Privacy

This privacy policy refers to the website www.humantechnopole.it (hereinafter also referred to as the ‘Site’).

This information notice, provided pursuant to Article 13 of the EU Regulation 2016/679 (hereinafter “the Regulation" or “GDPR"), describes how the personal data of users consulting the Human Technopole Foundation Site (hereinafter “HT") are processed.

This notice does not cover other sites or pages that may be reached through any link or content posted on the Site.

Users, by using the Site, accept this policy and are therefore invited to read it before providing personal information of any kind.

1. Identity and contact details of the data controller

The Data Controller of your personal data is the Human Technopole Foundation, based in Viale Rita Levi-Montalcini 1, 20157, Milan (MI), Italy, Tel. +39/02 30247001, e-mail: gdpr@fht.org.

2. Contact details of the Data Protection Officer (‘DPO’)

HT’s Data Protection Officer can be contacted at the following e-mail address: dpo@fht.org.

3. Categories of personal data processed

Navigation data

The computer systems and software procedures used to operate the Website acquire certain personal data, the transmission of which is implicit in the use of Internet communication protocols [by way of simplification only, IP address or domain names of the devices through which users connect to the Website, URI (Uniform Resources Identifier) notation addresses of the resources requested, system logs, id or unique device identifier, type of device].

This information is not collected in order to be associated with identified interested parties. In fact, HT does not collect any kind of personal data, but only information relating to the device and the country from which the users connect, together with the pages visited, in order to obtain anonymous statistical information on the use of the Website and to check its correct functioning, without, however, tracing such information back to a specific user.

Information provided voluntarily by the User

Through the Site it is possible to send requests and communications using the addresses and contact forms indicated therein. The provision of such data is compulsory, and is necessary in order to reply to the requests sent as well as to contact the sender again to obtain clarifications on what has been reported. In particular, personal data are provided by users for the purpose of using the services provided by the Controller.

In particular, users are identified when sending requests for information/assistance and communications through the addresses and contact forms indicated on the Site. In this case, the Data Controller shall process the sender’s contact data, necessary to reply, as well as all personal data included in the communications.

Through the Site it is also possible to subscribe to the Human Technopole Foundation newsletter by filling in the appropriate form and entering your name, surname and e-mail address.

Cookies

Cookies are small text files that websites visited by the user send to the user’s terminal, where they are stored and then retransmitted to the same sites the next time the same user visits.

Typically, cookies can be installed:

• directly by the owner and/or manager of the website (so-called first-party cookies);
• by managers unrelated to the website visited by the user (so-called third-party cookies) and this by virtue of the presence on the site consulted of elements that can be traced back to different sites or web servers (e.g. images, specific links to pages on other domains, etc.).

Information collected through first-party cookies is stored by the operator of the site that the user visited, while information collected through third-party cookies is stored by the third parties themselves.

Types of cookies

Cookies are used for different purposes (e.g. performing computer authentication, session tracking, etc.) and, depending on the purpose pursued by a holder, can be distinguished into different categories:

a. Technical cookies

Technical cookies are those that allow the normal navigation of a site as well as its correct functioning. Since they enable activities that are essential for optimal use of the Site, their function is to make it easier for users to consult the Site. They are not used for any other purpose and are normally installed directly by the website owner or operator. They can be divided into:

i. browsing or session cookies: they ensure normal navigation and use of the website (allowing, for example, to make a purchase or authenticate to access restricted areas);

ii. analytics cookies: these are used to collect information on the use of the sites and can be assimilated to technical cookies where they are used directly by the site operator to collect information, in aggregate form, on the number of users and how they visit the site;

iii. functionality cookies: they allow the user to navigate according to a set of selected criteria (e.g. language) in order to improve the service rendered to the user.

The use of such cookies (first or third-party) is indispensable for the proper functioning of a website and the services linked to the sites themselves (e.g. login or access to reserved functions on the sites).

Users’ prior consent is not required for the installation of such cookies.

b. Profiling cookies

Profiling cookies are aimed at creating profiles of the user visiting a site and are used in order to send advertising messages in line with the preferences expressed by the user when browsing the web.

The prior consent of the person concerned is required for the use of profiling cookies.

For details on the list of cookies, retention times, how to disable them and their respective owners, the user is invited to read the cookie policy accessible at this link.

4. Purpose and legal basis of processing

Personal data are processed by the data controller for the following purposes:

• responding to user requests for information and assistance. The processing is functional to fulfil a user request and is based on the execution of a contract or pre-contractual measures;
• Sending newsletters. Processing is based on the consent of the person concerned;
• ensure the proper functioning of the web pages and their content. In this case, data processing is based on the legitimate interest of the Data Controller.

5. Modalities of data processing

Data will be processed using methods and procedures strictly necessary for the pursuit of the purposes for which they were collected, manually and/or with the aid of electronic instruments. In order to avoid the risk of data loss, illicit use or incorrect use, unauthorised access or alteration, appropriate technological and managerial security measures have been adopted.

Personal data will be processed by the Data Controller, by personnel authorised to process them or by persons specifically appointed as Data Processors. At any time, the data subject may ask the Data Controller for the full list of the appointed Data Processors involved in the processing of data for the purposes set out in this statement.

6. Retention of personal data

The Data Controller adopts the following policies regarding the retention of user data:

• The data voluntarily provided by the user through requests/communications to the addresses on the Site will only be kept for the time necessary to respond to the requests/communications received;
• The data provided for subscription to the newsletter will be retained by the owner until the data subject withdraws his consent.

7. Categories of recipients of personal data

For the purposes of this information notice, your personal data may be processed by the persons appointed by HT as Data Processors for purposes strictly related to those indicated above.

Furthermore, upon specific request, HT is obliged to communicate the data to the Judicial Authority. The communication of personal data will be carried out in accordance with legal obligations.

8. Rights of data subjects

You may exercise your rights under Article 15 et seq. of Regulation (EU) 2016/679 at any time by sending a communication to the following address: gdpr@fht.org.

9. Complaint to the Control Authority

We would like to remind you that you have the right to lodge a complaint with the Supervisory Authority (Garante per la protezione dei dati personali) pursuant to Article 77 of the GDPR, if you consider that the processing of your data violates the provisions of the GDPR.

10. Changes to the policy

This information is valid from April 14 2023 and is subject to updates. For this reason, the user is invited to check its content periodically.

This information on cookies is provided pursuant to Regulation (EU) 2016/679 (hereinafter the “Regulation“) and in compliance with Article 122 of Legislative Decree No. 196/2003 – Personal Data Protection Code (hereinafter the “Privacy Code“), as well as the General Provisions of the Guarantor for the Protection of Personal Data No. 229 of 8 May 2014 and No. 231 of 10 June 2021 on cookies, and is addressed to those who connect to the website https://humantechnopole.it.

This information is provided only for the above-mentioned site (hereinafter referred to as the ‘Site‘) and not for any other websites that may be consulted by the user via links on the Site.

1. Data controller

The Data Controller is the Human Technopole Foundation, with registered office in Viale Rita Levi-Montalcini 1, 20157, Milan (MI), Italy, Tel. +39/02 30247001, e-mail: gdpr@fht.org (hereinafter “HT" or also the “Data Controller“).

This information sheet will explain the purposes and methods by which HT uses cookies, which categories of information are processed, what rights data subjects have in respect of processing and how to exercise them.

2. What are cookies and what are they used for

Cookies are small text files that websites visited by the user send to the user’s terminal, where they are stored and then retransmitted to the same sites the next time the same user visits.

Typically, cookies can be installed:

• directly by the owner and/or manager of the website (so-called first-party cookies);
• by managers unrelated to the website visited by the user (so-called third-party cookies) and this by virtue of the presence on the site consulted of elements that can be traced back to different sites or web servers (e.g. images, specific links to pages on other domains, etc.).

Information collected through first-party cookies is stored by the operator of the site that the user visited, while information collected through third-party cookies is stored by the third parties themselves.

3. Types of cookies

Cookies are used for different purposes (e.g. performing computer authentication, session tracking, etc.) and, depending on the purpose pursued by an owner, can be distinguished into different categories:

a. Technical cookies

Technical cookies are those that allow the normal navigation of a site as well as its correct functioning. Since they enable activities that are essential for optimal use of the site, their function is to facilitate consultation of the site by users.

They are not used for any further purposes and are normally installed directly by the owner or operator of the website. They can be divided into:

i. browsing or session cookies: they ensure normal navigation and use of the website (allowing, for example, to make a purchase or authenticate to access restricted areas);

ii. analytics cookies: these are used to collect information on the use of sites and can be assimilated to technical cookies where they are used directly by the site operator to collect information, in aggregate form, on the number of users and how they visit the site;

iii. functionality cookies: they allow the user to navigate according to a set of selected criteria (e.g. language) in order to improve the service rendered to the user.

The use of such cookies (first or third-party) is indispensable for the proper functioning of a website and the services linked to the sites themselves (e.g. login or access to reserved functions on the sites).

Users’ prior consent is not required for the installation of such cookies.

b. Profiling cookies

Profiling cookies are aimed at creating profiles of the user visiting the site and are used in order to send advertising messages in line with the preferences expressed by the user when browsing the web.

The prior consent of the person concerned is required for the use of profiling cookies.

4. List of cookies on the site.

5. Deleting and managing cookies

You can set your device to accept all cookies, receive notifications when a cookie is sent or not receive cookies at all.

For optimal management, activation and deactivation of cookies depending on the browser used to view the Site, we provide you with the following links to help sections of the most commonly used browsers: Internet Explorer, Safari, Chrome, Firefox, Opera.

More information on how cookies and targeted advertising work can also be found at www.youronlinechoices.eu and www.allaboutcookies.org.

6. Who you can contact with your requests and to exercise your rights

For any further information or to exercise your rights under Articles 15-22 of EU Regulation 2016/679, please send an e-mail to gdpr@fht.org.

Finally, you have the right to lodge a complaint with the Data Protection Authority.

7. Changes to this Cookie Policy

The possible entry into force of new sector regulations, the updating of the various types of cookies or technological innovations may require changes to this policy. It is therefore possible that it may be modified over time. We therefore invite the user to periodically consult this page.

HT assures that it will do everything within its power to provide the user with any information regarding the cookies that will be issued.

Information on the processing of human source data and materials pseudonymised at source and made available to the scientific community by third parties for the conduct of scientific research activities. 

 In order to carry out its scientific research activities and in line with the best practices in the sector, Human Technopole Foundation (“Foundation" or “HT") may use data sets (such as – by way of example – data relating to habits and lifestyles health and genetic characteristics of subjects participating in research projects in the medical and epidemiological field) as well as biological materials (such as – by way of example – biological samples, primary cell cultures and cell lines) of human origin that are made available to the scientific community by third parties (“Providers", such as data repositories, biobanks, commercial operators and other research institutes).

This information policy describes the methods for processing biological data and materials (including genetic) of human origin voluntarily provided by the interested parties to the following suppliers for scientific research purposes

and obtained by the Human Technopole Foundation (or “HT") for the performance of its scientific research activities. 

HT will receive data and materials in relation to which (prior to the transfer to HT) any direct personal identifiers (such as personal data, social security number or other direct identifiable data) will be removed. HT will not receive or know the re-identification keys or any other element that identifies the data subjects. Therefore, HT will not be able to trace the identity of the concerned subjects by means that can be reasonably used. So, the data and materials are received for HT in a sufficiently anonymized form by the Provider and such that the identification or identifiability of the Data Subjects is prevented by means that are reasonably likely to be used for that purpose within the meaning of recital 26 of the EU Regulation 2016/679 (“GDPR"). 

The anonymised nature of the data in question excludes them from the scope of the legislation on the protection of personal data. 

Without prejudice to the foregoing and without prejudice to the technical and organizational measures implemented by HT to prevent even the attempt of re-identification, with a view to maximum transparency towards the parties concerned, the Foundation publishes herein the same information provided in relation to personal data, also pursuant to Article 14 GDPR. 

1. Identity and contact details of the Data Controller 

The Data Controller is Fondazione Human Technopole, with registered office in Viale Rita Levi Montalcini 1, 20157, Milan (MI), Italy, Tel. +39/02 30247001, e-mail: gdpr@fht.org. 

2. Contact details of the Data Protection Officer (“DPO") 

HT’s Data Protection Officer can be contacted at the following email address: dpo@fht.org 

3. Purpose of the processing and consent of the data subject 

The purpose underlying the collection and processing of such data concerns the conduct of scientific research activities and as may be better detailed from time to time in specific projects and lines of research. 

The Provider of the data and materials shall provide, either directly or through the third party that collected them, information regarding the research projects from which such data and materials originate and the use of the data and materials for scientific research purposes for which they are intended, and shall collect consents from interested parties to participate in such projects and to use the data and materials for such research purposes. 

4. Nature of the data processed 

HT will process the following categories of data: 

• data that do not fall under the special categories referred to in Article 9 GDPR and do not constitute information relating to criminal convictions and offences pursuant to Article 10 GDPR (“common data, such as gender, age, country of residence, information on habits and lifestyle") 
• special categories ex art. 9 GDPR, such as health-related data (such as diagnosis, comorbidities, response to treatment, survival etc.) and genetic data. 

Data may also be processed through the use for research purposes of biological materials that are the source of the data or with which such data are associated. 

The transfers of biological data and materials from the necessary Providers to the Foundation take place within the framework of study projects carried out and research purposes pursued by HT and approved by the Provider. Such projects foresee the stipulation of specific agreements on the transfer or access of data and materials (i.e. named, for example, “MTA – Material Transfer Agreement", “DTA – Data Transfer Agreement", “DAA “Data Access Agreement" or other agreements however named stipulated through the proposal and acceptance of the making available of data and materials in the respect of specific terms and conditions communicated by the Provider). 

Prior to the transfer or making available of the data or materials, the Supplier shall take technical measures by which the data is pseudonymised and, in the transfer process, the Supplier shall not disclose, nor shall FHT receive in any way the pseudonymisation key for the data and materials, or any other element that would indicate or otherwise trace HT to the identity of the data subjects. 

Therefore, in the light of the technical and organisational measures adopted by HT, which also include the obligation of researchers who have access to the data and samples not to attempt to re-identify the donors in any way, the Foundation is not in any way able to trace the identity of the data subjects, taking into account the means reasonably available to it. The data, therefore, are to be considered anonymous in accordance with recital 26 of the GDPR and, therefore, exempt from the rules on the protection of personal data. Only in the event that it is necessary to re-identify a data subject, HT will be supported by the Provider, subject to the consent of the data subjects. 

5. Modalities of treatment 

The data are transferred by the Supplier to the Foundation and subsequently processed in digital form by the same in compliance with the agreement signed between the Parties and the guidelines and protocols applicable to the specific Study Project. 

No form of automated processing is foreseen. Access to the data is permitted only and exclusively to the personnel involved and adequately appointed to process the data in question. 

6. Categories of data recipients 

The data will be processed by researchers and collaborators of HT adequately appointed and instructed as authorized subjects to the processing. 

The data are not transferred or communicated or in any way disclosed except as expressly permitted within the agreements with the supplier, the information made available and informed consent given by those concerned and in any case than necessary in relation to the purposes described in paragraph 3 of this information. 

For the storage of the processed data, the Foundation will use an “Isilon" storage system installed on premise in the Foundation’s Shelter and managed by the Foundation’s ICT Team. 

In addition to the above, if the necessary conditions are met, with a written agreement HT may entrust third parties (persons in charge of the treatment) to carry out on behalf of HT certain treatment activities. The 

Foundation, in these cases, will address exclusively to subjects that will offer suitable guarantees and that will be able to assure the highest standards in matter of data protection in order to guarantee in an adequate way the privacy and the security of the data 

7. Transfer of data outside the European Economic Area 

No transfers are made outside the European Union. The data stored on the storage systems of HT are, in fact, inside the European Union. In any case, in the hypothesis in which the Foundation should proceed to carry out a transfer outside the European Union, it would behave in the same way as it does with reference to personal data and that is to use one of the mechanisms as per art. 46 ss. GDPR, in the absence of an adequacy decision by the European Commission. 

8. Data retention 

Data storage is carried out in accordance with the same security measures that HT implements with regard to personal data. 

Data is retained for as long as necessary to carry out the research activities. Generally, data and materials are kept for 10 (ten) years from the end of each Project. This is without prejudice to the possibility that, at the end of this period, the Foundation may evaluate the possibility of not eliminating the data/materials that are of interest for scientific research, providing – if the conditions exist – to determine their conservation for a longer period, in analogy to what is foreseen for personal data pursuant to art. 5 of the GDPR and in compliance with the prescriptions of art. 89 of the GDPR itself. 

It is reiterated that the retention will concern data rendered, prior to transfer, in such a form that HT will not be able to trace the identity of the data subjects. 

9. Rights of the interested parties 

The point of contact of the interested parties for information and exercise of their rights is the Supplier, who, through the contractually provided mechanisms, creates a suitable communication channel with HT, in order to assure the interested parties the effectiveness in the exercise of their rights. Where appropriate, the Supplier will be able to communicate the references of the Foundation to the interested parties who request it. 

Data subjects shall have the right to obtain, where the circumstances exist and having regard to the possible limitations of the case, access to their data and the rectification or erasure of those data or the restriction of processing operations concerning them or to object to processing. 

10. Complaint to the Control Authority 

It is possible to lodge a complaint with the Authority (for Italy this Authority is the “Garante per la protezione dei dati personali") pursuant to Article 77 of the GDPR, if you believe that the processing of your data is subject to the application and violates the provisions of the GDPR.

1.SUBJECT
Human Technopole Foundation (hereinafter “HT") makes use of social web tools in order to inform, communicate and keep external users up-to-date on the activities it carries out, as well as on personnel selection notices. To this end, HT uses the institutional website (humantechnopole.it) and social media as indicated below.

The Site and the socials used are managed by the staff of the Communications Area, who may occasionally make use of external collaborators and consultants.

2.PURPOSE

The External Social Media Policy has been prepared in order to inform external users of the rules of behaviour to be observed in the digital spaces of Human Technopole. The final version of the document is available to users on the HT website.

3.DIGITAL AND SOCIAL CHANNELS

For its activities, the Foundation relies on:

• Website
• Facebook
• Instagram
• Twitter
• LinkedIn
• YouTube
• Flickr
• Mastodon

4.CONTENTS

The content published on the social channels is designed to inform external users about the main activities of the institute, as well as about projects, initiatives, promoted events and news concerning HT activities.

Social channels are also used to foster user involvement through discussion and dialogue with a view to transparency and sharing.

The Communications Area staff may create original content of a textual, photographic, infographic, video, etc. nature that may be used under the Creative Commons BY-NC-ND licence. Contents and messages of public interest and utility created by third parties (Institutions, Associations, News Organisations, Users) may also be shared and relaunched through the institute’s channels.

The advertising spaces in the margins of the content published on the pages of the social networks used by HT are not controlled by the Foundation, but are managed independently by the managers of the individual social networks

5.MODERATION

Human Technopole’s digital and social channels are regularly moderated by staff in the Communications Area during the Foundation’s working hours.

HT manages the spaces for communication and dialogue within its profiles in the various social networks by asking its users – who have the opportunity to actively participate through forms of interaction such as comments, messages or self-publication of content – to respect a few simple rules:

• Always express your opinion in a fair and measured manner without using polemical and disdainful tones, basing it as far as possible on verifiable facts and objective circumstances, and respect the opinions of others and the image of HT, its employees, collaborators and suppliers.
• On social networks, everyone is responsible for the content they publish and the opinions they express. Insults, vulgarity, insults, threats and, in general, violent behaviour will not be tolerated.
• Published content must always respect people’s privacy and confidentiality. References to facts or details of no public relevance that harm the personal sphere of third parties should be avoided.
• The interest of the topics in relation to the purposes of HT is an essential requirement: it is not possible to use these spaces for purposes other than the institutional purposes of the Foundation.
• Each discussion is linked to a specific theme: all participants are asked to respect this, avoiding broadening the discussion in a generic and indiscriminate manner.
• Any form of advertising, spamming or promotion of private interests or illegal activities is not tolerated.
• For the protection of users who write, posts/comments that directly or indirectly disseminate personal information of a particular kind in accordance with Art. 9 EU Reg. 2016/679 are not allowed.
• Content that infringes copyright or the unauthorised use of registered trademarks is not permitted.

In any case, all posts, comments or audio/video material that:

• Have a political or propaganda content;
• Present inappropriate language and/or a threatening tone and/or violent, vulgar or disrespectful behaviour
• Have contents that are offensive, defamatory or denigrating of HT and that may harm HT’s interests, image and reputation;
• Present unlawful content or incitement to commit unlawful activities;
• Have content that is offensive, misleading, alarmist or infringes the rights of third parties;
• Disclose personal data and information or that may cause damage or harm the reputation of third parties;
• Present obscene, pornographic or child pornographic content or content that offends the common morals and sensibilities of users;
• Have discriminatory content on grounds of gender, race, ethnicity, language, religious belief, political opinion, sexual orientation, age, personal and social conditions;
• Promoting or supporting illegal activities, infringing copyright or misusing a registered trademark;
• Include so-called ‘off topic’ comments;
• Include personal data of a particular kind in accordance with Art. 9 EU Reg. 2016/679.

Judgements to remove posts, comments or other content are final. Anything posted by users of social networks is subject to the terms of service of the various social networks and may be used by these companies as per their terms and conditions. For more information, please consult the respective terms of service.

In the event of a breach of the aforementioned conditions or those contained in the terms of service of the tools used, HT reserves the right to use banning or blocking (when possible after an initial warning) to prevent further actions, and to report the user to the platform managers and possibly to the police (in cases of criminal offences).

Messages containing personal data (e-mail addresses, telephone numbers, addresses, etc.) as well as those concerning health conditions may be removed to protect the persons concerned.

6.TIME AND MANNER OF RESPONSE

The modalities and timeframes for responding to questions, requests and petitions addressed to HT may vary depending on their nature and the channel used. In the event that the social channels are not the adequate instrument to satisfy specific requests of the users, the request will be forwarded to the Office deemed competent. In any case, HT’s social profiles do not constitute the channel for collecting specific reports or complaints, which we invite users to address to the competent department (Contact Us page).

7.PRIVACY AND PROCESSING OF PERSONAL DATA

Please note that the processing of users’ personal data complies with the policies in use on the platforms used. Personal or special data as referred to in Art. 9 EU Reg. 2016/679 included in comments or posts published within the social media channels owned by HT will be removed.

Data shared by users through private messages sent directly to channel operators will be treated in compliance with Italian privacy laws and HT’s privacy policy.

8.CONTACTS

The Data Controller of your personal data is the Human Technopole Foundation, based in Viale Rita LeviMontalcini 1, 20157, Milan (MI), Italy, Tel. +39/02 30247001, e-mail: gdpr@fht.org