Privacy Policy

Information on the processing of personal data pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR).

FOREWORD

This information takes into account what is indicated by the GDPR and the Privacy Code (Legislative Decree 30 June 2003 n. 196). The document was also drawn up on the basis of the Privacy Guarantor's Guidelines (especially the Guidelines for combating spam issued by the Privacy Guarantor on 4 July 2013).

Data Controller: FONDAZIONE FESTIVAL DEI DUE MONDI ONLUS

Site to which this privacy policy refers: https://www.festivaldispoleto.com/ (Site).

The Data Controller has appointed a DPO (Data Protection Officer). Therefore, you can send any request for information directly to the Data Controller by writing to odv@festivaldispoleto.com

GENERAL INFORMATION

This document describes how the Data Controller processes your personal data provided on the Site.

The main treatments of your personal data are described below. In particular, the legal basis for the processing is explained, if the provision is mandatory and the consequences of not providing personal data. To better describe your rights, if necessary, we have specified if and when a certain processing of personal data is not carried out.

Registration on the Site

The Site does not offer the possibility of registration. Therefore, the Data Controller does not process your personal data for this purpose.

Purchases on the Site

It is not possible to make purchases on the Site. Therefore, your personal data will not be processed for this purpose. {abandoned-cart} {follow sushop}

Respond to your requests

Your data will be processed to respond to your requests for information. The provision is optional, but your refusal will make it impossible for the Data Controller to answer your questions. The legal basis for the processing is the legitimate interest of the Data Controller in following up on the user's requests. This legitimate interest is equivalent to the user's interest in receiving a response to communications sent to the Data Controller.

Generic marketing

Subject to your consent, the Data Controller may process the personal data you provide in order to send you advertising material and/or newsletters relating to its own products or those of third parties. The legal basis for this processing is your consent. The provision of personal data for this purpose is purely optional. Failure to consent to the processing of data for marketing purposes will make it impossible for you to receive advertising material relating to products/services of the Data Controller and/or third parties and the impossibility for the Data Controller to carry out market surveys, even aimed at evaluating the degree of user satisfaction, as well as to send you newsletters. These communications will be sent to the e-mail you provided on the Site.

Profiling

The Data Controller does not carry out “profiling” with your personal data. Therefore, we will not send you advertising material and/or newsletters relating to your own products or those of third parties of your specific interest.

Transfer of data

The Data Controller does not transfer your personal data to third parties.

Geolocation

The Site does not implement tools for geolocating the user's IP address.

Curriculum Vitae

It is not possible to send a curriculum vitae through the Site. Therefore, your data will not be processed for these purposes.

Appointment booking

Third-party systems for booking appointments with the Data Controller are not active on the Site. Therefore, your data will not be processed for this purpose. In any case, you can always contact the Data Controller at the contacts indicated in the epigraph.

Communication of personal data

As part of its ordinary activities, the Data Controller may communicate your personal data to certain categories of subjects. In Article 2 You can find the list of subjects to whom the Data Controller communicates your personal data. To facilitate the protection of your rights, Article 2 may specify in some cases when your data are not disclosed to third parties.

The 'communication' of personal data to third parties is different from the 'transfer' (governed by the previous point). In fact, in the communication, the third party to whom the data is transmitted can use it only for the specific purposes described in the relationship with the Data Controller. In the transfer, on the other hand, the third party becomes the independent Data Controller of the personal data. In addition, to transfer your personal data to third parties, your consent is always required.

Notwithstanding the foregoing, it is understood that the Data Controller may in any case use your personal data to correctly fulfill the obligations established by the laws in force.

SPECIFIC PRIVACY POLICY

Art. 1 Processing methods

1.1 The processing of your personal data will be mainly carried out with the aid of electronic or automated means, in the manner and with the appropriate tools to guarantee their security and confidentiality in accordance with the GDPR.

1.2 The information acquired and the methods of processing will be relevant and not excessive compared to the type of services provided. Your data will also be managed and protected in secure IT environments adapted to the circumstances.

1.3 No “special data” is processed through the Site. Special data are those that may reveal racial and ethnic origin, religious, philosophical or other convictions, political opinions, membership in parties, unions, associations or organizations of a religious, philosophical, political or trade union nature, health status and sexual life.

1.4 Judicial data are not processed through the Site.

Art. 2 Communication of personal data

The Data Controller may communicate your personal data to specific categories of subjects. Below are the subjects to whom the Data Controller reserves the right to communicate your data:

  • The Data Controller may communicate your personal data to all those subjects (including Public Authorities) who have access to personal data by virtue of regulatory or administrative measures.
  • Your personal data may also be communicated to all those public and/or private entities, natural and/or legal persons (legal, administrative and tax consultancy firms, judicial offices, chambers of commerce, chambers and offices of labor, etc.), if the communication is necessary or functional to the correct fulfilment of the obligations deriving from the law.
  • The Data Controller makes use of employees and/or collaborators in any capacity. For the proper functioning of the Site, the Data Controller may communicate your personal data to these employees and/or collaborators.
  • The Data Controller does not use companies, consultants or professionals in charge of installing, maintaining, updating and, in general, managing the Data Controller's hardware and software. Therefore, your data will not be communicated to these categories of subjects.
  • To send its communications, the Data Controller uses external companies responsible for sending this type of communication (CRM platforms). Your personal data (in particular the email) may then be communicated to these companies.
  • The Data Controller does not use external companies to provide customer care services.
  • The personal data of the buyers are not disclosed to couriers or forwarders.

The Data Controller reserves the right to modify the above list based on its ordinary operations. Therefore, you are invited to regularly access this information to check to which subjects the Data Controller communicates your personal data.

Art. 3 Storage of personal data

3.1 This article describes how long the Data Controller reserves the right to keep your personal data.

  • For marketing purposes, personal data will be kept until consent is revoked. For inactive users, personal data will be deleted one year after sending the last email viewed.

3.2 Notwithstanding the provisions of Article 3.1, the Data Controller may keep your personal data for the time required by specific regulations, as amended from time to time.

Art. 4 Transfer of personal data

4.1 The Data Controller is based within the European Union. Therefore, the processing of your data is secure from a regulatory point of view as it is governed by the GDPR. If the transfer of your personal data takes place in a non-EU country and for which the European Commission has expressed an adequate judgment, the transfer is in any case considered safe from a regulatory point of view. This article 4.1 indicates from time to time the countries to which your personal data may possibly be transferred and where the European Commission has expressed a judgment of appropriateness.

  • The user is therefore invited to regularly access this article to verify if the transfer of your personal data takes place in a country with these characteristics.

4.2 Notwithstanding the provisions of Article 4.1, your data may also be transferred to non-EU countries and for which the European Commission has not expressed an adequate judgment. You are therefore invited to regularly review this article 4.2 to ascertain to which of these countries your data may be transferred. To allow the correct functionality of the Site, your personal data may be transferred to the U.S.A. In these cases, the Data Controller will adopt any suitable contractual measure to ensure an adequate level of protection of personal data, including, among others, the Standard Contractual Clauses approved by the European Commission on 4 June 2021.

4.3 In this article, the Data Controller indicates the countries to which it may specifically direct its business. This circumstance may imply the application of the legislation of the reference country, together with that of the GDPR.

  • At the user's request, the Data Controller will apply to the processing of personal data the possibly most favorable legislation provided for by the user's national legislation.

Art. 5. Rights of the interested party

Pursuant to art. 13 of the Privacy Regulation, the Data Controller informs you that you have the right to:

  • ask the Data Controller for access to your personal data and the correction or cancellation of the same or the limitation of the processing concerning you or to oppose their processing, in addition to the right to data portability
  • revoke consent at any time without prejudice to the lawfulness of the processing based on the consent given before the revocation
  • lodge a complaint with a supervisory authority (e.g.: the Guarantor for the protection of personal data).

The above rights may be exercised with a request addressed without formalities to the contacts indicated in the Introduction.

Art. 6. Amendments and Miscellaneous

The Data Controller reserves the right to make changes to this information at any time, giving appropriate publicity to users of the Site and in any case guaranteeing adequate and similar protection of personal data. In order to view any changes, you are invited to consult this information regularly. In the event of substantial changes to this privacy statement, the Data Controller may also notify you by email.

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