GDPR

PRIVACY POLICY – UPDATE PURSUANT TO EU REGULATION 679/2016 ON DATA PROTECTION – GDPR

ASUMIE has updated its privacy policy to the European Regulation 679/2017 -GDPR.
It will now be easier for you to understand how and why we process your data and to exercise your rights.
Information pursuant to art. 13, European Regulation 679/2016 (so-called “GDPR”)


a. Owner and methods of data processing
Your personal data are processed by Imparole società Cooperativa -Via B. Luini 3 – Cernusco sul Naviglio (MI) – Data Controller – mainly by electronic means.


b. Data to which the information refers
Your data, those already acquired and present in the Imparole archives and those that you may communicate to us during your relationship with our Cooperative.
The data in question are: personal and contact details and data necessary for the payment of services (possibly acquired from third party intermediaries for payments, donations: banks, Post Office, credit card operators…), profiling information as described in par. c. (ii).


c. Purpose and legal basis of data processing
(i) Management of payments, membership to our activities and initiatives of Imparole
The processing is aimed at allowing the Controller to optimally manage payments, including activities instrumental thereto (e.g.: communications on payments, donation summaries) and what is necessary to comply with applicable regulations (tax, civil, administrative) or other legal obligations of the Controller. Processing for these purposes is based on the relationship established between the Data Controller and the data subject relating to the data subject’s adhesion to the activities of Imparole, the fulfilment of legal obligations by the Data Controller.
The provision of all the data necessary to manage the activities requested by the data subject from time to time is compulsory and without it it will be impossible to manage the relationship with the latter.
Contact activities may be carried out using both traditional methods (paper mail and telephone calls by operators on fixed and mobile numbers) and e-mail, text messages and/or instant messaging.
(ii) Marketing and profiling.
The processing is aimed at allowing the Owner to make promotional, informative and institutional contacts on its projects, activities and initiatives, surveys and research towards users and all persons who have expressed interest in Imparole’s activities (e.g. rehabilitation services, diagnostic process, projects, initiatives, Summer Campus…).
Such contacts are implemented by means of actions designed in a personalised manner on the basis of the behavioural characteristics (e.g. communicated problem, adhesion to similar initiatives…), interests and preferences expressed by the data subject on the occasion of his/her participation in the various initiatives of the Owner; this allows to select – in the varied context of the initiatives carried out by Imparole – those of actual interest to the data subject (e.g. adhesion to certain activities, projects…) and to address him/her only contents in line with them (“profiling”).
It is underlined that Imparole does not design or carry out contact actions with generic content, but only carries out contact actions of a personalised type as described, so as to avoid unwelcome contacts or contacts not of interest to the data subject.
From the structural and inseparable instrumentality of the described profiling to any promotional action by Imparole, it follows the necessity to attribute a single legal basis to the marketing and profiling purposes: the processing for these purposes is based on the legitimate interest of Imparole – Società Cooperativa – to keep constant the relationship established with the person who has manifested himself over time as a user benefiting from specific activities at the centre, as a supporter or as interested in specific types of initiatives of the Owner, in order to stimulate his/her support.
Contact activities may take place through both traditional methods (paper mail and telephone calls by operators on fixed and mobile numbers) and via e-mail.

d. Data retention periods
All data processed for the purposes of managing payments or adhesion to Imparole’s initiatives will be stored until the end of the relationship established and within the terms and limits set forth by the applicable regulations, in particular administrative, civil and tax regulations.
For Marketing purposes, data (including profiling data) shall be kept until the data subject exercises his/her right to object; failing this, they shall be kept as long as Imparole continues its activity towards the user or actions and activities consistent with the profile of the data subject and for which consent has been given in advance.
All data processed by Imparole, at the end of the retention periods defined above, will be anonymised for statistical use.


e. Categories of recipients of data, and subjects who may have access to them during processing
The data may be communicated to third parties for instrumental purposes such as the payment of services (such as: the bank of reference of the bank transfer or cheque presented), who will act as autonomous data controllers.
The natural persons authorised to process data for the purposes indicated are the persons in charge of managing relations with users who benefit from Imparole’s activities, both actual and potential, from administration to the organisation of awareness campaigns and institutional and statutory activities, to Web services, information systems and data security.


f. Rights of the data subject
Pursuant to Articles 15-22, GDPR, by writing to the data controller at the above-mentioned postal address or email comunicazioni@imparole.it , you may exercise your rights of access, consultation, rectification, erasure and oblivion, restriction of the processing of your data and – where applicable – obtain the transmission of your data to another data controller (data portability), as well as object to their processing for legitimate reasons or – where applicable – withdraw your consent.
In addition, the data subject has the right to lodge a complaint with the Data Protection Authority to assert his/her rights.
With particular reference to the processing of data for the purposes of profiled marketing described above, it should be noted that the data subject has the right to object at any time, free of charge and without giving any reason, to the processing of his/her data for such purposes, and that he/she may also exercise the right to object separately for traditional and automated contact activities: if it is not specified which contact methods are referred to, the objection to the processing of data for profiled marketing shall be understood as extending to all contact tools. This right may also be exercised by writing to the Controller’s postal address or by sending an e-mail to supporto@imparole.it.


g. Contact
For the exercise of rights and to request a complete list of the data processors and of the persons to whom the data may be communicated and who will use the data for their own processing always in connection with the purposes indicated under c., as well as any information relating to the Controller’s privacy policy, write
via e-mail to supporto@imparole.it