PRIVACY POLICY
Art.13 of Regulation EU no.679/2016
April 2024
Introduction
Under European Regulation no.679/2016 (hereinafter, the “Regulation”) and national law on personal data protection (hereinafter referred to collectively as “Privacy Law”), CENTER FOR CIRCULAR ECONOMY IN COFFEE invites you to carefully read this Privacy Policy, which contains important information on the protection of your Personal Data.
The processing of your Personal Data will be based on the principles of correctness, lawfulness, transparency, purpose and storage limitation, minimisation and accuracy, integrity, and confidentiality, in accordance with the provisions of the Regulation.
***
1. DATA CONTROLLER
The Data Controller is CENTER FOR CIRCULAR ECONOMY IN COFFEE (hereinafter “Center for Circular economy in Coffee ” and/or the “Data Controller”) with registered office in Turin – Via Bologna 32, in the person of its legal representative pro tempore.
2. DATA PROCESSORS
Your Personal Data may be processed by companies appointed as Data Processors to carry out activities related to the processing of Personal Data on behalf of Center for Circular economy in Coffee. The Data Controller has drawn up a list of Data Processors, which is constantly updated and which it makes available to you by contacting it at the addresses given in point 10 of this Notice.
3. PERSONAL DATA PROCESSED
- Personal details
- Contact information
- Geolocation and/or Internet browsing data
- Photographs and/or video recordings
- Information provided through requests sent to the Center for Circular economy in Coffee
4. PURPOSES AND LEGAL BASIS OF THE PROCESSING
In accordance with the needs associated with accessing the various sections of the Center for Circular economy in Coffee websites (and without prejudice to the individual initiatives that involve the provision of specific Personal Data, for which specific privacy notices will be published on a case-to-case basis), the purposes of the processing of your Personal Data and the related legal grounds are indicated below:
- Management of requests and/or initiatives: Personal Data will be collected in order to answer requests sent to us via email, via website and/or via social networks such as, by way of example but not limited to, requests relating to (a) submission of projects, best practices, (b) applications to become a new member of the Center for Circular economy in Coffee, (c) managing participation in our initiatives; d) handling of general information requests. The legal bases for this processing are the execution of the contractual measures and the legitimate interest of the Data Controller.
Other purposes:
- Marketing: Subject to your specific consent, we may process your Personal Data in order to send you, by e-mail/SMS, commercial communications as well as to invite you to take part in our promotional initiatives, to participate in our events and to register for our newsletter. The legal basis of this processing is the Consent of the Data Subject, which can be withdrawn at any time.
- Sharing data with Founding Members for their purposes: we share your contact data with Founding Members for their autonomous purposes. This processing is based on your prior consent. The full list of Founding Members can be found in the dedicated section of this website.
In addition to the previous cases:
- Analysis purposes: the Personal Data you have provided when interacting with the Center for Circular economy in Coffee world and the information regarding this interaction will be collected in our database and will be used to anonymously analyse and improve the services we offer, to assess the efficiency of the activities and initiatives promoted by Center for Circular economy in Coffee and to conduct statistical analysis on the composition of the database. The legal basis of the processing is the legitimate interest of the Data Controller.
- Any other purpose for which you have provided your specific consent can be withdrawn at any time.
5. NATURE OF THE PROVISION
The provision of your Personal Data, depending on the purpose pursued, could have optional or obligatory nature. When the nature of the provision is mandatory it means that failure to provide the required Personal Data may affect the possibility to use some services (e.g. to fill in the form to become a member). When the nature of the provision is optional you will have the possibility to take advantage of basic services but not additional services (e.g., to provide consent to receive promotional communications).
The compulsory or optional nature of the provision of your Personal Data will be marked each time using symbols (e.g. “*”) placed next to the information that requires the provision of data for the respective purpose.
6. PROCESSING METHODS
Your Personal Data will be processed in compliance with the provisions of current Privacy Law with the use of electronic or automated means and manual methods, strictly following the purposes for which the data has been collected, via databases, the electronic platforms managed by the Center for Circular economy in Coffee or by third parties (appointed as Data Processors), the integrated IT systems of Center for Circular economy in Coffee and the aforesaid third parties, and/or websites owned or used by Center for Circular economy in Coffee.
Your Data will be processed using methods that ensure the highest level of confidentiality and only by people trained and authorised to process it. The Data Controller adopts all the appropriate technical and organisational measures to ensure a level of security appropriate to the risk presented in relation to the processing.
The Personal Data will be processed mainly at the offices of the Data Controller and at the places where the Data Processors are located.
7. SHARING AND TRANSFER OF PERSONAL DATA
Your Personal Data may be made accessible, for the purposes stated above, to Founding Members of Center for Circular economy in Coffee.
The Personal Data you provide may be transferred to third-party companies located within, as well as outside, the European Union/ European Economic Area. These companies carry out the aforementioned activities concerning treatments of personal data on behalf of the Data Controller and will operate as Data Processors.
Transfers of personal data to Center for Circular economy in Coffee third-party located outside the EU/EEA are made in accordance with Chapter V of the Gdpr. In particular, they are based on Standard Contractual Clauses (SCC) approved by the European Commission. To obtain copies of these SCCs please contact the Controller at the addresses listed in Section 10 of this Privacy Policy.
Finally, your Data may be sent to the judicial authorities where necessary and in the cases provided for by law.
8. STORAGE PERIOD OF THE DATA
In order to ensure compliance with the principles of necessity and proportionality of the processing, we have defined various Personal Data storage periods for the individual purposes described:
- The data collected for the sending of promotional material, for which consent has been given, will be stored for a period of no longer than 24 months or for any other period of time that may be indicated by the supervisory authorities. If you have not provided the above consent, your personal data will be made anonymous and used for statistical analysis.
- The data collected in order to manage and answer requests of the Center for Circular economy in Coffee and the data provided when interacting with the Center for Circular economy in Coffee world will be stored for the period necessary to carry out the requests and will subsequently be deleted if there is no further contact, except for administrative requirements (for instance, a request concerning a complaint will be stored beyond the period needed to solve it, in order to fulfil administrative requirements).
9. RIGHTS OF THE DATA SUBJECT
You can exercise the rights set out in articles 15 et seq. of the Regulation vis-à-vis the Data Controller at any time, including:
- the right to obtain confirmation as to whether or not personal data concerning you exists, regardless of it being already recorded, and communication of such data in intelligible form;
- the right to withdraw the consent you have given for the purposes of the processing at any time;
- the right to access, rectify, erase and limit the processing and portability of your personal data;
- the right to object to its processing any time you wish.
- the right to commence proceedings before the competent supervisory Authority, if you think that the processing of your data is contrary to the laws in force.
10. METHODS FOR EXERCISING YOUR RIGHTS
If you wish to exercise the aforesaid rights, or you wish to have more information on the processing of your personal data, please write an email to info@circulareconomyincoffee.org