Privacy Policy

At CivicaMente srl, we are committed to protecting your data.
A new General Data Protection Regulation n. 679/2016 (the so-called “GDPR”) is now effective throughout Europe on May 25, 2018.
Find out how we handle and protect your personal information by reading our new updated Privacy Policy.
The e-mail address of our Privacy Officer is ines.lazzarini@civicamente.it, we will be happy to respond to any questions you may have.
If you need to contact us, you can use the contact form on the site.
Last review June 30, 2022.
PRIVACY POLICY
This policy will allow you to discover, before accessing the various sections of the Website, how CivicaMente srl processes your personal data, including both data you provide directly (such as your first name, surname, e-mail address, etc.) and the data which CivicaMente srl collects in the manner described in the section “The personal data we collect and how we collect it” (hereinafter, collectively, the “Personal Data”). Please view the policy before providing your Personal Data.

Identity and contact details of the Controller
The Controller is CivicaMente srl, with registered office in Via Foscolo, 10 – 25080 Padenghe sul Garda (BS) – Italy
Please find our contact details here: https://www.civicamente.it/
CivicaMente srl will process your Personal Data in accordance with Regulation EU no. 2016/679 and national personal data protection regulations (hereinafter the “Privacy Regulation”).

The Personal Data we collect and how we collect it
CivicaMente srl may collect and then process your Personal Data when you browse the Website and/or access certain sections of it. When you connect to the Website, the IT systems and the software procedures which allow them to function automatically and indirectly provide and/or acquire certain information (such as the so-called “cookies”, as specified in the section “Privacy Policy – Cookies”, at the end of this policy document, “IP” addresses, the domain names of the computers used by users who connect to the Website, the “Url” address of the resources requested, the time of the request to the server).
Any requests for information or services you submit could lead to collection and subsequent processing of your Personal Data (such as first name, surname, e-mail address, etc.).
In particular, your Personal Data may be collected:
– when you fill out on-line forms;
– through your publication of Contributions (as defined below), the content of which could include Personal Data which you have provided directly on social networks managed independently by third parties, including, but not limited to, Facebook, Twitter, etc. (hereinafter “Social Networks”). By “Contributions”, we mean images, comments, catchphrases associated with the subject of the Website, contents and any other information you have conceived and published on the pages of Social Networks dedicated to CivicaMente srl, including any image you provide.
If you choose to register for the newsletter service or to send a request through the “Contact us” section of the Website, you must provide certain Personal Data to allow CivicaMente srl to satisfy your needs, so the relative boxes of the registration form are marked with an asterisk or otherwise indicated as obligatory. Providing Personal Data which is not marked with an asterisk or otherwise indicated as obligatory is entirely optional and there will be no consequences if this Personal Data is not provided or is incomplete or imprecise. However, if you do not provide the Personal Data marked with an asterisk or otherwise indicated as obligatory, or said data is incomplete or imprecise, the service you request cannot be supplied. If you fail to provide any of the obligatory Personal Data, a CivicaMente srl error message will appear listing the missing obligatory Personal Data.

The purposes of processing your Personal Data and the legal basis for processing
Based on the needs you indicate each time on accessing the various sections of the Website (and excluding individual initiatives which require specific Personal Data to be provided, for which specific information will be published each time on the Website), the purposes of processing your Personal Data and the legal basis for processing are indicated below.
Your Personal Data will be processed for the following purposes only with your consent to processing, which may be withdrawn at any moment, by sending a request to the Controller via the “Contact us” section of the Website, or, for the newsletter, also using the link at the bottom of each newsletter e-mail:

a) Management of your requests and response to them
You may decide to consent to processing of your Personal Data to allow CivicaMente srl to manage and respond to your requests relating to services and the various initiatives relating to CivicaMente srl, or to the Website (“Contact us” section of the Website). In this case, your consent is requested when you submit the requests. If you decide not to consent to processing of your Personal Data for said purposes, you will be unable to send the request.

b) Receiving the newsletter
You may decide to register with the newsletter service dedicated to CivicaMente srl, by providing the relative consent. In this case, your consent is requested when you register with the newsletter service.
Furthermore, even without your consent, CivicaMente srl may process your Personal Data for the following purposes:
I. management of activities linked to your use of the Website, including publication of your Contributions on the pages of Social Networks dedicated to CivicaMente srl (since processing is necessary for execution of a contract or pre-contractual measures).
II. management and fulfilment of legal obligations (accounting, administrative, tax obligations, etc.).
III. management of complaints and any disputes (as this is a legitimate interest of the Controller).

How we process your Personal Data
Processing of your Personal Data may include any type of operation, such as collection, recording, organisation, storage, consultation, processing, rectification, selection, extraction, comparison, use, interconnection, blocking, disclosure, erasure, and destruction.
Your Personal Data will be processed mainly with automated tools, but also on paper, adopting logic strictly linked to the related purposes, using databases and electronic platforms managed by CivicaMente srl or by third parties appointed as external processors for this purpose and/or through the integrated IT systems of CivicaMente srl and of said third parties and/or websites owned or used by CivicaMente srl.
The Controller has assessed the level of security to be sufficient, taking account of the risks which could derive from loss, destruction, rectification, unauthorized disclosure, accidental or illegal access, abuse, or alteration of your Personal Data. In particular:
– it has adopted security measures appropriate to the risks.
– it stores your Personal Data on servers located within Europe, which have an advanced and daily back-up system.

Where we process your Personal Data
Your Personal Data will be processed primarily at the Controller’s offices and in places where the processors are located. For further information, contact the Controller at the addresses indicated in the section “Identity and contact details of the Controller”.

How long we keep your Personal Data
To ensure compliance with the principles of necessity and proportionality of processing, the Controller keeps the Personal Data for different periods, depending on the individual purposes being pursued:
(i) in order to manage and respond to your requests relating to services and initiatives of CivicaMente srl, or the Website (“Contact us” section of the Website), your Personal Data will be kept for the time strictly necessary to fulfil your request.
(ii) for sending of newsletters, your Personal Data, excluding contact details, will be kept for a maximum period of 5 years.
(iii) for management of activities linked to your use of the Website, including publication of your Contributions on the pages of Social Networks dedicated to CivicaMente srl, your Personal Data will be kept for the time strictly necessary to supply the service you have requested.
(iv) for management and fulfilment of legal obligations (accounting, administrative, tax obligations, etc.), your Personal Data will be kept for the time strictly necessary for said purpose.
(v) for management of any complaints and disputes, the Personal Data will be kept for the period strictly necessary for this purpose and, in any case, not beyond the applicable time limits.

The recipients of your Personal Data
Your Personal Data may be communicated to and processed by:
(i) legal or natural persons who act as external processors, performing activity in outsourcing, appointed by CivicaMente srl or by the external processors of CivicaMente srl (including parties assigned to perform assistance, communication, promotion of activities, advertising agencies, suppliers of IT services, the Website operators, electronic platform operators, partners, credit institutions, professional consultancy firms).
(ii) employees and/or collaborators of the Controller (including system administrators), who operate under its direct authority, who will be authorized to process your Personal Data.
(iii) employees and/or collaborators of the external processors (including system administrators), who operate under the direct authority of the external processors and will be authorized to process your Personal Data.
Your Personal Data will not be communicated to third parties, except when communicated by CivicaMente srl to consultants to protect its rights, nor disclosed.

Minors
Minors under 16 years of age must not provide information or Personal Data to CivicaMente srl without parental consent. If this consent is not provided, minors cannot send requests via the Website or register with the newsletter service. CivicaMente srl invites anyone with parental responsibility on minors to inform them on secure and responsible use of the Internet and the Web and to implement the procedures indicated in the phase of sending the request and registering for the newsletter service concerning individuals under 16 years of age.

Identity and contact details of the processors
A complete list of the Personal Data processors may be consulted by contacting the Controller at the address indicated in the section “Identity and contact details of the Controller”.

Your rights in relation to processing of your Personal Data
As the data subject, you are granted numerous rights by the Privacy Regulation. In detail, you are entitled to:
1. Obtain from the Controller confirmation of whether or not your Personal Data exists, even if not registered, and its disclosure in intelligible form, and also access to your Personal Data (by obtaining a copy) and the related information (including the purposes of processing, the categories and origin of the Personal Data, the categories of recipients to whom it has been or could be disclosed, the retention period (when possible), the rights which may be exercised).
2. Obtain from the Controller the rectification of your Personal Data and supplementing of any incomplete Personal Data.
3. Obtain from the Controller the erasure of your Personal Data without undue delay, including when the Personal Data is no longer necessary for the purposes for which it has been processed or the legal basis for processing no longer exists.
4. Obtain from the Controller the conversion into anonymous form or blocking of your Personal Data if it is processed illegally, including data which it is not necessary to store, in relation to the purposes for which the Personal Data was collected or subsequently processed.
5. Obtain from the Controller the limitation of processing of your Personal Data, also when you dispute its accuracy or object to processing, for the period necessary for the respective checks to be performed.
6. Receive your Personal Data in a structured, commonly used, machine-readable format, and transmit or, if technically feasible, obtain transmission of your Personal Data to another controller without impediments, in cases in which processing is carried out by automated means and is based on your consent or when necessary for execution of a contract to which you are a party.
7. Withdraw consent to processing of your Personal Data for any of the purposes for which it has been provided.
You may exercise your rights with CivicaMente srl by accessing the “Contact us” section of the Website or by sending a letter by ordinary mail to CivicaMente srl, to the address indicated in the section “Identity and contact details of the Controller”.
Furthermore, if you believe that processing of your Personal Data breaches the Privacy Regulation, you may lodge a complaint with the Data Protection Supervisory Authority in the State in which you reside, where your workplace is located or in which the presumed breach has occurred, or contact said Authority to request information on exercising of your rights under the Privacy Regulation.

The right to object to processing of your Personal Data
At any moment and for reasons linked to your own specific situation, you are entitled to object to processing of your Personal Data which is based on a legitimate interest pursued by the Controller or by third parties. In this case, the Controller abstains from further processing of your Personal Data unless it demonstrates the existence of legitimate and binding reasons which prevail over your interests, rights or freedoms or processing is necessary to ascertain, exercise or protect a legal right.
You can withdraw your consent to processing for sending of newsletters and object to processing of your Personal Data, by accessing the “Contact us” section of the Website.
If you object to processing of your Personal Data for this purpose, the Controller will be unable to carry out the related processing.

 

The European Commission support for the production of this publication does not constitute an endorsement of the contents which reflects the views only of the authors, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
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