Privacy policy

INFORMATION ON THE PROCESSING OF PERSONAL DATA

pursuant to Article 13 of Legislative Decree 196/2003 and Articles 13 and 14 of EU Regulation 2016/679 on the protection of individuals with regard to the processing of personal data (hereinafter, for brevity, the “Regulation” or “EU REG.”) and subsequent amendments. Opera Universitaria di Trento aims to contribute to the achievement of the institution’s general strategic objectives; pursuant to and for the purposes of Articles 13 and 14 of European Regulation 679/2016, Opera Universitaria di Trento provides you with the following information regarding the processing of your personal data, including data provided by you during the provision of services through specific sections of the website, in order to process your specific requests and the resulting services.

Specific information on the processing of personal data may be provided in each section of the website or during the activation of each specific service requested from Opera Universitaria, to which reference is made.

Purpose of processing of personal data and legal basis for processing

The collection and processing of your personal data is carried out:

1. to implement the purposes of Opera Universitaria di Trento, provided for in its founding law, Provincial Law No. 9 of 24 May 1991, for the purpose of providing the services specified in that law. In such cases, the legal basis for processing consists in the performance of contractual obligations by Opera Universitaria di Trento. Specifically for registration, for the provision of scholarships, the provision of accommodation, the provision of ancillary services such as canteens, access to gyms, theater services, and participation in events and musical and literary  competitions.
2. to properly fulfill obligations established by laws, regulations, or EU legislation, as well as to comply with measures issued by authorized public authorities or by supervisory and control bodies to which Opera Universitaria di Trento is subject. In such cases, the legal basis for processing is the fulfillment of a legal obligation pursuant to Article 6.1, letter c) of the GDPR);
3. for purposes ancillary to the provision of the services provided for by Provincial Law No. 9 of May 24, 1991, such as, for example, to monitor the quality of services or statistical surveys, a one-off and unless your express opposition. In such cases, the legal basis for the processing is the data holder’s legitimate interest in a correct and timely performance of its services pursuant to Art. 6.1, letter f) of the EU REG.
4. with your explicit consent, for purposes ancillary to the provision of the services provided for by Provincial Law No. 9 of May 24, 1991, such as, for example, subscribing to newsletters, sending informational communications and promotions of services. In such cases, the legal basis for the processing is the expression of explicit consent pursuant to Art. 6.1, letter a) of the EU REG.

Nature of data provision and consequences of failure to provide data

Refusal to provide personal data or failure to consent to their processing makes impossible for Opera Universitaria di Trento to proceed with the liquidation of the requested services and to implement the purposes set out in paragraph 1, letters a) and b) of this privacy policy.

The provision of data for the purposes set out in paragraph 1, letters c) and d) of this privacy policy is optional, and the data subject is therefore free to give or deny consent. Even after consent has been given, the data subject is free to withdraw it at any time.

Data processing methods

The processing of your personal data will be based on the principles of lawfulness, fairness, and transparency, protecting your privacy and that of your family members, in compliance with the principles set out in Article 5 of the EU REG. Processing may be carried out manually, using paper documents, and also with the aid of electronic or automated means;

The data is collected and processed at the Opera Universitaria headquarters in Trento, in dedicated document archives/servers.

Your personal data is processed using appropriate technical and organizational security measures pursuant to Art. 32 of the EU REG., to ensure a level of security appropriate to the risk, minimizing the risk of destruction or loss, unauthorized access, or processing not in accordance with the purposes of collection.

Your personal data is not subject to automated decision-making or profiling.

Special categories of personal data (“sensitive data”)

Pursuant to Article 9, paragraph 1 of the EU REG., “sensitive data” means “personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.”

To achieve its purposes, Opera Universitaria di Trento may process your sensitive data, such as data relating to your health or that of your family members, as well as trade union membership.

The processing of your sensitive data will be carried out with all guarantees and in compliance with the limitations set by the EU REG. Specifically, the processing will only concern data strictly relevant to the aforementioned obligations, tasks, or purposes, which cannot be fulfilled or achieved through the processing of anonymous data or personal data of a different nature.

Sensitive data may be processed with the data subject’s explicit consent, or pursuant to Article 9, paragraph 2, letter d) of the EU Regulation, even without the data subject’s consent when the processing is carried out, in the context of its legitimate activities and with adequate safeguards, by an association or other non-profit organization pursuing trade union objectives, provided that the processing concerns only members, former members, or persons who have regular contact with the association or organization for its purposes and that the personal data is not disclosed externally without the data subject’s consent.

Furthermore, pursuant to Article 9, paragraph 2, letter h) of the EU REG., sensitive data may be processed without consent even where the processing is necessary, inter alia, for the management of health or social systems and services pursuant to Italian or European Union law.

Data communication

Your personal data will not be disclosed.

For the purposes set out in point 1) of this information notice, Opera Universitaria di Trento may need to communicate your personal data to trusted external parties, specifically:

1. professional bodies, including their territorial branches, as well as to  third-party companies, limited, where necessary, to the performance of institutional services and tasks;
2. credit institutions for banking and payment services, companies that manage electronic postal services, document archiving and storage companies, and other outsourced providers of related services;
3. healthcare facilities and medical specialists with whom it has a conventional relationship;
4. medical consultants, healthcare personnel, and legal advisors of Opera Universitaria di Trento;
5. insurance or reinsurance companies, or directly to third-parties liable in the event of a claim for compensation.

The aforementioned parties, as appropriate, will process the data as independent data controllers or “data processors,” duly appointed to do so under contractual agreements drawn up in accordance with the provisions of Article 28 of the EU REG.

Your personal data will not be transferred to a non-EU third country or international organisations. Occasionally, at the express request of the data subject, in compliance with the provisions of the EU REG., they may also be transferred outside the national territory to process payments for services at foreign banks.

Personal data retention period

Your personal data referred to in letters a) and b) will be retained for the entire duration of the contractual obligation and provided for  by the organization’s institutional purposes, and even after its termination for the time necessary to fulfill all applicable legal obligations (e.g., tax-related) and/or administrative obligations related to or arising from the contractual obligation itself.

The data for purposes c) and d) will be deleted or anonymized after 24 months.

Identity and contact details of the Data Controller and the Data Protection Officer (DPO)

The data controller is Opera Universitaria di Trento, with registered office in Trento, Via della Malpensada n. 82/A.

The data controller can be contacted at the email address: operauniversitaria@pec.operauni.tn.it or by telephone at +39 0461 217411, fax at +39 0461 217444.

The updated list of data processors, upon request, is available at the operational headquarters of Opera Universitaria di Trento.

The Privacy Officer, whom you may contact to exercise the rights provided for by the EU REG. listed in point 8 below, can be contacted using the following contact details: Opera Universitaria di Trento, Via della Malpensada n. 82/A, 38123 Trento

Fax: +39 0461.217444 – Certified Email: operauniversitaria@pec.operauni.tn.it –

Email: referenteprivacy@operauni.tn.it – Telephone +39 0461.217411.

It is also communicated that the Data Protection Officer (“Data Protection Officer”) has been appointed and can be contacted at the following email address: dpo@operauni.tn.it.

Data Subject Rights

At any time, where you may exercise them, pursuant to art. 7 of Legislative Decree 196/2003 and Articles 15 to 22 of the Regulation, you will have the right to:

• request confirmation of the existence or otherwise of your personal data
• obtain the indications regarding the purposes of the processing, the categories of personal data, the recipients or categories of recipients to whom the personal data have been or will be communicated and, where possible, the retention period
• obtain rectification and erasure of data
• obtain restriction of processing
• (where applicable) obtain data portability, i.e., receive your data from a data controller in a structured, commonly used, and machine-readable format and transmit it to another data controller without impediments
• object to processing at any time, and also in case of processing for direct marketing purposes
• object to automated decision-making concerning individuals, including profiling
• ask the data controller for access to your personal data and for rectification or erasure of your data, or for restriction of processing concerning you, or to object to their processing in additional to the right to data portability
• withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal
• propose a complaint with the Italian Data Protection Authority, located in Rome, Piazza Venezia 11, Authority’s official website: garanteprivacy.it

The exercise of these rights is not subject to any formal requirements and is free of charge.

Data Controller

The Data Controller is Opera Universitaria – Tel. +39 0461.217411 – Via della Malpensada, 82/A – 38123 Trento

The Personal Data Protection Officer (RPD) /Data Protection Officer (DPO)

The Data Protection Officer can be contacted at the following contacts: email: dpo@operauni.tn.it