REV. 0.1 of August 8, 2024
PRIVACY POLICY – PRIVACY NOTICE
NOTICE ON THE PROCESSING OF PERSONAL DATA PURSUANT TO
ART. 13 OF REGULATION (EU) 2016/679
SARDEGNA VERSO L’UNESCO, with registered office in Cagliari at Ex Manifattura
Tabacchi, at Opificio lnnova, Viale Regina Margherita no. 33, Tax Code 92260980922 (hereinafter referred to as “Data Controller” or “Controller”), pursuant to Regulation EU 2016/679
(hereinafter: “Regulation”) – considers privacy and the protection of Personal Data to be a
very important aspect of its activities. Therefore, before transmitting any personal data to the Controller, we invite you to carefully read this Notice: it contains important information on the processing of your Personal Data. “Personal Data” means any information relating to an identified or identifiable natural person (“data subject”); a natural person is considered identifiable if they can be identified, directly or indirectly, with particular reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to their physical, physiological, genetic, mental, economic, cultural, or social identity.
This Notice:
• is intended for the website https://www.sardegnaversounesco.org/ and its subdomains
(hereinafter: “Site”);
• constitutes an integral part of the Site and the activities we carry out;
• is provided pursuant to art. 13 of the Regulation, to those who interact with the web services
of the Site and the Controller, either by simple consultation or by using specific services made available through the Site.
The Controller can be contacted at the following address: sardegnaversounesco@gmail.com
This document has been drafted pursuant to art. 13 of Regulation EU 2016/679 (hereinafter: “Regulation”) to allow you to understand our privacy policy, how your personal information is processed when you use our sites, and, if applicable, to give your free and informed consent to the processing of your Personal Data.
The information and data you provide or otherwise acquired in the context of participation in the activities of Sardegna verso Unesco – such as participation in events – hereinafter “Services” – will be processed in compliance with the provisions of the Regulation and the confidentiality obligations that inspire the activities of Sardegna verso Unesco.
According to the principles of the Regulation, the processing carried out by Sardegna verso Unesco will be based on the principles of lawfulness, fairness, transparency, purpose limitation and data retention, data minimization, accuracy, integrity, and confidentiality.
INDEX
1. Data Controller
2. Personal Data subject to processing
a. Navigation data
b. Data voluntarily provided by the data subject
REV. 0.1 of August 8, 2024
3. Purpose of processing
4. Legal basis and mandatory or optional nature of processing
5. Recipients of Personal Data
6. Retention of Personal Data
7. Transfer of data abroad
8. Rights of the data subject
9. Changes
10. Cookies
1. Data Controller
SARDEGNA VERSO L’UNESCO, with registered office in Cagliari at Ex Manifattura
Tabacchi, at Opificio lnnova, Viale Regina Margherita no. 33, Tax Code 92260980922,
can be contacted at the email address sardegnaunesco@gmail.com
2. Personal Data subject to processing
Following the navigation of the Site, we inform you that Sardegna verso Unesco will process your
Personal Data, which may consist of an identifier such as a name, an identification number, an online identifier, or one or more factors specific to your physical, economic, cultural, or social identity suitable for making the data subject identified or identifiable.
Other Personal Data may be processed by you freely provided in the request forms (for example, to obtain information about products and services). Any sensitive data, as per art. 9.1 Reg. 2016/679/EU, should not be processed unless explicit consent is given by the data subject.
a. Navigation data
The computer systems and software procedures used to operate the Site
acquire, during their normal operation, some Personal Data, the transmission of which
is implicit in the use of Internet communication protocols. This information
is not collected to be associated with identified data subjects, but by its very nature
could, through processing and associations with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names
of computers used by users who connect to the Site, addresses in URI
(Uniform Resource Identifier) notation of the requested resources, the time
of the request, the method used to submit the request to the server, the size
of the file obtained in response, the numeric code indicating the status of the response given by the server (successful, error, etc.), and other parameters related to the operating system and the user’s computing environment. This
data is used solely to obtain anonymous statistical information on the use of the
REV. 0.1 of August 8, 2024
Site and to check its proper functioning, to identify anomalies and/or abuses, and
is deleted immediately after processing. The data could be used
to ascertain responsibility in the event of hypothetical computer crimes against the site or
third parties: except for this eventuality, web contact data does not persist for more than
seven days.
b. Data voluntarily provided by the data subject
We may process personal and/or contact data such as name, surname, email, and phone number.
Data relating to payments and other banking information, for example, contained in payment receipts for training course fees or online purchases of products or
services.
If you communicate Personal Data of third parties to Sardegna verso Unesco, you must
guarantee – assuming full responsibility – that this particular case of processing
is based on a suitable legal basis pursuant to art. 6 of the Regulation, which legitimizes the
communication to Sardegna verso Unesco and the related processing of the information in
question.
3. Purpose of processing
The processing of data that we intend to carry out may have the following purposes:
a. Allow the provision of the Services you request, such as:
site registration;
subscription to the email newsletter;
registration for training courses;
sharing of content on the site;
general information requests;
registration for events and initiatives organized by Sardegna verso Unesco;
management of your possible contractual relationship with Sardegna verso Unesco;
promotion and management of donations and sponsorships for Sardegna verso Unesco;
review and analysis of resumes for collaboration purposes with Sardegna verso Unesco;
b. respond to requests for assistance or information;
c. fulfill any legal, accounting, and tax obligations;
d. assert or defend rights in legal proceedings in the event of abuses in the use of the Site and/or our
Services or for disputes of a contractual or non-contractual nature.
REV. 0.1 of August 8, 2024
4. Legal basis and mandatory or optional nature of processing
The legal basis for the processing of Personal Data for the purposes referred to in section 3(a-b) is
art. 6.1.b) of the Regulation, as the processing is necessary for the provision of the Services
or for responding to requests from the data subject. Providing Personal Data for these
purposes is optional, but failure to do so would make it impossible to
activate the Services provided by the Site.
For the processing that falls within the statutory purposes of Sardegna verso Unesco, included among those referred to in letter 3(a), data of members or subjects in regular contact with Sardegna verso Unesco may be processed. If you have purchased services or goods from Sardegna
verso Unesco, your data may be processed for the purpose of sending direct advertising materials in relation to products or services of Sardegna verso Unesco similar to those you purchased, without your consent (so-called “soft spam”). The processing of your data for such
purposes is the legitimate interest referred to in art. 6.1.f) of the Regulation and art. 130 paragraph 4 of Legislative Decree 196/2003. In any case, pursuant to art. 21 of the Regulation, you have the option of
opposing such processing at any time, initially or on the occasion of subsequent
communications, easily and free of charge, even by writing to the Controller at the contact details
indicated above, as well as obtaining an immediate response confirming the cessation of such
processing (art. 15 of the Regulation).
The purpose referred to in section 3(c) represents a processing of Personal Data carried out pursuant to
art. 6.1.c) of the Regulation, to fulfill a legal obligation. Once Personal Data is provided, the processing is necessary to fulfill a legal obligation to which
Sardegna verso Unesco is subject. The processing for the purposes referred to in section 3(d)
would be carried out pursuant to art. 6.1.f) of the Regulation.
5. Recipients of Personal Data
Your Personal Data may be shared, for the purposes referred to in section 3 above, with:
• a. subjects who typically act as data processors pursuant to art.
28 of the Regulation, namely: i) persons, companies, or professional firms that provide
ass istance and consultancy to Sardegna verso Unesco in accounting, administrative, legal, tax, financial, and debt collection activities in relation to
the provision of Services; ii) subjects with whom it is necessary to interact for the provision
of the Services (e.g., hosting providers) iii) or subjects delegated to perform
technical maintenance activities (including maintenance of network equipment and
electronic communication networks); (collectively “Recipients”); the list of
data processors who process data can be requested from the Controller.
• b. subjects, entities, or authorities, independent data controllers, to whom it is mandatory
to communicate your Personal Data by law or by order of the
authorities;
REV. 0.1 of August 8, 2024
• c. persons authorized by Sardegna verso Unesco to process Personal Data pursuant to
art. 29 of the Regulation necessary to perform activities strictly related
to the provision of the Services, who have committed to confidentiality or have a
suitable legal obligation of confidentiality (e.g., employees of Sardegna verso Unesco)
6. Data retention
The Personal Data processed for the purposes referred to in section 3(a-d) will be retained for the
time strictly necessary to achieve those same purposes in compliance with the principles
of data minimization and retention limitation pursuant to art. 5.1.e) of the Regulation. In any
case, the Controller will process Personal Data for the time necessary to fulfill contractual
and legal obligations.
More information on the data retention period and the criteria used to
determine that period can be requested by writing to the Controller.
7. Transfer of data abroad when using platforms for live streaming or for providing content and materials in training courses
If platforms such as
Facebook Workplace or Zoom are used to enjoy training services, for live streaming of lessons and/or for sharing
informational materials, it should be noted that this use of services may necessarily involve the export of the data subject’s data (identification, contact data, data and metadata relating to the days, times, and content of
training sessions) outside the territory of the European Union
required by such service. This transfer occurs based on
the derogation provided for in Article 49 paragraph 1 letter b) of the Regulation, as the
transfer is occasionally necessary for the performance of the training service
contracted by the data subject with the Data Controller.
8. Rights of data subjects
Pursuant to Articles 15 and following of the Regulation, you have the right to request at any
time, access to your Personal Data, rectification, or deletion of the same, the
limitation of processing in the cases provided for by art. 18 of the Regulation, to obtain in a
structured, commonly used, and machine-readable format the data concerning you, in the cases provided for by art. 20 of the Regulation. At any time, you may
withdraw the consent given pursuant to art. 7 of the Regulation; file a complaint with the competent supervisory authority pursuant to Article 77 of the Regulation (Garante per la Protezione dei Dati
Personali WWW.GARANTEPRIVACY.IT) pursuant to art. 77 of the Regulation, if
you believe that the processing of your data is contrary to the current regulations.
You can make a request to object to the processing of your data pursuant to Article 21 of the
Regulation in which you provide evidence of the reasons justifying the objection: the
REV. 0.1 of August 8, 2024
Controller reserves the right to assess the request, which would not be accepted if there are
compelling legitimate reasons to proceed with the processing that override your interests,
rights, and freedoms.
Requests should be made in writing to the Controller.
9. Changes
This privacy policy is effective as of August 8, 2024. Sardegna verso Unesco reserves the
right to modify or simply update its content, in part or completely, also
due to changes in applicable law. Sardegna verso Unesco will inform you of such
changes as soon as they are introduced, and they will be binding as soon as
they are published on the Site. Sardegna verso Unesco therefore invites you to regularly visit this section to stay informed of the most recent and updated version of the privacy policy so that you are always aware of the data collected and how Sardegna verso
Unesco uses it.
10. Cookies and online trackers
This cookie policy refers exclusively to the site (“Site”) and should be understood as
an integral part of the Site’s Privacy Policy.
1. Definitions, characteristics, and application of the legislation
Cookies are small text files that sites visited by the user send and store on the user’s
computer or mobile device, to be retransmitted to the same sites upon the next visit.
Thanks to cookies, a site remembers the actions and preferences of the user (such as login data, chosen language, font size, other display settings, etc.) so that they do not have to be specified again when the user returns to visit that site or navigates from one page to another on it. Therefore, cookies are used to perform computer authentications, session tracking, and storage of information regarding the activities of users who access a site and may also contain a unique identification code that allows tracking the user’s navigation within the site itself for statistical or advertising purposes. While browsing a site, the user may also receive cookies from sites or web servers other than the one being visited (so-called “third-party cookies”).
Some operations could not be performed without the use of cookies, which in some cases are therefore technically necessary for the very functioning of the site.
There are various types of cookies, depending on their characteristics and functions, and these may remain on the user’s computer or mobile device for different periods of time: so-called session cookies, which are automatically deleted when the browser is closed; so-called persistent cookies, which remain on the user’s device until a preset expiration date.
REV. 0.1 of August 8, 2024
According to current Italian legislation, the use of cookies does not always require the explicit consent of the user. In particular, “technical cookies” do not require such consent, i.e., those used solely for the purpose of transmitting a communication over an electronic communications network, or to the extent strictly necessary to provide a service explicitly requested by the user. In other words, these are cookies that are essential for the functioning of the site or necessary to perform activities requested by the user.
2. Types of cookies used by the Site
The Site uses the following types of cookies and offers the possibility to deselect
them, except for third-party cookies for which the user must refer
directly to the relevant selection and deselection procedures of their respective cookies, indicated
through links:
Technical cookies – navigation or session cookies – strictly necessary for the operation of
the Site or to allow the user to use the content and features requested.
Analytical or profiling cookies.
3. How to view and modify cookies through your browser
(so-called browser)
The user can select which cookies to authorize through the appropriate procedure
provided in the Cookie Settings section, as well as authorize, block, or
delete (in whole or in part) cookies through the specific functions of their
browser: however, if all or some of the cookies are disabled, it is possible that the Site
may not be accessible or that some services or certain functions of the Site may not be available or may not work properly, and/or the user may be forced to modify or manually enter certain
information or preferences every time they visit the Site.
For more information on how to set cookie preferences
through your browser, you can consult the relevant instructions:
• Internet Explorer
• Firefox
• Chrome
• Safari
4. Cookie settings
Below, users can make a choice and specifically indicate which
cookies to authorize.
The user is informed that not authorizing technical cookies may result in the inability
to use the Site, view its content, and use its related services. Disabling functionality cookies may result in some services or certain functions of the Site not being available or not working properly, and the user may be forced to
modify or manually enter certain information or preferences each time they visit the Site. As for cookies sent directly by the Site manager, in addition
to the procedure made available on this page, the user can block or delete (in whole or in part) cookies through the specific functions of their browser (see above for more information).
The user’s choices regarding the Site’s cookies will be recorded in a specific technical cookie, with the characteristics reported in the specific cookie table. However, this cookie may, in some circumstances, not work properly:
in such cases, the user is advised to delete the unwanted cookies and inhibit their use also through their browser’s functionalities. The user’s cookie preferences must be reset if different devices or browsers are used to access the Site.