DISCLOSURE PURSUANT TO EU REGULATION 2016/679 (GDPR): EMERGENCY ONG Onlus, with headquarters in Via Santa Croce 19, 20122 Milan (MI) – Italy, as data Controller under EU Regulation 2016/679 (hereafter the “GDPR”), intends to provide clear and comprehensive information about the rights of data subjects under the GDPR, in compliance with the principles of lawfulness, fairness and transparency while processing personal data.
1. DATA CATEGORY Personal data processed by the Data Controller includes: (i) identification data (name, age, sex, tax code); (ii) contact/location data (residence or home address, postal code, home/mobile phone, e-mail); (iii) bank and/or payment details.
2. PURPOSE AND LEGAL BASIS Personal data will be processed for the following purposes:
- a) to carry out the donation procedure and/or to participate to specific initiatives promoted by the Controller, including any related activities requiring data processing (e.g. accounting process, summary or statement, financial reporting, registration form etc.);
- b) to comply with internal administrative procedures and to fulfil consistent legal obligations or regulations in force in Italy (e.g. communication to the Italian Internal Revenue Agency (Agenzia delle Entrate), if applicable, for the pre-compiled income tax statement, pursuant to the Decree of the Ministry of the Economy and Finances of 30.01.2018);
- c) to send informative, promotional and fundraising communication material related to EMERGENCYs’ activities, with appropriate personalisation based on the interests and preferences already expressed by the donor/supporter.
The provision of data for the purposes referred to in items a) and b) above is necessary to ensure the execution of contractual obligations and in compliance with internal administrative procedures or fulfilment of legal obligations and regulations in force in Italy. In the event that data processing is not allowed – or subsequently withdrawn – the donation procedure and/or participation to the above-mentioned initiatives will not be possible.
The “personalized” processing referred to in item c) above will be based on the legitimate interest of EMERGENCY, for the purpose of making the relationship with the supporter/donor more transparent, effective and long-lasting by means of consistent information on running activities and related needs, either during their start-up or during ther development. EMERGENCY believes it is of the utmost importance for the recipient to receive messages of its own interest, and so reflecting common expectations from a donor/supporter.
The donor/supporter can ask at any time to stop receiving this type of communication or to receive all communications, excluding the personalization filter.
3. DATA PROCESSING The processing of personal data which is necessary with respect to the purposes indicated above (pursuant to Art. 4 of the GDPR) are: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, confrontation, use, interconnection, blocking, communication, cancellation and destruction of data.
Personal data will be processed and stored, when appropriate, both on paper and electronically – including automatic processing – applying the highest available standards of security and confidentiality.
4. RECIPIENTS (either natural persons or legal entities) Personal data will be processed only by authorised staff and possibly disclosed to:
- a) banking institutions, which will process them to manage payment means and, when required and feasible, to the Italian Internal Revenue Agency (as referred to in item 2.b above));
- b) third parties who may be appointed as data Processors under Art. 28 of the GDPR when in charge of specific processing operations, including communications and related activities (i.e. suppliers in charge of phone calls, sending of activity reports or other printed materials, e-mails, texts and so on) or to which data needs to be shared to comply with the law, legislation or codes of conduct, or to organise specific awareness initiatives.
Personal data in encrypted form only – i.e. “pseudonymization” – may be transferred to third recipients (e.g. Facebook) for personalised advertisements (see the purposes in 2.c)).
The full list of appointed data Processors under art. 28 of the GDPR will be available at any time by addressing a notice to firstname.lastname@example.org
. Personal data will not be disclosed for other purposes and will not be disseminated to the public.
5. RRIGHTS OF DATA SUBJECTS Data subjects can exercise their rights under Art. 15 et seq. of the GDPR at any time, and more precisely:
- a) to have full access to the set of personal data processed by the Controller;
- b) to obtain the rectification, integration, erasure of personal data or – when it’s due – the restriction of processing;
- c) to object to specific processing of personal data, when it’s due;
- d) to withdraw consent, when required, at any time: the possible withdrawal does not affect the lawfulness of the processing;
- e) to have full access to the list of appointed data Processors;
by addressing a request to the attention of the Chief Privacy Officer, Alessandro Bertani, at EMERGENCY ONG Onlus, Via Santa Croce, 19 – 20122 Milano (MI) – Italy or by mailing email@example.com
Data subjects may also file a complaint with the Italian Data Protection Authority (i.e. “Garante Privacy”).
(FOR ITALIAN TAXPAYERS ONLY – Data subjects can also object to their personal or donation data to be communicated to the Revenue Agency by sending an e-mail to firstname.lastname@example.org or email@example.com, or by sending a fax to +39 06 50762650.)
6. TERMS OF DATA STORAGE Personal data will be stored for no longer than necessary for the purposes for which the personal data are processed – in any case for a term not exceeding 10 years from the date of donation – without prejudice to any other rights, obligations or protection means provided by law.
7. DATA PROTECTION OFFICER The Data Protection Officer appointed by the Controller is Mr. Nicola Tarantino. Mr. Tarantino can be contacted by addressing a notice to EMERGENCY ONG Onlus, Via Santa Croce, 19 – 20122 Milan or by mail at firstname.lastname@example.org.
Last updated: 9 January 2020.
This Privacy Notice may be updated The latest version will be always available on this web page.