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PRIVACY POLICY

Information notice pursuant to Art. 13 of the Reg. UE 2016/679 (General Data Protection Regulation | GDPR)

ASSO DPO - Privacy policy

Pursuant to Reg. UE 2016/679 (General Data Protection Regulation) we provide you the deserved information concerning processing of collected personal data. The notice is not valid for external links; Data Controller is not to be considered responsible for third parties’ web pages.
The notice is drawn up pursuant to art. 13 Reg. UE 2016/679 (General Data Protection Regulation), inspired to DIRECTIVE 2009/136/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 25 November 2009, and to Simplified Arrangements to Provide Information and Obtain Consent Regarding Cookies – 8 may 2014 by Italian Data Protection Authority, considering the EDPB Guidelines 05/2020 on consent under Regulation 2016/679.

Personal data

Any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can directly or indirectly be identified, in particular by reference to an identifier such as a name, an identification number, a location data, an online identifier or to one or more specific factors to the physical, physiological, genetic, mental, economic, cultural or social identity (C26, C27, C30).

Navigation data

Computer systems and procedures software preceded to the operation of this site, acquire, during their normal exercise, some personal data whose transmission is implicit using Internet communication protocols. This category includes: IP addresses, URI/URL (Uniform Resource Identifier/Locator), time of request, type of request, outgoing packet size, server status of response (received, error, etc…) and other parameters related to the operating system (for further information see Cookies policy of this site).

Data provided by data subject

The optional, explicit and voluntary dispatching of messages to contact-addresses, as well as compilation and forwarding of forms that are on the Data Controller’s website, involves the acquisition of sender’s personal data necessary to reply, as well as all the personal data included in messages themselves.

Detailed Notices

Detailed notices related to specific services or processing are available on specific pages of the site.

Cookies

Click here for more information about the cookie policy.

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1. Who is the data controller? How to contact him?

Pursuant to art. 4 ad 24 Reg UE the Data Controller is Associazione Data Protection Officer (ASSO DPO), with registered office in 20121 Milano – P.le Principessa Clotilde n. 6, P.IVA 08258580961, C.F. 97656960156, in person of its Legal Representative Dott. Matteo Colombo.

contacts: email info@assodpo.it; telephone number: 800561720.

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Purposes of processing, legal basis, data retention and nature of conferral

Purpose A)
Website browsing.

• LEGAL BASIS: legitimate interest (art. 6 par. 1 lett. f) and recital 47 GDPR): processing is necessary for pursuing data controller’s (or third party) legitimate interest, provided that the interests or the fundamental rights and freedoms of the data subject are not overriding, taking into consideration his reasonable expectations based on the relationship with controller. Activities strictly necessary for site operation and platform browsing services.
• DATA RETENTION: single session. For further information see the cookie policy;
• NATURE OF CONFERRAL: mandatory in order to permit the website navigation.

Purpose B) (see the policy in the contact area).
Eventual contact form filling.

• LEGAL BASIS: legitimate interest | answering data subject requests (art. 6 par. 1 lett. f) and recital 47 GDPR).
• DATA RETENTION: for the time necessary to reply to the request and in any case no longer than 1 year.
• NATURE OF CONFERRAL: the provision of data is necessary to allow the Data Controller to provide feedback to the requests received through the form. Failure to provide the data marked with the symbol* or the indication (required), will make it impossible to obtain the information requested.

Purpose C)
Signing-up to Associazione Data Protection Officer and diffusion of identification data through the publication of the “Register of Members” 
(specific policy available in the sign-up area).

• LEGAL BASIS: with regard to registration with the association, the legal basis is the fulfilment of contractual obligations (art. 6, par. 1 letter b GDPR). With regard to the disclosure of identification data, the legal basis varies depending on the type of member: it may be the legal obligation (art. 6, par. 1 letter c GDPR and LAW 14 January 2013, n. 4, art. 4 c. 1 and art. 5 c. 2 letter b)) which requires the Association to prepare and publish the list of members Soci Effettivi – Persone Fisiche updated annually; or the consent, if other types of members, such as Educational, wish to appear on the list (“Register of Members”).
In any case, all categories of members, at the time of registration, may also freely choose whether to give, upon consent, further identifying information to be included in this list (such as, for example, the province of residence).

• DATA STORAGE PERIOD: duration of registration and, after termination, 10 years. With regard to the disclosure on the “Register of Members” of personal data NOT of members Soci Effettivi – Persone Fisiche and additional data, the person concerned is always free to revoke the consent given.
• NATURE OF CONFERRAL: the provision of data is optional or mandatory depending on the specific purpose for which the data is processed. Failure to provide the data marked with the symbol* or indication (required), will make it impossible to register. The provision of data without * is optional and will not preclude the completion of the registration.

Purpose D)
Filling in forms to send your application to join the working groups / scientific committee of the Association Data Protection Officer ASSO DPO.

• LEGAL BASIS: legitimate interest | request of the data subject (art. 6 par. 1 lett. f) and recital 47: for the constitution of the working groups / scientific committee necessary for the pursuit of the aims of the association itself, minding also the relationship existing between the data subject (associate) and the Data Controller.
• DATA RETENTION: in case of non-selection of the data subject – 12 months; in case of selection of the data subject – duration of the mandate of the working group / scientific committee and after the termination 10 years.
• NATURE OF CONFERRAL: the provision of data marked with the symbol* or indication (required) is mandatory to apply. Failure to provide the data will make it impossible to send your application to join the working groups / scientific committee.

Purpose E)
Filling in of forms to use the “Sportello del Consumatore” services (art. 2, comma 4, l. 4/2013)
(see specific information notice in the “Sportello del consumatore” area): to obtain information about the professional activity in general and the quality standards required from members, as well as to report any complaints in case of litigation with individual professionals, with the commitment of the professional association for the agreed resolution of the dispute reported by the consumer (see specific information notice in the Sportello per il consumatore Area).
• LEGAL BASIS: law obligations (art. 6, lett. c GDPR), the Association must promote forms of guarantee to protect the user in case of litigation with individual professionals, as well as provide feedback in case of requests relating to the professional activity in general and the quality standards required from members (art. 2, paragraph 4 Law 4/2013).
• DATA RETENTION: in the case of a simple request for information regarding the professional activity in general and the quality standards required from members, for the time necessary to respond to the request and in any case no longer than 1 year. In case of reports and for the management of cases of litigation with individual professionals, for the period necessary for the management and resolution of the dispute.
• NATURE OF CONFERRAL: the provision of data is mandatory to use the services of the “Sportello del consumatore”. Failure to provide the data marked with the symbol* or wording (required), will make it impossible to use the services referred to in this point.

Purpose F)
Registration to “Area Riservata” of the website in order to consult and download documents and information reserved to associated.

• LEGAL BASIS: fulfilment of contractual obligations deriving from registration to the Association (art. 6, par. 1 lett. b) GDPR).
• DATA RETENTION: the conferral of data is mandatory in order to access the Reserved Area. In case of non-conferment, you cannot access this area of the website.

Purpose G)
Registration to the Congress ASSO DPO in webinar mode; management of administrative-accounting activities related to the event; use of the e-mail contact to inform those interested about the Congress and to send communications related to the service.
The processing operations carried out for administrative-accounting purposes are those related to the performance of activities of an organizational, administrative, financial and accounting nature, regardless of the nature of the data processed which, in the case of subjects already associated are: name, surname, email address and ASSO DPO card no.; while in the case of subjects not associated are: name, surname, email address, bank details (for the collection of the transfer). In the context of the webinar, no additional information will be collected with respect to the purposes pursued: the tool used, in fact, does not track or monitor in any way the behavior of the participants on the platform (see specific notice in the Congress Registration area ASSO DPO).

• LEGAL BASIS: d pre-contractual obligations related to registration to the Congress (art. 6, par. 1 letter b) GDPR); legal obligation (art. 6, par. 1 letter c) GDPR and LAW 14 January 2013, n. 4, art. 2 c. 3 “Professional associations promote, also through specific initiatives, the continuous professional formation of their members […]”).
• DATA RETENTION: 10 years or otherwise stated by law;
• NATURE OF CONFERRAL: mandatory, tightly essential to give execution to contractual and law obligations. In case of non-conferment, the data Controller won’t be able to proceed with the registration to the Congress.

Purpose H)
Newsletter service. The association, in pursuing the fundamental aims of the Statute, including “promoting research and the spread of knowledge”; “promoting the valorization of the role of the DPO and fostering its professional growth”, offers a newsletter service.
This activity is carried out through the e-mail coordinates provided directly by the interested party during the registration phase or through the free filling in of forms on the website. The interested party will receive, through this channel, institutional communications, news about the association and, more generally, notifications regarding, for example, events such as the Congress, new webinars, new articles published on the site and on the others official channels of the association.
The data controller, in order to compare and possibly improve the results of communications, uses systems for sending newsletters and communications with reports. Thanks to reports, the Data Controller will be able to discover, for example: the number of readers, single openings, unique “clickers” and clicks; devices and operating systems employed to read the communication; details of email sent, delivered or not. All these data are employed with the purpose of comparing, and possibly improving, the communication results (see specific policy for subscribing to the newsletter).

• LEGAL BASIS: the processing is necessary for the pursuit of the legitimate interest of the data controller or third parties, as long as the interests or fundamental rights and freedoms of the data subject which require the protection of personal data do not prevail. The legitimate interest of the data controller is to pursue the institutional information purposes pursued by the Association (art. 6 par. 1 letter f) GDPR and recital 47). As required by the Opinion 6/2014 of the Working Group Art. 29 – WP29 – on the concept of legitimate interest, the Data Controller conducted a “LIA” (Legitimate Interests Assessment), balancing the interests of the parties and the rights at stake. The interested party may oppose the legitimate interest of the Data Controller both at the time of joining the Association and afterwards.
• DATA RETENTION: the data subject may object to the processing based on legitimate interest in an easy way and free of charge (each communication made will contain the link to exercise the opt-out).
• NATURE OF CONFERRAL: the provision of data for this purpose is optional and, where lacking, personal data won’t be processed for such purpose; the denial of conferral will not undermine benefits from other purposes.

Purpose I)
Disclosure of personal data, including the image (photo/video/audio), for promotional and informative activities aimed at publicizing the activity, the services of the Association.
Personal data may be collected during events organized by ASSO DPO (e.g. congresses, seminars, training, etc.). The disclosure will take place through the publication of personal data (including images) through different tools and communication channels such as magazines, brochures, presentations, websites, social networks.

• LEGAL BASIS: consent (art. 6, lett. a GDPR): the data subject has provided consent to the processing of his personal data.
• DATA RETENTION: data will be retained until opposition (opt out/consent withdrawal). Hard copies will be diffused up to exhaustion and your image won’t be reproduced anymore.
• NATURE OF CONFERRAL: data conferral for this purpose is optional and, where lacking, personal data won’t be processed for such purpose; the denial of conferral will not undermine benefits from other purposes.

Purpose L)
Transfer of data to third parties (partners and sponsors of the Data Controller) for marketing purposes
, i.e. to receive promotional material and commercial/informative communications from third parties, who operate, for example, in the following areas: insurance companies for professional liability policies of the Data Protection Officer, certification bodies, consulting and training companies, universities, software houses and, in general, third parties affiliated to ASSO DPO. The list of these third parties and active agreements is available at the following link: https://www.assodpo.it/convenzioni/.

• LEGAL BASIS: consent (art. 6, lett. a GDPR): the data subject has provided his consent to process his or her personal data.
• DATA RETENTION: until opposition (opt out/consent withdrawal).
• NATURE OF CONFERRAL: data conferral for this purpose is optional and, where lacking, personal data won’t be processed for such purpose; the denial of conferral will not undermine benefits from other purposes.

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3. Who the collected data will be communicated to?

Provided data will be shared with recipients who will treat them as data Processors (art. 28 Reg. UE 2016/679) and/or as natural person acting under the controller’s or processor’s authority (art. 29 Reg. UE 2016/679) for former purposes.
Namely, data will be shared with:
– companies contractually associated to the Data Protection Officer Association;
– subjects who provide services for the management of the information system used by the Data Protection Officer Association and telecommunications networks;
– professionals, studies or companies in the assistance and consultancy field;
– subjects who provide services for the management of the activities indicated above in the purposes (subjects for communication, printing brochures, flyers, websites, videos) with prior consent;
– platform managers for the services listed above (site hosting, YouTube);
– commercial Partners, with prior consent;
– competent authorities for compliance with legal obligations and / or provisions of public bodies, upon request;
– other associated, upon request.
The list of the data Processors is constantly updated and available writing to  info@assodpo.it or sending a traditional mail to the Data Controller registered office.

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4. Does Asso DPO transfer data to a third country and/or to international organisations?

Personal data may be transferred only with prior consent of the data subject and, in this case, they will be transferred to countries outside the EU exclusively for the purpose of transmission on social platforms; such transfer will then be managed as established in the general conditions and in the privacy policies of the related social networks. If it should be necessary to transfer your data to non-EU countries, this will be done in compliance with the limits and conditions of the articles 44 and ss. of EU Reg. 2016/679. The data subject may obtain information about the guarantees for data transfer writing an email to the address info@assodpo.it or at the registered office of the Data Controller.

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5. Are personal data processed by an automated mean?

We do not process data by automated mean, profiling included.

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6. Which rights am I entitled to? How can I exercise them?

You can exercise your rights, as required by art. 15 and subsequent of the General Data Protection Regulation UE 2016/679 (GDPR) contacting the data Controller at the email address: info@assodpo.it. You have the right, at any time, to obtain from the data Controller the access to your personal data, request their rectification, erasure or processing restriction and, if applicable, data portability. Furthermore, you have the right to object anytime to your personal data processing based upon legitimate interest. Where applicable, you have the right to withdraw consent without prejudice to the lawfulness of the processing based on the consent given before the withdrawal.
To unsubscribe from newsletter service (E-Mail), please write to info@assodpo.it (object: “cancellazione da automatizzato”) or use our automated unsubscribing tools.
Without prejudice to any other administrative or judicial remedy, in case you consider the processing conflicting with Reg. UE 2016/679, pursuant to article 15 lett. f) you have the right to lodge a complaint with a supervisory authority (www.garanteprivacy.it).
In case of request for data portability, the Data Controller will provide your personal data in a structured format, commonly used and readable by automatic device.

7. More information
Data controller retains the right to modify, update, add or remove parts of this statement at his own discretion, in any moment.

Date of review: 21/07/2020