MILOSAOMILOSAOPeoples & Cultures

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Privacy Policy

This document is being updated.

PRIVACY POLICY

Information notice on the processing of personal data pursuant to Article 13 of Regulation (EU) 2016/679 (GDPR)

This notice describes how Milosao – Popoli e Culture APS (the “Association” or “we”) collects, processes and protects the personal data of users who visit our website or interact with the Association, in compliance with Regulation (EU) 2016/679 (“GDPR”) and the Italian data protection legislation (Legislative Decree 196/2003, as amended by Legislative Decree 101/2018).

1. Data Controller

The Data Controller is:

  • Milosao – Popoli e Culture APS
  • Registered office: Via Alessandro Manzoni 24, 73100 Lecce (LE), Italy
  • Tax code (Codice Fiscale): 93106270759
  • Certified e-mail (PEC): info@pec.milosao.org

The Association is not legally required to appoint a Data Protection Officer (DPO); should one be appointed, the relevant contact details will be published on this website.

2. What data we process

Depending on how you interact with us, we may process the following categories of data:

2.1 Data provided voluntarily by you

  • Contact data – name, surname, e-mail, telephone number, submitted through the contact form or by e-mail.
  • Newsletter subscription data – e-mail address and, optionally, name.
  • Membership and volunteering data – identifying and contact data and, where necessary for statutory or legal purposes, other data collected during membership or volunteer registration procedures (including offline).

2.2 Data collected automatically

  • Navigation data – IP address, browser type, operating system, pages visited and duration of the visit, collected through cookies and similar technologies (see the Cookie Policy).

The Association does not intentionally collect special categories of data (“sensitive data”) through the website. Where such data are necessary for specific activities (e.g. reception and integration projects for migrants), they are processed only on the basis of explicit consent or another appropriate legal basis.

3. Purposes and legal bases of processing

Your data are processed for the following purposes, on the corresponding legal bases under Article 6 GDPR:

  • Responding to requests (contact form / e-mail) – basis: legitimate interest or pre-contractual measures, Art. 6(1)(b)/(f).
  • Sending the newsletter and communications – basis: your consent, Art. 6(1)(a).
  • Managing membership and volunteering – basis: performance of the associative relationship and legal obligations, Art. 6(1)(b)/(c).
  • Compliance with legal, accounting and tax obligations – basis: legal obligation, Art. 6(1)(c).
  • Statistics and website improvement – basis: consent for non-technical cookies, Art. 6(1)(a).

4. Methods of processing

Data are processed by electronic and, where necessary, paper means, in accordance with the principles of lawfulness, fairness, transparency, minimisation and purpose limitation. Appropriate technical and organisational measures are applied to prevent loss, unauthorised access, alteration or unlawful disclosure of data.

5. Disclosure and categories of recipients

Data may be disclosed, to the extent necessary for the above purposes, to:

  • authorised collaborators, volunteers and members of the Association;
  • technical service providers (hosting, e-mail, newsletter platform, statistics services), appointed as Data Processors under Article 28 GDPR;
  • professional advisors (accountants, lawyers) and public authorities, where required by law.

Data are not disseminated and are not subject to sale to third parties.

6. Transfers outside the European Union

Some service providers (e.g. Google, social media platforms, YouTube) may process data outside the European Economic Area. In such cases, the transfer takes place on the basis of appropriate safeguards under Articles 44–49 GDPR, such as the Standard Contractual Clauses approved by the European Commission or adequacy decisions.

7. Retention period

  • Contact data / requests: up to 24 months from the last request.
  • Newsletter data: until you withdraw consent (unsubscribe).
  • Membership / volunteering data: for the duration of the relationship and for the periods required by law (typically 10 years for tax/civil obligations).
  • Navigation / cookie data: as indicated in the Cookie Policy.

8. Your rights

In accordance with Articles 15–22 GDPR, you have the right to request:

  • access to your personal data;
  • rectification or updating of inaccurate data;
  • erasure of data (“right to be forgotten”);
  • restriction of processing;
  • objection to processing;
  • data portability;
  • withdrawal of consent at any time, without affecting the lawfulness of processing carried out before withdrawal.

To exercise these rights, you may write to us at: info@pec.milosao.org. You also have the right to lodge a complaint with the Italian Data Protection Authority (“Garante per la protezione dei dati personali” – www.gpdp.it).

9. Nature of data provision

The provision of data is voluntary; however, failure to provide the necessary data may make it impossible to respond to your requests, send the newsletter or manage membership/volunteering.

10. Changes to this notice

The Association reserves the right to modify or update this notice to reflect legal or organisational changes. The version in force is the one published on this website, bearing the update date shown at the top.