Subject: INFORMATION pursuant to Articles 13 and 14, European Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of individuals with regard to the processing of personal data (in short, the “Information Notice” and the “Regulation” or the “GDPR”, respectively)
General Introduction
The purpose of this Privacy Policy is to describe how the website www.alteritas.it is managed with regard to the processing of personal data of users/visitors who consult it (hereinafter, the “Site”).
The Disclosure is made only for this website and not also for other websites that may be consulted by the user through links.
In addition, this policy is intended to allow users of the Site to learn about the purposes and methods of the Site Owner’s processing of personal data if they are provided.
Users should read this policy carefully before submitting any type of personal information and/or filling out any electronic form that may be on the Site.
A. About Us
ALTERITAS – Interaction among Peoples, founded in Verona in 2009, now an accredited research institution, studies forms of contact and exchange between cultures and peoples of different origins, languages, cultures and traditions (hereinafter, “Alteritas” or the “Holder”). Through the analysis and classification of the types of exchange and interaction between peoples observed at different times in history and with different disciplinary perspectives, relational databases are created and made available to the scientific community and the general public.
For years, Alteritas has considered of fundamental importance the protection of the personal data of its associates and users by ensuring that the processing of personal data, carried out by any means, whether automated or manual, takes place in full compliance with the protections and rights recognized by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data (hereinafter, the “Regulation”) and on the free movement of such data and by D. Legislative Decree No. 196/2003, as amended and supplemented by Legislative Decree 101/2018 (hereinafter, the “Code”) and by any other applicable national and/or EU legislation.
For the purposes of this document, the data controller is:
Alteritas – Interaction among Peoples, in the person of its pro-tempore legal representative, with registered office at 8 Via Seminario, Verona 37129. C.F. 93222050234. Email address: info@alteritas.it
This policy refers to the website: www.alteritas.it
B. Why this paper
For the purposes of this document, the term personal data refers to the definition contained in Article 4 (1) of the Regulation i.e. “any information relating to an identified or identifiable natural person; any natural person who can be identified, directly or indirectly, by reference in particular to an identifier such as a name, an identification number, location data, an online identifier, or to one or more characteristic elements of his or her physical, physiological, genetic, mental, economic, cultural or social identity” (hereinafter, the “Personal Data”) is consideredidentifiable.
The Regulations stipulate that, before processing Personal Data-which term is to be understood, according to the relevant definition in Article 4 under 2) of the Regulations, “any operation or set of operations, whether or not involving automated processes, applied to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, comparison or interconnection, restriction, erasure or destruction” (hereinafter, the “Processing”) – it is necessary for the person to whom such Personal Data belongs (hereinafter, the “Data Subject”) to be informed about the reasons why such data is required and how it will be used.
The purpose of this document is therefore to provide you, in a simple and clear manner, with all the information you will need to enable you to communicate your Personal Data to us in an informed and conscious manner and, at any time, request and obtain clarifications and/or corrections and exercise your rights.
If necessary, this notice may be accompanied by an appropriate form (i.e. web form) for the granting of consent as required by Article 7 of the Regulations, articulated according to the use that Alteritas intends to make of your Personal Data.
C. To whom you may address your inquiries
For all matters related to the Processing of your Personal Data and/or in case you wish to exercise your rights, you may send a written communication to the e-mail address info@alteritas.it.
D. For what purposes will your Personal Data be processed?
Your Personal Data will be processed for the following purposes:
(i) For the operational management of the Site. This means that the Data Controller processes your Personal Data (especially the Data it collects automatically as you browse) to enable the Site you are using to function and to improve its performance.
(ii) To manage the security of Your Data and the Site. Ensuring the security of Your Data and the Site is our contractual and legal duty. We strive to make our web spaces an increasingly safe place for our users.
(iii) Accounting, administrative, fiscal and related purposes, in fulfillment of the obligations provided for by laws, regulations and EU legislation, or provisions issued by Authorities legitimized to do so by law and by Control Bodies. The provision of personal data necessary for these purposes is obligatory and its processing does not require the consent of those concerned. Refusal to provide them will result in the impossibility of establishing relations with the Site Owner.
(iv) to fulfill pre-contractual and contractual obligations arising from any contractual relationship, as well as to carry out all the institutional activities proper to the Controller for the performance of its relationship with you.
(v) Protection or defense of rights in court. We may process your Personal Data to protect or defend a right of ours before a court of law, or other competent authority.
E. To which entities will your Personal Data be disclosed?
Your Personal Data may be disclosed to specific recipients, to whom the Data is disclosed in order to allow the Data Controller to properly carry out all the Processing activities outlined in this document. By recipients the Regulations mean: “the natural or legal person, public authority, service or other body that receives communication of Personal Data, whether or not it is a third party” (hereinafter the “Recipients”).
Such Recipients, may process your Personal Data as:
– Data Processors or
– Persons Authorized / Designated for Processing.
By way of example but not limited to, your data may be made available:
– to personnel or internal and/or external collaborators of the Owner who carry out operations or activities related, instrumental, functional to that of the Owner or who provide the Owner with specific services of an administrative, evaluative, communication and/or support nature.
– to third parties (e.g., any providers for the management and maintenance of the website, suppliers, credit institutions, professional firms, etc.) who perform outsourcing activities on behalf of the Controller, in their capacity as data processors.
For more information about who these parties are and for what reason and on the basis of what safeguards Alteritas may disclose your Data to them, please write to the e-mail address: info@alteritas.it.
If required by law or to prevent or suppress the commission of unlawful acts or crimes, your Personal Data may be disclosed to public bodies or judicial authorities without them being considered Recipients (in accordance with Article 4, number 9, GDPR) and, therefore, without them receiving instructions regarding the Processing they will have to carry out.
F. How long will your Personal Data be processed?
The Regulations stipulate that your Personal Data must be “kept in a form which permits the identification of Data Subjects for a period of time not exceeding the fulfilment of the purposes for which they are processed; Personal Data may be kept for longer periods provided that they are processed solely for archiving in the public interest, scientific or historical research or statistical purposes, in accordance with Article 89, paragraph 1, subject to the implementation of appropriate technical and organizational measures required by this Regulation to protect the rights and freedoms of the Data Subject” (see Art. 5 paragraph 1 letter e) of the Regulation).
In this regard, we would like to point out that, in accordance with this principle, we will process your Data only as long as necessary to pursue the processing purposes listed in Section D of this document.
In particular, your Personal Data will be processed for a period of time equal to the minimum necessary, as indicated by Recital 39 of the Regulation, that is, until the termination of the existing contractual relationship between you and the Data Controller without prejudice to a further retention period that may be imposed by legal regulations as also provided for in Recital 65 of the Regulation and in any case according to the prescriptive terms established by law.
G. What are your rights?
The Regulations guarantee you the exercise of numerous rights, which we summarize as follows:
– Right of access: you have the right to know, among other things, what personal data we process, for what purposes we process it, to whom we disclose it, and you have the right to obtain a copy of it.
– Right to revoke consent: if you have given us your consent, you can still revoke it at any time, easily by contacting us at info@alteritas.it. Revocation of your consent does not affect the lawfulness of the processing carried out up to that point.
– Right of Correction: if you find that any Personal Data you have disclosed to us is incorrect or incomplete, we will correct the error or complete the information we hold.
– Right to Deletion: you may request the deletion of your Personal Data unless we are required by law to keep it, or we need the Data to be able to prove wrongdoing and defend ourselves before a court, or we need to use it for important reasons of public interest.
– Right to restrict processing: if you request that the processing carried out on your Data be restricted, it prevents us from processing the data for the purposes for which the data was collected. This implies that we will limit ourselves to retaining your Data and will solicit your consent, if any, whenever we need to carry out processing for each additional purpose pursued. Even if you have exercised this right, we remind you that your Data may still be processed for the exercise or defense of a right in court or to protect the rights of another person or for important reasons of public interest.
– Right to data portability: you may, at any time, request and receive your Personal Data in a structured, commonly used and readable format on your device to transfer it directly to another data controller.
– Right to Propose a Complaint to the Supervisory Authority: without prejudice to your right to protect your interests in the competent judicial instances, you have the right to propose a complaint to the competent Data Protection Authority (in Italy, the Garante).
– Right to object: you may object, at any time, to the processing of your Personal Data if it is processed without your consent as long as you give detailed reasons.
H. Where is your Personal Data processed?
Your Personal Data will be processed primarily within the European Economic Area and are not, unless specific operational needs arise, transferred outside the European territory.
Should it be necessary to use the services of third parties located outside the European territory, we inform you in advance that:
– we have appointed such individuals as Data Processors within their competence pursuant to Article 28 of the Regulations; and
– the transfer of your Personal Data to such parties will be carried out in strict compliance with the provisions of Articles 44 et seq. of the Regulations.
This assures you that all necessary measures will be taken in order to ensure the fullest protection of your Personal Data as this transfer will be based on contractual agreements or other appropriate legal bases prepared to protect your rights and interests.
