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800 561720

PRIVACY POLICY – JOIN ASSOCIATION ASSO DPO

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

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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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2. Purposes of processing, legal basis, data retention and nature of conferral (complete list of the Data Controller’s purposes of processing available in the privacy policy web in the footer of the website)

Purpose C)
Signing-up to Associazione Data Protection Officer (specific policy available in the sign-up area)

  • LEGAL BASIS: Processing aimed at fulfilling law obligations (art. 6, lett. c GDPR) and contractual obligations related to the registration (art. 6, lett. b GDPR).
  • DATA RETENTION: for the entire membership period and 10 years after its termination.
  • NATURE OF CONFERRAL: The conferral of personal data is mandatory or optional depending on the purpose for which the data is processed. Whether data marked with an * or with the wording (requested) are not conferred, it will be impossible to sign up.

Purpose D)

Data disclosure, images included (photo, video, audio), for promotional activities aimed at advertise the activity, the services and the organization of the data Controller. The data diffusion will occur through data publication (images included), through different communication channels 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 for one or more specific purposes.
  • 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 purpose D) 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 E)

Data transfer to third parties (partners and sponsors of data Controller) for marketing purposes, namely to receive promotional and marketing/commercial communication from third parties acting in the following fields: insurance for the professional liability of Data Protection Officers, certification bodies, consultancy and trading firms, Universities, software house. The list of the predicted is available on demand.

  • 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 purpose E) 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 F)

Direct marketing

Whether the data subject fills any forms for the data collection, in specific areas related to Direct Marketing purposes: prior consent and until opposition for direct marketing, market research, direct sales, surveys on satisfaction degree, newsletters and promotional, commercial and advertising material or regarding events and initiatives, through automated means of E-Mail, telefax, messages, SMS, MMS or other types, as well as operator-phone calls, paper mail or other information material.

The Data Controller does make use of reports relating to newsletters and promotional communication, aimed at comparing and possibly improving results. 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; user’s detailed activity; details of sent, delivered and forwarded emails; All these data are employed with the purpose of comparing, and possibly improving, the communication results.

  • LEGAL BASIS: Consent (art. 6, let. a GDPR): the data subject has provided the consent to process his personal data.
  • DATA RETENTION: Until opposition (opt out/consent withdrawal).
  • NATURE OF CONFERRAL: Data conferral for purpose D) 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)

Filling in of forms in order to use the “Sportello del Consumatore” service – art. 2, paragraph 4 of Law 4/2013 (see specific information notice in the Sportello per il consumatore Area)

  • LEGAL BASIS: law obligations (art. 6, lett. c GDPR); legitimate interest | request of the data subject (art. 6 par. 1 lett. f) and Recital 47 GDPR): The Association must promote forms of guarantee to protect the user in case of a dispute with individual professionals, as well as to obtain information relating to the professional activity in general and the quality standards required of them by members (art. 2, comma 4 L. 4/2013).
  • DATA RETENTION: for the reporting period and then for 10 years.
  • NATURE OF CONFERRAL:  The conferral of personal data is mandatory or optional depending on the purpose for which the data is processed. Whether data marked with an * or with the wording (requested) are not conferred, it will be impossible to sign up.
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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); – 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.

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 s.s. 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, 16, 17, 18, 19, 20, 21 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. Furthermore, you have the right to object anytime to your personal data processing as well as to data portability.

You have the right to oppose to the processing based upon consent and/or legitimate interest.

To unsubscribe from direct marketing updates (E-Mail or sms), please write to info@assodpo.it (object: “cancellazione da automatizzato”) or use our automated unsubscribing tools.

To unsubscribe from traditional direct marketing updates (operator phone calls), please write to info@assodpo.it  (object: “cancellazione da tradizionale”).

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 you with a structured format, commonly used and readable, by automatic device, the personal data concerning you, without prejudice to paragraphs 3 and 4 of the art. 20 of Reg. (EU) 2016/679.

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: 28/11/2019