Information on the processing of personal data of users who consult the website www.reclaimedland.org
The data provided to the FEEM Srl through the website www.reclaimedland.org (hereinafter also referred to as the “Website”) is processed in accordance with the provisions of the current legislation on the protection of personal data, in particular the Regulation (EU) 2016/679 (General Data Protection Regulation, hereinafter referred to as the “GDPR”).
In compliance with the aforementioned regulations, particularly Article 13 of the GDPR and Directive 2002/58/EC as amended by Directive 2009/136/EC on cookies, as well as the “Cookie and Other Tracking Tools Guidelines” issued by the Italian Data Protection Authority on June 10, 2021, we provide you with the following information regarding the processing of personal data.
The Data Controller of personal data is the FEEM Servizi Srl, with registered office in Milan (MI) – 20123, Corso Magenta, 63, email: firstname.lastname@example.org, certified email (PEC): email@example.com, and telephone number: +39 40336934. Any requests for clarification regarding the processing of data or to exercise the rights granted by the Regulation, or for further information, can be sent through the aforementioned channels.
2.Nature of data provision
To make use of the services offered through the Website, the user may be required to provide personal data necessary to ensure the use of such services. In particular, for the completion of forms on the Website, the provision of data marked with an asterisk (*) is necessary for managing and responding to user requests. It should be noted, however, that the user is free to provide the requested data, as there is no legal obligation to provide them. However, failure to provide the data indicated as necessary will make it impossible for the Data Controller to provide the requested service.
3.Types of data processed – Purposes and legal basis of the processing
Among the personal data collected by this website, either independently or through third parties, are:
- Browsing and usage data (through cookies);
- Personal data voluntarily provided by the user.
The User is responsible for the publication or sharing of third-party personal data through the website and guarantees that they have the right to communicate or disclose such data, releasing the Data Controller from any liability towards third parties.
3.1 Browsing and usage data
The computer systems and software procedures used to operate the Website automatically acquire certain personal data, the transmission of which is inherent in the use of Internet communication protocols.
These data are processed for purposes related to the provision of services offered through the Website, including ensuring the proper functioning of the services themselves.
This category of data includes:
- Visitor’s IP address;
- Date and time of access;
- Page viewed;
- Referring page, if any;
- Browser and operating system used.
These are not collected to be associated with identified individuals, but by their very nature, they could allow the identification of users through processing and association with data held by the Data Controller or by third parties.
Browsing and usage data are processed for the following purposes:
- Ensuring the proper functioning of the Website and the usability of its services, including the display of content on external platforms and interaction with social networks and external platforms;
- Obtaining aggregate and anonymized statistical information about the use of the Website (e.g., most visited pages, number of visitors per hour or day, geographical areas of origin, etc.);
- Protecting our systems from possible cyber attacks.
In relation to such data, the legal basis for processing can be found, depending on the cases, in the performance of a contract of which the data subject is a party (pursuant to Article 6, paragraph 1, letter b) of the GDPR) or in the pursuit of a legitimate interest of the Controller (pursuant to Article 6, paragraph 1, letter f) of the GDPR).
3.2 Personal data provided by the data subject
The personal data voluntarily provided by the user, through the completion of forms in certain sections of the Website or by sending email messages to the email addresses indicated or accessible through links on the Website, are processed by the Controller for purposes related to the provision of services offered through the Website. In this case, the legal basis for the processing is the performance of a contract of which the data subject is a party, pursuant to Article 6, paragraph 1, letter b) of Regulation (EU) 2016/679 (GDPR).
In particular, the personal data provided by the data subject may be processed for the following purposes: a) concerning the data provided through the optional and voluntary sending of email messages to the email addresses indicated on the Website (including, in particular, the sender’s email address and any other personal data included in the message) in order to carry out the necessary processing activities to respond to the user’s requests.
Specific information will be published on the Website’s pages or on external platforms accessible through the Website, set up to provide certain services (such as the portal dedicated to spontaneous applications for collaborations with the Foundation) or to participate in specific initiatives promoted by the Controller, also in collaboration with external partners (webinars, events, training initiatives, etc.).
4.Modalities of the processing
The processing will be carried out using paper and/or computerized tools, also by authorized parties who operate under the direct authority and according to the instructions provided by the Controller, with logic strictly related to the indicated purposes and, in any case, in a manner that ensures the security and confidentiality of the processed data. The processing operations are carried out in a way that guarantees the security of the data and systems. Specific security measures are adopted to minimize the risks of destruction or loss, including accidental loss, unauthorized access, or processing that is not permitted or in accordance with the purposes stated in this notice. However, the security measures implemented do not allow for absolute exclusion of the risks of interception or compromise of personal data transmitted via electronic means. Therefore, it is recommended to verify that the user’s device is equipped with adequate software systems for the protection of telematic data transmission, both incoming and outgoing (such as up-to-date antivirus systems, firewalls, and spam filters).
In compliance with the provisions of Article 5, paragraph 1, letter e) of Regulation (EU) 2016/679, the data will be kept by the Controller for a period not exceeding the time necessary to achieve the purposes for which the data was collected and subsequently processed. In particular: a) the data provided through the optional and voluntary sending of email messages to the email addresses indicated on the Website will be retained for the time necessary to respond to the data subject; b) the data provided for newsletter subscription will be kept for as long as the service itself is active: therefore, the data will be retained until the data subject requests cancellation from the service.
6.Recipients of personal data
Personal data may be disclosed to:
- Authorized collaborators and employees of the Controller, within the scope of their respective duties;
- Providers of services offered through the Website or related to its functioning, who act as Data Processors pursuant to Article 28 of Regulation (EU) 2016/679, including WP Engine for hosting services. Further recipients of data collected through the Website, or as a result of using certain services provided through external platforms accessible from the Website, will be indicated in specific information notices dedicated to the processing related to such services. Under no circumstances will personal data be communicated, disclosed, transferred, or otherwise transmitted to third parties for illicit purposes without providing appropriate information to the data subjects and obtaining their consent, where required by law. The communication of data may occur upon request of the judicial authority or public security authority, in the manners and cases provided by law.
7.Transfer of data abroad
Personal data will not be transferred abroad to countries or international organizations outside the European Union that do not guarantee an adequate level of protection recognized under Article 45 of the GDPR, based on an adequacy decision of the EU Commission. In case it becomes necessary for the provision of Website services, the transfer of personal data to countries or international organizations outside the EU, for which the Commission has not adopted any adequacy decision under Article 45 of the GDPR, will only take place if adequate safeguards are provided by the recipient country or organization, in accordance with Article 46 of the GDPR, and provided that data subjects have enforceable rights and effective remedies. In the absence of an adequacy decision of the Commission under Article 45 of the GDPR, or adequate safeguards under Article 46 of the GDPR, including binding corporate rules, cross-border transfers will only take place if one of the conditions indicated in Article 49 of the GDPR is met.
8.Rights of the data subject
In accordance with the applicable regulations, each data subject has the right to access their personal data and request its rectification, updating, or erasure, or the restriction of processing if the data is incomplete, inaccurate, or unlawfully collected. Data subjects also have the right to object to the processing of their personal data for legitimate reasons or to request data portability.
In particular, the data subject has the right to obtain confirmation as to whether or not personal data concerning them exists, even if not yet recorded, and to receive such data in an intelligible form.
The data subject also has the right to obtain the following information: a) the purposes and methods of the processing; b) the logic involved in the processing carried out with the aid of electronic tools; c) the identity details of the Controller, data processors, and individuals or categories of individuals to whom the personal data may be disclosed or who may become aware of it as authorized processors.
The data subject has the right to obtain: a) the updating, rectification, or integration of their data; b) the erasure, anonymization, or blocking of data processed unlawfully, including data that does not need to be retained for the purposes of the processing; c) the restriction of processing in cases provided for by Article 18 of the GDPR; d) notification that the operations referred to in points a), b), and c) have been brought to the attention of those to whom the data has been communicated or disclosed, except in cases where such fulfillment is impossible or involves a disproportionate effort compared to the protected right.
The data subject has the right to object, in whole or in part, for legitimate reasons, to the processing of personal data concerning them, even if pertinent to the purpose of collection.
9.Exercise of rights
To exercise these rights, data subjects can send an email to firstname.lastname@example.org. Data subjects may also exercise their rights through non-profit organizations, bodies, or associations that are of public interest and active in the field of protecting the rights and freedoms of data subjects with regard to the protection of personal data, by providing an appropriate mandate. Data subjects may also be assisted by a trusted person. For further information on the purposes and methods of personal data processing, please write to the email address email@example.com. To learn about their rights and stay updated on the regulations regarding the protection of individuals with regard to the processing of personal data, data subjects can contact the Garante per la protezione dei dati personali (Italian Data Protection Authority) by visiting the website at http://www.garanteprivacy.it/.
Updated in September 2023
What are cookies Cookies are small text files that are stored on your computer or mobile device when you access and use the website www.reclaimedland.org (hereinafter referred to as the “Site”). These files contain information about your browsing activities on the site and can be used for various purposes, such as ensuring the efficient functioning of the Site, improving the user’s browsing experience, storing user preferences, analyzing Site usage, and personalizing content and advertising.
Effective Date: 12-Sep-2023
Last Updated: 12-Sep-2023
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