DATA CONTROLLER AND DATA PROCESSOR OFFICER
The data controller is Havas Life Italy S.r.l. Via San Vito 7 – 20123 Milan (hereinafter “Company” or “Data Controller“). The data protection officer can be contacted at the following email address: firstname.lastname@example.org.
The processing related to the services of this Website is only handled by technical personnel in charge of processing, or by any technical staff in charge of occasional maintenance operations, as well as by other subjects authorized to process by the data controller. The Company may transmit the collected data to third parties such as institutional bodies or national and local authorities and to group companies when necessary to pursue the purposes of the processing or where there is a legal obligation of communication or where it is necessary according to the Terms and Conditions or in execution of other agreements in place with the user or in order to protect the rights, assets and safety of the Company or third parties. The foregoing includes exchanging information with other companies and organizations to combat legal activities.
The Company may involve third parties for the processing of data collected through the Website. These third parties will act as data processors pursuant to art. 28 of the GDPR. It should be noted that some of the subjects may also act as independent data controllers, subject to the release of appropriate statement pursuant to art. 14 GDPR, unless otherwise provided by law.
If the data is transferred to countries outside the European Union, this will be done in compliance with the conditions set out in Articles 44 and following of the GDPR or in cases specifically provided for by national or European Union law. Furthermore, in consideration of the Company’s membership of an international group and the existence of telematic, computerized and correspondence links in general between the various companies of the group, some personal data will be transferred, for the purposes referred to in this statement, to such companies in countries in any case belonging to the European Union.
PERSONAL DATA COLLECTED
• Navigation data: this category of data includes the IP addresses or domain names of the computers used by users who connect to the site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the environment computer scientist of the user.
The computer systems and software procedures used to operate this Website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.
This information is not collected to be associated with identified interested parties, but which, by its very nature, could, through processing and association with data held by third parties, allow users to be identified.
These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning and data will be immediately deleted after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the Website: except for this possibility, the data on web contacts do not currently persist for more than seven days.
• Data provided voluntarily by the user: this category includes, for example, the name, surname, email, telephone number, curricular data etc. for the use of the services offered on the Website and the participation to the relevant intiatives through the following methods: (i) registration on the Website; (ii) filling-in the submission form and uploading of documents for the participation to the selction “IDEE CALL FOR ABSTRACT”; (iii) subscription to the newsletter service and exchange of email with the Company (in cases, for example, of requesting information) also through the “Assistance” or “Contacts” area of the Website (iv) any other data collection form. In this case, the Company may use the data provided by you and may keep the content of the messages sent, together with the email addresses and related replies for the sole purpose of responding to requests received.
In accordance with the GDPR, the data collected by accessing the Website or using it, as well as directly provided in any other way, will be stored in a filing system in the legal availability of the Company.We inform you that the navigation data will be processed to guarantee and manage navigation on the Website, to obtain anonymous statistical information on the use of the Website (i.e., to understand how users interact with our web platform and allow us to improve it) and to check its correct functioning. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the Website. The other data voluntarily provided by the user collected from time to time are mainly used for the following purposes: (i) registration, management and documentation of Your registration on the Website; (ii) registration, management and documentation of Your participation to the selection “IDEE CALL FOR ABSTRACT” for the presentation of the selected clinical case during the “Meet the expert” virtual sessions, part of the IDEE 2021-2022 program (“Event”); (iii) registration, management, organization and documentation of the newsletter service and delivery of informative and marketing materials regarding the Event and any other initiative of the Company; (iv) the purposes indicated in any other data collection form; (v) to respond to your requests relating to the assistance offered by the Site. In this regard, we inform you that by selecting the “send” button present in each data collection form, you declare that the information and your personal data are correct and updated and that you have read this Notice.
The legal basis for your personal data processing depends on the purpose of the specific processing. About navigation data, the processing for the purposes above-mentioned is legitimized by the need to guarantee the navigation service (Article 6, paragraph 1, letter b, GDPR) as well as by the legitimate interest of the Data Controller to process the data relating to the Website to understand how users interact with the web platform and allow it to be improved (Article 6, paragraph 1, letter f, GDPR). As for the other data provided voluntarily by the user that may be processed (see points nos. (i), (ii), (iv) and (v) above), the legal basis of the processing is to be found in the need to execute a request of the user or to carry out pre-contractual measures adopted at the request of the same (Article 6, paragraph 1, letter b, GDPR), as well as in the legitimate interest of the Data Controller to fulfill the requests of its users (Article 6, paragraph 1, letter f, GDPR). In relation to point n. (iii), the legal basis of data processing is represented by need to execute a request of the user or to carry out pre-contractual measures adopted at the request of the same (Article 6, paragraph 1, letter b, GDPR) if you specifically request the delivery of newsletters or marketing materials or by the consent pursuant to art. 6, paragraph 1, lett. a, of the GDPR in all other cases. In any case, the consent to the processing of your data can be revoked at any time, as better specified in the “DATA SUBJECTS RIGHTS” section below.
This website uses technologies commonly known as “cookies”, including those of third parties. It should be noted that any consent for the use of these technologies and the related data processing, where required, is optional, but we warn you that in the event that consent is not given, navigation and access problems to all or parts of the Website or with respect to the full functionality of the same may arise. If you want to learn more or opt out of all or some cookies click here.
OPTIONAL PROVISION OF DATA
The processing of your browsing data is optional. However, we remind you that failure to provide such data may prevent correct navigation of the Website and the provision of any services requested. The provision of additional personal data contained in the application forms or in the “Contacts” section to request the sending of information material or other communications is optional. Failure to provide them could make it impossible to fulfill requests. It should be noted that, in any case, you can object to the processing of your data at any time, as better specified below.
METHOD OF PROCESSING AND STORAGE
The processing of the collected data will be carried out in compliance with the principles set out in art. 5 of the GDPR and of the principles of lawfulness, correctness and transparency, purpose limitation, data minimization, accuracy, conservation limitation, integrity and confidentiality and accountability.
The processing for the identified purposes will take place using computerized and manual methods, using electronic or paper supports, based on logical criteria functional to the purposes for which the data were collected, in compliance with the confidentiality and security rules provided for by the GDPR and by the related national implementing rules. In any case, pursuant to art. 32 GDPR, the Company has adopted all appropriate security measures to prevent the risks that could arise from the processing of data, such as the destruction, loss and illicit use of data, as well as unauthorized access to them.
Any personal data collected will be kept for the time strictly necessary to carry out the operations for which they were collected. In particular, the navigation data will be deleted immediately after processing, except in the event of computer crimes against the Website. In this case, in fact, the navigation data could be used to ascertain the related responsibilities. The personal data contained in the data collection forms or in the e-mails requesting information sent by the user himself, will be kept only for the time necessary to process the same requests or to fulfill the applicable legal or regulatory obligations and in any case for the time necessary to guarantee the exercise of the Company’s rights.
DATA SUBJECTS’ RIGHTS
We undertake to keep your personal data confidential and to guarantee the exercise of your rights. We inform you that the Data Controller guarantees the exercise of your rights which you can exercise without charge and at any time by sending an email to email@example.com or by writing to Havas Life Italy S.r.l. via San Vito 7, 20123 – Milan, simply indicating the reason for your request and the right you intend to exercise.
In particular, regardless of the purpose or legal basis under which we process your data, you can exercise the following rights:know if the data controller holds and/or processes your personal data and, to this end, ask us for access to such data also by obtaining a copy (Article 15 of the GDPR);
• ask us to correct or supplement the data in our possession (Article 16 of the GDPR). In any case, keep in mind that by actively providing us with your personal data by any means, you guarantee its truthfulness and accuracy. Therefore, any loss or damage caused to the Website or to the Website manager or to a third party due to erroneous, inaccurate or incomplete information reported in the registration forms, will be the sole responsibility of the user;
• ask us to delete your personal data in our possession if one of the reasons provided by art. 17 GDPR;
• ask us to interrupt or limit the processing only to some personal data, if one of the reasons provided by art. 18 GDPR;
• request data portability pursuant to art. 20 GDPR. This means that if we are authorized to process your personal data on the basis of your consent or the execution of the services requested by you, you will be able to receive the personal data you have provided to us in a structured, commonly used and machine-readable format, to be able to directly transmit them to another company, as long as it is technically possible;
• object in whole or in part to the data processing for the purpose of sending advertising material and market research (Article 21 of the GDPR). This means that you can withdraw your consent to the processing of your data at any time. Furthermore, you can object to the processing even when it is based on our legitimate interest.
Complaints in relation to the processing can be lodged with the competent Authority: Italian Data Protection Authority, Piazza Venezia n. 11 – 00187 Rome, Fax: (+39) 06.69677.3785, Telephone switchboard: (+39) 06.696771, E-mail: Protocol@gpdp.it Certified Mail: Protocol@pec.gpdp