judicial or administrative authority.