Privacy Policy

The purpose of this document is to inform Users with regard to Personal Data collected from the website itwend.org (hereinafter, the

Application).

The Data Controller, as identified below, may amend or simply update, wholly or in part, this Privacy Policy informing the Users about the changes. The amendments or updates shall be binding as soon as they are published on the Application. Therefore, the User is invited to read the Privacy Policy at every access to the Application.

If the User does not accept any amendments to the Privacy Policy, the User must terminate the use of the Application and he may ask the Data Controller to remove his Personal Data.

1. Personal Data collected by the Application

The Data Controller shall collect the following categories of Personal Data:

A. Voluntary contents and information provided by the User

•Contact information and contents: Personal Data that the User voluntarily provides to the Application during use, such as personal

details, contact information, login credentials to services and / or products provided, interests and preferences, personal interests

and preferences and any other personal contents, etc.

•Sensitive Data: Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union

membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data

concerning health or data concerning concerning the sex life or sexual orientation of a natural person.

If the User does not communicate Personal Data, for which there is a legal or contractual obligation, will be impossibile to the Data Controller to provide, in whole or in part, its services. It will be impossible also in case that Personal Data is necessary requirement for the use of the service or for the contract conclusion.

The User who communicates to the Data Controller third parties Personal Data, is directly and exclusively liable for their origin, collection, processing, communication or disclosure.

B. Data and contents automatically acquired while using the Application

•Technical Data: the computer system and the software procedures functional to this Application may acquire, in the course of their

ordinary activity, any Personal Data whose communication is implicit in the use of internet communication protocols. Such information is not collected to be associated with identified Users, however, those Data, due to its nature, may identify Users in the Processing and through the association with Data held by third parties. This category includes IP addresses or domain names used by Users who connect to the Application, addresses of Uniform Resource Identifier (URI) of the requested resources, time of the request, method used submitting the request to the server, size of the file obtained, etc.

•Usage Data: Data may be collected relating to the use of the Application by the User, such as the pages visited, the actions performed, the features and services used by the User.

•Geolocation Data: the Application may collect location Data, which may be accurate or inaccurate. The precise location Data may consist in GNSS Data (Global Navigation Satellite System, such as GPS), as well as in Data which identify the nearest repeater, Wi-Fi hotspots and bluetooth, communicated when you enable products or features based on the location.

C. Personal Data collected through cookies or similar technologies

This Application uses cookies, web beacons, unique identifiers and any other similar technologies to collect Data regarding pages, visited links and other actions, which you may perform while using our Services. They are stored for being communicated back to the same websites at the next visit of the User.

The User may read the complete Cookie Policy at the following address: http://itwend.org/cookie-policy.

2. Purposes of the processing

Collected Personal Data may be used for the performance of contractual and pre-contractual obligations and legal obligations as well as for the following purposes:

•support and contact with the User

•storage, hosting and management of backend infrastructure

•handling of Users database

•communications and/or transfer for third party market research and third-party surveys

•communication and/or transfer to third parties for promotional and commercial purposes

•monitoring, analysis and tracking of User behavior

•optimization and distribution of traffic

•sending of e-mails or newsletter and handling of mailing list

•comment and feedback

•communication for our market research and surveys

3. Personal Data processing methods

The Processing of Personal Data is performed with paper, IT and/or digital tools, with methods of organizations and with logics strictly related to the indicated purposes.

In certain cases, subjects other than the Data Controller who are involved in the organization of the Data Controller (such as personnel management, sales personnel, system administrators employees, etc.) or who are not (as IT companies, service providers, postal couriers, hosting providers, etc.) may access to Personal Data. These subjects, will be appointed, where necessary, as Data Processors by the Data Controller and will have access to Users Personal Data whenever required, and shall be contractually obliged to keep it confidential.

The updated list of Data Processors may be requested via email at the email address info@seiplus.org.

4. Legal basis for the processing

The Data Controller processes Personal Data regarding the User should the following conditions apply:

•the User has given consent for one or more specific purposes

•Processing is necessary to comply with a legal obligation to which the Data Controller is subject

• Processing is necessary for the purposes of the legitimate interest pursued by the Data Controller or by a third party It is always

possible to ask the Data Controller to clarify the concrete legal basis of each processing.

5. Place

Personal Data are processed in the operative offices of the Data Controller and in any other place in which the parties involved in the Data processing are located. For further information, you may contact the Data Controller at the following email address info@itwend.org or at the following mailing address Via Giacosa 38, Turin TO 10125 Italy .

6. Security of processing

The Data Processing is performed through adequate methods and tools to ensure the Personal Data security and confidentiality, as the Data Controller has implemented appropriate technical and organizational measures which guarantee, in a provable way, that the Processing complies with the applicable law.

7. Period of storage of Data

  The Data Controller will store Personal Data for the necessary time to perform the purposes connected with the performance of the agreement in force between the Data Controller and the User and Data shall not be stored beyond the duration of years 5 after the end of the relationship with the User. In any case Data could be stored within the limitation term prescribed by the current regulations. When the Processing of Personal Data is necessary for the purposes of the legitimate interests pursued by the Data Controller, Personal Data shall be stored until the performance of the relevant interest.

When the Processing of Personal Data is based on the User consent, the Data Controller may store Personal Data until the withdrawal of the User.

Personal Data may be stored for a longer period of time in order to perform a legal obligation or public Authority order.

All Personal Data shall be deleted at the end of the period of storage. At the expiration of such period, the rights of Data access, rectification, erasure and portability must not be exercised.

8. Automated individual decision-making

All collected Data shall not be subject to automated individual decision-making, including profiling, which may produce legal effects concerning the User or may significantly affect the User.

9. Rights of the User

The Users may exercise specific rights with respect to Personal Data processed by the Data Controller. In particular, the User has the right to:

•withdraw its consent at any time;

•object the Processing of its Data;

•access its Data;

•monitor and request the rectification of Data;

•obtain a restriction of Processing;

•obtain the erasure or remotion of its Personal Data;

•receive its Data or obtain the transfer to a different Data Controller;

•lodge a complaint before the supervisory authority for the protection of personal data or start legal proceedings.

In order to exercise their rights, the Users may send a request to the contact information of the Data Controller indicated in this document. These requests are free of charge and performed by the Data Controller in the shortest possible time, in any case no later than 30 days.

10. Data Controller

The Data Controller is SEIplus, with registered office in Via Giacosa 38, 10125 Turin TO, Italy, Tax Code/VAT Code 97834170017, e-mail info@seiplus.org.

Latest update: 20/03/2019

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