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Privacy policy pursuant to Art. 13 EU Regulation 2016/679 (GDPR)
Last updated 18 May 2022
This policy is provided in respect of and for the protection of the data of those who interact with the web services of the Itat Istituto torinese analisi transazionale research project accessible electronically at www.itat-formazione.it (hereinafter also "the Website").
In accordance with the general principle of transparency set out in EU Regulation 2016/679 and the provisions of Italian law (Legislative Decree 193/03, as amended by Legislative Decree 101/18), these pages also describe the methods for managing the Website in relation to the processing of personal data relating to identified or identifiable persons consulting it.
The information is provided exclusively for the Website www.itat-formazione.it and not also for any other websites, if consulted by the user through specific links.
GENERAL PRINCIPLES
In application of the general principles set out in Article 5 of EU Regulation 2016/679, the personal data of users of this website are:
- processed lawfully, fairly and transparently;
- collected for specified, explicit and legitimate purposes and subsequently processed in a way that is not incompatible with those purposes
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed ('data minimisation');
- accurate and, if necessary, updated and, where appropriate, rectified;
- kept in a form which permits identification of the data subject for no longer than it is necessary for the purposes for which they are processed;
- processed in a manner that ensures adequate security of personal data, including protection, by appropriate technical and organisational measures, against unauthorised or unlawful processing and against accidental loss, destruction or damage.
DATA CONTROLLER
The data controller of personal data is the Itat Istituto torinese analisi transazionale (hereinafter also "the Data Controller"), which can be reached at the following email address: info@itat-formazione.it.
DATA PROCESSOR
Pursuant to Art. 28 GDPR, the company Web&Com, as the entity in charge of the technological maintenance of the Website, has been designated as the data processor on behalf of the Controller (hereinafter also "the Controller"), also based on the level of adequacy of the technical and organisational measures put in place, such as to meet the requirements of the aforementioned Regulation and to ensure the protection of the rights of the data subjects. No change regarding the addition or replacement of sub-processors shall be made by the Data Processor without having informed the Controller.
TYPES OF DATA PROCESSED
1. Navigation data
The computer systems and software procedures used to operate this Webite acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected in order to be associated with identified interested parties, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the site, the URI (Uniform Resource Identifier) notation addresses of the resources requested, 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 (successful, error, etc.) and other parameters relating to the user's operating system or 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 operation. The data could be used to ascertain responsibility in the event of hypothetical computer crimes to the detriment of the site.
2. Data provided voluntarily by the user
The optional, explicit and voluntary sending of electronic mail to the addresses indicated on this Website entails the subsequent acquisition of the sender's address, which is indispensable for replying to the requests of the interested party, as well as any other personal data included in the message sent. Failure to provide even a part of the aforementioned data may make it impossible for the Data Controller and its managers to reply to the message sent by the data subject and to satisfy his/her requests.
Specific summary information will be progressively reported or displayed on the pages of the website set up for particular services on request.
3. Cookies
This Website used so-called "technical" cookies "aimed solely at carrying out the transmission of a communication over an electronic communications network, or to the extent strictly necessary for the provider of an information society service explicitly requested by the contracting party or user to provide such service" (Art. 122, Paragraph 1, Privacy Code, as amended by Legislative Decree 101/2018; Communication of the Italian Privacy Authority of 8 May 2014 "Identification of the simplified procedures for the provision of information and the acquisition of consent for the use of cookies").
The use of so-called "session" cookies (which are stored persistently on the computer of the person concerned and disappear when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to enable the safe and efficient exploration of the site.
The use of session cookies avoids the use of other IT techniques potentially prejudicial to the confidentiality of users' browsing and does not allow the acquisition of personal data identifying the user.
Analytical and persistent cookies
As with most websites, this Website collects information relating to user navigation (e.g. geographical location of the Internet access provider, type of browser used, IP address, pages visited on the site, number of users, etc.). The data obtained from these cookies are managed by the Data Controller as the operator of the site exclusively for statistical purposes, to prepare reports on the use of the site, to improve the content of the site and to make it easier to use.
This Website uses persistent cookies, i.e. systems for tracking users (Google Analytics, Google Adwords, Facebook) for which the user's consent is required.
Third-party cookies
Any companies that send content to the Data Controller's portal and those that can be reached via links from the portal pages (e.g. Youtube, Facebook, Instagram) may, at their discretion, also use persistent cookies on users' computers, aimed at storing the user's browsing data, starting from the moment the user clicks on the relevant link. In this case, the use of cookies is beyond the control of the Controller. Most browsers automatically accept cookies, but it is also possible to reject them completely, or selectively accept only some of them, by modifying the browser's security settings (Internet Explorer, Google Chrome, Mozilla Firefox, Safari Opera, etc.). Each browser has different procedures for managing settings. If the user inhibits the loading of cookies, some components of the site may be unavailable and some pages may be incomplete.
Further information on the use of cookies can be found in the cookie policy attached to this privacy statement.
PURPOSE OF PROCESSING AND LEGAL BASIS
Through this Website, the Data Controller shall process the personal data of the data subject in order to allow him to navigate according to his needs. In any case, the processing of personal data is aimed solely at the fulfilment of the Controller's institutional purposes, within the limits provided for by supranational and domestic legislation. Such purposes comply with the lawfulness criteria provided for by the European legislation protecting the processing of personal data and, in particular, according to Art. 6, par. 1, letters A) and F) of EU Regulation 2016/679, therefore:
- based on the consent expressed by the data subject for the use of persistent cookies and tracking systems;
- for the provision of the requested service the pursuit of the legitimate interests of the Data Controller or third parties, taking into account the balancing with the interests or fundamental rights and freedoms of the data subject.
Legitimate interests include: the dissemination of information on the nature of the entity and its aims; the dissemination of the research program for which the entity is intended; the promotion of events and appointments; the publication of documents, communiqués and information on the life of the entity and the progress of research.
In particular, the data collected by this Website, or voluntarily provided by the data subject, are necessary for the purposes of browsing, possible filling in of forms for registration or contact requests; possible filling in forms for the receipt, upon consent, of newsletters or communications of a promotional nature from the Data Controller. No direct marketing or commercial activities are carried out on this Site, nor any profiling activities for such purposes.
DATA PROCESSING METHODS AND DISSEMINATION
The processing of the data of interested parties is carried out through the use of manual, computerised and telematic tools. Such use is carried out in such a way as to guarantee the security of the data and their confidentiality and is limited to the operations necessary to achieve the purposes for which they were collected. Specific measures are observed to prevent loss of data, illegal or incorrect use and unauthorised access.
No data acquired through the web service is disseminated. Personal data provided by sending e-mails are used solely for the purpose of contacting the interested parties who have requested them and to perform the service or provision requested.
The personal data collected will not be disclosed to third parties except and exclusively for the promotion and fulfilment of the institutional purposes promoted by the Data Controller and for the sharing of the initiatives intended for this purpose, in order to facilitate the participation of the persons concerned. The data will also be communicated where necessary for the fulfilment of legal obligations incumbent on the Controller in accordance with current legislation.
Any transfer of data in electronic format will only be made to those who have undertaken to respect privacy and guarantee compliance with the relevant legislation.
PLACE OF DATA PROCESSING
The processing operations connected to the web services of this Website take place at the aforesaid premises of the Data Controller and are carried out only by technical personnel in charge of processing or by persons who may be appointed to carry out occasional maintenance operations, as well as by the Data Processor appointed pursuant to Article 28 GDPR.
ONLINE COLLECTION OF PERSONAL DATA - OPTIONAL NATURE OF DATA CONFERMENT
Please note that the optional and voluntary sending of electronic mail to any email address of the Controller entails the subsequent acquisition of the sender's address, which is necessary to respond to requests, as well as any other personal data included in the communication sent.
DURATION OF PROCESSING
The personal data collected are processed for the time strictly necessary to achieve the purposes for which they are processed and in any case for the time necessary to carry out the services offered by this Website and in any case for no longer than 24 months.
Personal data provided optionally and, therefore, voluntarily, by the data subject, such as data sent by e-mail to the addresses indicated on the Site, are retained until the service requested by the data subject is performed and in any case for a period not exceeding 12 months, except in cases where the Data Controller retains the data in order to comply with legal obligations or to exercise its rights.
TRANSFER OF DATA ABROAD
Personal data are not transferred to non-EU countries.
ACCESS TO EXTERNAL LINKED WEBSITES
The Website contains links to third-party sites for the further convenience and information of the user. When the user uses these links he/she leaves the website of this Data Controller and accesses a different site, over which the Data Controller has no control and for which it has no responsibility in relation to the processing of data. You are therefore advised to examine the policy of each website you visit.
RIGHTS OF THE DATA SUBJECTS
Pursuant to the provisions of Chapter III of EU Regulation 2016/679, the data subject whose personal data is being processed may exercise the right to:
- Access to personal data (by which is also meant the right to obtain free of charge information about the personal data held by the Controller and to obtain a copy of it in an accessible format);
- Rectification of inaccurate, imprecise or obsolete data (upon specific indication by the data subject and where they are not the expression of evaluative elements);
- Revocation of consent (if and to the extent that the data processing is carried out on the basis of the consent given by the data subject. Such revocation entails termination of the processing);
- Deletion of data - "right to be forgotten" - (where the data are no longer necessary for the purposes for which they were collected, i.e. in the event of withdrawal of consent, objection to processing in the absence of any overriding legitimate reason to proceed, unlawful processing, fulfilment of a legal obligation and in all other cases provided for by law, without prejudice to the exercise of the Controller's rights);
- Data portability (with transmission of the data in a format accessible to the data subject, without infringing the rights and freedoms of others);
- Submission of complaints to the supervisory authority.
For contacts and information on the protection of personal data, including the exercise of the rights referred to in the preceding paragraph, please contact the Data Controller at info@itat-formazione.it.
THIS SITE'S COOKIE POLICY IN COMPLIANCE WITH THE ITALIAN PRIVACY AUTHORITY'S DIRECTIVE
A cookie is a small amount of data, often containing an anonymous unique identifier code, which is sent to the data subject's browser (the software that enables surfing the web) by a web server and which is subsequently stored on the hard disk of the user's device. The cookie is then re-read and recognized by the website that sent it each time a subsequent connection is made. This facilitates recurring visits and increases the usefulness of the site for the benefit of the user. This is why cookies are important and make navigation between sites faster and more immediate. There are different types of cookies, ranging from user profiling to the collection of statistical data to the use of information for sending commercial offers. No data is acquired by the site in this regard. There are no profiling systems for commercial purposes. This site makes use of user tracking systems (Google Analytics, Google Adwords), without anonymization of user addresses.
Cookies differ according to their duration, the domain that installed them and their function.
Duration
Session cookies
These are temporary files that are stored until the site is abandoned (or the browser is closed).
Persistent cookies
These are files that are stored and maintained even after the site is abandoned and the browser is closed. They are only deleted after the expiry date indicated in the cookie itself. This site makes use of this type of cookie.
Domain
“Proprietary" cookies
These are files that are installed on your device directly by the site you are browsing on. This site uses tools of this type.
“Third-party" cookies
These are files that are installed by external sites, through code embedded in the pages of the site you are browsing. Examples of third-party cookies are those installed by social plugins (for sharing content) or visit analysis cookies. Third-party cookies are generally not indispensable for browsing, so they can be rejected by default, through specific functions of the user's browser and, for convenience and completeness of information, described below. Third-party cookies for profiling purposes may be present from time to time, depending on the content uploaded, subject to requesting the consent of the person concerned.
Technical cookies
These are typically used to perform computer authentication, session monitoring and store specific information about users accessing a web page.
Analytics cookies
These are used to collect information, in aggregate form, on the number of users and how they visit the site itself, and thus to compile general statistics on the service and its use. The site collects Google Analytics cookies with non-anonymised IP. The privacy policy of Google Analytics is available at this address (https://policies.google.com/privacy?hl=it). The user can block or limit the receipt of cookies via their browser options. To prevent Google Analytics from using your data, a browser add-on for deactivating Google Analytics JavaScript is available at this address (https://tools.google.com/dlpage/gaoptout?hl=it/).
Cookies and social widget buttons
To ensure that the content of a site can be shared on social networks by visitors to the site, it is possible to integrate tools called widgets provided by the social networks themselves into the pages.
These tools (usually blocks of code inserted in the pages of the host site) may collect third-party cookies installed by social networks (e.g. Facebook, Instagram, Youtube). Such widgets may use their own, i.e. 'third-party', cookies. Deactivating them does not affect the use of the site, except in those sections where widgets may be installed (e.g. for integrating videos or maps) and in some cases the possibility of quickly sharing content or commenting on certain areas of the site. As of the date this policy was updated, this Site does not use this type of cookie.
Advertising cookies
At the time of issue of the update of this policy this site does not make use of cookies of this type. If the Owner intends to proceed with the use of advertising cookies it will duly inform users of the site with a request for consent where necessary.
Users' prior consent
Pursuant to the aforementioned Article 122 of the Italian Privacy Code, the sending of technical cookies is necessary for the proper functioning of certain parts of the www.itat-formazione.it website and for its navigation.
With Legislative Decree 69/2012, the prior consent of users is not required for the installation of such cookies. In fact, based on the indications of the network of Privacy Authorities of the Member States, there are cookies for which prior consent is not required:
1. Cookies with data filled in by the user (session identifier), lasting one session or persistent cookies limited to a few hours in some cases;
2. Authentication cookies, used for the purpose of authenticated services, lasting one session;
3. User-centred security cookies, used to detect authentication abuses, for a limited persistent duration;
4. Media player session cookies, such as 'flash' player cookies, for the duration of a session;
5. Session cookies for load balancing, of one session duration;
6. Persistent cookies for user interface customization, lasting one session or a little longer;
7. Cookies for content sharing via third-party social plug-ins, for members of a social network and who have logged in.
Otherwise, consent is required for the installation of non-anonymized Analytics cookies (including third-party) and profiling cookies. In particular, with reference to the use of cookies or permanent user tracking or monitoring systems, access to the Website may involve the server sending text files to the user's terminal PC in order to obtain information on navigation. The opening banner allows the choice between installing all the cookies on the Site or loading only the technical cookies necessary for browsing. The Site Owner will keep track of the consent of the person concerned by means of a technical cookie. In this way, the display of the cookie banner on subsequent visits by the person concerned will be avoided. The person concerned may freely decide to accept or refuse the sending of all or some of the cookies on his or her terminal equipment.
In any case, it should be noted that the sending by the server of certain technical cookies is necessary to allow the operation of certain parts of the service that require identification of the user's path through certain pages of the Site. In the absence of these cookies, therefore, the operation of the Site may be impaired or impossible.
Interested parties are informed that once they have accepted the installation of cookies, they can change their choice at any time and easily deactivate the operation of all or some of the cookies directly through the configuration options of the browser used. For the sake of completeness of information, below are summary instructions and references to the developers' full instructions on how to disable cookies via browser configuration for the main browsers available.
https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d
https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox
https://support.google.com/chrome/answer/95647?hl=en&co=GENIE.Platform%3DDesktop
https://support.apple.com/it-it/guide/safari/sfri11471/mac
https://support.apple.com/en-us/HT201265
Amendments to this policy
This policy may be subject to change. Any amendments will enter into force at the same time as they are published on the Website.
Contact and questions
If you have any questions about the use of your personal data, please send an e-mail to:
info@itat-formazione.it
