Privacy Policy

The present Privacy Policy is provided in accordance with art. 13 of EU Regulation 2016/679 (GDPR) and the current Italian legislation for the protection of personal data, Legislative Decree no. 196/2003 and subsequent amendments, especially Legislative Decree no. 101/2018, and applies exclusively to those who interact with the website www.associazionevia.org. The information refers only to this website and does not extend to other external websites and/or linked sites that may be visited by the User. Its purpose is to describe the methods of managing the website with reference to the processing of personal data of those who consult its content and to allow these individuals, in case of data provision, to know the purposes, methods, timing, and location of the processing carried out by the Data Controller.

1. Data Controller
The Data Controller, according to current regulations, is the website administrator, Giulia Carbone, CF CRBGLI88E63C589D, Associazione VIA, Via Galliano 22 12080 Vicoforte (CN), CF 93063860048, contactable at the following email addresses: info@associazionevia.org.

2. Methods of Processing Personal Data
The processing is carried out using computer and/or telematic tools, with organizational methods strictly related to the purposes indicated here. In light of what is prescribed in EU Regulation 2016/679, the Data Controller ensures that the processing of the Personal Data acquired will be based on the principles of lawfulness, fairness, transparency, accuracy, and minimization, and undertakes to protect their integrity and confidentiality by adopting appropriate security measures to prevent unauthorized access, disclosure, alteration, or destruction.

3. Personal Data Subject to Processing
Among the Personal Data processed by this website, independently and/or through third parties, are:

1. Data collected automatically (hereinafter referred to as Navigation Data)
2. Data voluntarily provided by the User

3.1. Navigation Data
The computer systems and software procedures used to operate this website acquire, during their normal operation, some technical and navigational data, the transmission of which is inherent to the use of Internet communication protocols. This category of data includes IP addresses, domain names, the type of browser used, the method used to connect to the site, the date and time of the request, the web page of origin of the visitor (referral) and exit, as well as other parameters relating to the user’s operating system and computer environment. Navigation Data is acquired not for the purpose of identifying users but solely for the purpose of obtaining anonymous statistical information, in aggregate form, on the use of the Site and its services and/or checking its correct functioning. This data will be deleted immediately after processing.

 

3.2. Data Voluntarily Provided by the User
Where the User uses one of the services offered, especially communication services (Newsletter, Contact Form, and Consultation Request Form), the Data Controller may collect all voluntarily provided Data, but their use will be solely aimed at providing the requested service. In this category of data, there are: name and email address, the provision of which is necessary to respond to requests and contact the sender, as well as any other optional data, always provided voluntarily, such as the phone number.

4. Purpose of Processing and Legal Basis
The Data that the User chooses to provide voluntarily is collected to allow the website to provide its services, as well as for the following Purposes:

a) to perform statistical analysis on aggregated and anonymous data, analyze User behavior, improve products and services provided by the Controller, and meet the User’s expectations. It is important to note that none of this information is related to individuals, and since the identification of the user is precluded, no explicit consent is required.

b) to carry out commercial, promotional, and profiling activities following the voluntary subscription by the User to the Newsletter service, who, by subscribing, makes themselves available to receive promotional and marketing communications based on the activity carried out on the Site;

c) to carry out consulting and/or professional assignments only in cases where the User, with explicit consent, communicates their Data through requests for assistance or information. Such Data will be used solely for the evaluation of the assignment and for its eventual fulfillment;

d) to fulfill any legal, accounting, and tax obligations;

e) for other purposes connected, accessory, and/or instrumental to the services offered by the website.

As prescribed by current regulations, processing is lawful only if and to the extent that one of the conditions provided for in art. 6 of EU Regulation 2016/679 is met. The purposes listed above represent a legitimate processing of Personal Data pursuant to art. 6, c.1, lett. a), b), and f) of the GDPR. Without prejudice to the legitimate interest of the data controller, processing is necessary for the provision of the services provided by the site and for the execution of pre-contractual measures taken at the request of the User. Furthermore, the Data Subject always expresses consent to the processing for the aforementioned purposes under letters b) and c). It should therefore be clarified that for the purposes in question, the provision of personal data is always optional, but the absence of this would result in the impossibility of responding to requests for information, activating consulting services, and/or receiving applications for any work collaborations.

5. Recipients of the Data
In addition to the Data Controller, in limited cases, the Data may be accessed by:

1. a) categories of specifically trained Data Processors involved in the organization of the website (administrative, commercial, marketing, legal, system administrators);
2. b) external subjects such as third-party technical service providers or hosting providers who, in such cases, under art. 28 GDPR, will be appointed Data Processors. The updated list of Data Processors, if appointed, can always be requested from the Controller at the email addresses previously indicated. To know in detail the technical service providers with whom the website shares the acquired Data, reference is made to point IX of this information.

Outside of the aforementioned hypotheses, personal data will not be disclosed except to subjects, Entities, and Authorities to whom disclosure is mandatory pursuant to legal or regulatory provisions.

6. Data Retention Period
As expressly provided for in art. 5, c. 1, lett. e) of the GDPR, the Data is kept for a period not exceeding the achievement of the Purposes for which it is processed. Specifically:

• data collected for statistical purposes will be kept only in anonymous and aggregated form;
• data collected based on the User’s Consent may be kept until it is revoked by the data subject;
• data collected for consulting requests or professional assignments will be kept for the time strictly necessary for the performance of the assignment and for the execution of the contract of which the User is a party, as well as for ancillary purposes (e.g., tax obligations, judicial protection, etc.).

At the end of the retention period, the Data will be deleted or returned to the User, unless there are further purposes for their retention. Further information regarding the data retention period and the criteria used to determine this period can always be requested by contacting the Controller at the email address info@associazionevia.org.

7. Location of Processing and Transfer of Data to Third Countries
The Data is processed at the operating headquarters of the Data Controller. The Data may be processed by natural persons and/or legal entities, operating on behalf of the Controller, located in EU or non-EU member countries. In the event that the Data is transferred outside the EEA, the Controller ensures that the processing by such recipients takes place in accordance with the methods prescribed by current legislation. More information, upon request, can be obtained from the Controller at the above-mentioned contacts.

8. Cookies
This website uses cookies. Cookies are small text files that visited sites send to the User’s terminal and are stored to be retransmitted to the same sites upon subsequent visits. Their purpose is to make the User’s experience more efficient because through storage the site remembers actions and preferences, and this, in turn, will also allow for the customization of content and ads. Given that there are different types of cookies (Technical, Third Party, Analytics, etc.), for detailed information on how these are used by this website, reference is made to the Cookie Policy.

9. Services Provided by Third Parties
Some personal data of the User may be shared with third-party technical service providers who, as Data Processors, will process the Data on behalf of the Controller without disclosing or using it for purposes other than those that legitimized its acquisition. The third-party services used by this website are:

1. Statistical Services
2. Email Address Management Services (Newsletter)

9.1. Statistics
Statistical services allow the Data Controller to monitor and analyze usage data and serve to track User behavior. In particular, this website uses Google Analytics as an analysis service offered by Google Ireland Limited.

Google uses Personal Data for the purpose of analyzing the use of the website by Users, compiling reports on site activities and User behavior, as well as verifying how often the site is visited, how it is tracked, and which sections are most frequently viewed. The collected data is processed in aggregate and anonymous form. Among these are: browser identifier, date and time of interaction with the site, originating page, IP address, cookies, etc. The data collected does not allow the personal identification of Users and is not crossed with other information relating to the same individuals. This data is shared with other Google services. Google may use Personal Data to contextualize and personalize ads within its advertising network. Furthermore, it may transfer this information to third parties where required by law or where such third parties process the information on behalf of Google.

Where the User deems it appropriate not to make their activity on the Site available to Google, they can install the browser add-on to disable Google Analytics using the following link.  

For further information, please refer to Google’s Privacy and Terms.

10. Interaction with Social Networks
This website also incorporates referral links for Social Networks to allow the User easy interaction with them. In case an interaction service is installed, it is possible that, even if the User does not use it, it may collect traffic data relating to the pages on which it is present. In any case, the interactions and information acquired by this website are subject to the Privacy Settings chosen by the User for each Social Network, while the collection and use of such information by them are governed by their respective Privacy Policies to which reference is made below.

10.1. Instagram (Meta Platforms, Inc.)
Instagram buttons are interaction services with the social network Instagram, provided by Meta Platforms, Inc. Personal Data collected: Cookies and Usage Data. Processing location: Ireland – Privacy Policy

10.2. WhatsApp
WhatsApp buttons are interaction services with the WhatsApp social network, provided by: if you reside in the European region, WhatsApp Ireland Limited provides you with services based on Terms of Service and Privacy Policy, if you live outside the European region, WhatsApp LLC provides you with services based on Terms of Service and Privacy Policy. Personal data collected: Cookies and Usage Data. Processing location: Ireland – Privacy Policy

11. Rights of the Data Subject
As an interested party, you have the right at any time to obtain confirmation of the existence or otherwise of your Personal Data, to know its content and origin, to verify its accuracy, request its integration, updating, rectification, deletion, portability, and limitation of processing, and to oppose its processing. You also have the right to lodge a complaint with the competent supervisory authority if you believe that the processing of your data violates current legislation. To exercise your rights, you can contact the Data Controller via the email addresses indicated in point I of this statement.

12. Changes to the Privacy Policy

This privacy policy is subject to updates in compliance with legal or regulatory provisions. The Data Controller reserves the right to make changes with timely notice. Therefore, Users are invited to regularly consult this section to become aware of the most recent and updated version of the policy. Unless otherwise specified, the previous Privacy Policy will continue to apply to the Data collected up to that time. If the User decides not to accept the changes made, they will be required to cease using the website and may request the Data Controller to remove their Personal Data.

This Privacy Policy is updated as of April 4, 2024.