Privacy Policy

THE INTERNATIONAL COMMITTEE FOR THE DEVELOPMENT OF THE PEOPLE - CISP, (hereinafter, also "the Organisation" or "CISP NGO") is aware of the importance of safeguarding privacy and the right of individuals to the protection of their personal data.

For this reason, we apply rules of conduct - in line with Regulation (EU) 2016/679 of 27.04.2016 and the legislation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the "Regulation") - that guarantee safe, controlled, and confidential navigation on our website.

These Regulations may undergo changes over time; therefore, we invite you to periodically consult this section of our site. We invite you to read the rules that our association has set in collecting and processing personal data and in always providing a satisfactory service to the users of its site.

Pursuant to art. 13 et seq. of the Regulations, the information is provided for the interested parties who consult and interact exclusively with the Site www.cisp.ngo and not for other websites that may be reached by the user via links.

BASIC PRINCIPLES OF THE CISP PRIVACY POLICY 

CISP NGO processes personal data (Article 4, paragraph 1, Regulation (EU) 2016/679: 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’) exclusively for the purposes and in the manner illustrated in the information to be provided, which is presented to the user each time he/she accesses a section of the site in which the direct or indirect submission of personal data is required.

• se data that have been willingly provided by the user;
• use technical cookies to facilitate site navigation and analytical cookies for statistical purposes;
• use profiling cookies only if the user has given consent to such use;
• transmit the data to third parties (data controllers - art. 4, paragraph 8 of the Regulation (EU) 2016/679: ‘a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller’) exclusively for purposes instrumental to what has been expressly requested and carefully selected by us;
  disclosing the data to third parties for activities related to what is of interest or where required by law, regulation or Community legislation;
• only after explicit consent (art. 4, paragraph 11, GDPR: ‘any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her’), disclose the data to third parties for their own processing;
  meet requests for access to personal data, rectification or cancellation of the same, for the exercise of the right to be forgotten, to restrict processing or the right to object to processing of personal data;
• to ensure the execution of the right to data portability as well as to oppose the processing of data for the purpose of information communications on our projects and requests for financial contributions in support of our institutional activities;
• ensure the correct and lawful processing of your data, safeguarding your confidentiality, and apply appropriate security measures to protect the confidentiality, integrity, and availability of the data.

INFORMATION TO BE PROVIDED PURSUANT TO ART. 13 OF THE REGULATION AND CRITERIA USED FOR THE DETERMINATION OF DATA RETENTION PERIODS

The data that may be required are used to meet the requests expressly made by the user (typically the forwarding/submission of news, at the time when this service will be restored; as of today, registration only allows greater use of the site).

The forms to be filled in - either online or to be downloaded - may include both data that are strictly necessary to adhere to what is of interest and whose failure to be indicated does not allow the request to be carried out, and data of optional conferment. Therefore, the user is free to provide any personal data reported in the request forms or however indicated in contacts with the Organisation to request information or for the other purposes listed above. In these cases of compulsory provision of data, their absence may make it impossible to obtain what has been requested.

Personal data will be processed mainly by electronic procedures and with the aid of analytical and statistical tools by CISP ONG Onlus, - DATA CONTROLLER - with headquarters at Via Germanico 198, 00192 Rome (RM). For the purposes mentioned above, the data will be kept until the data subject revokes his/her consent or exercises his/her right to object.

Pursuant to Articles 15-22 of the REGULATION, by writing to the data controller at the relevant postal address or at the e-mail address privacy@cisp-ngo.org , you may exercise your rights of access, consultation, rectification, erasure and oblivion, limitation of the processing of your data and - if applicable - obtain the transmission of your data to another data controller (data portability), as well as object to their processing for legitimate reasons or revoke your consent.

Please also note that the person concerned has the right to lodge a complaint with the supervisory authority to assert his/her rights. By writing to the postal address indicated above or by sending an e-mail to privacy@cisp-ngo.org, the data subject may request a complete and updated list of the data processors.

RIGHTS OF DATA SUBJECTS WITH REGARD TO THEIR DATA

You may exercise at any time, at the e-mail address privacy@cisp-ngo.org (alternatively, by writing to CISP NGO, - Via Germanico 198, 00192 Rome) the rights ex-art.15-22, REGULATION below:

Right of access (Article 15, REGULATION). 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:

• the purposes of the processing;
• the categories of personal data concerned;
• 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;
• where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
• 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;
• the right to lodge a complaint with a supervisory authority;
• where the personal data are not collected from the data subject, any available information as to their source;
• 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. (e.g., if the person is associated with a profile of donation habits by cross-referencing donation amount with frequency and campaign).

Right of rectification (Article 16, REGULATION)

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. Considering 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.

Right to erasure (‘right to be forgotten’) (Article 17, REGULATION)

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:

• the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

• 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;

• 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);

• the personal data have been unlawfully processed;

• 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;

• the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).

Right to restriction of processing (Article 18, REGULATION)

The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

• 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;

• the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;

• 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;

• 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

Notification obligation regarding rectification or erasure of personal data or restriction of processing (Article 19, REGULATION)

The data subject shall have the right to request that the rectification or erasure of personal data or restriction of processing be communicated by CISP ONG Onlus to other subjects to whom the data may have been disclosed. CISP ONG Onlus may not comply with the request if the means to be employed are disproportionate to the right to privacy invoked by the person.

Right to data portability (Article 20 of the Regulation)

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:

• 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
• 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.

Right to object (Article 21, REGULATION)

The data subject shall have the right to object at any time to processing of personal data concerning him or her for the purpose of pursuing the legitimate interests of CISP NGO Onlus or third parties, 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.

Automated individual decision-making, including profiling (Article 22, REGULATION)

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. In particular, the individual has the right to object to profiling to which he/she is subjected by automated processes.

Paragraph 1 shall not apply if the decision:

• is necessary for entering into, or the performance of, a contract between the data subject and a data controller;
• 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
• is based on the data subject's explicit consent.

The individual shall have the right the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the CISP decision.

CRITERIA USED TO DEFINE THE LIMIT OF DATA RETENTION

The data will be kept in our files (Article 4, paragraph 6 of the Regulation: ‘any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis’) according to criteria that vary based on the category of the data, the nature of the processing and the purpose of the processing. The criteria or the precise storage limit are described in the information to be provided pursuant to Article 13 of the Regulation when personal data are supplied.

In principle, the following evaluations of CISP NGO Onlus apply to establish the criterion of data conservation:

• all data regarding the various forms of support to the initiatives of CISP ONG Onlus are kept as long as the relationship remains active and for a number of years equal to the number of years that laws, regulations, including EU regulations, impose for administrative and accounting purposes
• all the data used for marketing activities with profiling, whose processing is supported by a positive action of the person to such processing, explicitly declaring that he/she wishes to do so, are kept as long as the profile of the person concerned is in line with the personalised communications created through the crossing of the information at our disposal and, therefore, as long as CISP ONG Onlus continues its mission with projects, initiatives, actions and activities that require economic contributions or that promote awareness (e.g. petitions, emergency appeals, opinion requests and surveys) that are of interest to the person who has expressed the desire to receive information of this type and that reflect the person's characteristics and behaviour and are, therefore, of their specific interest and not disruptive. Again, such retention shall cease if the data subject objects at any time to the processing of personal data concerning him or her carried out for such purposes, including profiling in so far as it is related to such direct marketing.

After the periods have elapsed, the identifying data shall be transformed into an anonymous form and used only for statistical reports which do not allow the identity of the person to be traced but which are useful for the purpose of adapting projects, initiatives and actions for the implementation and achievement of CISP's statutory and institutional objectives. Personal data will therefore be destroyed.

DATA PROCESSORS

Your personal data may be processed, either manually, electronically or telematically, either directly by CISP ONG Onlus or by third parties that carry out processing operations on behalf of our association with experience, technical skills, professional approach, and reliability, respecting the security and confidentiality of the information and that we constantly monitor in their work. The processor is ‘a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller’ (art. 4, paragraph 8, REGULATION) and it is contractually bound by CISP ONG Onlus, with a definition of the limits of operations on the data, of the data it may process and of the categories of data subjects to whom the data refer, and with a prohibition to use the data in any way other than for the task assigned. If formally authorised by CISP, it may avail itself of the services of other data processors, who shall be contractually bound by the data processor directly appointed by CISP: violations committed by such other data processors shall fall under the responsibility of the first data processor and not of CISP.

The complete and up-to-date list of the data controllers (and, if applicable, of the data controllers appointed by the first controller, subject to CISP's authorisation) can be obtained by e-mail from privacy@cisp-ngo.org. (Or, by writing to CISP ONG ONLUS, - Via Germanico 198, 00192 Roma).

THIRD PARTIES TO WHOM YOUR DATA HAS BEEN DISCLOSED

Your data may be made available to third parties and independent data controllers for purposes connected with the provision of services of interest to you or in compliance with laws and regulations that require their communication, as well as to supervisory bodies.

WHAT COOKIES ARE AND HOW THEY ARE USED BY CISP NGO 

Cookies are pieces of information saved on the hard drive of your PC, which are sent by your browser to a Web server, and which refer to your use of the network. Consequently, they allow us to know the services you use, the sites you visit and the options you have expressed while surfing the net.

Therefore, this information is not provided spontaneously and directly, but leaves a trace. The data collected through cookies will be used for technical purposes, to guarantee easier, more immediate and faster access to the site and its services and easier navigation for the individual user.

Profiling cookies may also be used, subject to the user's consent, to create user profiles based on the sections of the site or the actions performed by the user on this site or surfing the web.

The use of so-called session cookies (which are not permanently stored on the user's computer and are automatically deleted when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to enable the safe and efficient exploration of the site. The so-called session cookies used on this site avoid the use of other IT techniques that could potentially compromise the confidentiality of users' browsing and do not allow the acquisition of personal data identifying the user. In any case, it is possible to configure your browser in such a way that you are notified when a cookie is received and then decide whether to accept it.

To find out about our cookie policy and the cookie policies of third parties, we invite you to read the relevant extended information by clicking here.

BROWSING DATA

The computer systems and software procedures used to operate this site acquire some personal data during their normal operation whose transmission is implicit in the use of Internet communication protocols.

This information is not collected to be associated with identified users, but by its very nature could allow the users to be identified through processing and association with data held by third parties. This category of data includes IP addresses or the domain names of the computers used by users connecting to the site, the URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error or similar) and other parameters relating to the user's operating system and computer environment.

These data are used only to obtain anonymous statistical information on the use of the site and to check its correct functioning and are deleted immediately after being processed. The data could be used to determine responsibility in the event of hypothetical computer crimes against the site.

SECURITY OF YOUR PERSONAL DATA

CISP ONG Onlus adopts suitable and preventive security measures to safeguard the confidentiality, integrity, completeness, and availability of your personal data. As established by the regulations governing the security of personal data, technical, logistical, and organisational measures are put in place to prevent damage, loss (including accidental loss), alteration, improper and unauthorised use of the data that concern you.

CISP ONG Onlus has put in place adequate technical and organisational measures to ensure a level of security appropriate to the risk that might affect the rights and freedoms, including privacy and confidentiality, of individuals. It adopts security measures that include, among others:

• "pseudonymisation" (Article 4, paragraph 5, REGULATION: ‘the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person’) and data encryption
• systems that permanently safeguard/protect the confidentiality, integrity, availability and resilience of processing systems and services
• systems for promptly restoring the availability of and access to personal data in the event of a physical or technical incident
• procedures for regularly testing, verifying, and evaluating the effectiveness of technical and organisational measures to ensure the security of processing.

Similar preventive security measures are taken by third parties (data controllers) to whom the Organisation has entrusted processing operations of your data on its own behalf.

On the other hand, the Organisation shall not be held responsible for untruthful information sent directly by the user (e.g.: correctness of e-mail address or postal address or other personal data), as well as information concerning the user that has been provided by a third party, even fraudulently.