With this privacy notice ("Notice"), the THSN Foundation (as defined below) wishes to provide the participants in its charitable initiatives with information about how their personal data are processed.
1. Fondazione Generali - The Human Safety Net - Philanthropic Organisation processes your personal data as data controller Fondazione Generali - The Human Safety Net - Philanthropic Organisation (hereinafter, also "Fondazione THSN"), with registered office in Piazza Duca degli Abruzzi 2, 34132 Trieste, Italy, processes your personal data as Data Controller within the meaning of Article 4 of EU Regulation 679/2016 (hereinafter, "GDPR"). If you have any questions or if you wish to exercise your rights regarding the processing of your personal data, you may contact our Privacy Focal Point or our Data Protection Officer:
• by e-mail at: privacy@thehumansafetynet.org; dpothsn@thehumansafetynet.org
• by traditional mail at: Fondazione Generali – The Human Safety Net – Ente Filantropico, Piazza Duca degli Abruzzi, 2, 34132 Trieste Italia.
2. How and why do we use your personal data?
We process your personal data using computerised methods and procedures that guarantee an adequate level of security in order to:
1) follow up on your request to print and/or email you the photo you took and the collectibles generated during your visit;
2) send you, with your prior consent, newsletters regarding fundraising and volunteering programmes, initiatives, activities and, in general, events organised by the Fondazione THSN, also in collaboration with its partners;
3) carry out profiling activities regarding your interests and preferences, as identified by processing – also in an automated manner – your personal data in order to send you newsletters, with your prior consent, in line with said interests and preferences;
4) send you a follow-up communication regarding the programme you have chosen to support by allocating half of your ticket price to it
5) to assert or defend a right of Fondazione THSN, its officers, representatives against you or third parties, in or out of court;
6) to fulfil any legal, tax, accounting and administrative obligations to which Fondazione THSN is subject; and
7) to perform activities in connection with any transactions or transformations pertaining to Fondazione THSN or its assets and for the execution of such transactions.
3. Why do we ask you to provide your personal data?
We process your personal data based on the following legal grounds, which vary according to the purpose of the processing as set out in paragraph 2 of this Notice: - purpose 1: to process your request pursuant to Article 6(1)(b) of the GDPR. To this end, the communication of your data is mandatory since the refusal to provide the data for this purpose will make it impossible to process with your request; - purpose 2: your optional, free, specific and explicit consent in accordance with Article 6(1)(a) of the GDPR, failing which we will not be able to send you any newsletters, even though they may be in line with your interests and preferences. You may withdraw your consent at any time as also described in paragraph 7; - purposes 3, 4, 5 and 7: the legitimate interest – within the meaning of Article 6(1)(f) of the GDPR – of Fondazione THSN to send you newsletters in line with your interests and preferences, to keep you up to date with the programme you have chosen to support, to defend its rights, those of its officers and representatives in or out of court, and to carry out any transactions or transformations relating to Fondazione THSN or its assets. As explained in paragraph 7 below, you may object to the processing and, in that case, your personal data may not be used for the above-mentioned purpose, unless Fondazione THSN can prove the existence of compelling legitimate grounds for processing that override your interests, rights and freedoms or for the establishment, exercise or defence of a right in court; - purpose 6: to fulfil legal obligations to which Fondazione THSN is subject, pursuant to Article 6(1)(c) of the GDPR. To this end, the communication of your data is mandatory since the refusal to provide the data for this purpose will make it impossible for Fondazione THSN to fulfil its obligations.
4. Which type of personal data do we use?
We process only common personal data for the achievement of the above-mentioned purposes. We mainly process your: - identification and contact data (first name, last name, home address, e-mail address, etc.); - photo; - as well as any other categories of personal data that you freely provide.
5. Who is your data shared with?
Our staff processes your personal data using computerised methods and procedures that guarantee an adequate level of security. Your personal data may only be shared with third parties who have been appointed to carry out certain activities relating to the management of the relationship with Fondazione THSN in connection with the purposes of processing as indicated in paragraph 2 above. Both our staff and third parties, in their capacity as data processors and controllers respectively, process your personal data for the above-mentioned purposes - with the exception of independent Data Controllers and Joint Controllers - based on appropriate instructions regarding the correct method of processing. Insofar as applicable, your personal data may be shared with other companies belonging to the Generali Group.
6. Where is your personal data transferred to?
As a general rule, we do not transfer your personal data to countries outside the European Economic Area. In exceptional cases, and limited to the purposes mentioned in paragraph 2 above, we may transfer your personal data to the country where the above-mentioned recipients reside. In any event, your personal data is transferred in compliance with applicable laws and international agreements, and using adequate and appropriate protection measures (such as, for example, transfer to a country ensuring an adequate level of protection or the adoption of standard contractual clauses approved by the EU Commission). Where legally necessary, Fondazione THSN will implement any additional measures as required by applicable laws.
7. What rights can you exercise regarding the processing of your personal data?
You may exercise your right of access, rectification, updating, integration, erasure, restriction of processing, portability with respect to your personal data. If you have given consent to the processing of your personal data, you may withdraw your consent at any time, without prejudice to the lawfulness of the processing based on consent before the withdrawal. If your personal data are transferred outside the European Economic Area, you have the right to obtain a copy of these data as well as an indication of the Country(ies) where your personal data were made available. Insofar as applicable, you have the right to object to the processing of your personal data and to request the interruption of processing operations when they are based on legitimate interest (please refer to how we use your personal data and on what grounds). If you believe that the processing of your personal data is in breach of applicable privacy laws, you have the right to lodge a complaint with a supervisory authority. You may contact the Garante per la Protezione dei Dati Personali as indicated on the relevant website (www.garanteprivacy.it). You may exercise your rights by contacting Fondazione THSN or the Data Protection Officer using the contact details given above. The request to exercise rights is free of charge, unless the request is manifestly unfounded or excessive.
8. How long do we retain your personal data?
Your personal data are kept for the period of time that is necessary to fulfil the purposes for which they were collected, pursuant to paragraph 2 above. In particular, processed personal data are stored:
- purpose 1: for the period of time that is necessary to fulfil your request (printing and/or sending photos) and in any case no later than midnight on the day of your visit;
- purpose 2: for the duration of the newsletter service, i.e. until you decide to withdraw your consent and in any case for a period not exceeding 36 months;
- purpose 3 : for a period not exceeding 36 months after collection;
- purpose 4: for a period not exceeding 6 weeks after collection;
- purposes 5 and 7: for 10 years, equal to the limitation periods provided for by the applicable legislation, without prejudice to any longer retention periods resulting from any pending disputes;
- purpose 6: for the period provided for by the applicable legislation. At the end of the retention period, your data will be erased.
Changes and updates to this privacy notice
In consideration of possible future amendments to the applicable privacy laws, Fondazione THSN may amend and/or update this privacy notice wholly or in part. It is, however, understood that any substantial amendments, additions or updates will be communicated to you in accordance with the regulations in force also by means of publication on Fondazione THSN's website www.thehumansafetynet.org.
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