The Global Campus of Human Rights ETS with registered office in Venice Lido (VE), Riviera San Nicolò, 26, P.Iva / C.F. in the header (hereinafter also “Global Campus”, “GCHR” or “Owner”), as Data Controller (in the person of the pro-tempore legal representative), informs you, in accordance with art. 13 of Legislative Decree 196/2003 and subsequent amendments (“Privacy Code”) and of EU Regulation 679/2016 applicable from 25 May 2018 – General Data Protection Regulation (“GDPR”) (from now on Privacy Code and GDPR are collectively referred to as “Applicable Regulations”), that your data will be processed in the manner and for the following purposes:
Personal data subject to processing
“Personal Data” means any information relating to an identified or identifiable natural person.
Personal data provided directly by the data subject
Global Campus processes the Personal Data necessary for the pursuit of the purposes listed below.
During the processing activity, personal data of third parties sent by you to Global Campus may be processed.
With respect to these hypotheses, it acts as an independent data controller, assuming all legal obligations and responsibilities. In this case, it confers on this point a broader indemnity with respect to any dispute, claim, request for compensation for the damage of the treatment, etc. that should reach Global Campus from third parties. In any case, if you provide or otherwise process personal data of third parties for the use of the services requested by you, you guarantee, from now on – assuming all related responsibility – that this particular hypothesis of treatment is based on an appropriate legal basis pursuant to of the art. 6 of the Regulation which legitimizes the processing of the information in question.
In particular, the processing will concern: personal data (name, surname, ID, GCA access password, year of birth, nationality, image), contact data (email, telephone number, address) and data concerning your academic curriculum (year of degree, organization name, languages spoken / written, topics of interest, academic background) and professional background.
Purpose of data processing and legal bases
The personal data concerning you, which are normally directly provided by you or communicated by autonomous data controllers (associated universities) and occasionally gathered from sources accessible to the public, are processed by Global Campus for the following purposes:
a) Establishment, management and termination of the contractual and commercial relationship of which you are a party or the execution of pre-contractual measures adopted at your request:
1) Registration, storage and updating of the personal data of the interested parties within the GCA (Global Campus Alumni),
2) management of the GCA database to promote interaction between members in order to strengthen professional relationships and promote work in the Global Campus of Human Rights regional hubs.
For these purposes, the provision of personal data is mandatory and therefore we do not ask you to give your consent. Any partial or total failure to provide the data will result in the partial or total impossibility of achieving the aforementioned purposes.
For these purposes, the legal basis is for common data: art. 6 par. 1 letter b) GDPR (execution of a contract of which the interested party is a party).
b) Purposes necessary to ascertain, exercise or defend a right in court or whenever the judicial authorities exercise their judicial functions.
For these purposes, the Data Controller may process personal data without your consent because it represents a legitimate processing of Personal Data pursuant to the Applicable Law since, once the Personal Data has been provided, the processing is indeed necessary to fulfill a legal obligation to to which the Data Controller is subject pursuant to art. 6 par. 1 letter c), in case of emergence of particular data, the legal basis is art. 9 par. 2 lett. f) GDPR ,; in case of emergence of data relating to criminal convictions and offenses, the legal basis is art. 10 GDPR.
c) Purposes for which it is necessary that you give your consent to the processing of your personal data: in particular for the following purposes:
1) management of cultural / recreational activities, courses, events and other GCA projects aimed at promoting the network;
2) to process studies, research, market statistics, send you advertising, promotional, informative material, commercial information or surveys on the services offered by Global Campus through email, instant messaging and / or through the official pages of Global Campus on social networks, apps.
The provision of data for these purposes is optional and your consent pursuant to art. 6 par. 1 letter a) GDPR is necessary. Any refusal to provide data does not in any way affect your membership in the GCA network.
We therefore ask you to express, through the attached form, your consent, or not, to the processing of such data. Any consent given may be revoked at any time without prejudice to the lawfulness of the processing based on the consent given before the revocation.
Data processing methods
The processing of your personal is carried out by IT, telematic and manual tools, with logics strictly related to the purposes themselves and, in any case, in order to guarantee their security.
Categories of subjects to whom the data may be communicated
The personal data provided may be disclosed to recipients, appointed pursuant to art. 28 of EU Reg. 2016/679, who will process the data as managers and / or as natural persons acting under the authority of the owner and manager, in order to comply with contracts or related purposes. Specifically, the data may be disclosed to recipients belonging to the following categories: subjects who provide services for the management of the information system and communication networks of Global Campus, studies or companies in the context of assistance and consultancy relationships, competent authorities for compliance of legal obligations (on request).
The subjects belonging to the aforementioned categories perform the function of Data Processing Manager, or operate in total autonomy as separate Data Controllers. The list of designated data processors is constantly updated and available at the Global Campus headquarters.
The Data will also be processed by resources inside the Global Campus offices, adequately trained, who operate as personnel authorized to process the Data.
Personal data may be transferred abroad within or outside the European Union, within the limits and under the conditions set out in Articles 44 and ss. of EU Regulation 2016/679 specifically:
- towards third countries international organizations for which the Commission intervened with an adequacy assessment (Article 45 of EU Reg. 2016/679)
- to third countries or international organizations that have provided adequate guarantees and from which the interested party has enforceable rights and effective remedies (Article 46 of EU Reg. 2016/679);
- towards third countries international organizations on the basis of exceptions in specific situations (Article 49 of EU Reg. 2016/679).
The data will be transferred:
- to Authorities abroad, upon request, in the event that it is necessary to verify the qualification.
Your personal data will be kept, starting from their receipt / update, for the time necessary to achieve the purposes described above. In particular
- for the purposes referred to in points a) and c1) unlimited, up to the exercise of the right of opposition, also constituting an archive for the purposes of scientific research;
- for the purposes referred to in point b) for the time allowed to the Data Controller by Italian law to protect their interests (Art. 2947 co. 1 and 3 of the Italian Civil Code);
- for the purposes referred to in point c2): 24 months and in any case until the withdrawal of consent or until the exercise of the right of opposition art. 21 GDPR
The rights of the interested party
Within the limits of the Applicable Law, you have the right to ask Global Campus, at any time, to access your Personal Data, to rectify or delete them or to oppose their processing, limitation of processing and to obtain in a structured format, commonly used and readable by an automatic device, the data concerning you.
Requests should be sent via e-mail to the address: email@example.com
Pursuant to the Applicable Law, you have in any case the right to lodge a complaint with the competent supervisory authority (Guarantor for the Protection of Personal Data) if you believe that the processing of your Personal Data is contrary to current legislation
This information update is effective from 20 July 2020. Global Campus reserves the right to modify or simply update its content, in part or completely, also due to changes in the Applicable Regulations. Global Campus will inform you of these changes as soon as they are introduced and will be binding as soon as they are sent to the interested party for the purposes for which consent is not required.