PROCLADE Internazionale – ONLUS (PROCLADE), a non-profit ETS organization, Tax Code 09248901002, with registered office in Rome, Via Sacro Cuore di Maria 5 – 00197 Rome (hereinafter, the “Controller”), as data controller, informs you pursuant to Article 13 of Legislative Decree no. 196 of 30 June 2003 (hereinafter, the “Privacy Code”) and Article 13 of EU Regulation no. 2016/679 (hereinafter, the “GDPR”) that your data will be processed in the following ways and for the following purposes:
- Subject of the Processing
The Controller processes personal and identifying data (for example: name, surname, address, telephone number, e-mail address, banking and payment details) – hereinafter “personal data” or simply “data” – communicated by you during contacts and activities with the Controller.
- Purpose of the Processing
Your personal data are processed:- Without your explicit consent
(Art. 24 letters a), b), c) Privacy Code and Art. 6 letters b), e) GDPR), for the following Service Purposes:
PROCLADE processes the personal data provided by you or already held by it in order to conclude, manage, and carry out the activities requested by you. For example: distance adoptions, participation in development projects and/or micro-projects, donations, bequests, allocation of the 5×1000 tax contribution in favor of Vides within the context of your income tax declaration, volunteering, activist roles, etc. - Only with your specific and separate consent
(Articles 23 and 130 Privacy Code and Article 7 GDPR), for the following Marketing Purposes:
to receive informational e-mails regarding projects, initiatives, actions, institutional activities, and social advertising by PROCLADE, including our newsletter, according to the user’s preferences and interests in order to avoid sending unwanted topics;
to receive informational SMS messages regarding projects, initiatives, actions, institutional activities, and social advertising, according to the user’s preferences and interests in order to avoid sending unwanted topics.
- Processing Methods
The processing of your personal data is carried out through the operations indicated in Article 4 of the Privacy Code and Article 4 no. 2 GDPR, namely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, deletion, and destruction of data.
Your personal data are processed both in paper form and electronically and/or through automated means.
The Controller will process personal data for the time necessary to fulfill the above purposes and, in any case:
no longer than 10 years after the termination of the relationship for Service Purposes;
no longer than 2 years from data collection for Marketing Purposes.
- Access to Data
Your data may be made accessible for the purposes referred to in Articles 2.A and 2.B: - to employees and collaborators of the Controller or affiliated companies in Italy and abroad, in their capacity as persons authorized to process data and/or internal data processors and/or system administrators;
- to third-party companies or other entities (for example: banks, professional firms, consultants, etc.) carrying out outsourced activities on behalf of the Controller, in their capacity as external data processors.
- Communication of Data
Without the need for express consent (pursuant to Art. 24 letters a), b), d) Privacy Code and Art. 6 letters b) and c) GDPR), the Controller may communicate your data for the purposes referred to in Article 2.A to IT service providers, storage service providers, or other technical/organizational service providers, as well as to subjects to whom communication is required by law for the fulfillment of such purposes.
These subjects will process the data in their capacity as independent data controllers.
Your data will not be disseminated.
- Data Transfer
Personal data are stored on servers located within the European Union. In any case, the Controller may transfer servers outside the EU if necessary. In such cases, the Controller guarantees that the transfer of data outside the EU will take place in compliance with applicable legal provisions, after signing the standard contractual clauses provided by the European Commission.
- Nature of Data Provision and Consequences of Refusal
The provision of data for the purposes referred to in Article 2.A is mandatory. Without them, we cannot guarantee the Services referred to in Article 2.A.
The provision of data for the purposes referred to in Article 2.B is optional. Therefore, you may decide not to provide any data or later deny the possibility of processing data already provided. In this case, you will not receive newsletters, commercial communications, or advertising material related to the Services offered by the Controller. However, you will still be entitled to the Services referred to in Article 2.A.
- Rights of the Data Subject
As a data subject, you have the rights set forth in Article 7 of the Privacy Code and Articles 15 GDPR, including the right to: - obtain confirmation as to whether or not personal data concerning you exist, even if not yet recorded, and their communication in intelligible form;
ii. obtain information about:
a) the origin of personal data;
b) the purposes and methods of processing;
c) the logic applied in case of processing carried out with electronic instruments;
d) the identification details of the Controller, processors, and designated representative pursuant to Article 5, paragraph 2 of the Privacy Code and Article 3, paragraph 1 GDPR;
e) the subjects or categories of subjects to whom personal data may be communicated or who may become aware of them in their capacity as designated representatives, processors, or authorized persons; - obtain:
a) the updating, rectification, or, where interested, integration of the data;
b) the deletion, anonymization, or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which they were collected or subsequently processed;
c) certification that the operations referred to in points a) and b) have been notified to those to whom the data have been communicated or disclosed, unless this proves impossible or involves disproportionate effort; - object, wholly or partially:
a) on legitimate grounds, to the processing of personal data concerning you, even if relevant to the purpose of collection;
b) to the processing of personal data concerning you for the purpose of sending advertising material, direct sales, market research, or commercial communications through automated calling systems without operator intervention via e-mail and/or traditional marketing methods via telephone and/or postal mail.
Please note that the right to object to direct marketing through automated means also extends to traditional methods, and in any case the data subject may exercise the right to object even partially. Therefore, the data subject may choose to receive only traditional communications, only automated communications, or neither.
Where applicable, you also have the rights referred to in Articles 16–21 GDPR (right to rectification, right to erasure, right to restriction of processing, right to data portability, right to object), as well as the right to lodge a complaint with the Supervisory Authority.
- Methods for Exercising Rights
For any communication regarding the processing of personal data, the user may contact the data controller, namely PROCLADE Internazionale, ETS non-profit organization, Tax Code 09248901002:- by writing to projects.proclade@gmail.com or certified e-mail procladeinternazionaleets@legalmail.it
- by calling +39 06 80910022
- or by post to: Via Sacro Cuore di Maria 5 – 00197 Rome, Italy.
- Controller, Processors, and Authorized Persons
The Data Controller is President Pedro Belderrain Belderrain, with registered office at the organization’s headquarters.
The updated list of processors and persons authorized to process data is kept at the operational headquarters in Via Sacro Cuore di Maria 5 – 00197 Rome.
CONSENT ACQUISITION
I give my specific and separate consent to the processing of my personal data for the purposes indicated in point 2B).
