Latest update: 25/05/2018
PRIVACY POLICY ACCORDING TO ART. 13 OF THE GDPR
This privacy policy tells you how Fondazione Housing Sociale obtains, defines and uses your personal information and what your rights are. Fondazione Housing Sociale is the Data controller, in accordance with art. 4 of General Data Protection Regulation about the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereafter “GDPR”).
For further informations, click under:
- Definitions
- Who are we and how can you contact us?
- Data processing collected using the site
- Handling of data useful for navigation purposes
- Use of cookie
- Notice concerning minors of 16 years old
- Exercise of the rights of the data subject
- Right to propose a complaint
- Change and updates
1. Definitions
“Personal data” (ex art. 4 no. 1 of GDPR) means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” (ex art. 4 no. 2 of GDPR) means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
2. Who are we and how can you contact us?
Business Name: Fondazione Housing Sociale
Headquarter address: via Bernardino Zenale, n. 8, 20123 Milano (MI)
Phone: +(39)-02-36683000
Email: privacy@fhs.it
3. Data processing collected using the site
Personal Data collected
Fondazione Housing Sociale collects and process personal data provided by data subjects sush as identification data (i.e. name, surname, e-mail address)
Processing Purposes
Fondazione Housing Sociale processes personal data collected using the site for:
- Sending by e-mail information and promotional material in the form of newsletters.
- Manage existing or future relationships, in other words answer requests or questions submitted and solve problems related to our services.
The following table specifies for each above identified purpose, lawfulness of processing, categories of personal data, categories of data subjects and period for which the personal data will be stored:
| Purposes of processing | Lawfulness of processing | Type of personal data | Storage Period | Categories of recipient |
|---|---|---|---|---|
| Purpose 1 | Consent | Identification data | 24 months | * |
| Purpose 2 | Implicit Consent by sending an email or calling C.32 Clear affirmative act | Identification data | Until request accomplishment | * |
TABLE 1
*Categories of recipient
In relation to the mentioned purposes, personal data could be communicated to the following companies and/or persons, located in UE countries, which provide services, also external, on behalf of the Data Controller. Among which**, in order to clarify, we just give an example, not as an exhaustive list:
- Societies providing IT services;
- Communication agencies;
- Consulting societies in marketing area;
- Supervisory bodies.
(**) (**) Recipients / Processors list with additional data useful for the purpose of identification, is available at the Data Controller.
Personal data transfer to a country extra-UE
Data Controller does not transfer personal data out of UE countries.
Period for which the personal data will be stored
Please refer to Table 1 column 4.
Data subject rights
With reference to the abovementioned data processing, the data subject can exercise the following rights provided by GDPR:
- Right of access by the data subject [art. 15 of the GDPR];
- Right to rectification [art. 16 of the GDPR];
- Right to erasure (‘right to be forgotten’) [art. 17 of the GDPR];
- Right to restriction of processing, including in the case of unlawful processing or disputing the accuracy of personal data by the data subject [art. 18 of the GDPR];
- Right to data portability [art. 20 of the GDPR];
- Right to object [art. 21 of the GDPR];
- Right not to be subject to a decision based solely on automated processing [art. 22 of the GDPR].
The aforementioned rights may be exercised according to the provisions of the Regulations by sending an email to privacy@fhs.it.
Fondazione Housing Sociale, in compliance with the art. 19 of the EU Regulation, proceeds to inform recipients to whom the personal data have been communicated, any corrections, cancellations or limitations of the treatment requested, where this is possible.
If the purpose of processing pursued by Fondazione Housing Sociale has as its lawfulness of processing the consent, the interested party has the right to withdraw, at any time, the consent by sending an email to privacy@fhs.it. Pursuant to art. 7 of the EU Regulation, the withdrawal of consent does not affect the lawfulness of the treatment based on consent made prior to the revocation.
If data subject considers that his rights have been compromised, he has the right to lodge a complaint with a supervisory authority.
For further information about rights and how exercise them, please refer to the following appropriate section.
The Company does not make use of any automated decision-making process.
Modalities of the processing
Personal data will be processed in paper, digital and telematic form and inserted in the applicable data banks (candidates and social housing inhabitants, ecc.), which can be consulted and processed by the operators and processors designated by the Data Controller who will be able to carry out the consultation, use, handling, comparison and any other appropriate operation, direct or automatic, respecting the legal requirements necessary to guarantee the confidentiality and the security of the data, as well as their accuracy, updating, and their relevancy to the declared aims.
4. Handling of data useful for navigation purposes
The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.
This is information that is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified.
Among the information that can be collected we have the IP addresses, the type of browser or the operating system used, the addresses in notation URI (uniform resource identifier), the domain name and the addresses of the websites from which the access or exit (referring / exit pages), the time at which the request was made to the server, the method used and information on the response obtained, further information on the user’s navigation on the site (see also the related section to cookies) and other parameters relating to the operating system and the user’s computer environment.
These same data could also be used to identify and ascertain responsibilities in case of any computer crimes against the site.
5. Use of cookie
The following information is made to the user in implementation of the provision of the Supervisory Authority for the protection of personal data of May 8, 2014 “Identification of simplified procedures for the disclosure and acquisition of consent for the use of cookies”.
WHAT ARE COOKIES?
Cookies are small text strings that a website can send, while browsing, to your device (be it a PC, a notebook, a smartphone, a tablet, usually stored directly on the browser used for navigation) . The same website that transmitted them, then it can read and record cookies that are on the same device to obtain information of various kinds. Which? For each type of cookie there is a well-defined role.
HOW MANY TYPES OF COOKIES EXIST?
There are two basic macro-categories, with different characteristics: technical cookies and profiling cookies.
Technical cookies are generally necessary for the proper functioning of the website and to allow navigation; without them you may not be able to view the pages correctly or use some services. For example, a technical cookie is essential to keep the user connected throughout the visit to a website, or to store the language, display, and so on. Technical cookies can be further distinguished in:
- navigation cookies, which guarantee the normal navigation and use of the website (allowing, for example, to make a purchase or authenticate to access restricted areas);
- analytics cookies, similar to technical cookies only when used directly by the site operator to collect information, in aggregate form, on the number of users and how they visit the site.
- functionality cookies, which allow the user to navigate according to a series of selected criteria (for example, the language, the products selected for purchase) in order to improve the service provided.
Profiling cookies are more sophisticated! These cookies have the task of profiling the user and are used in order to send advertising messages in line with the preferences expressed by the user during his navigation.
Cookies can still be classified as:
- session cookies, which are deleted immediately when the browser is closed;
- persistent cookies, which – unlike session cookies – remain in the browser for a certain period of time. They are used, for example, to recognize the device that connects to the site facilitating authentication operations for the user.
- first-party cookies (first-part cookies) or cookies generated and managed directly by the manager of the website on which the user is browsing.
- third-party cookies (third-part cookies), which are generated and managed by parties other than the operator of the website on which the user is browsing (in force, as a rule, a contract between the owner of the website and the third part).
WHICH COOKIES FONDAZIONE HOUSING SOCIALE USES?
We use technical and analytics cookies, designed to ensure the proper functioning of our site, without which your browsing experience would not be pleasant. To improve our site and understand which parts or elements are most appreciated by users, as an anonymous and aggregate analysis tool, we use third-party cookies, ie Google Analytics. These cookies are not our property, for more information, therefore, you can consult the information provided by Google at the following address: http://www.google.it/policies/privacy/partners/.
We, also, use cookies related to Vimeo for studying the progress of the presence of users on the website.
By expressing your consent or continuing to browse or accessing other elements on the site, you consent to the installation of these cookies. You can always proceed with their cancellation as indicated in the instructions below.
The following table shows specifically the cookies used.
| NOME | TIPO | DURATA | SCOPO | OPT-OUT |
|---|---|---|---|---|
| Google Analytics | Third party Analytics cookie | session | 1 group of cookies belonging google.com are used to study the progress of the presence of users on the website. It does not perform profiling but manages aggregate data in which your IP could be managed | Click to deactivate |
| Vimeo | Third party Analytics cookie | 1 group of cookies belonging vimeo.com are used to study the progress of the presence of users on the website. It does not perform profiling but manages aggregate data in which your IP could be managed | Click to deactivate | |
| cookie_notice_accepted | Technical First party cookie | 24 hours | It is used to store acceptance of cookies when accessing the site | Click to deactivate |
In the following table, we inform more in details about third party cookies used.
* This website uses tools that reduce the identifying power of cookies, such as anonymisation of users’ IP addresses before processing or storage by Google inc.
Finally, below are links to the most popular browsers, where there are information about how to disable the storage or delete cookies already stored on the browser:
6. Notice concerning minors of 16 years old
Children under 16 can not provide personal data. Fondazione Housing Sociale will not be in any way responsible for any collection of personal data, as well as false statements, provided by the minor, and in any case, if you notice its use, Fondazione Housing Sociale will facilitate the right of access and cancellation forwarded by the legal guardian or by those who exercise parental authority.
7. Exercise of the rights of the data subject
The data subject, in relation to the personal data subject of this privacy policy, shall be entitled to exercise the rights provided for by the EU Regulation below:
- Right of access by the data subject [art. 15 of the GDPR]: the data subject has the right to obtain from the Data Controller confirmation that his personal data is being processed and, in this case, access to the information expressly provided for in the aforementioned article, including the purpose of the processing, the categories of data and recipients, the retention period, the existence of the right of cancellation, correction or limitation, the right to propose a complaint, all the available information on the origin of the data, the exemplary and non-exhaustive any existence of an automated decision-making process pursuant to art. 22 of the Regulations, as well as a copy of their personal data.
- Right to rectification [art. 16 of the GDPR]: the data subject has the right to obtain from the data controller the correction and / or integration of the incorrect personal data concerning him, without unjustified delay;
- Right to erasure (‘right to be forgotten’) [art. 17 of the GDPR]: the data subject has the right to cancel his / her personal data without unjustified delay, if one of the reasons expressly provided by the aforementioned article exists, including as an example and not exhaustive the need for treatment with respect to the purpose, revocation of the consent on which the treatment is based, opposition to the treatment in case it is based on non-prevailing legitimate interest, unlawful data processing, deletion due to legal obligations, data of minors treated in the absence of the conditions of applicability expected by art. 8 of the Regulations;
- Right to restriction of processing [art. 18 of the GDPR]: in the cases provided by art. 18, including the unlawful processing, the contestation of the accuracy of the data, the opposition of the interested party and the loss of the need for treatment by the data controller, the information provided by the data subject must be processed only for storage unless the consent of him and the other cases expressly provided by the aforementioned article;
- Right to data portability [art. 20 of the EU Regulation]: the data subject, in cases where the processing is based on consent and contract and is performed by automated means, he may request to receive personal data in a structured format, commonly used and readable by automatic device, and he has the right to transmit them to another Data Controller;
- Right to object [art. 21 of the GDPR]: the data subject has the right to object to the processing of his / her personal data, in the event that the processing is based on a non-prevailing legitimate interest or is carried out for direct marketing purposes;
- Right not to be subject to a decision based solely on automated processing [art. 22 of the GDPR]: the data subject has the right to be not subjected to a decision, including profiling, based solely on automated processing (for example carried out exclusively through electronic tools or computer programs).
The description given above does not replace the text of the articles cited here which are referred to and that you can read exuastly and fully in the following section “Legal references about rights of data subject”.
8. Right to propose a complaint
If the data subject considers that his/her right has beeen compromised, he/she has the right to lodge a complaint to the supervisory authority (or Data protection Supervisor), according to the methods indicated by the same authority. If you are italian you can refer to the following link:
http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524.
For more information on the rights of the data subject provided by Supervisory Authority, please refer to the following section “Legal references about rights of data subject”.
9. Change and updates
This privacy policy reports the date of its last update in the header.
Fondazione Housing Sociale can make changes, update or additions to this privacy policy also as a consesequences of any new additive legal obligations, regulations, Italian and European law.
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Legal references about rights of data subject
Article 15
Right of access by the data subject
The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
- a) the purposes of the processing;
- b) the categories of personal data concerned;
- c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
- f) the right to lodge a complaint with a supervisory authority;
- g) where the personal data are not collected from the data subject, any available information as to their source;
- h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.
The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.
Article 16
Right to rectification
The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Article 17
Right to erasure (‘right to be forgotten’)
The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
-
- a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;
- c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
- d) the personal data have been unlawfully processed;
- e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
- f) i dati personali sono stati raccolti relativamente all’offerta di servizi della società dell’informazione di cui all’articolo 8, paragrafo 1.
Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
- a) for exercising the right of freedom of expression and information;
- b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
- d)for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
- e) for the establishment, exercise or defence of legal claims.
Article 18
Right to restriction of processing
The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
- a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
- b) ithe processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
- c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
- d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.
Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.
Article 19
Notification obligation regarding rectification or erasure of personal data or restriction of processing
The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it.
Article 20
Right to data portability
The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
- a) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and
- b) the processing is carried out by automated means.
In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Article 21
Right to object
- The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
- Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
- Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
- At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.
- In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.
- Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
Article 22
Automated individual decision-making, including profiling
- The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
- Paragraph 1 shall not apply if the decision: a) is necessary for entering into, or performance of, a contract between the data subject and a data controller; b) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or c) is based on the data subject’s explicit consent.
- In the cases referred to in points (a) and (c) of paragraph 2, the data controller shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
- Decisions referred to in paragraph 2 shall not be based on special categories of personal data referred to in Article 9(1), unless point (a) or (g) of Article 9(2) applies and suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests are in place.
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DATA PROTECTION OFFICER
Silvia Luini
via Bernardino Zenale, 8
20123 Milano
Tel +39 02 36 68 3001
