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PRIVACY POLICY Privacy policy of the Piccabulla cultural association's website *********** This page describes how the Piccabulla website is managed, with reference to the processing of personal data of users consulting it. This notice is also provided pursuant to art. 13 of Legislative Decree no. 196 of 30 June 2003 (hereinafter referred to as the Privacy Code) to those interacting with the Piccabulla site and its web services, accessible telematically from the address http://www.piccabulla.it, corresponding to the home page of the association's site. The notice only applies to Piccabulla's website and not to other websites that the user may consult through links. The informative note is also based on Recommendation no. 2/2001 that the European Authorities for the protection of personal data, meeting in the Group established by art. 29 of Directive no. 95/46/EC, adopted on 17 May 2001 to identify certain minimum requirements for the collection of personal data online and, in particular, the methods, times and nature of the information that data controllers must provide to users when they connect to web pages, regardless of the purposes of the connection. The "Data Controller" of the processing Following consultation of this site, data relating to identified or identifiable persons may be processed. The "owner" of their treatment is the Piccabulla Cultural Association, in the person of its president Sabrina Pompa (or rather Sabrina Lilli, maternal surname, adopted in all the pages of the site) and legal representative, domiciled at its registered office in Rome (RM) in v.dei Savorelli, 75 . In the various sections of the website, if data processing is carried out, it always relates to the Data Processor. Place of data processing Data processing related to the web services of this site takes place at the aforementioned registered office and is carried out only by the member(s) in charge of data processing, "person(s) in charge" designated by the president or Stefano Bertoldi (stefano@piccabulla.it) No personal data deriving from the web service is disseminated. Personal data supplied by users are used solely for the purpose of performing the service or provision requested and are communicated to third parties only if necessary for that purpose. Types of data processed a) Navigation data The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of the Internet. This is information that is not collected in order to be associated with identified interested parties, but which by its very nature could, through processing and association with data held by third parties, make it possible to identify the navigating users. This category of data includes the "IP addresses" or domain names of the computers used by users connecting to the site, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used to submit the request to the web server, the size of the file obtained in response, the numerical code indicating the status of the response given by the web server (successful, error, etc.) and other parameters relating to the user's operating system and IT environment. This data is used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check the correct functioning of Piccabulla's website. It should be noted that the aforementioned data could be used to ascertain responsibility in the event of computer crimes to the detriment of Piccabulla's website or of the structures (hardware) of the person responsible or of other sites connected or linked to it: except for this eventuality, at present the data on web contacts do not persist for longer than is necessary and for the association's institutional purposes only. b) Data provided voluntarily by the user When requests are made to send e-mails to the addresses indicated in the relevant section of Piccabulla's website, this entails the subsequent acquisition of certain items of the requesting party's personal data, including the requesting party's e-mail address, which is necessary in order to reply to requests. Specific information, including summary information, will be progressively reported or displayed on the pages of the site set up for these particular requests. c) Cookies A cookie is a small "data file" that some websites, while being visited, may send to the address of the user who is browsing them in order to trace his/her path within the site and collect data in an exclusively anonymous form to improve the offer and usability of the site itself. The Piccabulla RFC Cultural Association website makes use of so-called "technical" cookies; these serve exclusively to carry out navigation or to provide any services requested by the user. They are not used for any other purpose. Analytical cookies" are also used, which the Privacy Guarantor has assimilated to technical cookies for site optimisation. In this case, information may be collected in aggregate form on the number of users and how they visit the site. Therefore, the same rules apply to analytics cookies, in terms of information and consent, as for technical cookies. Optional supply of personal data Apart from what has been specified for browsing data, the user is free to supply the personal data indicated in the electronic request forms, in the sections of the website set up for particular information and/or services on request. It should be noted, however, that failure to provide such data may sometimes make it impossible to obtain what has been requested. Processing methods and security measures Personal data are processed by automated and non-automated means only for the time strictly necessary to achieve the purposes for which they were collected. Specific security measures are observed to prevent the loss of data, illicit or incorrect use and unauthorised access. Rights of the data subjects The subjects to whom the personal data refer, possibly collected in the above-mentioned specific sections, have the right at any time to obtain confirmation of the existence or non-existence of such data and to know its content and origin, verify its accuracy or request its supplementation or updating, or rectification pursuant to Art. 7 of the Privacy Code (Right of access to personal data and other rights). The interested party has the right to request cancellation, transformation into anonymous form, as well as to oppose in any case, for legitimate reasons, their processing. Any requests should be addressed to: Piccabulla Cultural Association The Piccabulla Cultural Association consciously does not use its website to request and/or process data from minors under the age of 18. Considering that the state of perfection of the automatic control mechanisms does not currently render them free from errors and/or dysfunctions, it is specified that the present document constitutes the "Privacy Policy" of the Piccabulla website and will be subject to updating. INFORMATION pursuant to art. 13 of the Privacy Code to be provided to users - through the website - as established by the Order of the Guarantor Authority for the Protection of Personal Data INFORMATION IN ACCORDANCE WITH ART. 13 OF THE ITALIAN LEGISLATIVE DECREE. LGS. 196/2003 1) Purposes and modalities of the processing for which the data are intended 2) Sensitive data 3) Categories of subjects to whom the data may be communicated or who may become aware of the data in their capacity as data processors and/or persons in charge of processing 4) Rights of the data subject 5) Data Controller and Data Processor 1) Purposes and modalities of the processing for which the data are intended The Piccabulla cultural association (hereinafter briefly referred to as the "Association") informs you that the personal data in its possession, collected directly from the data subject or from third parties, may be processed, including by third parties (also located abroad) for: a. Fulfilment of obligations provided for by laws, regulations and EU legislation, or provisions issued by Authorities empowered to do so by law and by supervisory and control bodies. The provision of personal data necessary for such purposes is compulsory and its processing does not require the consent of the parties concerned. b. Purposes strictly connected with and instrumental to the management of relations with members, associates and/or customers (e.g. acquisition of information prior to the conclusion of a contract, execution of operations on the basis of obligations arising from the contract concluded with customers). The provision of personal data necessary for these purposes is not compulsory, but refusal to provide such data may - in relation to the relationship between the data and the service requested - make it impossible for the Association to provide the service itself. The relative processing does not require the consent of the person concerned. c. Purposes functional to the Association's activity, such as the survey of customer satisfaction on the quality of the services rendered and on the activity carried out by the Association by means of personal interviews online or by telephone, questionnaires, etc.; the promotion, dissemination and/or processing of personal data for the purposes of the Association's activities. the promotion, dissemination and/or sale of products and services of the Association or of third parties connected with institutional activities, carried out by means of letters, landline and/or mobile phones, advertising material, automated communication systems, electronic mail, MMS (Multimedia Messaging Service) and SMS (Short Message Service) messages, etc.; the processing of studies and market research, carried out by means of personal or telephone interviews, questionnaires, etc, and the performance of public relations activities. The provision of the data necessary for these purposes is not compulsory and their processing requires the consent of the person concerned. The processing is carried out by means of manual, computerised and telematic tools with logic strictly related to the aforementioned purposes and, in any case, in such a way as to guarantee the security and confidentiality of the data. 2) Sensitive data The Association processes sensitive data of its members and/or customers only in order to carry out specific services and operations requested by them (e.g. payment of membership fees). In such cases, the Association may only carry out such operations if it has obtained the written consent of the requesting data subject. 3) Categories of subjects to whom the data may be communicated or who may become aware of the data in their capacity as data processors and/or persons in charge The Association - without the need for the consent of the data subject - may communicate the personal data in its possession to those subjects to whom such communication must be made in fulfilment of an obligation provided for by law, by a regulation or by the EU legislation. The Association, moreover, may communicate, with the consent of the person concerned, data concerning its members and/or customers to external companies, bodies or consortia, including foreign ones, that carry out, also on its behalf, activities and processing similar to the institutional ones of the same association; Natural persons belonging to the following categories may become aware of the data in their capacity as appointees, with regard to the data necessary to carry out the assigned tasks: associates, collaborators, workers employed by the Association or seconded to it, temporary workers, interns and consultants. 4) Rights of the data subject The Privacy Code grants the data subject specific rights, including the right to know what data concerning him/her is held by the Association and how it is used, to obtain the deletion, transformation into anonymous form or blocking of data processed in breach of the Privacy Code, as well as the updating, rectification or, if interested, the integration of data, and to object, for legitimate reasons, to the processing itself. Finally, the data subject may at any time object to processing aimed at sending commercial and advertising material, direct sales or market research. 5) Data Controller and Data Processor The "data controller" is the Piccabulla Cultural Association, which has its registered office in via dei Savorelli 75 - 00165 Rome and its operational headquarters in via dei Savorelli 114 - 00165 Rome, while the Data Processor to whom the data subject may refer in order to exercise the aforementioned rights is the President at the registered office. The Piccabulla Association points out that the interested party retains the rights provided for in Article 7 of the Privacy Code.
