Privacy Policy

Data Protection Policy
Responsible party: Federazione Nazionale Insegnanti Centro di iniziativa per l'Europa (Acronym FENICE) Fiscal code 94051250630.
Last updated 25.12.2018

1. Data protection principles
   FENICE is committed to processing data in accordance with its responsibilities under the GDPR. Article 5 of the GDPR requires that personal data shall be:

   1. processed lawfully, fairly and in a transparent manner in relation to individuals;

   2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;

   3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

   4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;

   5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and

   6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”

2. General provisions

   1. This policy applies to all personal data processed by FENICE.
   2. The Responsible Person shall take responsibility for FENICE’s ongoing compliance with this policy.
   3. This policy shall be reviewed at least annually.

3. Lawful, fair and transparent processing

   1. To ensure its processing of data is lawful, fair and transparent, FENICE shall maintain a Register of Systems.
   2. The Register of Systems shall be reviewed at least annually.
   3. Individuals have the right to access their personal data and any such requests made to FENICE shall be dealt with in a timely manner.

4. Lawful purposes

   1. All data processed by FENICE must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
   2. FENICE shall note the appropriate lawful basis in the Register of Systems.
   3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data. 
   4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in FENICE’s systems.

5. Data minimisation

   1. FENICE shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
   2. The contact form asks for name and email.

6. Accuracy

   1. FENICE shall take reasonable steps to ensure personal data is accurate.
   2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

7. Archiving / removal

   1. To ensure that personal data is kept for no longer than necessary, FENICE shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
   2. The archiving policy shall consider what data should/must be retained, for how long, and why.

8. Security

   1. FENICE shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
   2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
   3. When personal data is deleted this should be done safely such that the data is irrecoverable.
   4. Appropriate back-up and disaster recovery solutions shall be in place.

9. Breach
   In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, FENICE shall promptly assess the risk to people’s rights and freedoms.

Third-party services

Some third-party services help us to manage the website. We may share some information about our visitors with them, as part of their service. They have been carefully selected because we believe they behave correctly with regard to privacy:

1. YouTube: web platform that allows the sharing and display on the network of videos owned by Google Inc.;
2. Google Maps: service accessible from the relative website provided by Google Inc. that allows the search and display of maps;
3. Google Plus: a free social network created by Google Inc.;
4. Facebook: a social network service owned and managed by the company Facebook Inc.;
5. Twitter: social networking and microblogging service, created by the Obvious Corporation of San Francisco;
6. LinkedIn SlideShare: Web 2.0 service that hosts presentations created by Linkedin.

reCAPTCHA

We use the reCAPTCHA service provided by Google Inc. (Google) to protect your submissions via internet submission forms on this site. This plugin checks if you are a person in order to prevent certain website functions from being (ab)used by spam bots (particularly comments). This plugin query includes the sending of the IP address and possibly other data required by Google for the Google reCAPTCHA service. For this purpose your input will be communicated to and used by Google. However, your IP address is previously truncated by Google within member states of the European Union or in other states which are party to the agreement on the European Economic Area and is, as such, anonymized. Only in exceptional cases is a full IP address transmitted to a Google server in the United States and truncated there. On behalf of the operator of this website, Google will use this information to evaluate your use of this service. The IP address provided by reCaptcha from your browser shall not be merged with any other data from Google.
This data collection is subject to the data protection regulations of Google (Google Inc.). For more information about Google's privacy policy, please visit: https://policies.google.com/privacy?hl=en
By using the reCAPTCHA service, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Cookie Policy

With this cookie policy, we wish to inform you about the use of cookies or similar storage technologies (hereinafter “cookies”) on this website.

What are Cookies?

Cookies are small text files that are stored by your browser on your device to save certain information or image files, such as pixels. The next time you visit our website on the same device, the information saved in the cookies will subsequently be transmitted either to our website (“First Party Cookie”) or to another website to which the cookie belongs (“Third Party Cookie”).

Through the information saved and returned, the respective website recognizes that you have already accessed and visited it with the browser you use on that device. We use this information to be able to design and display the website in an optimum way in line with your preferences.

In that respect, only the cookie itself is identified on your device. Beyond this extent, your personal data will only be saved upon your express consent or if it is strictly necessary to be able to use the service offered to and accessed by you accordingly.

Consent to the use of Cookies

Cookies that are not absolutely necessary to make the services available on our website are only used when we receive your consent. As soon as you actively use our website by continuing to use our website after the cookie banner has been displayed, you consent to the use of cookies.

You can, of course, customize your cookie settings at any time, for example by activating or deactivating individual cookie categories.

You can find out how to deactivate or delete cookies in general (i.e. including the essential cookies) in your browser can be found under the last point of this Cookie Policy.

Cookie Categories

We divide the cookies we use into the following categories based on their purpose and function:

• Strictly Necessary Cookies;

• Functional Cookies;

• Performance Cookies; as well as

• Marketing / Third Party / Consent Based Cookies

Strictly Necessary Cookies

Strictly necessary cookies guarantee functions without which you cannot use this web page and service as intended. These cookies are used exclusively by this website and are therefore first party cookies. This means that all information stored in the cookies will be returned to this website.

Strictly necessary cookies serve, for example, to ensure that you as a registered user always remain logged in when accessing various subpages of our website and thus do not have to re-enter your login data every time you access a new page.

The following strictly necessary cookies are used on our website:

The use of strictly necessary cookies on this website is possible without your consent. For this reason, strictly necessary cookies cannot be activated or deactivated individually. However, you can deactivate cookies in your browser at any time. This function is only available for cookies that require your consent, i.e. the functional, performance and marketing / third party / consent based cookies. However, you can deactivate cookies in your browser at any time (see below ”Deactivation or deletion of all cookies”).

The legal basis for the use of these first party cookies is the legitimate interest (i.e. interest in the analysis, optimization and economic operation of the website and services) within the meaning of Art. 6 (1) (f) GDPR).

Functional Cookies

Functionality cookies enable our website to store information already provided (such as registered name or language selection) and to offer you improved and more personalized functions based on this information. These cookies collect and store only anonymous information so that they cannot track your movements on other websites.

The following functional cookies are used on this website:

You can opt out of using Functional Cookies at any time by adjusting your Cookie Settings accordingly.

The legal basis for the use of these functional cookies is the legitimate interest (i.e. interest in the analysis, optimization and economic operation of the website and services) within the meaning of Art. 6 (1) (f) GDPR).

Performance Cookies

Performance cookies collect information about how our websites are used in order to improve their attractiveness, content and functionality. These cookies help us, for example, to determine whether and which subpages of our website are visited and in which content users are particularly interested. In particular, we record the number of visits to a page, the number of subpages accessed, the time spent on our website, the order of the pages visited, which search terms led you to us, the country, region and, if applicable, the city from which access has been made, and the proportion of mobile devices accessing our websites. The IP address of your computer, that is transmitted for technical reasons, is also automatically anonymized and does not allow us to draw any conclusions about the individual user.

The site visitor also has the right to object to the processing of personal data that is used for statistical purposes in accordance with Art. 89 para. 1 GDPR for reasons that arise from the particular situation of the user in question. In order to exercise the aforementioned and other data subject rights, the affected party may, at any time, contact the site owner via the contact address provided in the imprint or privacy policy.

The following Performance cookies are used on our website:

You can opt out of using Performance Cookies at any time by adjusting your Cookie Settings accordingly.

Marketing / Third Party / Consent Based Cookies

Marketing / Third Party / Consent Based Cookies originate from external advertising companies (among others) and are used to gather information about the websites visited by the user, in order to e.g. create targeted advertising for the user.

The following Marketing / Third Party / Consent Based Cookies are used on our website:

You can withdraw your consent to the use of Marketing / Third Party / Consent Based Cookies individually and at any time with effect for the future by adjusting your Cookie Settings accordingly.

Due to the various purposes described above, the legal basis for the processing of personal data using cookies is set out in Article 6 (1) (f) GDPR. Where the site visitor has given us consent to the use of cookies on the basis of a notice(Cookie banner) displayed on our websites (“cookies banner”), the legality of the data usage is additionally governed by Art. 6 (1) (1) (a) GDPR.

Deactivation or deletion of all cookies

You can set your web browser in such a way that cookies are generally prevented from being saved to your device and/or that you are asked each time whether you are in agreement with cookies being enabled. You can also at any time delete cookies that have been enabled again. You can find out how all this works in detail via your browser’s help function.

Please note that generally deactivating cookies may lead to functional restrictions on our website.