This Application collects some Personal Data of its Users.
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Fondazione Memoria della Deportazione – Via Dogana, 3 – 20123 Milano (Italia)
Types of Data collected
Personal Data may be freely provided by the User or, in the case of User Data, automatically collected during the use of this Application.
Unless otherwise specified, all Data requested by this Application are mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. In cases where this Application indicates certain Data as optional, Users are free to refrain from communicating such Data, without any consequences on the availability of the Service or its operation.
Users in doubt as to which Data are mandatory are encouraged to contact the Data Controller.
Modalities and place of processing of collected Data
The Data Controller takes appropriate security measures to prevent unauthorised access, disclosure, modification or destruction of Personal Data.
The processing is carried out using computer and/or telematic instruments, with organisational methods and logics strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects involved in the organisation of this Application (administrative, sales, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller, may have access to the Data. The updated list of Data Processors can always be requested from the Data Controller.
Legal basis for processing
The Controller processes Personal Data relating to the User where one of the following conditions exists:
- the User has given consent for one or more specific purposes; Note: in some jurisdictions, the Controller may be authorised to process Personal Data without the need for the User’s consent or another of the legal bases specified below, as long as the User does not object (“opt-out”) to such processing. However, this does not apply if the processing of Personal Data is governed by European legislation on the protection of Personal Data;
- processing is necessary for the performance of a contract with the User and/or the performance of pre-contractual measures;
- processing is necessary for the performance of a legal obligation to which the Controller is subject;
- processing is necessary for the performance of a task carried out in the public interest or in the exercise of public authority vested in the Controller;
- processing is necessary for the pursuit of the legitimate interest of the Controller or of third parties.
However, it is always possible to request the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on law, required by a contract or necessary to conclude a contract.
The Data are processed at the Data Controller’s premises and at any other place where the parties involved in the processing are located. For further information, please contact the Data Controller.
The User’s Personal Data may be transferred to a country other than the one where the User is located. To obtain further information on the location of the processing, the User may refer to the section on Personal Data processing details.
The User has the right to obtain information about the legal basis for the transfer of Data outside the European Union or to an international organisation under public international law or consisting of two or more countries, such as the UN, as well as about the security measures taken by the Controller to protect the Data.
The User can verify whether one of the transfers just described takes place by examining the section of this document relating to details on the processing of Personal Data or request information from the Controller by contacting it at the contact details given at the beginning.
Data are processed and stored for the time required by the purposes for which they were collected.
- Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the performance of that contract is completed.
- Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User may obtain further information regarding the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the Controller.
When the processing is based on the User’s consent, the Data Controller may keep the Personal Data longer until such consent is revoked. Moreover, the Controller may be obliged to keep the Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
At the end of the retention period the Personal Data will be deleted. Therefore, at the end of this period, the right of access, deletion, rectification and the right to Data portability can no longer be exercised.
Purposes of the Data collected
The User’s Data are collected to enable the Data Controller to provide the Service, to comply with legal obligations, to respond to requests or enforcement actions, to protect its rights and interests (or those of Users or third parties), to detect any malicious or fraudulent activities, and for the following purposes: Statistics, Contacting the User and Location Based Interactions.
To obtain detailed information on the purposes of the processing and the Personal Data processed for each purpose, the User may refer to the section “Personal Data Processing Details”.
Personal Data Processing Details
Personal Data are collected for the following purposes and using the following services:
Contacting the User
Contact form (This Application)
The User, by filling in the contact form with his/her Data, consents to the use of such Data to respond to requests for information, quotes, or any other nature indicated in the header of the form.
Personal Data processed: surname; email; name.
Geolocation (This Application)
This Application may collect, use and share Data related to the User’s geographical location in order to provide location-based services.
Most browsers and devices provide by default tools to deny geographical tracking. If the User has expressly authorised this possibility, this Application may receive information on his/her actual geographical location.
Personal data processed: geographical location.
The services contained in this section allow the Data Controller to monitor and analyse traffic data and serve to keep track of the User’s behaviour.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google uses the Personal Data collected in order to track and examine the use of this Application, compile reports and share them with other services developed by Google.
Google may use the Personal Data to contextualise and personalise the advertisements of its advertising network.
Personal Data processed: Cookies; Usage Data.
Users may exercise certain rights with regard to the Data processed by the Data Controller.
- In particular, the User has the right to
- withdraw consent at any time. The User may revoke the consent to the processing of its Personal Data previously expressed.
- object to the processing of their Data. The User may object to the processing of its Data when it is done on a legal basis other than consent. Further details on the right to object are set out in the section below.
- access to their Data. The User has the right to obtain information on the Data processed by the Controller, on certain aspects of the processing and to receive a copy of the Data processed.
- verify and request rectification. The User may verify the correctness of its Data and request that it be updated or corrected.
- obtain the restriction of the processing. When certain conditions are met, the User may request the restriction of the processing of its Data. In this case, the Data Controller will not process the Data for any purpose other than its preservation.
- obtain the deletion or removal of their Personal Data. When certain conditions are met, the User may request the deletion of its Data by the Data Controller.
- receive their Data or have them transferred to another Data Controller. The User has the right to receive its Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred without hindrance to another data controller. This provision is applicable when the Data are processed by automated means and the processing is based on the User’s consent, on a contract to which the User is party or on contractual measures related thereto.
- Proposing a complaint. The User may lodge a complaint with the competent data protection supervisory authority or take legal action.
Details on the right to object
When Personal Data are processed in the public interest, in the exercise of public authority vested in the Controller or in pursuit of a legitimate interest of the Controller, Users have the right to object to the processing for reasons related to their particular situation.
Users are reminded that if their Data are processed for direct marketing purposes, they may object to the processing without giving any reason. To find out whether the Controller processes Data for direct marketing purposes, Users may refer to the respective sections of this document.
How to exercise rights
In order to exercise their rights, Users may address a request to the contact details of the Controller indicated in this document. Requests are filed free of charge and processed by the Controller as quickly as possible, in any case within one month.
Further information on treatment
The User’s Personal Data may be used by the Data Controller in legal proceedings or in the preparatory stages to its possible establishment for the defence against abuses in the use of this Application or related Services by the User.
The User declares that he/she is aware that the Data Controller may be obliged to disclose the Data by order of public authorities.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services used by it may collect system logs, i.e. files that record interactions and which may also contain Personal Data, such as the User’s IP address.
Information not contained in this policy
Further information in connection with the processing of Personal Data may be requested at any time from the Data Controller using the contact details.
Responding to ‘Do Not Track’ requests
This Application does not support “Do Not Track” requests.
To find out whether any third-party services used support them, the User is invited to consult their respective privacy policies.
If the changes affect processing whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.
Definitions and legal references
Personal Data (or Data)
Personal data is any information that, directly or indirectly, even in conjunction with any other information, including a personal identification number, makes a natural person identified or identifiable.
This is the information collected automatically through this Application (including by third party applications integrated in this Application), including: IP addresses or domain names of the computers used by the User who connects with this Application, URI (Uniform Resource Identifier) notation addresses, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the server response (successful, error, etc.), the country of origin, the characteristics of the browser and operating system used by the visitor, the various time connotations of the visit (e.g. the time spent on each page) and details of the itinerary followed by the User. ), the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (e.g. the length of time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User’s IT environment.
The individual using this Application who, unless otherwise specified, is the Data Subject.
The natural person to whom the Personal Data refer.
Processor (or Manager)
Data Controller (or Owner)
The natural or legal person, public authority, service or other body that, individually or jointly with others, determines the purposes and means of the processing of personal data and the instruments adopted, including the security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.
The Service provided by this Application as defined in the relevant terms (if any) on this site/application.
European Union (or EU)
Unless otherwise specified, any reference to the European Union in this document shall be deemed to extend to all current member states of the European Union and the European Economic Area.
Cookies are tracking tools that consist of small portions of data stored within the User’s browser.
Tracking Tool means any technology – e.g. cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that allows Users to be tracked, for example by collecting or storing information on the User’s device.