Information on the Processing of Personal Data

Information on the Processing of Personal Data

Articles 13 and 14 Regulation (EU) 2016/679 (“GDPR”)

The Pontificio Ateneo Sant’Anselmo and the Badia di Sant’Anselmo are engaged in the protection and safeguarding of personal data of visitors and users of the website www.collegiosantanselmo.com. The processing of your personal data is therefore based on the principles of lawfulness, fairness and transparency and is carried out according to the terms and conditions of this Information that we invite you to read with particular attention. It contains relevant information on why and on how we process your personal data and lists your rights with regard to these treatments.

We also inform you that this Notice applies only to the activities on our Site and does not apply to personal data collected through links to external sites. As better specified below, we invite you to consult their information to know how your data will be processed.

1. HOLDER AND MANAGER OF DATA PROTECTION

The Pontificio Ateneo Sant’Anselmo, with headquarters at 00153 Rome, Piazza dei Cavalieri di Malta, 5 Tax Code 97509190589, and the Badia di Sant’Anselmo, with headquarters at 00153 Rome, Piazza dei Cavalieri di Malta, 5 Cod Fiscal 80202010585, are Joint Data Controllers of the processing of personal data pursuant to art. 26 GDPR (hereafter: the Joint Data Controllers). The relationship between the Joint Data Controllers is regulated by a specific written agreement that can be consulted on request.

The Joint Data Controllers have appointed a Manager of Data Protection (hereinafter, also MDP) who may be contacted for any request or information on the processing of personal data at: privacy@anselmianum.com

1. TYPE OF DATA COLLECTED and LEGAL BASIS OF PROCESSING

At the moment of your access and while browsing, our Website collects different categories of personal data:

• The so-called navigation data (IP address, type of browser and device parameters used to connect to the site, name of the Internet service provider (ISP), date and time of visit, web page of origin of the visitor (referral) and exit). This data is collected and used anonymously and aggregated for statistical purposes, to allow the site to work properly and for security reasons. The processing of this type of data is therefore permitted on the basis of a legitimate interest of the joint holders and does not require your consent.

On the site there are some features that allow you to reach us and interact with us.

– Through the contact pages and addresses on the site, you can interact with the administrative and accounting offices of the Ateneo and the Badia, with the registrar, with the library, with the Academic Authorities and also with the teachers of our faculties. When you send us an e-mail, we will collect your e-mail address and the data you would like to provide us (normally, name and surname, address) and that will be used by us in order to process your request. We will keep this information for as long as necessary in relation to your request. We inform you that the individual teachers of our Ateneo whose personal email address is listed on the Website, are Data Controllers or Data Processors, depending on the case, for the data that you will provide directly to them.

• Students can pre-enroll in university and pre-enroll in our courses using the specific section of the website. To this end we will ask you to provide us with your common data, those of residence, a copy of your document, a photograph of you, a certificate certifying previous studies, a letter of introduction (all in digital format) as well as information related to your income. All data is processed using manual and / or computerized and telematic tools in order to guarantee its security, integrity and confidentiality in compliance with the provisions in force. During the pre-enrollment process we may ask you or become aware of some sensitive data (for example, your health, your racial origin, your refugee status or requests for asylum) that will be processed for the sole purpose for which they are collected and will be kept for the time strictly necessary for this purpose, adopting adequate security measures. The aforementioned data are provided voluntarily and their communication is an expression of the consent of the interested party for the purposes just described. The Ateneo has prepared a specific document on the processing of student data that will be delivered at the time of registration and is available at our offices or on request at: privacy@anselmianum.com

• Our site offers interested parties the opportunity to subscribe to the platform eLearning to attend distance courses organized by the Ateneo Sant’Anselmo (see the section of the website: Programma eAnselmo). We have prepared a registration form in which we ask you to provide us with your common data, contact details, the answer to the question of whether you are a layman or religious and information about your interest in the platform. The purposes of the processing are the correct management of the requested service and the compilation of mailing lists information of the activities of the Joint Data Controllers; for this second purpose you will be asked to express an explicit consent through a flag on the form developed by Google. All data will be processed with manual and / or computerized and telematic tools in order to guarantee its security, integrity and confidentiality in compliance with current regulations. The data will be kept for the time necessary to supply the service requested by you. We inform you that the eLearning platform is located on an external site accessible at elearning.anselmianum.com and is managed by the company Moodle Pty Ltd. You can consult their information on the processing of personal data at:
  https: // moodle .com/
  privacy-notice /      

– During the course registration process and in the case of your donations we may also be aware of your tax information (personal data, social security number, VAT number) and bank (credit card number). These data are processed for the specific purpose for which they were collected (payments management) with manual and / or computerized and telematic tools in order to guarantee their security, integrity and confidentiality in compliance with current regulations.

The provision of all data listed above is optional and their processing is based on your consent. Your refusal to provide the requested data will not imply consequences simply for browsing our site but will not allow us to provide the requested service.

1. NOTES ON EXTERNAL ON-LINE SERVICES

The Website uses cookies which are small text files that allow one to collect and store information on user preferences and incorporates plugins and / or buttons for social networks in order to allow easy sharing of the content of the site on your social profiles.

Information on the use of cookies in Sant’Anselmo

The decision of the Guarantor

The Guarantor for the protection of personal data issued on 8 May 2014 the provision: Identification of the simplified procedures for the disclosure and the acquisition of consent for use cookies (Published in the Official Gazette No. 126 of 3 June 2014). This provision can be consulted on the web page

http://www.garanteprivacy.it/
web/guest/home/docweb/-/
docweb-display/docweb/3118884.

Cookies

The pages of a website may contain text, images, and other multimedia information, but may also contain “instructions” that are automatically executed by the user’s browser. The web page may also contain instructions for storing information about the user’s device (cookies).

Cookies are distinguished by a different intended use:

• Technical cookies: they only intended to improve the user browsing experience, or to provide a service expressly requested;
• Profiling cookies: they have the purpose of obtaining information on the user that can be used for purposes not requested by the user, for example, to convey advertisements of greater interest to the user.

Sant’Anselmo cookies

The provision of the Guarantor, to which reference should be made for a better definition of terms, establishes, for the protection of users, that each site declare which type (purpose) of cookies it uses.

In this regard we inform you that in general for access to the web pages / services produced by Sant’Anselmo and presented in their pages, ie pages with URLs … collegiosantanselmo.com / …, where not otherwise explicitly specified, are used exclusively technical cookies. In general, Sant’Anselmo does not produce and publish web pages that use profiling cookies.

Any exceptions to this policy are explicitly highlighted on each page / service affected by the exception.

Third-party cookies

Some web pages of Sant’Anselmo include third-party services. For these pages the privacy policy followed regarding cookies is that of external service providers to which reference is made.

The cases in which third-party services are:

• use of services that allow interaction with social networks (eg “social plugin”) or with other external platforms (eg: Youtube video display, Google Maps);
• the Ateneo search engine uses the Google indexing service;
• in the case of some questionnaires (eg: the platform eLearning) Google generation services are again used;
• in the case of use of a sharing service present on the page.

In all these cases the policy on the processing of data that is followed on cookies is established by third parties.

In accordance with the provision of the Guarantor of 8 May 2014, we report below the links with which you can examine the policies adopted by third parties regarding the processing of personal data and the use of cookies:

Google / Youtube: Cookie – Privacy ;

Google Web Fonts: Privacy – FAQs ;

Vimeo: Privacy ;

Facebook: Cookie – Privacy ;

Twitter: Cookie – Privacy ;

Soundcloud: Privacy ;

Flickr: Cookie – Privacy ;

The pages … collegiosantanselmo.com / … of the site also use the service Google Analytics which, however, has exclusively statistical purposes on aggregate and non-personal data.

How to limit the use of cookies

We also inform you that you can independently choose which cookies to give your consent by selecting the option of your liking on your browser from the service settings, reachable at the following links:

Safari – Google Chrome – Mozilla Firefox – Internet Explorer

Embedded content from other websites: more information

Some content on the site may include content from external websites (for example videos, images, articles, etc.). We inform you that the aforementioned contents follow the privacy policies and the use of cookies from the sites of origin and may therefore collect your data, use cookies, perform navigation tracking operations, and monitor your interaction with such external content in cases in which you have a limited access account with a password and you are connected to that website.

WPML

The site incorporates the commonly-used plug-in WordPress Multilingual, which uses cookies to identify the current language of the visitor, the last language visited and the language of users who have logged in. While using the plug-in, WPML will share site data through the installer. No user data will be shared.

Activity Log Plugin

If you are a registered user, your activities may be tracked and stored.

1. RECIPIENTS OF DATA

The personal data collected on our Site are intended for the administration bodies of the Joint Data Controllers, the administrative, accounting, communications and system administrators of the Joint Data Controllers, and in general to all managers, supervisors and agents responsible for the processing of data appointed by the Joint Data Controllers in the performance of their duties. The data may also be disclosed to third parties who provide external services for the management of the Site, market researchers, technical service providers, mail carriers, hosting providers, IT companies, communication agencies and those performing profiling activities. Your data may eventually be transferred abroad, in accordance with the provisions of current legislation, even in countries outside the European Union. The transfer to countries outside the EU, in addition to cases in which this is guaranteed by the adequacy decisions of the European Commission, is carried out in such a way as to provide appropriate and proper guarantees under the GDPR.

We inform you that the collected data will never be disclosed and will not be communicated to the public without your explicit consent, except for the communications necessary for the fulfillment of legal obligations.

The processing of personal data may also take place by third parties on behalf of the Joint Data Controllers; in this case the Controllers will appoint them as Data Processors and define in writing their duties and the limits of the appointment.

1. PERIOD OF CONSERVATION OF PERSONAL DATA

The personal data collected will be stored in a form that allows identification of data subjects for a period of time not exceeding the achievement of the purposes for which the personal data are processed. The data collected for purposes of inclusion in the mailing list will be kept until your request for cancellation from the service. The data relating to commercial transactions will be kept for the time required by the regulations on the conservation of accounting records. You can request from our Data Protection Manager the information on the retention period of your data and on the general principles we apply (privacy@anselmianum.com)

1. RIGHTS OF THE INTERESTED PARTY

We inform you that you are granted the following rights:

• the right to ask the joint holders access to your personal data and their correction or cancellation of the same or the limitation of treatment or to oppose their treatment,
• the right to data portability;
• the right to lodge a complaint with the supervisory authority (Manager of Data Protection).

It is also your right to obtain from the Manager confirmation that data processing is currently underway and to obtain the following information: the purposes, the categories of data processed, the recipients or categories of recipients and all information on their origin.

For all the necessary information and to exercise your rights, you can contact our MDP at the address: privacy@anselmianum.com

This Privacy Policy on the processing of personal data and on the use of cookies has been updated on 14 November 2018 and may be subject to additions or changes depending on any national or international regulatory changes applicable to the Site.

The Joint Data Controllers

Pontificio Ateneo and Collegio Sant’Anselmo
Badia di Sant’Anselmo