The C.G.M. consortium, in its capacity as data controller of the data of users, called data subjects, provides them with the information provided for in Articles 13 and 14 of the EU General Data Protection Regulation 2016/679 (GDPR).
The data of the data subjects may be known by external parties, for example the developer and maintainer of the site, who have been selected from among those who offer guarantees of adopting security measures and who implement appropriate technical and organisational measures to protect the rights and freedoms of the data subjects. The relationship between the data controller and these subjects, referred to as data processors, is governed by a contract. The data subject may always request an updated list of the data processors.
CATEGORIES OF DATA PROCESSED
The data controller uses data acquired from the site during the user’s navigation, for which it refers in particular to the cookies policy, which can be reached via the appropriate link. This data includes, for example, IP addresses, the date and time of access to the site, the list of pages visited and other parameters relating to the user’s operating system and computer environment, for which transmission is implicit in the use of web navigation protocols. In some sections of the site, e.g. for the purpose of subscribing to the newsletter, the data subject may voluntarily enter his/her own data (usually identification data and an e-mail address), which will be used only for the purpose of providing the requested service. The data controller does not process data falling into the special categories set out in Article 9 of the Regulation, for example data on health and religious, trade union, philosophical, political or sexual orientation.
LEGAL BASIS AND PURPOSE OF PROCESSING
The processing of certain data is strictly necessary for the operation of the site (such as technical cookies, regarding which please refer to the relevant policy); in the absence of this data the site could not function and therefore could not guarantee the performance of the service requested. Therefore, the user’s consent is not required for their processing, as the legal basis of the processing is the contract between the parties or the need to perform the service in favour of the users. For all other data (e.g. for the activation of profiling cookies or for newsletter subscription) the legal basis for processing is consent, which is always freely revocable.
PLACE OF PROCESSING AND DATA RETENTION PERIOD
The data of the interested parties are not transferred outside the European Union and are stored, as far as cookies are concerned, according to the specific indications contained in the relevant policy, and as far as the others are concerned only for the time necessary to guarantee the performance of the service requested, as in the case of subscription to the newsletter.
MEANS OF DATA PROCESSING
The site processes navigation data using cookies, as specified in the relevant policy. The site also has a section in which the user can enter the requested data. Insertion is not necessary; however, if the data requested is not provided, the data controller will not be able to respond to requests or complete the requested activity (e.g. registration for a course).
RIGHTS OF THE DATA SUBJECT
With regard to their personal data the data subject may exercise the rights provided for in Articles 15 to 22 of the EU General Data Protection Regulation 2016/679, as well as the right to withdraw consent (Article 7, § 3).
In particular the user has the right to ask the data controller (who can be reached at the contact details indicated on the website, where it is also indicated how to contact the data protection officer) for access to his/her data (15), to ask for rectification (16), erasure (17) and portability (20) as well as to object to the processing (21) or request restriction (18); he/she may also lodge a complaint with the data protection authority (77).
For all clarifications on the subject of data processing and for the exercise of rights, which can take place without any formal constraints, the data subject may contact the Data Protection Officer (DPO) of the data controller, who can be reached at the e-mail address email@example.com and the telephone number 02 9304277, where a message can be left on the answering machine if necessary.