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PRIVACY POLICY

Collegio Carlo Alberto > Privacy Policy



PRIVACY NOTICE FOR WEBSITE USERS

according to article 13 of the Regulation (EU) 2016/679 (“GDPR”) General Data
Protection Regulation


DATA CONTROLLER

Fondazione Collegio Carlo Alberto
Fiscal Code n. 94049090015
Headquarter: 8 Piazza Arbarello, Turin, Italy, 10122
Data controller e-mail: privacy@carloalberto.org

In accordance with Art. 13 of the Regulation 2016/679 of the European Parliament
and of the Council of 27 April 2016 on the protection of natural persons with
regard to the processing of personal data and on the free movement of such data
(hereinafter referred to as “GDPR”), Fondazione Collegio Carlo Alberto
(hereinafter referred to as “Data Controller” or “Collegio Carlo Alberto”), as
Data Controller, inform you (hereinafter referred to as “User” or “Data
Subject”) that your personal data will be processed for the following purposes
and in the following manner:


1. TYPES OF DATA COLLECTED

The Data Controller processes personal data, including identification data (e.g.
name, surname, e-mail, phone number, etc.) and usage data of the User
(hereinafter referred to as "Personal data" or "Data") collected through the
Data Controller's website, located at https://www.carloalberto.org/ (hereinafter
referred to as "Website").

The information relating to the network used by the User (e.g. IP address) may
also be collected and processed by the Data Controller.


2. PURPOSES AND LAWFULNESS OF PROCESSING

Your Personal data will be processed for the following purposes:

 a. Respond to the User’s information requests via e-mail (in the letter case,
    the data processing will not be conducted directly through the Website);
 b. Enable the User to register for events organized by the Data Controller
    and/or its Partners. To facilitate the event registration process, the Data
    Controller utilizes the Google Forms service provided by Google Ireland
    Limited (hereinafter referred to as Google) to collect your Personal Data
    for identification and registration purposes. Please note that Data
    processing does not occur directly through the website. Instead, it is
    carried out in accordance with the procedures specified in the present
    Privacy Policy and the Google Privacy Policy, which can be found at:
    https://policies.google.com/privacy;
 c. Acquire statistics and metrics to ensure the proper functioning of the
    Website;
 d. Exercise the rights of the Data Controller (e.g., data processing for
    exercise or defence of legal claims).

The lawfulness of the data processing is the following:

 * With regard to purposes (a) and (b), the Data processing is necessary for the
   performance of a contract to which the User is a party or for taking steps at
   the User’s request prior to entering into a contract;
 * For purposes (c) and (d), the lawfulness of Personal Data processing is
   grounded on the legitimate interests of the Data Controller, specifically in
   monitoring the proper functioning of the Website and processing Personal Data
   when required for establishment, exercise, or defence of legal claims.

The Users may not to communicate the Data for the above-mentioned purposes.
Failure to provide the Data, however, may render it impossible for the Website
to provide its services.

Furthermore, the Data Controller will process the User's Data, exclusively upon
the User's explicit consent given in accordance with Article 7 of the GDPR, for
the following purposes:

 e. To send emails and communications regarding Collegio Carlo Alberto’s
    initiatives, etc. The Data Controller relies on the Brevo (formerly,
    Sendinblue) platform to deliver newsletters. The processing of personal data
    is carried out in accordance with the provision outlined in the Brevo
    Privacy Policy, available at:
    https://www.brevo.com/legal/privacypolicy/#privacysibinc;
 f. For statistical purposes, subject to the User’s explicit cookie acceptance.
    The Data Controller employs such services as “Pixel” provided by Meta
    Platforms Ireland Limited (hereinafter referred to as Meta) and “Google
    Analytics 4” provided by Google to collect anonymized Data of the Website’s
    Users (e.g. tracker and usage data) that aids in understanding website usage
    patterns and performance. The data processing for statistical purposes is
    carried out in accordance with the procedures outlined in the Privacy Policy
    of the respective services. To gain a deeper understanding of the data
    processing, please refer to the following links:
    Google Privacy policy: https://policies.google.com/privacy
    Meta Privacy Policy: https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0

In order to obtain more information about cookie processing, please visit our
Cookie Policy at the following link:
https://www.carloalberto.org/cookie-policy-eu/

The lawfulness of the Data processing for purposes (e) and (f) is the consent of
the User.

The Consent is optional. Thus, the User may refuse to provide his/her consent
for the processing of Data for purposes (e) or (f). Moreover, the User may
revoke his/her consent to the processing of data at any time without affecting
the lawfulness of the processing based on the consent before the withdrawal.


3. RETENTION TIME

The Data Controller will store and process Personal data for the period of time
necessary to fulfill the purposes specified in this Privacy notice. Your Data
will not be retained for a longer period of time unless the current law requires
a more extended retention period. The Italian Civil Code requires to store all
the documents of commercial or legal relevance for a period of 10 years. The
Personal Data can also be stored for the period of time necessary for the
establishment, exercise or defence of legal claims.

The data collected for marketing and profiling purposes will be processed by the
Data Controller until the User withdraws his/her consent to the processing and
in any case, for a period not exceeding 10 years from the date when the Data was
collected.

For more information about the retention period for Data acquired through
cookies, please refer to our Cookie Policy:
https://www.carloalberto.org/cookie-policy-eu/


4. DISCLOSURE OF PERSONAL DATA

The User’s Personal data will not be disseminated but may be made accessible
where necessary for the provision of services or for compliance with statutory
obligations to:

 * employees or collaborators of the Data Controller in Italy or abroad, in
   their capacity of subjects authorized to process Personal data and/ or system
   administrators.
 * third-party companies or other subjects (e.g. credit institutions, IT
   consultants etc.) which carry out activities in outsourcing on behalf of the
   Data Controller, in their capacity of Processors.

The Data Controller may communicate your Personal data for the purposes
established by Art. 2 of the present Privacy notice to supervisory authorities,
legal authorities and public authorities to which it is obligatory to
communicate the Data, as well as to those subjects to which the communication is
obligatory by law for the fulfillment of the above-mentioned purposes.


5. TRANSFER OF PERSONAL DATA

The Personal data will be stored on servers located within the European Union
and managed by third-party companies duly appointed as Processors.

The Data Controller may transfer the User’s Personal data to a third country.
The data will be transferred exclusively to countries considered “adequate” and
therefore, “safe” by the European Commission or to the companies that ensure
appropriate safeguards pursuant to Articles 44-50 of the GDPR.


USERS RIGHTS

You may exercise the rights granted by the GDPR (articles 15-22), including:

 a. The right to receive confirmation as to whether the Data Controller is
    processing the User’s Personal data (access rights);
 b. The right to update, modify and/ or correct Personal data (right of
    rectification);
 c. The right to request the erasure of data or the restriction of the
    processing. This right can be granted if the process is unlawful or the Data
    Controller no longer needs the Personal data for the purposes of the
    processing (right to be forgotten and right to restriction of processing);
 d. The right to oppose to the processing (right of opposition);
 e. The right to propose a complaint to the Supervisory Authority in case of
    violation of the regulations regarding the protection of Personal data;
 f. The right to receive an electronic copy of the User’s Personal data (in a
    structured, commonly used and machine-readable format) and right to transmit
    those Data to another Data Controller without hindrance from the Data
    Controller to which the Personal Data has been provided (right to Data
    portability).


7. DATA CONTROLLER CONTACT INFORMATION

The Data Controller: Fondazione Collegio Carlo Alberto

Office: 8 Piazza Arbarello, Turin, Italy, 10122

You can contact the Data Controller to exercise your rights granted by the GDPR
by sending a registered letter to Fondazione Collegio Carlo Alberto at 8 Piazza
Arbarello, Turin, Italy, 10122 or by sending an e-mail to
privacy@carloalberto.org providing the following information: name, surname, a
copy of your identity document.


8. DATA PROTECTION OFFICER CONTACT INFORMATION

The Data Protection Officer (DPO):

ARGO BUSINESS SOLUTIONS SRL

Contact: Fabio Cassanelli

The DPO can be contacted by sending an e-mail to the following address:
collegiocarloalberto@argobs.it.


9. INFORMATION NOT CONTAINED IN THIS POLICY

More details concerning the collection or processing of Personal Data may be
requested from the Data Controller at any time. Please see the contact
information at the beginning of this document.


10. CHANGES TO THIS PRIVACY POLICY

The Data Controller reserves the right to make changes to this Privacy Notice at
any time by notifying its Users within this Website at the following link:
https://www.carloalberto.org/privacy/

Privacy Notice updated on: 09/10/2023



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