PRIVACY POLICY
pursuant to article 13 of Regulation (UE) 2016/679 of the European
Parliament and of the Council of 27 April 2016 on the protection of natural
persons with regard to the processing of personal data (in brief “GDPR”)
Dear users / customers,
in compliance with the European and Italian legislation
in force in the sector, we ensure that the protection of Your personal data is
guaranteed and that their confidentiality and integrity are preserved when You
browse our website https://www.interreg-euro-med-academy.eu and use it to obtain information about our courses and activities, to learn about us, to contact us, to enrol to our courses and,
in general, in all other several occasions in which you have relationships with
us, through the mutual exchange of contact information.
We invite You to inspect this policy concerning the
modalities, the means and the purposes of processing of Your personal data.
1 – Data Controller and
Processors
The Controller is UNIMED – Unione delle Università del
Mediterraneo, with registered office in Corso Vittorio Emanuele II, 244 - 00186 ROMA, which may be reached
to exercise the rights afforded by the GDPR or to obtain clarifications
concerning this policy, at the following addresses:
- e-mail:
dpo@uni-med.net
- telephone: 06 68581430 / 68806186
- or
by regular mail at the above-specified address.
The Data
Controller takes advantage of third parties that provide some services to
Unimed and / or support it in carrying out certain activities: they have been
appointed Data Processors pursuant to art. 28 GDPR.
2-
Categories of data processed and purposes of processing
A) During browsing through
the sections of our Website, which is permitted to any user without need to
register, we obtain and process the following personal data, for the specific
purposes listed:
(i) Browsing data concerning the session
The IT systems responsible
for the functioning of this Website acquire, during their normal functioning,
certain personal data whose transmission is implicit in the use of Internet
communication protocols (e.g. IP addresses, Internet connection and traffic data,
domain names of the devices used by Website visitors).
This information is not
collected to be associated to identified data subjects or to identify
users.
Without prejudice to the
specific provisions of paragraph 4 below in relation to the use of cookies on
the Website, these data are used for the sole purpose of obtaining anonymous
information on the use of the Website and controlling its correct
functioning.
The data might be used to
ascertain responsibilities in case of possible IT crimes against the Website.
(ii) Browsing data concerning services provided by third
parties and/or obtained by third parties through the Website
The development of some functionalities of the Website
takes place through services provided by third party entities (MOODLE,
as concerns the plugin for detecting, setting up and saving the preferences of
users regarding the language; Google, as concerns monitoring and analysis of
traffic data and of the behaviors of users on the Site, map’s functioning and
the memorization of user consent to the processing of personal data) through
the use of cookies, as specified in the following paragraph.
The
processing of the above-specified data has the purpose of ensuring the correct
functioning and use of our website, through: a) performance evaluations of the
Website during the browsing session, aimed at monitoring and improving the
services we offer; b) analysis of the browsing data, in aggregate form, for
statistical purposes and to keep track of the behavior of users, without this
entailing profiling activity, (using Google Analytics’ functionalities).
B) On our Website shows a “contact
form” tool, through which it is possible to contact the Company and send us
requests for information. The data are
collected and processed by a plug-in (which packages an e-mail subsequently sent
to a company mailbox) and are kept in the mailbox of incoming e-mails for a
limited period of time, for the sole purpose to respond to your requests.
Furthermore, our Website
shows, in the same “contacts” section, addresses and contacts of the registered
and operational offices of our Company; sending, optionally and voluntarily,
electronic mail to the addresses specified on this Website entails the consequent
acquisition of the address of the sender, necessary to reply to the requests,
as well as of any other personal data that may be included in the letter; by
sending the e-mail, You consent to the data processing for the specified
purposes.
We process the personal
data in question to allow You to contact us, to request information and/or
assistance, and to allow our Company to reply to Your requests.
C) On our Website there is
also a special “create account” tool, through
which it is possible to create an account on the website: we periodically
give information about our initiatives, the starting of new
projects, the progresses of ongoing projects.
We process the personal data, once the service has been activated
through subscription, to allow you to enrol into courses and Moocs hosted on our platform and always be informed about our activities,
initiatives and projects.
D) On all occasions when you come into contact with Unimed -
either indirectly, through on-line communications, or directly, both during
face-to-face meetings between Unimed staff / Directors and Associates or
partners and collaborators and while participating at some particular events,
conferences, seminars - we could acquire your personal and contact data (name,
surname, position / role / profession, institutional / professional e-mail
address, telephone number) by collecting business cards or exchanging
references, or by submitting specific application forms in the context of
relevant events and conferences: the above mentioned data are collected and
processed, by registering and organizing them into a database, to facilitate
future contacts between you and Unimed for the purpose of mutual comparison and
exchange of information.
The provision of the personal data (by delivering a business card,
by sharing the contact via messaging, verbal communication or filling the data
in the application forms) results as your consent to their processing by Unimed
for the above specified purposes.
3
– Legal ground for the processing
The processing of personal data,
depending on cases, is based on the following legal grounds:
• the pursuit
of a legitimate interest of the Controller to ensure the security of the
Website, control its correct functioning and obtain statistics in relation to
its use, as to the browsing data concerning the session, and to eventually
exercise or defend a legal claim (article 6., paragraph 1, letter f);
• the
consent given by the user (as time-to-time above indicated) to the processing
of data referred to in letters B), C) and D) and for what concerns the use of
the browsing data related to services provided by third parties through the
Website and/or obtained from third parties through the Website, (article 6,
paragraph 1, letter a). Consent may be withdrawn at any time.
4- Modalities of processing
The processing of personal data will be performed through IT
instruments, both automated and not automated (in such case, through human
intervention in the management of IT systems) and through the use of analog
instruments (paper management), according to logical processes closely
correlated to the purposes of the same processing and, in any case, with the
support of equipment and with modalities that guarantee the security and
confidentiality of the same data, preventing loss of data, illegal or incorrect
uses, and unauthorized accesses.
We use technical (“application”) cookies, both first party and third
party, for data processing on our Website.
A
“cookie” is a small quantity of data that are sent to the browser of the user by a Web server and that are subsequently
stored on the hard drive of his or her computer.
Third party cookies are cookies sent by
third party domains / partner websites that offer their functionalities inside
the pages of the Website and/or in the context of the operation of the Website (e.g.,
icons to express preferences expressed on social networks). The use of the data
collected by these external operators through cookies is subject to the
respective privacy policies. For detailed information on the preceding, we
suggest referring to the privacy policy of the services listed as third-party
cookies available on the respective websites.
Our Website does not use cookies for the
transmission of information of a personal nature e.g. first and last name,
e-mail address or telephone number), nor so called persistent cookies of any
kind, or system to track users.
The
use of so-called session cookies is strictly limited to the transmission of
session identifiers (represented by random numbers generated by the server),
necessary to enable the secure and efficient exploration of the website, and to
the acquisition of data to save the browsing preferences of the user (e.g.,
setting the language, managing statistics), in order to optimize the experience
on the Website. Session cookies used in this Website avoid recourse to other IT
techniques potentially prejudicial to the confidentiality of users’ browsing and
do not allow acquisition of personal data identifying the user.
Cookies may be deactivated[1] but, should this choice be made, users would not be able to use the
related functionalities and services. If You accept the use of cookies You
consent to the processing of Your data for the above-specified purposes (see
paragraph 2).
5- Disclosure and dissemination of data
The
entities that may become aware of the personal data are our employees and
collaborators, who take care of the administrative management of the Web page
and of relations with users / customers. The company taking care of the
management of the Website may, possibly, become aware of the personal data, on
the occasion of assistance / maintenance interventions.
The data are never transferred to, or in any case acquired by, third
party entities located or in any case operating in countries outside the
European Union, with the exception of the following: Google, LLC, limited to the
functionalities above indicated (the company is included in the so called Privacyshield List
https://www.privacyshield.gov/welcome:
thus, they guarantee an appropriate level of protection).
Furthermore, some Google services are provided by Google Ireland Limited
in favor of subjects based and / or operating within the European Union. Finally, the software platform used for the
implementation of our database is managed by e-Mentor Srl, an Italian company to whom the personal data are communicated as
the company has been appointed Data Processor pursuant to art. 28 GDPR.
Where needed, should we
have an obligation to report a crime or in any case the need to pursue a
legitimate interest to exercise or defend a legal claim on our part, the data
of users might be disclosed to the judicial Authority or to police forces.
Apart from the cases just specified, personal data will
not be disclosed to third parties and/or in any way disseminated outside the
context of the European Union.
6- Data retention periods
Browsing data are deleted immediately after the processing, at the
end of the browsing session (closure of the browser).
Data provided voluntarily by users (by sending e-mails), or by fax
or by telephone, will be stored for the 12 months following delivery to users
of the requested information, unless further storage of the data is necessary
to comply with legal obligations, or the parties enter into another relationship.
Data processed through third party cookies (including sharing
cookies) are stored for the period of time provided by the operators, according
to the respective privacy policies; data processed through the use of Google
Analytics cookies are stored for 26 months from their collection.
The data included in the Unimed’s
database will be processed and stored for a maximum period of 10 years from
their acquisition; unless, prior to the expiration of this term, the interested
party does not request cancellation or withdraw the consent to the processing.
7- Rights of the
data subject concerning the processing of personal data (Articles 15-22 and 77 of the Regulation)
It
is possible to submit requests to exercise the rights afforded by the
Regulation (access, rectification, erasure, objection, restriction and
portability if the conditions are present) by sending them to the above
indicated Unimed’s references.
To
enable us to respond quickly, we kindly ask You – thanking You in advance for
Your cooperation – to specify Your first and last name, e-mail address. Certain
requests (for example concerning exercise of the right to access) must be
accompanied by a photocopy of an identity document with Your signature to
verify Your identity; it is also necessary to specify the address at which You
wish to receive the answer. The answer will be sent within one month of receipt
of the request.
The
data subject has also the right, if he or she believes the processing of his or
her data to be performed in infringement of the provisions of the Regulation,
without prejudice to the right to complain to the competent civil or
administrative judicial authorities, to lodge a complaint with the Supervisory
Authority for the protection of personal data, within the limits of its jurisdiction.
[1] The following guides for
the deactivation or activation of cookies are also available for mainly-used
browsers:
Chrome Internet Explorer Firefox Safari Android iPhone, iPad
In addition, the User may take advantage
of the information provided by EDAA (EU), Network Advertising Initiative (USA)
and Digital Advertising Alliance (USA), DAAC (Canada), DDAI (Japan) or other
similar services, to manage the tracking preferences of the majority of
advertising instruments.
