Privacy Statement

PRIVACY POLICY
PURSUANT TO ART. 13 OF EU REGULATION 2016/679 AND COOKIE POLICY
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  1. - Foreword.
    The International Telematic University UNINETTUNO (hereafter UNINETTUNO) is responsible for the development of the IT platform of the DEO4PA project - Digital Ethics Officer certified training programme for European Public Administration, co-funded by the European Commission in the framework of the Erasmus+ programme Project Number: 2023-1-IT01-KA220-VET-000160330, specific programme: Cooperation Partnership in Vocational Education and Training.
    Through the website https://deo4pa.uninettuno.it/en/deo4pa.aspx it is possible to enrol in the course and access the didactic cyberspace that delivers the training contents developed within the DEO4PA project.
    Enrolment in the course and use of the DEO4PA project's teaching cyberspace are totally free of charge.
    The purpose of this document is to inform natural persons interested in enrolling in the course and using the DEO4PA project's educational cyberspace about the processing of their personal data.
  2. - Information on the Data Controller.
    UNINETTUNO, with registered office in Rome, Corso Vittorio Emanuele II n. 39, is the Data Controller of the personal data processing pursuant to the European Union Regulation 2016/679 and the Italian law (Legislative Decree n. 196/03).
  3. - The purposes of the processing, the categories of personal data and the legal basis of the processing.
    The DEO4PA project processes the personal data of data subjects only for the following purposes
    - navigation of the project website to provide users with information and guidance content;
    - user registration to access the course;
    - individual access to the didactic cyberspace to benefit from the training contents and assess the level of competences during all the phases of the learning process;
    - storage for controls by the Supervisory Authorities.
    • 3.1) Browsing data: this is the technical information automatically acquired by the IT system during consultation, by means of communication protocols; this information is used only to ensure normal browsing and use of the services, also according to the criteria selected (for example: the language chosen) and to obtain anonymous statistical information on the use of the portal or to control its operation and is not associated with identifiable users, but could allow indirect identification of the user through association with data held by third parties.
      The collection of navigation data is based on the use of cookies. Cookies are small text strings sent to the user's terminal (PC, notebook, smartphone, tablet, etc.) during consultation of the portal and sometimes stored in the browser in order to be retransmitted the next time the user consults it. The use of these cookies does not require the consent of the data subject as the activity is necessary for the performance of a free-of-charge contract to which the data subject is a party or for the performance of pre-contractual measures taken at the data subject's request (Art. 6 co. 1° lett. b of the European Union Regulation 2016/679 ‘GDPR’).
      The DEO4PA project website also employs Matomo analytics cookies aimed at collecting information, in aggregate form, on the number of users who have visited the portal and on their mode of consultation in order to generate internal statistics on the use of the portal for the purpose of improving the services offered, the effectiveness of which is limited to one day in the case of the ‘_pk_ses#’ cookie and to one year from its installation in the case of the ‘_pk_id#’ cookie. The use of these cookies also does not require the consent of the data subject as the activity is necessary for the pursuit of a legitimate interest of the owner (Art. 6 co. 1° lett. f of the European Union Regulation 2016/679 ‘GDPR’).
      Finally, the DEO4PA project website employs cookies from Google Inc. to perform the CAPTCHA test. These cookies are necessary to implement the security measure known as Challenge/Response authentication: the CAPTCHA test protects the owner from spam by asking to pass a simple test that proves that the user is a person and not a computer. The effectiveness of Google Inc. cookies is limited to the duration of the site browsing activity in the case of the ‘rc::c’ cookie and is persistent in the case of the ‘rc::a’ cookie. The use of these cookies does not require the consent of the person concerned.
      No cookies are used for promotional or advertising purposes, even if they are from third parties (so-called ‘profiling cookies’).
    • 3.2) Data actively communicated by the user: this is the personal data entered by the data subject in the course enrolment request form on the DEO4PA project website.
      The information entered (identification and contact data) is used exclusively to enrol the interested party in the course and create personal credentials (id and password) for access to the DEO4PA project's educational cyberspace.
      The collection of the personal data required for enrolment in the course is necessary and without it it is not possible to follow up the data subject's request.
      The processing of this personal data does not require the consent of the data subject as the activity is necessary for the performance of a free-of-charge contract to which the data subject is a party or for the performance of pre-contractual measures taken at the request of the data subject (Art. 6 para. 1 letter b of the European Union Regulation 2016/679 ‘GDPR’).
    • 3.3) Data produced by the user's interaction with the educational cyberspace of the DEO4PA project: this is the personal data generated and processed during the performance of the teaching and training activity in the educational cyberspace (number of accesses to the IT platform, number and duration of accesses to the video lessons and teaching materials, number of exercises carried out and related assessment/self-evaluation).
      This personal data is tracked for the purpose of profiling the activity of the data subject and enabling the tutor to make an assessment of the level of skills possessed during all stages of the learning process based on both quantitative and qualitative elements learned during the teaching activities. No automated decision-making process is envisaged.
      Also in this case, the processing of this personal data does not require the consent of the data subject as the profiling is necessary for the performance of the contract to which the data subject is a party (Art. 6 co. 1° lett. b of the European Union Regulation 2016/679 ‘GDPR’).
    • 3.4) Stored data: this is all personal data actively communicated by the user and produced by the user's interaction with the educational cyberspace of the DEO4PA project, permanently recorded by the system during the phases of the learning process and archived at the end of the course.
      Personal data stored by the Data Controller will only be communicated to the Supervisory Authority for the controls foreseen in the case of projects co-funded by the European Commission.
      These processing operations do not require the consent of the data subject as the safekeeping is necessary to fulfil a legal obligation (Art. 6 para. 1 letter c of the European Union Regulation 2016/679 ‘GDPR’).
  4. - Data location and security measures.
    All personal data of the data subject are processed and stored on servers located within the European Union owned and/or at the disposal of the Data Controller and/or appointed third parties, duly appointed as Data Processors. Therefore, personal data may be communicated to these processors for the provision of the services entrusted to them.
    The transfer abroad of personal data to non-EU countries is not envisaged.
    All personal data of the data subject are protected by appropriate IT security measures against unauthorised access, temporary unavailability and loss of information.
  5. - The duration of processing and the period of storage of personal data.
    At any time, the data subject is free to interrupt the processing of his or her personal data by deleting his or her registered account.
    The conservation period of navigation data collected through the use of cookies varies: some are automatically deleted from the system at the end of the session, others are deleted within a day or a year, and others are persistent, as better specified in paragraph 3.1 above).
    The personal data actively communicated by the user and those produced by the user's interaction with the educational cyberspace of the DEO4PA project are stored for the duration of the course and at the end will be archived for a maximum period of 5 years and then deleted.
  6. - The rights of the data subject.
    Any interested party has the right to ask the Data Controller:
    - access to and rectification of inaccurate personal data concerning him/her;
    - the integration of incomplete data;
    - the deletion of the same if they have been processed unlawfully or if the deletion is necessary to comply with a legal obligation;
    - the restriction of processing only to personal data concerning him/her whose accuracy is not contested by the data subject, pending completion of checks on the contested data, and to be informed before such restriction is lifted;
    - the delivery of the personal data he or she has provided, in a structured, commonly used and machine-readable format, or the transmission of those data to another data controller, including directly, if technically possible. Excluded from this right are personal data that have not been provided by the data subject and data processed for the performance of a task carried out in the public interest or in connection with official authority vested in the data controller.
    All requests can be forwarded to UNINETTUNO at the registered office, or to the following addresses: tel. +39 06 692076.70 / +39 06 692076.71 or to the e-mail address deo4pa@uninettunouniversity.net.
    The Controller shall comply with any request by the data subject without undue delay and, in any case, no later than one month from receipt of the request. This deadline may be extended by a maximum of two more months and the Controller shall inform the person concerned, within one month of receipt of the request, of the extension and the reasons for the delay.
    Should the data subject's requests be unfounded or excessive, in particular due to their repetitive nature, the Controller is entitled to charge him a fee or even refuse the request.
    In the event that the data subject considers that the processing concerning him or her is in breach of EU Regulation 2016/679 or that the Data Controller has not complied with his or her obligations in connection with the exercise of the aforementioned rights, he or she has the right pursuant to Article 77 of the same Regulation to lodge a complaint with the Supervisory Authority located in the Member State in which he or she normally resides or works, or with the one located in the place where the alleged breach occurred. This is without prejudice to any other administrative or judicial remedy.
  7. - The Data Protection Officer.
    The Data Controller has appointed Mr Gaetano Giordano as Personal Data Protection Manager, who can be contacted by email at the following address: dpo@uninettunouniversity.net or by tel./fax at +390637511524. Data subjects may contact him for all matters relating to the processing of their personal data and the exercise of their rights under the aforementioned Regulation, and he is bound to secrecy with regard to the performance of his duties.