Privacy Policy

Introduction 

Fondazione ICONS recognizes the importance of your personal data, for which reason it wishes to provide you with information about, and the greatest possible control over, the management of your personal data collected when using this internet site   This Privacy Notice is a document addressing you as Data Subject, i.e., the owner of your personal data. It explains which personal data we collect and how we use it.  Please read this document carefully. 

1. Data Controller of the Data Collected and Processed by the Site  

The Data Controller of the collected data on this site is Fondazione ICONS, with registered office in Italy at I-26900 Piazza della Vittoria 1, Lodi, Fiscal Code 92563110151. This means that Fondazione ICONS’ management has the accountability and the responsibility to set structure and procedures to treat and protect your data.  Appointed members of the staff are responsible for the actual treatment of your data; concretely they will treat your data as described in the following sections of this notice. 

Fondazione ICONS can be contacted for all data privacy questions at:   icons@icons.it,   Tel. +39 0371 091065 

2. Type of data and related treatment 

2.1 DATA VOLUNTARILY PROVIDED BY THE SUBSCRIBER 

The explicit and voluntary provision of personal data provided by you is essential in order to have access to certain services offered by Fondazione ICONS through the website (e.g., Newsletter Subscription or registration to events, if applicable) and to receive the requested update. This involves the collection of personal data and contact details, as well as any other personal data that are required to respond to requests or to provide the available services. Fondazione ICONS doesn’t collect nor treat sensitive data. Once the initiative to which you have subscribed is terminated, your personal data might be treated as per Art.2 in other similar initiatives where Fondazione ICONS carries out communication activities. They can also be used for generic communication activities in the content areas for which you may have expressed your interest.   

2.2 NAVIGATION DATA (DATA DERIVING FROM USER’S NAVIGATION) 

During routine activities, the computer system may store some of your browsing data. These data, although not collected in order to be associated with your identity, may allow indirect recognition of your identity when processing and associating with the data held by the Data Controller. For this reason, they could be considered “personal data” according to the Privacy Regulation. This category of data (which includes, by way of example but not limited to, IP addresses and domain names of the User’s computer) is collected by the Data Controller for statistical purposes in anonymous form, but by means of some data processing procedures it could be possible to trace the User identity in order to ascertain any liability for crimes committed via the Website or damages against it. 

2.3 NAVIGATION DATA PROCESSED WITH GOOGLE ANALYTICS OR SIMILAR APPLICATIONS 

Our website is using Google Analytics, a simple, easy-to-use tool that helps website owners to measure how Users interact with website content. Google Analytics gives us the ability to track the visitor interactions by using first-party cookies that can record information about the time and the page a User has seen, for example the URL of the page, and “remember” what a User has done on previous pages and the “cache memory” of the pages or websites the User has seen or interacted with. Google Analytics tracks and traces the website visitors IP address to identify the visitors based on the geographical location they provided. Google Analytics does not collect any personal information about the website Users as it reports website trends.  Fondazione ICONS shall not use (and shall not allow any third party to use) this Service to record, collect or upload any data that may/can identify an individual (such as for example name, email address, IP address, billing information) or other data that can be reasonably linked to such information by Google. You may decline cookies by deactivating them in your browser, but this may prevent you from accessing certain or all features of this website. 

3. What do we do with your personal data? 

Your data are part of our general database that we utilize to organize dissemination, communication and networking activities.  We are using your personal data for the following treatments: 

  • To send newsletters and information on the activities carried out by FondazioneICONS by means of traditional and web-based contact methods (e.g., e-mail, text messages etc.).  
  • To provide information and answers about our activities and initiatives.  
  • To carry out statistics and reports in anonymous form (e.g., assessment the download of the material provided, the number of times a website was accessed, the most visited pages, the average visit duration, the country of origin of Users etc.). 

We commit to ensure that Subscribers will always be free to opt-out and exercise their rights as regard to the treatments mentioned above. Each communication has an opt-out link where you can inform us about your decisions. 

4. Where do we store and protect your data? 

The data processing related to the website’s services takes place at the Headquarter of Fondazione ICONS located in Lodi (Italy) I-26900 via Volturno 15. The applicable law on the top of the EU GDPR 679/2016 is the Italian Privacy Regulation, considering the effective and actual processing activity and the context in which personal data are processed.  The data processing is performed by authorized members of the Fondazione ICONS staff who have been appointed and trained in maintaining security and confidentiality of personal data.  In addition to the data collection, the processing of your personal data may involve their recording, storage, modification, communication and cancellation. The data processing shall be carried out with the use of electronic equipment. Storage of personal data shall be in electronic form, for the time that is strictly necessary to meet the purposes and in accordance with local regulations and internal processes.  With regards to the personal information you provide, please note that all the necessary steps will be taken to ensure the confidentiality and security of shared data, in compliance with the provisions of the Privacy Regulation. In particular, we have implemented all the technical, organizational, logistical and procedural security measures in line with technological developments pursuant to the Regulation, in order to guarantee the minimum level of data protection required by the legislation in force.  The data are stored in a database that is hosted by a hosting & cloud service provider, which Fondazione ICONS relies on. The hosting and the related responsibilities are ruled by a specific contract. In this contract the above-mentioned Provider claims that the servers used to host and store the database are located in data centres within the European Union.  The services offered are in compliance with the relevant legislation on data protection thanks to the adoption of appropriate security measures. 

5. Cookies Policy 

Cookies are small text files that are stored on the User’s computer’s browser directory when visiting certain websites. The website uses cookies for specific and limited purposes, namely to provide easier navigation and for the purposes of internal security, of statistical analysis related to navigation and of system administration. Session cookies allow Users to be recognized within a website so any page changes or item or data selection you do is remembered from page to page. Session cookies are temporarily stored in the computer memory only during a User’s browsing session and are automatically deleted from the User’s computer when the browser is closed. Persistent cookies remain in the browser’s subfolder and are activated again once the User visits the website that created that particular cookie thus facilitating the navigation and making it faster (with the “keep me logged in” option). Analytical cookies collect anonymous data for internal purposes with the aim of providing a better browsing experience to the User. These data help us to understand how visitors use our website, the number of visits, the most visited pages, the average duration of visits and much more, allowing us to improve the content of our website and the way it is presented. These are third-party cookies, meaning that they are sent and managed by a Third Party whom the Data Controller has engaged to store User preferences and for marketing purposes. No personal information is collected about you or about your computer. All collected data are anonymous and aggregated. 

5.1 THIRD PARTY COOKIES 

Cookie  Domain  Description

  __utm  __utmb  __utmc  __utmz  icons.it  Website  Fondazione ICONS uses Google Analytics, which sets a cookie in order to anonymously identify when users return to specific websites.  Google uses the information sent with this cookie to store a history of website pages visited in a user’s session. This data will not be used to associate any part of your identity, anonymous or not, with any other data held by Google. 

Further information about how to opt-out of this cookie can be found at http://www.google.com/intl/en/privacypolicy.html 

6. Which is the legal ground on which we operate? 

The Data Controller has the Legitimate Interest to treat your personal data as per art. 6 (f) GDPR 179/2016. Our detailed rationale for claiming legitimate interest is based on a Legitimate Interest Assessment (LIA), periodically reviewed.  We believe that it is a mutual benefit to remain in contact; you will receive from us communications exclusively as detailed in the previous paragraphs. We are counting to hear from you back on the specific topics through our communication activity for a mutual growth. 

7. Data transfer 

Fondazione ICONS processes do not require any transfer of data to external third parties with the sole exceptions mentioned below.   Following the processes and treatments described above, your personal data can be communicated to the Data Controller’s staff.  Furthermore, and in so far as necessary, Personal data shall be disclosed to the following categories:  

  • Persons in charge of managing the website and the related activities.  
  • Persons who provide services for the management of the information system of the company.  
  • Persons carrying out monitoring, auditing and certification activities with regard to the business in which organizations are in, even in the customers’ interest. 

The personal data you provide will not be sold to or shared with third parties.  We will only then share your personal data if necessary and only with vendors or agents who work on our behalf for the purposes described in this Privacy Statement. In that case, your personal data are therefore shared with these agents, but only for the performance of services and on behalf of Fondazione ICONS.  Finally, and only to the extent that this is required by law or strictly necessary for the performance of the services or for the protection of our rights, or the rights of third parties or data subjects affiliated with us, we will provide your personal data to law enforcement agencies, research organizations, affiliated companies or in court proceedings. 

8. How to exercise your rights 

In order to allow you to exercise your rights, Fondazione ICONS implemented internal procedures described hereby. If you would like to know more or exercise your rights, please contact the Fondazione ICONS Headquarter contacting: phone +39 0371 091065. 

Below we report an exhaustive list of your rights:  

Right to be informed: about our purposes for processing the personal data, retention periods for that personal data, and whom it will be shared with.  

  1. Right of access: to access personal data  
  2. Right to rectification: Under Article 16 of the GDPR, individuals have the right to have inaccurate personal data rectified  
  3. Right to erasure: Under Article 17 of the GDPR individuals have the right to have personal data erased. This is also known as the ‘right to be forgotten  
  4. Right to restrict processing: Article 18 of the GDPR gives individuals the right to restrict the processing of their personal data in certain circumstances. This means that an individual can limit the way an organisation uses their data. This is an alternative to requesting the erasure of their data  
  5. Right of data portability: gives individuals the right to receive personal data they have provided to a controller in a structured, commonly used and machine-readable format. It also gives them the right to request that a controller transmits this data directly to another controller
  6. Right to object: Article 21 of the GDPR gives individuals the right to object to the processing of their personal data. This effectively allows individuals to ask to stop processing their personal data  
  7. Rights related to automated decision-making including profiling  
  8. Right to report a misconduct to the Italian Privacy authority

You can file an official complaint with the Data Protection Authority: www.garantedellaprivacy.it ( https://www.garanteprivacy.it/en/home/docweb/-/docweb-display/docweb/1089924) 

9. Changes to Privacy Notice 

If necessary, we may amend or update this Privacy Notice to reflect changes on the website and feedback from our users. If there are material changes in the way we use or process your personal data, we will notify you by posting a notice of the changes before these come into effect or by sending a notification to you directly. We encourage you to re-read this statement regularly to gain more information on how we use and protect your data.    

April 2021