Privacy Policy
Information on the processing of personal data pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 [“GDPR”] and Legislative Decree 30 June 2003 No. 196 [“Privacy Code”]
This privacy notice is intended to provide maximum transparency regarding the processing of personal data of those who request registration for event participation services or training programs, online donations, job applications, volunteer activities, requests for information about institutional activities, and purchases of solidarity products [“the Services”].
The Data Controller
The Data Controller is Fondazione Patrizio Paoletti per lo Sviluppo e la Comunicazione (tax code: 94092660540), with registered office in Rome, Via Nazionale 230; email [fondazione@fondazionepatriziopaoletti.org](mailto:fondazione@fondazionepatriziopaoletti.org); certified email (PEC) [fondazionepatriziopaoletti@pec.it](mailto:fondazionepatriziopaoletti@pec.it); telephone +39 06 8082599 [“the Controller”].
The Data Controller has appointed a Data Protection Officer (DPO) pursuant to Article 37 of the GDPR, Dr. Ilaria Sterpa. You may contact the DPO at any time for any questions or requests regarding your personal data and privacy by writing to [privacy@fondazionepatriziopaoletti.org](mailto:privacy@fondazionepatriziopaoletti.org).
Personal data processed
When registering for the Services, you will be asked to provide your contact details, such as name, surname, email address, telephone number, and optionally your social media contact.
Purposes of processing, legal basis, and retention periods
- Use of the Services and Controller obligations
Where processing is necessary for:
- your use of the Services, the legal basis is the performance of a contract to which the data subject is a party (Art. 6(1)(b) GDPR);
- analysis of service quality and user satisfaction, including for service improvement, the legal basis is the legitimate interest of the Controller (Art. 6(1)(f) GDPR);
- compliance with legal obligations, the legal basis is compliance with a legal obligation (Art. 6(1)(c) GDPR);
- the protection of a legal right of the Controller, the legal basis is the legitimate interest of the Controller (Art. 6(1)(f) GDPR).
Retention period: once the purposes related to the use of the Services and the analysis of their quality and user satisfaction have ceased, the personal data provided will be used and stored for the time necessary to comply with legal obligations of the Controller and to ensure the protection of its rights within the applicable limitation period.
- Sending communications regarding the Controller’s initiatives
The Controller may use your email address to send informational messages, including through automated tools, about initiatives similar to those of the Services: in this case, the legal basis is Article 130(4) of the Privacy Code. You may at any time opt out of receiving such communications.
The Controller may also use your email address, phone number, and social media contact to send informational and promotional messages regarding its initiatives, including those unrelated to the Services, such as newsletters and market research, via automated tools (email, SMS, fax, MMS, social network messages, WhatsApp, Messenger, instant messaging apps) and non-automated tools (postal mail, telephone calls with an operator): in this case, the legal basis is your consent, which you are freely asked to provide at registration.
Retention period: for these purposes, unless consent is withdrawn, data will be stored for a maximum period of 36 months.
- Sharing of personal data
If you wish, the Controller may share your personal data, including email, phone number, and social media contact, with its Partners engaged in related activities, with whom it has partnership agreements aimed at developing synergies and optimizing the achievement of respective missions.
Data sharing will allow these Partners, who will become independent data controllers, to send you informational and promotional messages about their own initiatives.
In this case too, the legal basis is your consent.
Retention period: up to 36 months, unless consent is withdrawn.
- Social network profiles and pages
Fondazione Patrizio Paoletti per lo Sviluppo e la Comunicazione maintains official pages on major social networks (e.g. Facebook, Instagram, YouTube) to promote its activities, publishing informational and promotional content regarding initiatives, services, and fundraising campaigns.
Users who follow these pages express their willingness to receive information and messages. Such consent is considered implicit based on user interaction and platform behavior.
Retention period: data will be processed until the user unfollows the pages.
Consequences of refusal to provide data and consent
- Failure to provide data required for Service use will make it impossible to register for the Services.
- Failure to provide consent for promotional communications or data sharing has no consequences and consent may be withdrawn at any time.
Processing methods and security measures
Personal data will be processed mainly using electronic, telematic, and manual tools, adopting appropriate security measures to minimize risks of unauthorized access, disclosure, alteration, loss, or destruction.
Disclosure and categories of recipients
Personal data will never be publicly disclosed.
Data may be processed by authorized personnel and processors bound by agreements with the Controller. Data may also be communicated to third parties (public authorities, law enforcement, or other entities) where required by law or contract.
Transfer to third countries
Data is processed within the EU. If transferred outside the EU, it will only be transferred to countries ensuring an adequate level of protection or subject to appropriate safeguards (e.g. standard contractual clauses).
Data subject rights
You may exercise rights under Articles 15–21 GDPR, including access, rectification, erasure, restriction, objection, and data portability.
You may also lodge a complaint with the relevant supervisory authority. In Italy: Garante per la Protezione dei Dati Personali, Piazza Venezia 11, 00187 Rome – email: [garante@gpdp.it](mailto:garante@gpdp.it) – PEC: [protocollo@pec.gpdp.it](mailto:protocollo@pec.gpdp.it) – website: [www.garanteprivacy.it](http://www.garanteprivacy.it).
Last updated: 23.02.2022
FONDAZIONE PATRIZIO PAOLETTI PER LO SVILUPPO E LA COMUNICAZIONE