Operational team
Privacy Policy in accordance with art. 13 GDPR
SMACT (società consortile per azioni (“SMACT”) is a competence center having its registered office in Venezia, Fondamenta S. Giobbe – Cannaregio 873, ZIP code 30121 (tax code and VAT n. 04516580273) and is the Data Controller of the personal data which you will provide by using the website www.smact.cc (the “Website”). In this Policy we will also refer to you as the “Data subject”, that is the person to whom the personal data relate.
The Data controller has appointed a DPO (“Data Protection Officer”), which you may contact at: privacy@smact.cc.
If you have any doubt regarding the processing of your data or if you want to exercise your rights, please write to: info@smact.cc, or per certified e-mail to: smact.competencecenter@legalmail.it.
Which personal data do we collect?
Through the Website, we collect the following data:
- Browsing data: the computer systems and software procedures used to operate the Website collect some personal data, whose transmission is an integral part of Internet communication protocols. We cannot directly identify you through such data, but this could still be possible in the event that they are elaborated and associated with other set of data provided elsewhere. We collect in particular information about:
• your IP address;
• the URI (Uniform Resource Identifier) of the requested sources;
• the time and date in which you use the Website;
• the operating system, the browser used, the screen resolution and other information relating to the device environment.
- Data provided on a voluntarily basis (e.g., name, e-mail address): SMACT will process these data, in accordance with the applicable law, to achieve the purposes specified in each form and in this Policy. The indication of certain data is compulsory in order to ensure the correct performance of the services required to the Data Controller. We presume that the data you communicate refer to you or to third parties who have authorised you to provide them. In this case, you assume all relevant obligations and responsibilities.
How do you process my data? On which legal basis?
In all the cases in which SMACT processes your data, it is allowed to do so pursuant to a specific legal basis which legitimate the processing.
Sometimes we need your consent to process your personal data, for example in order to send you newsletter.
Other times, when the applicable law allows it and having respect to your rights, SMACT may process your data without asking your consent. We are allowed to do so when we process your data to comply with a legal obligation or to reply to a request that you made by contacting SMACT or by requiring services through the Website.
Any refusal to provide data which are indicated as “necessary” may prevent SMACT from replying to your requests or from complying with legal obligations to which SMACT is subject.
At the end of the data retention period, the collected personal data will be irreversibly anonymised or deleted.
Personal data subject to processing:
Data provided to create a new account in the reserved area
Purposes:
1) to give you the possibility to subscribe to our events and courses and to take advantage of all our services;
2) to send you newsletter and communications, with your consent
Legal basis:
6.1.a GDPR - Consent
6.1.b GDPR – Contract or steps prior to entering into a contract
6.1.c GDPR – Legal obligation
Retention period:
Until the deletion of the account. You can withdraw your consent to marketing communications at any time, even if you want to keep your account open
Personal data subject to processing:
Data provided through the contact form
Purposes:
1) to respond to your requests;
2) to offer you technical support
Legal basis:
6.1.b GDPR – Contract or steps prior to entering into a contract
Retention period:
For the duration necessary to respond to your requests
Personal data subject to processing:
Data provided in e-mails sent to SMACT’s addresses
Purposes:
1) to respond to your requests
Legal basis:
6.1.b GDPR – Contract or steps prior to entering into a contract
Retention period:
For the duration necessary to respond to your requests. For the period necessary for the establishment, exercise or defence of legal claims
Personal data subject to processing:
Data collected through cookies
Purposes:
1) as regards technical or analytics cookies, to track your activities on the Website, in order to improve our services;
2) as regards profiling cookies, the data collected with your previous consent may be processed also by third parties (as indicated in the Cookie Policy https://www.smact.cc/cookie-policy) and will be used to show you targeted advertisement on this and on other websites; if you do not accept them, you will still see advertisements, but it will not be based on your interests
Legal basis:
6.1.a GDPR - Consent
6.1.b GDPR – Contract or steps prior to entering into a contract
Retention period:
Until the end of each browsing session or for the retention period indicated for each specific cookie (https://www.smact.cc/cookie-policy)
Will my data be shared with other subjects?
Your personal data may be disclosed, in close relation to the purposes specified above, only to:
- subjects authorised by SMACT to process personal data, that are committed to, or under, an appropriate statutory obligation of confidentiality;
- subjects in charge of the maintenance of the Website and to our legal or tax consultants, who will act as data processors or data controllers;
- the provider of the platform to which the Website is connected.
If you accept third parties’ cookies, your data will be shared with the subjects indicated in our Cookie Policy (https://www.smact.cc/cookie-policy).
In case of a payment through the Website, you will be redirected to another website, which will process your data as autonomous Data Controller.
On the Website you find some links which lead to the social network pages of SMACT, to allow an easy access to those contents. Such links do not send your personal data to the social networks as long as you are on our Website and do not click on them. The processing of personal data by social network platforms is regulated by their own privacy policies.
How can I delete my personal data?
If you create an account on our Website, you may delete it at any time by accessing the Reserved Area and clicking on “Delete account”, or by writing an e-mail to: info@smact.cc. To delete cookies, follow the instructions of our Cookie Policy (https://www.smact.cc/cookie-policy).
Which rights do I have as Data subject?
You will always keep control on your personal data.
More specifically, you have the right:
- to request information about the personal data processed by SMACT and to receive in a structured, commonly used and machine-readable format the personal data concerning you;
- not to be subject to a decision based solely on automated processing, unless you have provided your explicit consent;
- to ask the Data Controller the rectification or the erasure of your personal data or the restriction of their use only for certain purposes;
- to change your idea and ask us to stop processing your data, for example by deleting your account.
In some limited cases we may not be able to comply with your requests, as long as it is forbidden by law provisions or by the act of a public authority.
The requests to exercise your rights shall be sent to the Data Controller: info@smact.cc, or per certified e-mail to: smact.competencecenter@legalmail.it.
In any case, you have the right to lodge a complaint with the relevant supervisory authority (Data protection Authority) if you believe that the processing of your personal data is against the applicable law.
Where do you store my data?
We store your data also in servers located outside the European Union.
However, the service providers, as external Data Processors, declare that the third countries guarantee an adequate level of protection of data subjects rights by virtue of compliance with one or more of the conditions set out in Articles 45-47 of the GDPR. Data collected by third parties’ cookies may be transferred to Third countries as provided for in our Cookie Policy (https://www.smact.cc/cookie-policy) and in such third parties’ privacy policies.
Will you amend this Privacy Policy?
SMACT reserves the right to amend or update the content of this Privacy Policy whenever necessary. In the event of substantial amendments, especially referring to the purposes of processing, we will inform you by sending an e-mail to the provided e-mail address. If you do not agree with the amendment, you will be free to quit using our services, by deleting your account on the Website and/or by avoiding the communication of additional data.