Information on the processing of personal data (GDPR – EU Reg. 679/2016)
Information relating to the use of cookies (Provision of the Privacy Guarantor 229/2014)

For its statutory activities, InformaGiovani ETS collects and processes the data of its members and those who request to be informed.

What data do we treat and why?

• For members: personal data, postal and electronic addresses, any data relating to the state of health. The latter are solely aimed at preventing and managing any emergency situations that may occur during the performance of the association's activities. The data are necessary for sending communications relating to the association's activity and for participation in the same.
• for non-members: the email address, and, if provided at the discretion of the interested party, the name and region of residence. The data is used only for sending emails relating to the association's activities and for the information and newsletter service. Failure to provide the data makes it impossible to use the newsletter service;
• for users of the online training portal www.elearning-informagiovani.net, all data provided by the user himself at the time of registration as a student. The data are necessary for access to the site itself as well as, in the case of courses funded by the European Union or other public bodies, for the purposes of reporting on the progress of the activities. The email address is used to send the newsletter with the ordinary activities of InformaGiovani ETS. The Italian tax code is only necessary for journalists registered in the relevant professional register, for mandatory training activities.

How do we process data?
The data is stored locally (on PCs whose access is protected by password and/or biometric systems) in encrypted format. They are also stored remotely on the servers of the specific service providers listed below.

• For members: the data is stored on the server of the e-vet platform (www.e-vet.org) through which participation in volunteer activities is managed and the members' register is managed.
• for everyone, members and non-members, the email address (and, if provided by the interested party, the region of residence and telephone number) is stored on the Brevo platform (https://www.brevo.com/legal/privacypolicy) for the management of the newsletter service;
• for users of the portal elearning-informagiovani.net, on the servers of the Amazon UK company.
• Two backup copies of the data (both members and non-members) are stored in zero-access encrypted format on the servers of the company Pcloud in Luxembourg (www.pcloud.com/gdpr) and the company Proton AG in Switzerland (proton.me/legal/privacy)

Members' data, if they take part in association activities, may be transmitted to third parties, institutions, partners, once it has been verified that they have adopted privacy protection procedures and systems adequate to current legislation.

Newsletter behavior tracking
The data collected automatically by sending the newsletter are navigation data. Although these data are not collected in order to be associated with the user's identity, they could indirectly, through processing and association with data collected by the Data Controller, allow their identification. In particular:

• IP address
• browser and navigation device

Following the sending of the newsletter, the platform used makes it possible to detect the opening of a message and the clicks made within the newsletter itself, together with details relating to the IP address and the browser/device used. The collection of this data is essential for the functioning of the implicit renewal systems of the treatment (see the item Duration of the Consent) and an integral part of the sending platform's operation.
We inform you that the provision of the requested data is mandatory for members to be able to take part in the association's activities and any refusal to provide them could lead to partial or non-participation.
The data controller is the legal representative pro tempore of InformaGiovani ETS, with registered office in Palermo, via Mico Geraci 35 – Palermo – info@informa-giovani.net

Data protection office
The data controller is Mr. Pietro Galluccio (privacy@informa-giovani.net)

Exercise of rights.

Data owners may access the data at any time and exercise the rights provided for by current legislation by contacting us via letter or email. InformaGiovani ETS at privacy@informa-giovani.net.
In particular, it is possible to exercise the following rights:

• portability (knowing the data and receiving it in a readable and easy to understand format);
• total or partial modification;
• cancellation.
• The right to complain or report abuse can be exercised by contacting the Privacy Guarantor (garante@gpdp.it or the Data Protection Authority, P.za Montecitorio 121, 00186 Rome)

It is specified that in the specific case of InformaGiovani ETS, the right to be forgotten cannot be exercised by members, as the data provided relating to membership must be retained for a period of 5 years for the purpose of any transfer to public authorities that may require them for legal purposes (for example, verification of formal requirements for tenders and competitions or verification of compliance with anti-mafia regulations). Ceased members may still request to be removed from the mailing list for news on the association's activity.
In any case, InformaGiovani ETS does not make public, even in part, the data of its members, nor any other data in its possession.

Commitments of staff, volunteers and interns of InformaGiovani ETS

All the staff, all the volunteers and all the interns of the Association who, due to needs related to the carrying out of the association's activities, could become aware of sensitive data of other members and/or beneficiaries of the activities, are required to sign in advance a clause of confidentiality and commitment to compliance with the provisions of this Policy for the protection of privacy and personal data.

Duration of consent

Consent to data processing, except as specified above for the retention of member data, is considered valid until unsubscribing by the user, via the link in each email, or up to 24 months from the last communication of which there is evidence of interaction (click, opening, response). 

For information on the use of cookies (Provision of the Privacy Guarantor 229/2014) click here