Privacy

This privacy and cookies policy refers to the website www.humantechnopole.it (hereinafter also referred to as “Website”).

In accordance with Regulation (EU) 2016/679 (hereinafter “Regulation” or “GDPR”), this information notice describes how the personal data of users who consult the Website of Fondazione Human Technopole (hereinafter “HT”) are processed.

With reference to the processing of personal data through the services available on the Website (e.g., the followings: “Contact Us”, “Join Us” and “Subscribe to our newsletter”) that users may decide to use, please refer to the relevant specific information notices.

The present information notice does not concern other websites or pages that could be reached through any link or content that may be published on the Website.

1. Identity and contact details of the Data Controller

The Data Controller of your personal data is  Fondazione Human Technopole, based in Viale Rita Levi-Montalcini 1, 20157, Milan (Italy), Phone no. +39/02-30247001, gdpr@fht.org.

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

The Data Protection Officer of the Human Technopole Foundation may be contacted at the following email address: dpo@fht.org.

3. Purposes and legal basis of the data processing

The processing of personal data by HT will take place using cookies for the purposes of the operating and maintenance of the Website as well as the processing of statistics relating to the use of the Website in aggregate form.

The legal basis of such processing is the legitimate interest of the Data Controller or, where required, the consent to the storage of the specific category of cookies freely given by the user.
Further details on the purpose and legal basis of the use of cookies are included in point 4.2 “Cookies used on the Website” of the present information notice.

After the closing of the browsing session, no personal data is stored or furtherly processed by HT.

4. Nature of the data processed. Cookies used in the Website

The processing of personal data of users who consult the Website is carried out through the use of cookies.

4.1 Definitions, features and application of the regulations

Cookies are small text files that the websites visited by the user send and record on its computer or mobile device, to be re-transmitted to the same websites during a further visit.

Thanks to cookies, a website registers the user’s actions and preferences (such as login data, the chosen language, font size, other display settings, etc.) so that they do not have to be re-specified when the user visits again the aforementioned website or browses different pages.

Therefore, cookies are used to perform computer authentication, monitoring sessions and storing information regarding the activities of users accessing a website and may also contain a unique identification code that allows to track the user’s actions for statistical or advertising purposes.

While browsing on a website, the user may also receive on its computer or mobile device website or web server cookies different than those of the present website (the so – called “third party” cookies).

Some operations cannot be performed without the use of cookies, which in this case are called technical cookies and are necessary for the functioning of the website.

There are various types of cookies, depending on their characteristics and functions.

These can remain in the user’s computer or mobile device for different periods of time; more in detail:

– the so-called session cookies, which are automatically deleted when the browser is closed;

– the so-called persistent cookies, which remain on the user’s equipment until a pre-established expiry date.

The user’s express consent is not always required for the use of cookies.

In particular, “technical cookies”, i.e. those used for the sole purpose of transmitting a communication over an electronic communications network, or to the extent strictly necessary to provide a service explicitly requested by the user, do not require such consent.

In other words, these are cookies that are essential for a functioning website or are necessary to perform activities requested by the user.

Among technical cookies, which do not require an express consent for their use, are included:

– browsing or session cookies

– the “analytics cookies”, when used in compliance with the Supervisory Authority’s guidance directly by the site manager to collect information, in cluster, on the number of users and how they visit the website

– functional cookies, which allow the user to browse, according to a set of selected criteria, for example, the language, the products selected for purchase, to improve the service provided

On the other hand, consent is required for the following types of cookies:

– third-party cookies, which are installed on the user’s IT equipment from a website different than that of the provider, through specific links;

– profiling cookies, aimed at creating user profiles and used to send advertising messages in line with the preferences shown by the user while browsing. With regards to this point, the user can check and adjust his behavioural preferences via the “Youronlinechoices” website.

4.2 Cookies used on the Website

The Website uses the following categories of cookies.

Browsing or Session Cookies.

The use of browsing / session cookies is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to allow a safe and efficient website exploration.

In particular, the IT systems and software procedures aimed at the functioning of the Human Technopole Foundation’s website acquire, during their usual performance, some data whose transmission is necessary for the use of Internet communication protocols. This information is not collected to be linked to the identified data subjects, but they might allow to identify data through processing and association with data held by third parties.

These cookies are removed from the user’s computer when the browser is closed.

Analytics Cookies.

The use of analytics cookies is carried out  though a third party (Google) for the  purpose of obtaining  statistical information on the use of the website (such as the number of visitors to the website, the origin of the website visitors or the operating system used) and to check its correct functioning.

For any further detail relating to such cookies, please refer to the information provided by the respective third parties, at the following link: https://www.google.com/policies/privacy/partners/

 

The use of such cookies is carried out solely prior user’s consent.

 

Functional Cookies.

The use of functional cookies on the Website takes place exclusively to allow the user to browse according to the language chosen (Italian or English). to choose between the dark / light theme and to record the consent preference to the use cookies’s

These cookies are stored on the user’s device for a period of 12 months.

Third-parties Cookies

Fondazione Human Technopole’s website allows the use of cookies by the following third parties:

– youtube.com

– google.com

In particular, cookies by youtube.com are required to allow the presence of videos from the aforementioned website, while cookies by google.com are used to browse statistics (see also the previous paragraph “Analytics cookie”) and view maps (Google Analytics).

The use of such cookies is carried out by the related third parties only in case of expression of consent by the user. These cookies could include also profiling cookies.

For any further detail relating to such cookies used by those third parties, including their categories and featuresplease refer to the information provided by the respective third parties, at the following link:

Google: https://www.google.com/policies/privacy/partners/

YouTube https://policies.google.com/technologies/cookies?hl=en

4.3 Activation and deactivation of cookies

Cookies other than the technical ones (browsing or session ones and functional), can be rejected by denying the consent requested at the first access to the Website.

In any case, cookies can be disabled at any time using the related browser’s functions or  via the website web Youronlinechoices

Most browsers are set to automatically accept cookies

It is allowed to disable cookies’ storage in the browser. It is also allowed to delete cookies already stored on your computer. You can use the “Help” function of your browser to obtain more information on how to proceed.

Hereinunder you may find the link which show the procedures to be followed to structure the settings of the most used browsers: Mozilla Firefox; Internet Explorer; Chrome; Opera; Safari.

5. Categories of recipients of personal data

For the purposes of the present information notice, your personal data might be processed by the subjects appointed by HT as Data Processors for purposes strictly related to the to the purposes mentioned above.

Furthermore, upon a specific request, HT is deemed to communicate data to the Judicial Authority. The communication of personal data will be carried out on the basis of the obligations provided by law.

6. Rights of the Data Subjects

Data subjects have the right to obtain, if the circumstances set out by GDPR subsists, access to their personal data and the rectification or erasure of such data or the restriction of processing concerning them or to object to processing.

7. Complaint to the Supervisory Authority

We remind you that you have the right to submit a complaint to the Supervisory Authority (Garante per la protezione dei dati personali) pursuant to Article 77 of the GDPR, if you believe that your data processing infringes the provisions of the GDPR.

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

N.	Supplier	Cell Line/Data/Project Study – Research Center
1	Stem Cell Technologies Inc	“Collection of Human Aphereis Specimens from Healthy Donors for Future Scientific and Medical Reasearch”; “Prospective Collection of non-mobilized Leukocytes via Leukapheresis for Reasearch” – Neurogenomics Research Center
2	Promocell GmbH	C-12300 Primary Cells’ Culture for laboratory, testing and benchmarking activities – Neurogenomics Research Center
3	Queen Mary University of London	“Predicting Clonal Evolution in Colorectal Cancer” – Computational Biology Research Center
4	Technical University of Dresden	IPSC line CRTDi004-A to study brain development and mechanisms underlying neurological and neuropsychiatric disorders – Neurogenomics Research Center
5	Stem Cell Technologies	70025.1 Hu PB MNC, for Project “Cryo, 1.5x10e7 “Collection of Human Aphereis Specimens from Healthy Donors for Future Scientific and Medical Reasearch“; “Prospective Collection of non-mobilized Leukocytes via Leukapheresis for Reasearch” – Neurogenomics Research Center
6	Institute for Cancer Research	Health-related data from the “EPICC: Evolutionary Predictions in Colorectal Cancer” projects for the “Multiomic evolutionary analysis of colorectal cancer” – Computational Biology Research Centre
7	American Type Culture Collection	“K562” (ATCC-CCL-243); “HL-60” (ATCC-CCL-240); “DG-75” (ATCC-CRL-2625); “Raji” (ATCC-CCL-86); “Jurkat, Clone E6-1” (ATCC-TIB-152); “HeLa S3” (ATCC-CCL-2.2) – Genomics Research Center
8	RIKEN Bioresource Research Centre	409B2 cell line derived from a biological sample of human origin – Neurogenomics Research Centre
9	Leibniz-Institut Deutsche Sammlung von Mikroorganismen und Zellkulturen GmbH	cell lines of human origin “MEL-JUSO”; “CAL-51” derived from biological samples of human origin – Computational Biology Research Centre
10	Coriell Institute for Medical Research	the “GM12878” cell line derived from a biological sample of human origin – Genomics Research Centre
11	Institute for Cancer Research	organoids derived from clinical trials “JRC 3770 “PROSPECT-C, JRC 4164 “PROSPECT-R” and related data – Computational Biology Research Centre
12	European Institute of Oncology	the cell line and related data from the “Kolf2-C1Cells and ARID2 Mutation Corrected Derivative” project – Neurogenomics Research Centre
13	Database Of Genotypes And Phenotypes	Access to the data it contains, including genetic and health-related information – Genomics Research Centre
14	RIKEN JP	Data collected for the study project “FANTOM 6 – Functional ANnoTation Of The Mammalian genome” – Genomics Research Centre
15	Telethon Network of Genetic Biobanks	biological data and samples of human origin for neurogenomic studies – Neurogenomics Research Centre
16	WiCell Research Institute Inc.	H1 and H9 cell lines for the research activities of the Centre for Neurogenomics
17	European Oncology Institute	data and biological materials of fibroblasts from the Hospices Civils de Lyon – Neurogenomics Research Centre
18	Genomics England Limited	Access to the data contained in the “Genomics England 100,000 GENOMES PROJECT” repository
19	King’s College London	Materiali biologici di origine umana (campioni di cervelletto e relativi vetrini diagnostici) e dati associati (diagnosi clinica di Alzheimer o Parkinson e dati clinici corrispondenti quali la diagnosi della malattia, durata e patologie coesistenti
20	Sanger Open Target Consortium (OTAR) Collaboration	Dati privi di elementi identificativi diretti degli interessati parte del macro-progetto OTAR e messi a disposizione da Sanger: sequenze di DNA ed RNA, count tables e dati di imaging.
21	AD Knowledge Data Repository	Dati privi di elementi identificativi diretti degli interessati, provenienti da studi scientifici che hanno indagato il declino cognitivo del cervello umano. I dati includono informazioni genetiche e relative alla salute.
22	Riken (secondary distribution) – 3H Biomedical	Campioni di RNA e relativi derivati per il progetto FANTOM5 RNA
23	Riken (secondary distribution) – Cell Applications	Campioni di RNA e relativi derivati per il progetto FANTOM5 RNA
24	Riken (secondary distribution) – Cellular Engineering Technologies	Campioni di RNA e relativi derivati per il progetto FANTOM5 RNA
25	Riken (secondary distribution) – Sciencell	Campioni di RNA e relativi derivati per il progetto FANTOM5 RNA
26	Riken (secondary distribution) – Zen Bio Inc	Campioni di RNA e relativi derivati per il progetto FANTOM5 RNA
27	Uk Biobank	Accesso ai dati del repository “UK Biobank”
28	NIHR Bioresource	Accesso ai dati del repository “NATIONAL INSTITUTE FOR HEALTH AND CARE RESEARCH (NIHR) BIORESOURCE”
29	University of Bristol	Accesso e trattamento dei dati e materiali raccolti nell’ambito del progetto “Avalon Longitudinal Study of Parents and Children” (ALSPAC)”
30	University of Kyoto	Cellule staminali pluripontenti indotte (iPS Cells) derivate da campioni biologici dei donatori che partecipano allo studio “The Generation of Human Disease-Specific iPS Cells and the Use of Such iPS Cells for Disease Analysis”
31	Hospital for Sick Children (SickKids) e Istituto Europeo di Oncologia (IEO)	Progetto “Utilizzo per finalità di ricerca scientifica del materiale di Hospital for Sick Children e Istituto Europeo di Oncologia proveniente dallo Studio “Investigation of Genetic and Environmental Factors in Individuals with Advanced or Delayed Growth with or without Developmental Delay” – TESTA LAB MOVING”
32	University of British Columbia, Provincial Health Services Authority –	Progetto “Utilizzo per finalità di ricerca scientifica del materiale proveniente dagli Studi “Weaver Syndrome associated intellectual disability: mechanistic dissection of Polycomb dependent dysregulation in patient-derived neuronal lineage” e “Enhanced CARE for RARE Genetic Diseases in Canada (CARE4RARECanada)” – TESTA LAB MOVING”
33	Human Developmental Biology Resource (HDBR) e King’s College London (KCL) per la secondary distribution	– Progetto “Utilizzo per fini di ricerca del materiale di origine umana proveniente da Human Developmental Biology Resource (HDBR) – MTA KING’S COLLEGE LONDON”
34	Hartwig Medical Foundation	Progetto “Utilizzo dei dati contenuti nel repository “Hartwig Medical Foudation” a fini di ricerca scientifica
35	Italian Network of Genetic Isolates (INGI)	Progetto “Accesso ai dati del repository “Italian Network of Genetic Isolates (INGI)” relativi agli Studi sugli isolati genetici di Friuli Venezia-Giulia, Val Borbera e Carlantino, a fini di ricerca scientifica”
36	Queen Mary University of London	Progetto “utilizzo dei dati dello studio “East London Genes & Health (ELGH)” di Queen Mary University of London a fini di ricerca scientifica”
37	European Molecular Biology Laboratory e Centre for Genomic Regulation	Progetto “Accesso ai dati del repository “European Genome-Phenome Archive (EGA)” a fini di ricerca scientifica”

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.