What kind of data we collect?
Under 679/2016 UE Regulation on processing personal data when you use our services, you will accept that our Company would collect some of your personal data. This document aims to tell you which data we collect, why and how we use them.
We process two types of data:
- Data given us by the user;
- Data we collect by default.
Data given us by the user
When you register, we ask you some data necessary to be able to use our services.
That is to say, by way of example but not limited to that, data we ask for:
- Name and surname;
- Address, e-mail and password;
- Date of birth;
- Town or munucipality;
- Telephone number;
Data we collect by default
We collect the following data through the services you use:
- Technical data: for example IP address, browser type, information about his pc, data regarding the current position (approximative) of the device you are using;
- data collected by using the cookies or similar technologies: for further pieces of information, please visit the paragraph “Cookie”.
1. How to use the data collected?
We use the data collected to offer you every day our service, to inform you about our activities or to offer you a more customized service responding to your interests.
1.1. TO GUARANTEE YOU ACCESS TO OUR SERVICES AND TO IMPROVE THEIR EFFICIENCY.
We use your data to guarantee you access to our services and their efficiency, among which:
- registration to events and to the newsletter and possible creation of the log-in area;
- use of “Favorites” and “Saved research” functionalities;
- communications linked to the efficiency of our services;
- administrative, financial or tax activities.
Such processings are necessary to provide properly ISPI services to the users receiving them.
We use your data also to improve and implement the service, through the following processing:
- communications about services similar to the ones you use;
- market research, optional surveys and activities of detection about the degree of user satisfaction.
Such processings are based on the legitimate interest of the Holder and you can object to them at any moment (please read in particular paragraphs 3 and 4).
1.2. TO INFORM YOU ABOUT OUR ACTIVITIES
We use collected data, in the event you had explicitly given us the consent, to inform you about promotional activities that would be interesting for you.
In particular, we use them:
- to send pieces of information about our activities;
- to transmit warnings about courses promoted by ISPI School;
- to send for free our studies, the papers and the digital publications;
- to communicate promotional and commercial activities about ISPI events, initiatives or partnerships, through e-mail, social network, texting or push notifications;
- to improve the communication between ISPI and the users through activities of analyses and reporting related to the systems of promotional communication, such as the collection of the number of open e-mails, of the clicks on the links present inside the communication, the type of the device used to read the communication and the corresponding operating system or the list of the un-joint users to the newsletter.
1.3. TO OFFER YOU A CUSTOMIZED SERVICE
We elaborate the collected data, in the event you had explicitly given us the consent, to analyse your habits or consumer choices in order to offer you a more and more customized service, responding to your interests, and to improve our offer. Anyway, such analyses are not related to an automated decision-making.
2. Providing data is mandatory?
To provide personal data is mandatory only for the processing necessary to provide the serviced offered by ISPI ( the possible refusal for purposes of service providing makes impossible the use of the service itself); on the other hand, it’s optional for the promotional and profiling purposes and the possible refusal to give the consent has no negative consequences on the service providing offered on the website www.ispionline.it and the related applications.
3. Who are the targets of the processing?
3.1. HOLDER OF THE PROCESSING
Holder of the processing is the Italian Institute for International Political Studies with registered office in Milan (IT), Palazzo Clerici, via Clerici 5 – 20121 Milano C. F./ VAT number 02141980157.
For any request about your personal data, please read the following paragraph 3.2.
3.2. CONTACT DETAILS
Please remember that you can contact us at any moment and send us any question or request about your personal data and the respect of your privacy by sending an e-mail to email@example.com.
3.3. PERSONS TO WHICH IT’S POSSIBLE TO COMUNICATE PERSONAL DATA
The collected data inside the service providing may be transmitted to:
- the companies undertaking tasks strictly related and exploitative to the functioning- even technical- of the ISPI services, such as suppliers providing services aimed at the review and testing of the ads, suppliers of direct marketing and customer care services, companies providing archiving, administrative, payment and accounting services, linked companies proving technical components for the providing of some functionalities of the service;
- institutions and administrative and legal authorities as required by law.
Your personal data could be transfer outside European Union to be processed by our service suppliers. In this case, we make sure that this transfer will happen in accordance with the law and that there will be guaranteed an appropriate level of protection of the personal data based on a choice of adequacy, on standard clauses defined by the Binding Corporate Rules.
We never sell personal data to third parties.
4. How you can have information about data, modify them, delete them or have a copy of them?
4.1. ACCESS to the personal data from your log-in area and withdrawal of consent (OPT-OUT)
At any moment, you can look over your personal data inside your log-in area. Please enter with your account and click on the “Log-in area” section.
Please remember that at any moment you can withdrawal consents you have given entering your log-in area and removing the related flag.
4.2. Takeout and cancellation of the personal data processing
To take out your personal data or ask for their cancellation you can send an email to firstname.lastname@example.org from the e-mail address you have insert during the registration in ISPI.
Your personal data will be taken out within 30 days or, in the event of a particularly difficult takeout, within a month.
The cancellation will happen within the appointed technical time frame and in accordance with the period of storage spelt out in the following paragraph 5.
4.3. Exercise of your rights
Any individual using our service can:
- obtain from the holding, at any moment, information about the existence of his personal data, their origin, the aims and the processing mode and, if possible, to gain the access to the personal data and pieces of information you can find in the article 15 GDPR;
- to ask for the up-grade, the review, the integration, the cancellation, the limitation of the data processing in the event it happened one of the conditions laid down in the article 18 of GDPR, the transformation into anonymous form or the stock of personal data, processed infringing the law, including those ones in which it is not necessary the storage in relation to the purpose for which the data have been collected and/or then processed;
- to object, in whole or in part, for legitimate reasons, to the data processing laid down for the purposes of commercial information or of sending merchandise or of direct selling that is to say in order to make market research or commercials. Every user has also the right to withdraw the consent at any moment without undermining the legality of the processing based on the consent given before the withdraw;
- to receive your personal data, provided consciously and actively or through the use of the service, in a structured format, customary and readable by automatic device, and to transmit them to another holder of the processing unimpeded;
- to put a claim in to the General Authority for the personal data protection in Italy.
For any question or request about your personal data and the respect of your privacy please send an e-mail to the dedicated address email@example.com.
5. How and for how long your data will be stored?
The personal data storage will happen in paper form and/or digital and for the strictly necessary time to satisfy the set purposes, with respect for your privacy and for the law.
For purposes of analysis aimed to the development and improvement of the service, the personal data of the user will be able to have the same period of storage.
For direct marketing and profiling we store your data for a maximum period equal to the one laid down by law (that is to say of 24 and 12 mouths).
The invoices, the tax documents and the data about the transaction are stored for 11 years according to the law (including the fiscal obligations).
In the case of exercise of “right to be forgotten” through the request of an expressed cancellation of the personal data processed by the holder, we remind you that they will be stored, in a secure form and with a restricted access, only for purposes of assessment and combating criminal offences, for a period not longer than 12 months starting from the date of the request and then they will be deleted in a secure way or make them anonymous irreversibly.
6. How to ensure the protection of your data?
The data are collected by the entities, according to the law of reference, with a particular reference to the security measures laid down by GDPR (art. 32) for their processing through computer, manual and authorized facilities and with motives strictly linked to the laid down purposes and, anyway, in order to guarantee the security and the privacy of the data themselves.
In conformity with the applicable law, an anti-spam verification system on the users’ communications is activated. The data here inserted may be verified for the sole purpose of finding illegal activities, but they won’t be processed or communicated for commercial or promotional purposes.
The holder of the processing makes available the “Careers” page to consult the possible available ISPI work positions and he reserves the right to evaluate the applications submitted for the purposes of screening and recruiting staff.
The resumes received for specific selection may be stored and re-evaluated for future recruiting for work positions fitting the candidate profile, in a maximum time range of 2 years. The candidate may object to his personal data processing, at any moment, by sending an e-mail to firstname.lastname@example.org.
If you apply, please remember to insert in your resume the declaration providing authorisation to process your personal data for purposes of recruiting and please not insert the sensitive personal data (such as the state of health, the religious, philosophic and politic beliefs) not concerning the job offer.
This policy may be changed. If important changes to the user data processing by the holder are made, he will inform the user by publishing them most clearly on his pages or through other or similar means.
Cookies and similar technologies
1. What are the cookies?
The cookies are text files of small dimension that the websites visited by the users send to their devices, where they are memorized to be transmitted again to the same websites during the following visits. The cookies (and/or similar technologies such as the SDK technologies for the mobile field) can be stored permanently (persistent cookies) on your device or they can have a variable duration; indeed, they can be deleted with the closure of the browser or have a duration limited to the singular session (session cookies). The cookies can be installed by ISPI (first part cookies) or by other websites (third part cookies).
The cookies are used for different purposes as better specified in the following paragraph 2 of this page.
For the profiling activities, the personal data collected through cookies are processed for a maximum period of 12 month starting from the moment the authorisation to the processing is given. Here below you will find all the pieces of information about the cookies installed through the ISPI website and/or related applications and the necessary tips about how to handle your preferences about them.
Please remember that our platform supports the browsers and/or applications mentioned here below with the purpose of a fair service providing. For excellent results we suggest you to download the most recent version of your browser or application.
Please remember that ISPI can’t guarantee the proper functioning of the service and the effectiveness of the indications mentioned in this Statement for older versions of not supported browsers and/or applications.
1.1. DESKTOP BROWSER
- Chrome version 49.0 or the following one;
- Firefox version 52.0 or the following one;
- Internet Explorer version 11 or the following one;
- Safari version 8 or the following one.
1.2. MOBILE BROWSER
- iOS 7.1 or the following one (iPhone 4 or the following one): Safari;
- Android 4.1 or the following one: Chrome 28.0 or the following one, Samsung Browser 3.3 or the following one, Android browser;
- Windows Phone 8.1 or the following one: IEMobile.
1.3. BROWSER for Tablet devices
- Ipad: Safari;
- Android: Android Browser.
- IOS 6.1.0 or the following one;
- Android 3.2.0 or the following one.
2. Which cookies are present in ISPI?
2.1. FIRST PART COOKIES AND RELATED PURPOSES
The main purposes of the cookies installed by ISPI are:
- Technical, that is to say they are used with purposes connected to the service providing and to make possible or to improve the browsing on ISPI or to store the searches. Such cookies are essential for guarantee to our platform a proper functioning;
2.2. THIRD PART COOKIES AND RELATED PURPOSES
The main purposes of the cookies installed by third parties are:
- To collect statistical data about the use of the service by the users (e.g. visitors amount, visited pages ecc.). These cookies are used to analyse the traffic on our pages anonymously, without storing personal data.
- marketing: we analyse your online actions so that we can provide you, through third partners, contents and commercial offers fitting your interests also based on your previous browsing experience. This data are handles separated from the identification data in the hands of ISPI.
Furthermore, cookies specially designed for “social networks” could be activated. They let the users interact through the social networks (Share function, Facebook). When a page has this funcion, there is a direct link to the selected social network.
The consent to the use of profiling cookies is given by the user through the following ways: by closing the banner containing the short reporting, by scrolling down the page hosting the banner or by clicking on any element of it and it may be withdrawn at any moment.
All the technical cookies do not require any consent, so they are installed by default after the access to the website or to the service.
4. How to withdraw (opt-out) the consent to use the cookies?
The cookies can be totally disabled by the browser by using the dedicated function laid down in the most of the browsers.
But you should know that by disabling the cookies some ISPI functionalities couldn’t be usable any more.
LIST OF COOKIES USED (download pdf)
Your permission concerns the follow ISPI websites: www.ispionline.it