Policy privacy for sponsorships and donations
PRIVACY POLICY AND DECLARATION OF CONSENT TO PERSONAL DATA PROCESSING UNDER ART. 13 OF REGULATION (EU) NO. 2016/679 OF 27 APRIL 2016
This policy is issued under Art. 13 of Regulation (EU) no. 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and in compliance with the laws on personal data processing and on the free movement of such data.
Data Controller
Politecnico di Milano – Director General, delegated by the pro-tempore Rector – e-mail:
Internal Processor
Ms. Gloria Paoluzzi, Department Manager of the Architecture and Urban Studies Department, tel. +39 0223995550, email: gloria.paoluzzi@polimi.it
The personal data will be processed by other authorised parties who will receive instructions for that purpose under current legislation.
Data Protection Officer and contact details
Mr. Vincenzo Del Core – privacy@polimi.it Ph. +390223999378.
Processing purposes and legal basis, categories of data and storage period
For the purposes of applying the relevant European and national legislation (Reg. 2016/679, hereafter, Regulation), we inform you that your personal data will be used for the following purposes:
|
Personal data processing purposes |
Legal basis of the processing |
Personal data categories subject to processing |
|
Purpose 1: activity of promotion of awareness-raising events and campaigns for the Architecture and Urban Studies Department of Politecnico di Milano to raise funds for teaching, research and scientific promotion activities and for the so-called third mission, sending communications and private informative material to supporters and donors in paper and digital format. |
Public interest in accordance with Art. 6 letter e) of the GDPR; Art. 7 of Italian Law 168 of 1989, “autonomous forms of funding, such as voluntary contributions, business income, returns, profits and assignments of property, acts of charity and fees from contracts and conventions.” |
|
|
Purpose 2: management of the operations relating and consequent to donations |
Performance of a contract, to which the data subject is a party or steps prior to entering into a contract taken at the request of the data subject, under Art. 6, para. 1, letter b) of the EU Regulation. |
|
It is noted that, during the administrative procedures linked to donations, the data subject will always be able to express, by specific authorisation, free consent to the publication of his/her name and surname alongside the donation made. Anonymity will always be available as a preferred option.
During special events organised by Politecnico di Milano to promote Fundraising, photos and audio-video recordings may be taken of the participants, subject to providing an adequate privacy policy prepared in accordance with Art.13 of the EU Regulation and a declaration on the use of images and/or audio/video recordings.
Images and/or audio/video recordings collected in fulfilling Purpose 1 may be disseminated pursuant to Italian Law no. 150/2000, “Rules on information and communication activities of public administrations”, on institutional websites as well as through social media channels (by way of example but without limitation, Facebook, Twitter, YouTube).
Lastly, we note that the communication and/or dissemination of images and/or audio/video recordings entails the granting of a non-exclusive licence, of unlimited duration and for the whole world, which is transferable to third parties.
This licence includes the rights set out in Articles 12 et seq. of Italian Law no. 633/1941 including, by way of example but not exhaustively, the right of publication, the right of reproduction in any way or form, the right of transcription, editing, adaptation, processing and reduction; the right to communicate and distribute to the public, including the rights of projection, transmission and broadcasting (purely by way of example via IPTV, mobile terminals, VOIP, digital channels, etc.), including in summary and/or reduced form, using any technical means, the right to keep a copy of the images, including in electronic format and on any technological device that is known or may be invented in future, for the purposes and within the limits defined above. The use of the images does not give any entitlement to payment.
In any case, this excludes any use of the picture/portrayal that may cause prejudice to the honour, reputation or dignity of the person portrayed, photographed or recorded.
Nature of Data
The provision of data is optional. Any refusal to provide the data makes it impossible to carry out the performances.
Data processing methods
Processing for the aforementioned purpose may be carried out both on paper and digitally, manually and/or with electronic or automated tools, including in-house or external databases. The data is stored in paper archives for the processing duration and in digital format indefinitely under the obligations of transparency and proper functioning of the public administration.
In particular, the personal data are collected by the following methods:
a_Data provided directly by the data subject: personal data are collected directly from the data subject when he/she requests information on the activities, during the recording of an event, to make a donation, by registering to the social media channels of the Architecture and Urban Studies Department of Politecnico di Milano or in another manner that involves the direct communication of personal information. This type of information can also be collected if it is voluntarily made public by the data subject when interacting with the University departments.
b_Data provided indirectly by the data subject: personal data of the data subject may also be shared with the Architecture and Urban Studies Department of Politecnico di Milano by third parties, e.g., organisers of independent events or fundraising websites or organisations and associations affiliated with the University. The Architecture and Urban Studies Department of Politecnico di Milano may receive information on the data subject from foundations, associations and institutions connected with the University’s initiatives and missions. These independent third parties will provide the data only if the data subject has indicated the desire to support Politecnico di Milano and with his/her consent. Please therefore refer to the privacy policy provided by the third parties involved.
c_Data from other public sources: apart from information provided directly or indirectly, personal data may also be collected from publicly available sources, e.g. from reliable daily newspapers, company websites or social networks.
Only duly authorised persons are entitled to access the data acquired.
Categories of Recipients
The personal data collected may be communicated to:
- natural and/or legal persons, public and/or private, to associations and foundations connected with Politecnico di Milano which share the purposes of the University, when the communication is necessary or functional to the establishment and management of relationships to develop a fundraising link with donors and benefactors;
- Politecnico di Milano Alumni Association;
- legal advisors to obtain legal consultancy;
- persons to whom the right of access to those data is granted by virtue of regulatory measures;
- persons authorised by Politenico di Milano in the capacity of Controller, with reference to processing concerning staff management (Designated Persons, Processing Officers and System Administrators);
- Judicial authority, in order to exercise or defend a legal claim, even by a third party.
In particular, your personal data may also be communicated to other public administrations, even anonymously, if they need to process the data for any procedures under their own institutional remit, as well as to all public parties to which, in the presence of the respective conditions, the communication is required mandatorily by provisions of European law, standards or regulations, as well as insurance bodies in relation to claims for any accidents that may occur.
Data Storage Period
The data collected will be stored for the entire time necessary to allow for the management of the promotion services, but they will not be stored for longer than is necessary for processing. Legal obligations and tax and accounting rules will be taken into consideration. In addition, the Architecture and Urban Studies Department of Politecnico di Milano will retain the personal data according to storage timescales as part of its broader legal and regulatory obligations, even if that information is no longer necessary for purposes of promotion, development or fundraising.
Transfer to non-EU countries
The personal data will not be transferred in any way to countries outside the EU.
For activities or special events that may require the transfer of personal data to non-EU countries or to an international organisation, appropriate authorisation will be requested from the data subject.
Rights of Data Subjects
As the data subject, you may request from the Controller:
- confirmation of the existence or your personal data;
- access to your personal data and related information; correction of inaccurate data or supplementation of incomplete data; deletion of your personal data (under one of the conditions indicated in Art. 17, paragraph 1 of the Regulation and in respect of the exceptions envisaged by paragraph 3 of that Article); the restriction of processing of your personal data (in the presence of one of the circumstances indicated in Art. 18, paragraph 1 of the Regulation), the transformation into anonymous form or block on data processed in violation of the law, including data whose storage is no longer necessary for the purposes for which it was collected or processed.
As the data subject, you also have the right to object in full or in part:
- on legitimate grounds, to the processing of their personal data, even if it is relevant for the
purpose for which the data was collected;
- to the processing of their personal data, for the purposes of sending promotional material for Politecnico di Milano training initiatives and cultural events.
These rights can be exercised by contacting privacy@polimi.it.
If you believe that your rights have been violated by the data controller or a third party, you can lodge a complaint with the Data Protection Authority, or another relevant supervisory authority under the Regulation.
