Policy on the processing of personal data

(articolo 13 REG. UE 2016/679)

Pursuant to the provisions of Reg. EU 2016/679 (European Regulation on the protection of personal data (hereinafter “GDPR” or “Reg. EU 2016/679”), we provide the information required to process personal data collected while navigating the website www.ilcongedooriginale.it and by registering with/signing up to the “Il Congedo Originale” Community (hereinafter “Community”). This policy is available in accordance with 13 del Reg. EU 2016/679 (hereinafter “Policy”).

1.Data subject

Data controller, under the terms of Articles 4 and 24 of Reg. EU 2016/679, is Dr. Sonia Malaspina, (hereinafter, “Controller”), who can be contacted by email at: ilcongedooriginale@gmail.com.

2. Type of data processed

For Personal Data means any information relating to an identified or identifiable natural person (‘data subject’), in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person – see Article 4(1) GDPR. 1, n. 1 GDPR.

We inform you that, pursuant to Regulation EU 2016/679, the personal data provided by you or otherwise acquired by the Controller in accordance with applicable legal provision, may be processed in accordance with the above-mentioned regulation and with obligations of confidentiality. The processing of such data is covered by this Policy.

Processing of personal data means:“any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction”.“.

Natural person means: “an identified or identifiable natural person”.

3. Purpose and legal basis of data processing

Personal data relating to the user (i.e. the data contained in the Community Registration Form: first name, second name and email address and usage and tracking data for hosting and tracking purposes and for dashboard statistics, such as IP address, Client ID, reference URL, output URL, browser software, operating system, device information (resolution and language, date/time and/or clickstream data) will be processed by the Controller and/or by persons appointed and authorised by her, pursuant to the provisions set out in the following paragraphs, primarily by electronic means, for the following purposes:

subscribing to the Community and managing of the requests made by the user via the Community Registration Form, as well as verifying that the site functions correctly;
b) sending newsletters, invitations to events and updates on the latest initiatives involving the Community, activities sharing and promoting topics surrounding the Community and any related services provided by the Controller or by third parties, as well as for contacting you to ask about your willingness to take part in market research on topics related to those addressed by the Community;
c) conducting profiling activities;
d) fulfilling the legal, regulatory and legislative obligations, both national and/or community, as well as provisions issued by legally empowered authorities and supervisory and oversight bodies.

For the purposes indicated in (a), data will be processed in accordance with Article 6(f) of the GDPR (legitimate interest).
For the purposes indicated in (b) and (c), data will be processed in accordance with Article 6(a) of the GDPR (consent).
For the purposes indicated in (d), data will be processed in accordance with Article 6(c) and (f) of the GDPR (legal obligation and legitimate interest respectively).

4. Nature of conferment of data and refusal

The conferment of data for the purposes indicated in Point 3(a) is optional. However, if data is not conferred, it will not be possible to participate in the “Il Congedo Originale” Community or to manage the user’s requests.
The conferment of data for the purposes indicated in Point 3(b) is optional. If data is not conferred, it will not be possible to receive newsletters, invitations to events or updates on the latest initiatives involving the Community.
The conferment of data for the purposes indicated in Point 3(c) is optional. If data is not conferred, no profiling activities will be conducted.

5. Data recipients or categories of data recipients

Your data will be communicated to third parties only with your express consent, except for cases where such communication is obligatory by law or is necessary for legal purposes.

Your data will be communicated to third parties only with your express consent, except for cases where such communication is obligatory by law or is necessary for legal purposes. The personal data collected by the Controller may be communicated to various recipients who will process the data as autonomous controllers (Article 24 of Reg. EU 2016/679) and/or as data controller and/or as natural persons acting under the authority of the Controller and/or the Processor (Article 29 of Reg. EU 2016/679), for the purposes indicated above.

Data may also be communicated to others including:

  • Entities providing services to manage information systems and communications networks (including email and websites)
  • Providers of services and consultancy in general to institutions and individuals and to anyone to whom it is necessary to communication the data in order to fulfil the purposes indicated above;
  • Competent authorities for the fulfilment of legal obligations and/or the provisions of public entities, on request.

If your data is processed by other entities as data processors in accordance with Articles 4 and 28 of Reg. EU 2016/679, we will arrange all adequate safeguards in accordance with applicable legislation.
You can refer to the list of data processors, which is constantly updated, by contacting the Controller’s office.

6. Processing location of the data collected and transfer outside of the EU

Data processing and conservation in computerised archives may occur at the operational headquarters of the Controller, of any Processor, in any other location in which the parties involved in data processing are located, or anywhere that those entities providing data hosting services are located.
Your personal data will not be processed outside of the EEA (European Economic Area).

7. Storage period of personal data

When we have to collect your personal data, we ensure that it is as accurate and up to date as possible.

We store your data for the period necessary to fulfil the purposes for which your data has been collected and in any case for the time requested or permitted by the applicable laws and regulations.

In relation to the specific purposes referred to in this policy, data will be stored for a period equivalent to the duration of your subscription to the Community. Please note that you can cancel your subscription to the Community and/or newsletter at any time.

In relation to the purposes indicated in Point 3(c) of this Policy, data will be stored for 1 (one) year from the date of collection.

8. Your rights

You can exercise your rights as expressed by Articles 15, 16, 17, 18, 19, 20, 21 and 22 of Reg. EU 2016/679 by contacting the Controller via email: ilcongedooriginale@gmail.com. You have the right at any time to ask the data Controller for access to your personal data and to ask for it to be modified or cancelled and to request limitation of processing. You also have the right at any time to object to the processing of your data and to the portability of your data. Without prejudice to any other administrative or judicial remedy, if you consider that the processing of data concerning you violates the provisions of Reg. EU 2016/679, in accordance with Article 15(f) of the Regulation, you have the right to lodge a complaint with the Data Protection Officer, the supervisory authority, located in Piazza Venezia no. 11 (00187) Rome, following the procedures and instructions available on the website www.garanteprivacy.it, or to take appropriate legal action, citing Article 6. (1)(a) and Article 9 (2)(A) of Reg. EU 2016/679, you have the right at any time to revoke the consent provided, where applicable and requested. If you have requested portability of your data, the Controller will provide you with the personal data concerning you, in a structured format, for common and legible use, from an automatic device, without prejudice to Paragraphs 3 and 4 of Article 20 of Reg. UE 2016/679.

Last updated: 30 January 2023