PRIVACY NOTICE
Fondazione “Istituto Auxologico Italiano” (hereinafter also referred to as the Istituto Auxologico Italiano), in its capacity as Data Controller of the Personal Data (the “Controller”), intends to provide You, in Your capacity as a data subject (the “Data Subject”), with specific information regarding the processing of Your Personal Data that is necessary in relation to Your participation in the training courses provided by Istituto Auxologico Italiano, pursuant to Article 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter also “Regulation (EU) 2016/679”) and the European and national legislation that supplements and/or amends it.
DATA CONTROLLER AND DATA PROTECTION OFFICER
The Data Controller for Your personal data is Fondazione “Istituto Auxologico Italiano”, with registered office in Milan (Italy), Via L. Ariosto no. 13. Istituto Auxologico Italiano has appointed a Data Protection Officer (hereinafter also referred to as the “DPO”) in the person of Dr. Valerio Gatti, who can be contacted at the following email address: dpo@auxologico.it
CATHEGORIES OF PERSONAL DATA SUBJECT TO PROCESSING
By completing the registration form, You authorize the Data Controller to process Your personal data (hereinafter “Personal Data”) for the purpose of Your participation in training courses and the subsequent appropriate communications regarding updates to the same. In particular, Your identification and personal data (such as name, surname, date of birth, place of birth, gender, and nationality) will be processed; contact details (such as email address, telephone number, and residential or domicile address); professional data, such as company affiliation, role, and professional specialization (where provided); administrative and fiscal data (such as billing information and, where requested, invoice header for legal entities).
PURPOSE OF PROCESSING AND LEGAL BASIS
Your Personal Data will be processed for the purposes and in compliance with the conditions of lawfulness set forth in EU Regulation 2016/679, as indicated below:
- Art. 6, paragraph 1, letter b) (performance of the contract of which you are a user), for the purposes of managing registration and participation in training courses and events;
- Art. 6, paragraph 1, letter f) (pursuit of a legitimate interest of the Data Controller), for purposes related to the possible assessment, exercise, or defense of the rights of the Italian Auxological Institute in extrajudicial and/or judicial proceedings.
You may object to the processing by following the procedures indicated in the paragraph “Exercise of rights.” For more detailed information, You may contact the DPO and/or consult the institutional website in the privacy section.
METHODS OF PROCESSING
The stated purposes require that processing operations be carried out using methods strictly related to the purposes themselves and, in any case, in such a way as to guarantee the security and confidentiality of the data in full compliance with current legislation and, in particular, with the applicable security measures, as well as the relevant rulings of the Data Protection Authority. With the exception of paper documentation, which is stored in locked cabinets or in places with controlled access, all your Personal Data and Special Data are managed through the Italian Auxological Institute’s information system, which is managed for all the Data Controller’s facilities through the use of an IT platform based on servers centralized in a “private cloud” to which all the Italian Auxological Institute’s facilities are interconnected via a private, closed data network.
The policies on authentication, security, privacy, storage, and consultation of data are the same for all the facilities of the Italian Auxological Institute.
RECIPIENTS AND SCOPE OF DATA COMMUNICATION
Data processing is carried out by the healthcare and administrative staff of the Italian Auxological Institute, who have been specifically trained by the latter, as well as by parties outside the company organization who process data on behalf of the Data Controller – Istituto Auxologico Italiano – on the basis of a contract or other legal act that qualifies them as data processors pursuant to Article 28 of EU Regulation 2016/679 (e.g., software houses that maintain programs used in the company for the management of patient data, suppliers of electro-medical equipment or healthcare devices, and so on). Among these, for the technical management of the e-learning platform and the functions related to registration and participation in training courses and events, the Italian Auxological Institute uses the supplier Media Med Publicis SRL, with headquarters in Calea Grivitei 148 Sc. 1 Et. 1 Ap. 7 Cod 010742, Bucharest, Romania. For a list of these data processors, please contact the Italian Auxological Institute at dpo@auxologico.it
TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES OR INTERNATIONAL ORGANIZATIONS
Istituto Auxologico Italiano does not transfer Personal Data and Special Categories of Data of its patients to countries outside the European Union or the European Economic Area. Should this prove necessary in specific cases, the Italian Auxological Institute guarantees that the transfer will take place in accordance with the provisions of Chapter V of EU Regulation 2016/679 (Art. 44 et seq.), and therefore on the basis of an adequacy decision by the European Commission or, in the absence of such a decision, on the basis of standard contractual clauses adopted by the European Commission or any other legal basis explicitly provided for in the Regulation itself.
DATA RETENTION
Your Personal Data will be stored, for the purposes referred to in point I. above, for the time necessary to fulfill the related purposes (e.g., generating and sending invoices, 730 communications, etc.) and the related legal obligations; for the purposes referred to in point II., for the entire duration of the relevant proceedings and, in any case, until the expiry of the terms for the exercise of judicial protection and/or any appeals.
YOUR RIGHTS PERTAINING YOUR DATA
Regulation 2016/679, in Articles 15-22, grants You numerous rights, including the right to request the Data Controller to access, rectify, or erase Your data, to restrict the processing of your data, to object to the processing of Your data, as well as the right to data portability and the right to lodge a complaint with the Data Protection Authority. To exercise these rights, You must send a registered letter with return receipt addressed to the Italian Auxological Institute – General Management – Via L. Ariosto 13 – 20145 Milan, or by fax to 02.619112204, or by email to: dpo@auxologico.it
