Privacy Policy

Pursuant to Art. 13 of European Regulation 679/2016 on the protection of personal data (hereinafter referred to as GDPR), we inform you that the data you voluntarily provide will be processed by DM Cultura s.r.l., a sole-shareholder company (hereinafter referred to as DM Cultura), which is the Data Controller and can be contacted at: segreteriagenerale@dmcultura.it  

Purposes of the processing for which the personal data collected is intended

The personal data provided with your consent will be processed for the following purposes: 

  • To send information following an explicit request from you on the dedicated page (“Contact us”). The data will be processed by data processors who are employees and/or consultants of DM Cultura for technical and/or application purposes. 
  • To send information relating to communications, initiatives, and events promoted by DM Cultura. The data will be processed by employees and/or consultants of DM Cultura and may also be communicated, solely for the purposes mentioned above, to companies with which DM Cultura has contractual or business relationships in order to propose initiatives/events in partnership with DM Cultura, which will process the data as Data Protection Officers or agents authorised for this purpose. During the course of our initiatives/events, subject to specific authorisation and permission, photographs may be taken and/or audio-video recordings made – possibly also transmitted via streaming – which may depict the participants for the purposes of promoting, publicising and documenting the events. 
  • To undertake personnel selection and recruitment activities, where personal data will be processed exclusively with reference both to the positions for which you have applied and to other present and future positions, with the support of paper, computer or telematic means, in any case suitable for ensuring the security and confidentiality of the corresponding processing. The provision of such data is optional, but your refusal to provide it will make it impossible for the Data Controller to process your data and consequently to carry out the selection activities. In the case of self-application, your data may also be included in a computerised database and will be processed in accordance with existing selection and recruitment requirements. If you submit your CV in response to a recruitment message from us, your data will only be used for selection purposes related to this search. If, with specific authorisation, you invite us to process your data for other selections, this will be done in the same way as for self-applications. Your data will be processed by employees and/or consultants of DM Cultura in charge of data processing and may also be disclosed, solely for the above purposes, to companies with which DM Cultura has contractual relations or business relationships for the selection and recruitment of personnel. In addition, all the criteria set out in Legislative Decree 125/91 will be adopted to ensure non-discrimination between the sexes in the selection process. The processing of common personal data for the purposes strictly connected to the selection and recruitment activities and its inclusion in the DM Cultura database does not require your specific consent. Similarly, pursuant to Art. 6 (Lawfulness of processing) of the GDPR, consent is not required even if the CV contains personal data defined as “special category” as indicated by Art. 9 of the GDPR. 
  • For the sale of online courses sold in the catalogue or on demand, in webinar mode with personal data collected through the completion of the course participation form. 

Recipients of processed personal data

In addition to the recipients already indicated, it should be noted that your data may also be processed, for the sole purpose of administrative/accounting management, by external companies that undertake these activities, and for technical purposes by employees of the information systems of DM Cultura and/or by external companies, for the operation of navigation on the site and for the purposes indicated in the preceding paragraph. In all cases, third-party processing of the personal data you have provided will not take place without you having given specific consent. 

Retention period 

The personal data retention period for the purpose referred to in point a) above is 1 year from the date of completion of the form. 

The personal data retention period for the purposes referred to in point b) above is 2 years from the date of completion of the form. 

The personal data retention period for the purpose referred to in point c) above is one year from the date of inclusion of the CV or its most recent update. 

The personal data retention period for the purpose referred to in point d) above is 2 years and in any case in compliance with administrative/accounting regulations. 

Rights of the data subject 

During the period of time for which your personal data is stored, you will be able to exercise your rights under Chapter III of the GDPR (Articles 15 to 22 of the GDPR). Among these, we briefly remind you of the rights to: 

  • Withdraw consent at any time, without affecting the lawfulness of any processing based on consent given prior to withdrawal. 
  • Obtain access to and confirmation of the existence or otherwise of personal data concerning you. 
  • Learn the logic and purposes of the processing. 
  • Obtain the cancellation or blockage, or the updating, rectification or integration, of the data. 
  • Obtain your personal data, provided with your consent and processed by automated means, in a structured and readable format for transmission to another data controller. 
  • Object, on legitimate grounds, to the processing of such data and to lodge a complaint with a supervisory authority. 

The processing of your personal data will be based on principles of correctness, lawfulness and transparency and your privacy and your rights will be protected. Contact e-mail address for the exercise of rights: ufficiopersonale@dmcultura.it  

Profiling

DM Cultura does not collect personal data with the intention of profiling, defined as: “any form of automated processing of personal data consisting in the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to professional performance, economic situation, health, personal preferences, interests, reliability, behaviour, the location or movements of that natural person”, unless reference is made to data necessary to enable navigation on the site, to obtain anonymous statistical information on the use of the site and to check its correct functioning or used to ascertain responsibility in the event of hypothetical computer crimes against the site (reference cookie policy). 

For any information or request, you can contact directly: DM Cultura s.r.l., a sole-shareholder company, – ref. Privacy, Piazza di Sant’Andrea della Valle, 6 – 00186 Rome, segreteriagenerale@dmcultura.it. 

Additional information: Types of data collected

The Personal Data collected by this Application, either independently or through third parties, includes: Cookie, Usage Data, First Name, Last Name, Entity or Company, Entity Type, Phone Number and E-mail. 

Other Personal Data collected may be listed in other sections of this Privacy Policy or other notices displayed at the time of Data collection itself. Personal Data may be freely entered by the User or collected automatically during use of the Application. 

Any use of Cookies – or other tracking tools – by the Application or owners of third party services used by the Application, unless otherwise stated, are aimed at identifying the User and recording his/her preferences for purposes strictly related to the provision of the services requested. Failure by a User to provide certain Personal Data may make it impossible for this Application to provide its services. 

Users acknowledge their responsibilities for Personal Data related to third parties published or shared by the Application and warrant that they are entitled to disclose or disseminate said data, releasing the Data Controller from any liability to third parties. 

Method and place of processing for the collected Data Data processing methods

The Data Controller processes Users’ Personal Data using suitable security tools to protect against the unauthorised access, distribution, modification or destruction of Personal Data. Processing is carried out using electronic and/or telecommunication tools in line with organisational procedures and on the basis of principles strictly related and limited to the stated purposes. In addition to the Data Controller, in some cases, the Data may be accessed by categories of employees involved in the organisation of the Site (administrative, commercial, marketing, legal, system administrators) or external parties (such as third-party technical service providers, mail couriers, hosting providers, IT companies, communication agencies) and by Data Controller-appointed Data Protection Officers, where necessary. The updated list of Data Protection Officers can be requested from the Data Controller. 

Place 

The Data is processed at the operational headquarters of the Data Controller and in any other place where the parties involved in the processing are located. For further information, contact the Data Controller. 

Details regarding the processing of Personal Data Contact form

The User, by filling in the contact form with their Data, consents to its use to respond to the purposes indicated to requests for information, quotes, or any other category indicated in the header of the form. 

The Personal Data collected can include: Name, Surname, Organisation or Company, Organisation type, E-mail and Telephone number. 

Interaction with social networks and external platforms

These services allow you to interact directly with social networks or other external platforms, using the pages of this Application. The interactions and information acquired by this Application are in any case subject to the User’s privacy settings for each social network. If a service for interacting with social networks is installed, then it may still collect traffic data for the pages it is installed on, even if the Users do not use the service. 

This Application does not support “Do Not Track” requests. To find out whether any third-party services used support them, please consult their privacy policy. 

Facebook 'Like' button and social media widgets (Facebook, Inc.)

Facebook’s ‘Like’ button and social media widgets are services that enable interaction with the Facebook social network, provided by Facebook, Inc. Personal Data collected: Cookies and Usage Data. Processing location: USA – Privacy Policy  

Tweet button and Twitter social widgets (Twitter, Inc.)

The Tweet button and Twitter social widgets are social networking services provided by Twitter, Inc. Personal Data collected: Cookies and Usage Data. Processing location: USA – Privacy Policy  

Statistics

The services contained in this section allow the Data Controller to monitor and analyse traffic data and are used to keep track of User behaviour. 

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google uses the Personal Data collected to track and analyse the use of this Application, creating reports and sharing them with other services developed by Google. Google may use your Personal Data to contextualise and customise ads in its advertising network. Personal Data collected: Cookies and Usage Data. Processing location: USA – Privacy Policy – Opt Out  

Social Media Policy

DM Cultura is present on various social networks, in particular: 

The links to social networks are contained not only on the www.dmcultura.it website but also on our websites: https://www.sebina.it and http://reteindaco.sebina.it  

On social media we share our most significant projects and news that may be of interest to the culture sector. 

DM Cultura uses social media, given that it is a place of sharing and exchange open to all. Therefore, with the aim of guaranteeing a better experience, it has defined a specific corporate Social Media Policy. 

On DM Cultura social profiles it is FORBIDDEN to publish: 

  • Data and personal information of third parties without the explicit consent of the data subjects 
  • Images and materials that violate copyright/industrial rights 
  • Contents that are confidential or that otherwise infringe the rights of third parties 
  • Photographs and images collected without the consent of the data subjects 
  • Spam content 
  • Offensive and discriminatory comments 
  • Off-topic content 

Failure to comply with this policy will result in the removal of published comments and content and, in the most serious cases, even the blocking of access to our social channel, with notification for the necessary measures. 

DM Cultura is not responsible for the content posted by users on our social profiles. 

DM Cultura, moreover, in the execution of specific administration activities of its Facebook fan page does not perform profiling activities for advertising purposes, namely the collection of behavioural data in order to send personalised advertising to users (behavioural targeting) regardless of any profiling activities performed by Facebook itself. Activities for which DM Cultura and its administrators remain operationally and legally unconnected and exempt from any liability.  

Additional information on data processing Legal defence

The User’s Personal Data may be used by the Data Controller for defence in court or during the stages leading to possible legal action, against improper use by the User of the same or of related services. The User declares to be aware that the Data Controller may be required to disclose information if requested by public authorities. 

Specific information

Upon request of the User, in addition to the information contained in this privacy policy, this Application may provide Users with additional and contextual information about specific services, or the collection and processing of Personal Data. 

System Logs and Maintenance

This Application and any third-party services used by it may collect system Logs, which are files that record interactions and may also contain Personal Data, such as the User IP address, for operational and maintenance purposes. 

Information not contained in this policy

Further information from the Data Controller may be requested at any time in relation to the processing of Personal Data using the contact information. 

Changes to this Privacy Policy

The Data Controller reserves the right to make changes to this Privacy Policy at any time by informing the Users on this page. Therefore, please check this page frequently, taking as reference the “last updated” date shown at the bottom. In case of non acceptance of any changes to this Privacy Policy, Users are required to stop using this Application and may request that the Data Controller deletes their Personal Data. Unless otherwise specified, the previous privacy policy shall be applicable to Personal Data collected up to that point. 

Information about this Privacy Policy

The Data Controller is responsible for this Privacy Policy, which is drafted on the basis of forms prepared for the Application and stored on its servers.  

GLOSSARY

Personal Dara (or Data)

Personal Data shall mean 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 distinctive features of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. 

Usage Data

This is personal data collected automatically by the Application (or by any third-party applications that it uses), and includes the following: IP addresses or domain names of those computers used by the User when connecting to this Application, Uniform Resource Identifiers (URIs), time of request, method used to submit the request to the server, size of the file obtained in reply, numerical code indicating status of response from the server (successful, error, etc.), country of origin, characteristics of the browser and operating system used by the visitor, various temporal aspects of the visit (for example, time spent on each page) and details of the route taken within the Application, with particular reference to the sequence of pages visited, parameters related to the User’s operating system and IT environment. 

User

The individual who uses this Application, which must coincide with the data subject or be approved by them, and whose Personal Data is being processed. 

Data Subject

The natural or legal person to whom the Personal Data refer. 

Data Processor (or Processor)

The natural person, legal person, public administration and any other entity, association or organisation that processes personal data on behalf of the Data Controller. 

Data Controller (or Controller)

The natural person, legal person, public administration or any other entity, association or organisation with the right, also jointly with another Data Controller, to make decisions regarding the purposes and methods related to the processing of Personal Data and the means adopted, including the relevant security measures, concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application. 

This application

The hardware or software tool by means of which the Personal Data of Users are collected.