Information on Data Processing and Protection

Last Revision Date: 5 February 2024

This Notice is intended to inform the user on how personal data concerning him/her are processed.

Un Ponte Per ETS (UPP) is committed to respecting the rules of conduct – in line with the European Regulation 679/2016 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, as well as on the free circulation of such data (hereinafter “GDPR”) – which guarantee safe, controlled and confidential navigation on the network. This policy for the protection of the confidentiality of information may undergo changes over time, also in function of the additions and legislative and regulatory changes in the matter or for our institutional decisions, therefore, we invite you to periodically consult this section of our site.

User Rights

Users may exercise certain rights with reference to the Data processed by the Owner. In particular, the User has the right to:

  • Revoke your consent at any time.
  • Object to the processing of your Data.
  • Access your Data (the User has the right to obtain information on the Data processed by the Owner, on certain aspects of the processing and to receive a copy of the Data processed).
  • Verify and request rectification (the User can verify the accuracy of their Data and request its updating or correction).
  • Obtain the limitation of processing, when certain conditions apply (the User may request the limitation of the processing of his/her Data, in which case the Data Controller will not process the Data for any other purpose other than their conservation, provided that this fulfills the further obligations provided by law of the Data Controller).
  • Obtain the deletion or removal of your Personal Data (when certain conditions apply, the User may request the deletion of their Data by the Owner).
  • Receive your Data and/or have it transferred to another owner (the User has the right to receive his/her Data in a structured, commonly used and machine-readable format and, where technically feasible, to obtain the transfer without hindrance to another owner; this provision is applicable when the Data is processed with automated tools and the processing is based on the User's consent, on a contract to which the User is a party or on contractual measures connected to it).
  • Submit a complaint (the User may submit a complaint to the competent data protection supervisory authority or take legal action)

To exercise the above rights, requests should be addressed to the physical address of the Owner or by email   privacy[at]unponteper.it .
The email address  privacy[at]unponteper.it  is managed by:

  • Head of the Communication and Fundraising Department and
  • from the General Management,

as Responsible for any Complaint, Request and Rectification process according to the policies of this Organization.
See:  Complaint and Response Mechanisms Policy

Ownership and responsibility for data protection

Un Ponte Per ETS is the name of our association which has its registered office in Rome in via Angelo Poliziano 18 – 20 – 22.
The association Un Ponte Per ETS is the data controller pursuant to and for the purposes of EU Regulation 2016/679 (GDPR).
We publish our content through websites: one, the main one, whose address is  www.unponteper.it
a second  www.sostegniadistanza.unponteper.it , third site  www.figlidellostessomondo.it , fourth site  www.30anni.unponteper.it , fifth site  www.iraqicivilsociety.org , sixth  www.indifesadi.org , seventh  www.liberedirompere.unponteper.it , eighth www. iraqwithoutwater.org ; ninth  www.interventicivilidipace.org.

Through a  YouTube channel, a Facebook profile  ,  Twitter ,  Instagram ,  Linkedin .

For information on data processing, in addition to what is published on this page, you can contact the following email address:  privacy[at]unponteper.it .

Data collection and processing methods

UPP adopts appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data. Processing is carried out using computer and/or telematic tools, with organizational methods and logic strictly related to the purposes indicated.

In addition to the Owner, in some cases, other parties involved in the organization of may have access to the Data:

  • the Website (UPP staff, system administrators) or external parties (such as third-party technical service providers, hosting providers, IT companies, communications agencies) also appointed, if necessary, as Data Processors by the Owner.

The updated list of data controllers is available upon simple request, at the email address of the Data Controller  privacy[at]unponteper.it .

We use a number of third parties to provide services to us to run our business or to help us process information on our behalf (data processors). These include the following:

  • Telephone providers (TIM, Fastweb).
  • Email provider (Microsoft 365, Seeweb).
  • Mailing list provider (NPSolutions; GNU Mailman).
  • IT service providers (continuous consultancy with professional, Aruba).
  • Web Developers (continuous consulting with professionals).
  • Hosting provider (Seeweb).
  • Providers of services for personnel management and fulfillment of social security contributions (mandatory).
  • Providers of services for the safety and health of employed and volunteer staff (mandatory).
  • Providers of insurance protection services for our employed and volunteer staff and activities (recommended).
  • Mailing service provider (SMILE, TNT, Poste Italiane).
  • Online service provider of Banca Etica with Nexi Payments.

Information will be shared with these service providers only where and to the extent necessary to allow us to operate our business.

What personal data we collect and why we collect it

The data of the interested users are processed in order to respond to the requests expressly made by them. We also use such data to send informative communications relating to the activities and initiatives of UPP.

All data collection and subsequent processing activities are aimed at pursuing the following purposes:

  • General information request

Through our contact email  info[at]unponteper.it  we collect requests for generic information in order to provide the service requested by the user (request for information).

The legal basis for the processing of personal data for these purposes is art. 6.1.b) of the GDPR as the processing is necessary for the provision of services or to respond to requests from the interested party.

This data is retained for a period of 10 years.

  • Newsletter subscription

By subscribing to our newsletter, through the site mentioned above, we collect the email address of the user who wishes to subscribe.

The legal basis for the processing is the explicit and active consent, article 6.1.a) of the GDPR, which the user gives by requesting his/her subscription to the newsletter service.

We use a third-party service to send our electronic newsletter, managed through the GIVE Newsletter software owned by NP Solutions (Italy), therefore compliant with the GDPR requirements. You can access their privacy policy  by clicking here .

The information you send us for subscription to our newsletter will be stored and processed in GIVE owned by NP Solutions (Italy). For more information on the security measures regarding the processing of data by GIVE,  click here .

This data is retained for a period of 10 years, even in the event of inactivity of the interested party.

  • Sending and receiving CVs

Always for the legal basis mentioned above, art. 6.1.b) GDPR 679/2016, where the processing is necessary for the provision of services, the collection of personal data occurs and is regulated when the user sends us his/her curriculum vitae to apply for one or more open positions and communicated on the specific page of the site:
www.unponteper.it/vacancy
or to apply spontaneously, both for open positions and for the voluntary activities of the association via the email:
vacancy[at]unponteper.it

Consent to the processing relating to the requested service (application and selection) is expressed explicitly and actively by sending the CV. However, it is requested to explicitly state in the documents sent (CV and Letter of Motivation/Presentation) the wording:

“ I authorize the processing, as described in the Information on the Processing and Protection of Data of UPP especially for the part “Sending and Receiving Curricula Vitae” of 25 May 2018, of all the data reported above or otherwise verifiable pursuant to GDPR 679/2016. Sincerely ”

accompanying it with a signature.

The data thus acquired will be used only for the purposes of selecting candidates and possibly for the contractual part in the event of success in the selection.
The persons responsible for receiving this data are:

  • HR Manager UPP
  • General Directorate UPP

 The data controllers for this data are:

  • HR Manager UPP
  • General Directorate UPP
  • Head of Administration Department UPP (only in the case of positions in this UPP Department or at the time of the contract offer)
  • The supervisors for the open position who need to be involved in the selection process.

The persons responsible for maintaining this data are:

  • HR Manager UPP.
  • UPP General Management (only where there is effective inclusion in the staff, whether working or voluntary, of the association).
  • Head of the UPP Administration Department (only where there is effective inclusion in the staff, whether working or
       voluntary, of the association).

No further access to the data thus collected is permitted at any time, from acquisition to the end of the relationship.

Anyone applying for any position (salaried or voluntary) at UPP accepts that the data expressed in the CV, in the Motivation/Presentation Letter or those of the forms of expression of interest in voluntary activity may be used to verify the statements contained therein (references, general and specific checks) in compliance with the policies of this organization for the safety of the staff, members and beneficiaries of UPP.
In the absence of this, the application cannot be accepted.

The data is stored for an average period of 10 years unless a specific request for cancellation is made, unless it is necessary to maintain it for the purposes of contribution, management transparency required by law and by donors or providers of labor services, contributions, insurance protection and protection and health at work.

Any other further use of the data thus collected is excluded unless further consent is expressed for the receipt of information and connection with the associative lists that Un Ponte Per ETS maintains.
For the cancellation of the data and clarifications on its treatment write to:
privacy[at]unponteper.it .

  • Donations and Membership Fees

The personal data normally requested for donations or membership fees are personal details, contact details and payment instruments and coordinates.

The optional, explicit and voluntary sending of electronic mail to the addresses indicated on the association's website or the completion of electronic contact forms, or the sharing of personal and contact data during events and collections of this association entails the subsequent acquisition of the sender's address, necessary to respond to requests, as well as any other personal data included in the message.

Data is acquired in a secure manner (specify) only from:

  • Distance Support Program Manager.
  • Fundraising Manager.
  • Head of Communications and Fundraising Department.
  • Data acquisition manager (only in the case of direct collection during events and celebrations of
      this association).
  • Accounting clerk in the Administration Department.

The data is entered into an automated internal accounting system that processes the data for the sole purpose of accounting, donation administration and transparency of the UPP fundraising:
GIVE and COGE by NP Solutions (Italy)  here is the data protection information of the accounting service provider .

The data is processed directly only by:

  • Distance Support Program Manager and delegates specifically
  • Fundraising Manager.
  • Head of Communications and Fundraising Department.
  • Employees (2) Administration Department
  • Head of Administration Department

All other UPP staff and associates do not have direct access to the data collected for this purpose and are informed of the progress of the data only in anonymous form and by grouping.

This data is retained for a period of 10 years (in compliance with the obligations of keeping accounting records) but the interested party has the right to have a version kept that is restricted to compliance with the above-mentioned obligation and that there is no further processing of the data other than that kept for legal obligation and related obligations.

Transfers of information outside the European Economic Area

UPP has a hosting located outside the EU, in particular in the United States of America (US), for the management of the association mailing list ( GNU Mailman ).

All data transmitted via this platform is therefore transferred beyond the EU area.

On 12 July 2016, the European Commission adopted a decision on the so-called Privacy Shield, the agreement that regulates the transfer of data between the European Union and the USA.

The agreement protects the fundamental rights of individuals in the EU whose personal data is transferred to the United States, and establishes clear rules for companies that transfer data across the Atlantic.
The new regulation provides:

  • stringent data protection obligations for companies transferring data;
  • security measures regarding access to data by the United States Government;
  • specific tools for the protection of people;
  • the joint annual review of the agreement to monitor its implementation.

Redirect to external sites

UPP websites use so-called plug-ins to connect to your social media accounts.

All plug-ins on the site are marked with the logo owned by the social network (Facebook, Google, Twitter, YouTube).
When you visit a page of our sites and click on the logo (e.g. by clicking the “Like” button), the corresponding information is transmitted by the navigation software directly to the social network and, if applicable, stored by it.

For information on the purposes, type and methods of collection, processing, use and storage of personal data by the social network platform, as well as for the methods through which to exercise your rights, please consult the privacy policy adopted by the individual social network.

Browsing data

We use Google applications (Analytics and Ads) that record the navigation paths of users when visiting the pages of our sites during their normal operation. This category of data includes: IP addresses, the type of browser used, the operating system, the domain name, type of device, and the addresses of websites from which access was made, information on the pages visited by users within the site, the time of access, the duration of the visit on the single page, the analysis of the internal path and other parameters relating to the operating system and the user's IT environment.

To learn more about what information Google collects, how it uses this information, and how to control the information sent to Google, you can visit the Google Privacy Policy partners page  by clicking here .

Cookies

UPP websites do not only use profiling cookies.
For the use of cookies on the association's websites, please refer to the published information:   Information on use of the site_Cookies .

Embedded content from other websites

Articles on Un Ponte Per ETS sites may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

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