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pursuant to article 13 of Regulation (UE) 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 (in brief “GDPR”)
in compliance with the European and Italian legislation in force in the sector, we ensure that the protection of Your personal data is guaranteed and that their confidentiality and integrity are preserved when You browse our internet Website https://learn.uni-med.net, where our e-learning Platform is located, and use it to request registration of an account (by using the proper “Google form”), to obtain information on our activities, to login into the private area devoted to attending courses, to find our contact details and contact us, to subscribe to the newsletter service managed by the Anna Lindh Foundation (UNIMED’s Partner in the e-learning project).
We invite You to inspect this policy concerning the modalities, means and purposes of processing of Your personal data.
1 – Data Controller and Processors
The Data Controller is UNIMED – Unione delle Università del Mediterraneo, with registered office in Corso Vittorio Emanuele II, 244 - 00186 ROMA, which may be reached to exercise the rights afforded by the GDPR or to obtain clarifications concerning this policy, at the following addresses:
- e-mail: email@example.com
- telephone: +39 06 68581430 / 68806186
- or by regular mail at the above-specified address.
The Data Controller avails itself of third parties that provide some services to UNIMED and/or support it in carrying out certain activities: these third parties have been appointed as Data Processors pursuant to article 28 of the GDPR.
2 – Categories of data subject to processing and purposes of processing
A) While browsing through the sections of our Website, as any user may do without need of registration, we obtain and process the following personal data, for the specific purposes listed below:
(i) Browsing data concerning the session
The IT systems responsible for the functioning of this Website acquire, during their normal functioning, certain personal data whose transmission is implicit in the use of Internet communication protocols (e.g. IP addresses, Internet connection and traffic data, domain names of the devices used by Website visitors).
This information is not collected to be associated to identified data subjects or to identify users.
The data might be used to ascertain responsibilities in case of possible IT crimes against the Website.
(ii) Browsing data concerning services provided by third parties and/or obtained by third parties through the Website
Processing of the above-specified data has the purpose of ensuring the correct functioning and use of our website, through: a) performance evaluations of the Website during the browsing session, aimed at monitoring and improving the services we offer; b) analysis of the browsing data, in aggregate form, for statistical purposes and to keep track of the behavior of users, in any case without profiling.
B) A “registration form” web page (implemented through Google’s functionalities) is linked to our Website: by filling in the form with the requested information - some of which are compulsory whereas other are not - You can submit Your registration’s request to the private area of our e-learning Platform: then, a personal account is created and You are enabled to login (by using the username and password duly provided to You). Personal data collected on such occasions are mainly processed by UNIMED to issue the services You ask for, to improve the performance and the efficiency of those services, also differentiating between professional profiles, interests, etc., and for statistical purposes.
D) Furthermore, our Website shows an e-mail address: sending, optionally and voluntarily, electronic mail to such address entails the consequent acquisition of the address of the sender, necessary to reply to the requests, as well as of any other personal data that may be included in the letter; by sending the e-mail, You thus consent to data processing for the purposes specified.
We process the personal data in question to allow You to contact us, to request information and/or assistance, and to allow our Company to reply to Your requests. The e-mail provider is Google Suite.
3 – Legal ground for the processing
More in detail, UNIMED will process personal data collected from users to:
- respond to questions and requests to participate in course activities;
- provide for registration of participation;
- implement online activities;
- assure quality control, monitoring and evaluation;
- provide for recognition of the participation in the learning activity, through the award of a Certificate of Participation to the participants.
The processing of personal data, depending on cases, is based on the following legal grounds:
- the pursuit of a legitimate interest of the Controller to ensure the security of the Website, control its correct functioning and obtain statistics in relation to its use, as to the browsing data concerning the session, and to possibly exercise or defend a legal claim (article 6, paragraph 1, letter f of the Regulation);
- the performance of the services requested (article 6, paragraph 1, letter b) of the Regulation), with reference to the personal data that are necessary to create the personal account to access the Platform (marked as compulsory in the registration form);
- the consent given by the user (as indicated above from time to time) to the processing of data referred to in letters B), C) and D) above and concerning the use of the browsing data related to services provided by third parties through the Website and/or obtained from third parties through the Website, (article 6, paragraph 1, letter a). Consent may be withdrawn at any time.
Shall the personal data be processed for statistical purposes, the requirements of article 89 of the Regulation are fulfilled.
4 – Modalities of processing
Processing of personal data will be performed through IT instruments, both automated and non-automated (in such case, through human intervention in the management of IT systems) and through the use of analogical instruments (paper management), according to logical processes closely correlated to the purposes of the same processing and, in any case, with the support of equipment and with modalities that guarantee the security and confidentiality of the same data, preventing loss of data, illegal or incorrect uses, and unauthorized accesses.
We use technical (“application”) cookies, both first-party and third-party, for data processing on our Website.
A “cookie” is a small quantity of data that is sent by a Web server to the browser of the user and subsequently stored on the hard drive of his or her computer.
The use of so-called session cookies is strictly limited to the transmission of session identifiers (represented by random numbers generated by the server), necessary to enable the secure and efficient exploration of the website, and to the acquisition of data to save the browsing preferences of the user (e.g., setting the language, managing statistics), in order to optimize the experience on the Website. Session cookies used on this Website avoid recourse to other IT techniques potentially prejudicial to the confidentiality of users’ browsing and do not allow acquisition of personal data identifying the user.
5 – Disclosure and dissemination of data
The entities that may become aware of the personal data we process are our employees and collaborators, who take care of the administrative management of the Web page and of relations with users / customers. The company taking care of the management of the Website may, possibly, become aware of the personal data, on the occasion of assistance / maintenance interventions.
The data are never transferred to, or in any case acquired by, third-party entities located or in any case operating in countries outside the European Union, with the exception of the following: the Anna Lindh Foundation, having its registered office in Alessandria (EGYPT), which operates within European countries as well as North African countries.
As far as Google services are concerned, Google, LLC is included in the so called Privacyshield List https://www.privacyshield.gov/welcome: thus, the company guarantees an appropriate level of protection; furthermore, some Google services are provided by Google Ireland Limited in favor of subjects based and / or operating within the European Union.
Where needed, should we have an obligation to report a crime or in any case the need to pursue a legitimate interest to exercise or defend a legal claim on our part, the data of users might be disclosed to the Judicial Authority or to police forces.
Apart from the cases above specified, personal data will not be disclosed to third parties and/or in any way disseminated outside the context of the European Union.
6 – Data retention periods
Browsing data are deleted immediately after the processing, at the end of the browsing session (closure of the browser).
Data provided voluntarily by users (by sending e-mails) will be stored for the 12 months following delivery to users of the requested information, unless further storage of the data is necessary to comply with legal obligations, or the parties enter into another relationship.
Data processed through third-party cookies (including sharing cookies) are stored for the period of time provided by the operators, according to the respective privacy policies.
The data collected for the purpose of sending the newsletter will be processed and stored exclusively for the period during which the services, issued by Anna Lindh Foundation, will be active: therefore, until a possible request to no longer receive information is submitted.
The data used to create and manage the personal account that enable access to the e-learning Platform will be processed and stored exclusively for the period during which the e-learning service will be active: therefore, up to a possible request of deletion of the account.
The other personal data collected through the registration form will be processed and stored exclusively for the period during which the e-learning service will be active: unless, prior to the expiration of this term, the interested party does not request cancellation or withdraws the consent to the processing.
7 – Rights of the data subject concerning the processing of personal data (Articles 15-22 and 77 of the GDPR)
It is possible to submit requests to exercise the rights afforded by the Regulation (access, rectification, erasure, objection, restriction and portability if the conditions are present) by sending them to the contacts of UNIMED above indicated.
To enable us to respond quickly, we kindly ask You – thanking You in advance for Your cooperation – to specify Your first and last name, e-mail address. Certain requests (for example concerning exercise of the right to access) must be accompanied by a photocopy of an identity document with Your signature to verify Your identity; it is also necessary to specify the address at which You wish to receive the answer. The answer will be sent within one month of receipt of the request.
The data subject has also the right, if he or she believes the processing of his or her data to be performed in infringement of the provisions of the Regulation, and without prejudice to the right to complain to the competent civil or administrative judicial authorities, to lodge a complaint with the Supervisory Authority for the protection of personal data, within the limits of its jurisdiction.
Please consider that with reference to the data processed by Anna Lindh Foundation, the abovementioned requests to exercise the rights afforded by the Regulation are to be submitted directly to the Foundation.
 Moodle Pty, Ltd is an Australian company that provides a web service which allows educators, of any kind, to create a private space online, filled with tools that easily create courses and activities, all optimized for collaborative learning. The Moodle software is free and open source, and may be hosted by Moodle Pty, Ltd but also by anyone who wishes to manage an installation. In the latter situation, Moodle Pty, Ltd does not process any kind of personal data belonging to data subjects who apply to Platforms that use Moodle software.
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