Privacy Policy

Privacy Policy of Fondazione CLS Onlus

This Website collects some Personal Data from its Users.

Information pursuant to the REGULATION (EU) 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, and repealing Directive 95/46/EC (General Data Protection Regulation).

It is important to specify that “USER” means not only the natural persons who have directly entered into a contract with Officine Battistotti srl, but all the others that are considered in any case parties pursuant to art. 6, par. 1, lett. B) of the RGPD, including natural persons who have contributed to the implementation of pre-contractual measures taken on their own request (possible customers).

Owner and Data Controller

Fondazione CLS Onlus – Via Don Volpi 10 – 21047 Saronno VA Italy
Owner contact email: info@fondazionecls.org

Types of Data collected

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Cookies, Usage Data, email address, first name, surname, phone.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any use of Cookies – or of other tracking tools – by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party’s consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.
In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics, Displaying content from external platforms, Contacting the User, Hosting and Backup.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Comments

When visitors leave comments on the site, we collect the data shown in the comment form over the visitor’s IP address and the browser’s user agent string to facilitate spam detection.

An anonymized string created from your email address (otherwise known as hash) can be provided to the Gravatar service to see if you are using it. The privacy policy of the Gravatar service is available here: https://automattic.com/privacy/. After approving your comment, your profile picture is visible to the public in the context of your comment.

Visitor comments can be checked via an automatic spam detection service.

If you leave a comment, the comment and its metadata are kept indefinitely. This is how we can automatically recognize and approve any subsequent comments instead of keeping them in a moderation queue.

For users who register on our website (if any), we also store the personal information they provide in their user profile. All users can view, modify or delete their personal information at any time (except for their username that they can not change). Website administrators can also view and edit this information.

If you leave a comment on our site, you can choose to save your name, email address and website in cookies. They are used for your convenience so you do not have to re-enter your data when you leave another comment. These cookies will last for a year.

If you have an account and access this site, a temporary cookie will be set to determine if your browser accepts cookies. This cookie does not contain personal data and is deleted when you close the browser.

When you log in, several cookies will be set to save your login information and screen display options. The access cookies last two days while the cookies for the screen options last one year. If you select “Remember me”, your access will persist for two weeks. If you exit your account, access cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie does not include personal data, but simply indicates the ID of the just edited article. Expires after 1 day.

Media

If you upload images to the website, you should avoid uploading images that include embedded location data (EXIF GPS). Website visitors can download and extract any position data from the images on the website.

Content embedded by other websites

Articles on this site may include embedded content (such as videos, images, articles, etc.). Content embedded by other websites behave exactly the same way as if the visitor had visited the other website.

These websites may collect data about you, use cookies, integrate additional third-party tracking, and monitor interaction with that embedded content, including tracking your interaction with embedded content if you have an account and are logged in to that website.

What rights do you have on your data?

If you have an account on this site, or you have left comments, you can request to receive a file exported from the site with the personal data we have about you, including the data you have provided. You can also request that we delete all personal data concerning you. This does not include data that we are obliged to keep for administrative, legal or security purposes.

PLUGIN WORDPRESS
ITHEME SECURITY
What personal data we collect and why we collect it
Security Logs
The IP address of the visitors, the user ID of the logged in users, the username from the login attempts are recorded to verify malicious activity and to protect the site from specific types of attacks. Some conditions that cause the log can be: login attempts, requests to log out, requests for suspicious URLs, changes to the site content, password update
This information is kept for 14 days.

With whom we share your data
This site is scanned by Sucuri’s SiteCheck, to detect potential malware and vulnerabilities. No personal information is sent to Sucuri; Sucuri, however, while scanning the site, can find personal information published openly (for example in the comments), for more information check the privacy policy of Sucuri.

For how long we keep your data
Security logs are kept for 14 days.

Where we send your data
This site is part of a network of sites that offers protection against brute-force attacks. To enable this protection, visitors’ IP addresses must be shared with a service provided by ithemes.com. For more information check the iThemes privacy policy.

YouTube

The site incorporates YouTube (managed by Google) for viewing videos.
When you visit pages with YouTube plugins inside, a connection is made to YouTube servers. If you visit one of our pages with a YouTube plug-in, a connection is established to YouTube’s servers. Here, the YouTube server is informed about which of our pages you have visited. If you’re signed in to your YouTube account, YouTube allows you to associate your browsing behavior directly with your personal profile. You can avoid it by disconnecting your YouTube account. YouTube is used to make our website attractive. This constitutes a justified interest pursuant to art. 6 (1) (f) DSGVO.

Further information on the management of user data can be found in the YouTube data protection declaration at https://policies.google.com/privacy?hl=it&gl=it

 

Google Web Fonts

For a uniform representation of fonts, this page uses Web fonts provided by Google. When you open a page, the browser loads the required Web fonts in the browser’s cache to correctly display texts and fonts.
To do this, your browser must establish a direct connection to Google’s servers. Google therefore realizes that our web page has been read by your IP address. The use of Google Web fonts is performed in the interest of a uniform and attractive presentation of our plug-in. This constitutes a justified interest pursuant to art. 6 (1) (f) DSGVO.
If your browser does not support web fonts, a standard fonts are used from your computer.
Further information on the management of user data can be found at https://developers.google.com/fonts/faq and in the Google Privacy Policy at https://www.google.com/policies/privacy/

FORM SUSTAINER MEMBER

The User, by filling in his own Data with the form to become a supporting member, consents to their use to respond to requests for information or any other nature indicated by the header of the form.
Personal Data collected: name, surname, tax code, VAT (if company), address, email, telephone, company name (if entered), amount donated, any email associated with the PayPal account.

Users who become supporting members of the CLS Foundation could be contacted by the CLS Foundation for further clarification or for any problems during the donation process.

If the User wishes that their data be removed, they must request the data controller.

SPONTANEOUS DONATION FORM

The User, by filling in with his own Data the form to make a spontaneous donation, consents to their use to respond to requests for information or any other nature indicated by the header of the form.
Personal Data collected: name, surname, tax code, VAT (if company), address, email, telephone, company name (if entered), amount donated, any email associated with the PayPal account.

Users who make a spontaneous donation to the CLS Foundation may be contacted by the CLS Foundation for further clarification or for any problems during the donation process.

If the User wishes that their data be removed, they must request the data controller.

CONTACTING THE USER

Contact form

By filling out the contact form with their Data, the User consents to their use to respond to requests for information, quotes, or any other kind indicated by the form header.
Personal Data collected: name, surname, email, telephone, company name (if entered).

Contact by phone

Users who provided their telephone number may be contacted for commercial or promotional purposes connected to this Website, as well as to satisfy requests for support.
Personal Data collected: phone.

Mailing List or Newsletter ()

By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Website. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase.
Personal Data collected: name, surname, email.

HOSTING AND INFRASTRUCTURE BACKEND

Server Plan

This type of service has the function of hosting data and files that allow this Website to function, allow distribution and provide a ready-to-use infrastructure to provide specific features of this Website.
Some of these services work through geographically dispersed servers in different locations, making it difficult to determine the exact location where Personal Data is stored.
Server Linux on Provider Server Plan

Server Plan is a provider that offers a hosting service.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: Italy – Privacy Policy Server Plan.

SAVING AND BACKUP MANAGEMENT

This type of service has the function of hosting data and files that allow this Website to function, allow distribution and provide a ready-to-use infrastructure to provide specific features of this Website.

Backup on Server Plan
The Server Plan provider backs up site content.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: Italy – Privacy Policy Server Plan.

DISPLAYING CONTENT FROM EXTERNAL PLATFORMS

This type of services allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Widget Google Maps (Google Inc.)

Google Maps is a map visualization service managed by Google Inc. that allows this website to integrate such contents within its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy Google. Person adhering to the Privacy Shield.

INTERACTION WITH SOCIAL NETWORK AND EXTERNAL PLATFORMS (where present)

This type of service allows interaction with social networks, or other external platforms, directly from the pages of this Website. The interactions and information acquired from this Website are in any case subject to the User’s privacy settings related to every social network.
If an interaction service with social networks is installed, it is possible that, even if the Users do not use the service, the same collect traffic data relating to the pages in which it is installed.

Like button and social widgets of Facebook (Facebook, Inc.)

The “Like” button and Facebook social widgets are services of interaction with the social network Facebook, provided by Facebook, Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: USA – Privacy Policy Facebook.

+1 button and Google+ social widgets (Google Inc.)

The +1 button and Google+ social widgets are services for interacting with the Google+ social network, provided by Google Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: USA – Privacy Policy Google.

Tweet button and Twitter social widgets (Twitter, Inc.)

The Tweet button and Twitter social widgets are services of interaction with the Twitter social network, provided by Twitter, Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: USA – Privacy Policy Twitter.

LinkedIn button and social widgets (LinkedIn Corporation)

The LinkedIn button and social widgets are services of interaction with the social network Linkedin, provided by LinkedIn Corporation.
Personal Data collected: Cookies and Usage Data.
Place of processing: USA – Privacy Policy LinkedIn.

Instagram social button and widget (Facebook, Inc.)

The button and social widgets of Instagram are services of interaction with the social network Instagram, provided by Facebook, Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: USA – Privacy Policy Instagram.

ANALYTICS

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage Data. IP addresses collected through Google Analytics are anonymized.
Duration of Data Retention: 14 months.
Place of processing: USA

CONTACTS MANAGEMENT AND SEND MESSAGES (NEWSLETTER)

This type of service allows you to manage a database of email contacts, telephone contacts or contacts of any other type, used to communicate with the User.
These services may also allow us to collect data relating to the date and time the messages are displayed by the User, as well as to the User’s interaction with them, such as information on clicks on the links inserted in the messages.

The Newsletter Plugin
The Newsletter Plugin (WordPress Plugin) is an address management and email message service provided by Web Agile S.a.s. by Fietta Roberto
Personal Data collected: email, name, surname.
Place of processing: Italy – Privacy Policy The Newsletter Plugin.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.
he User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

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

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Website and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.