Privacy Statement and Cookies Policy

The International Telematic University UNINETTUNO (hereafter referred to as UNINETTUNO), based in Rome (Italy), Corso Vittorio Emanuele II n. 39 (Tax Code Nr. 97394340588), in its capacity of “Holder of the Treatment” communicates you, in compliance with the art. 13 of the EU Regulation 2016/679, the following information concerning the treatment of the personal data of the users of portal and of the services available at the following links:
http://www.uninettunouniversity.net, http://www.uninettuno.it and http://www.uninettuno.tv .

1. Nature of the treated data, modes and aims of the treatment.
   The navigation and consultation of the portal can imply the treatment of the following data that can be directly or indirectly referred to the user:
   • Navigation data: they are technical information that are automatically acquired by the information system during consultation, through communication protocols; these data are used only to obtain anonymous statistical information on the use of the portal and to check its functioning and are not associated to identifiable users, even if they may allow to indirectly identify the user by association with data owned by third parties.
   • Data actively communicated by the user: these are the user's personal data entered in the information request form; these data are used to process the request and answer the user. Only on the basis of the user's express authorization, stated by ticking the relative box in the information request form, the contact data (email and telephone) can be used to send promotional messages and other direct marketing communications concerning UNINETTUNO's activities.
   • Data for using online services: these are the personal data of the user required to carry out his registration and online acknowledgement to the restricted area of the portal and allow the use of the relative services. The data relating to personal credentials are recorded to allow the automatic authentication procedure, while the information relating to the date and duration of accesses are recorded for security reasons.

2. Use of necessary technical cookies.
   The collection of navigation data is based on the use of cookies.
   Cookies are small text strings that are sent to the processor (PC, notebook, smart phone, tablet etc.) by the user while consulting the portal and that are stored in the browser to be retrieved on the following occasion of consultation.
   UNINETTUNO portal utilizes only “technical cookies” (that is to say those that are aimed at the online transmission of the information and services requested by the user) to assure the general navigation and use of the services also in function of selected criteria (for example, the selected language) whose effectiveness is for the most part limited to the duration of browsing activity on the site. The use of these cookies does not require the consent of the concerned person.
   The UNINETTUNO portal also utilizes Matomo's analytics cookies aimed at collecting information, in aggregate form, on the number of users who have visited the portal and their consultation mode to generate internal statistical data on the use of the portal in order to improve the services offered, the effectiveness of which is limited to one day in the case of the "pk_ses#" cookie and one year after its installation in the case of the "pk_id#" cookie.
   In both cases, the data collected is not transmitted to third parties. The use of these cookies also does not require the consent of the concerned person.
   Finally, the UNINETTUNO portal utilizes cookies from Google Inc. to perform the CAPTCHA test. These cookies are necessary to implement the security measure known as Challenge/Response authentication: the CAPTCHA test protects the owner from spam by asking to pass a simple test that proves that the user is a person and not a computer. The effectiveness of Google Inc. cookies is limited to the duration of site browsing activity in the case of the "rc::c" cookie and is persistent in the case of the "rc::a" cookie. The use of these cookies does not require the consent of the concerned person.
   No cookies are used for promotional or advertising purposes, even if they are from third parties (so called "profiling cookies").

3. Juridical bases of the treatment of data.
   The treatment of the above-mentioned personal data of the user to allow the navigation inside UNINETTUNO’s portal and to forward requests is necessary and instrumental to the use of the online services and, consequently, it is, therefore, required for the execution of the contract of which the concerned person is part or to the execution of pre-contractual measures adopted upon demand of the user himself. For this reason, the treatment does not require the consent of the concerned person.
   The processing of the user's personal data for promotional and direct marketing purposes is based on the consent of the person concerned. Such consent is free and does not condition the consultation of the website or the request for information; it can be revoked at any time and without any reason through UNINETTUNO's communication channels.
   Finally, the processing of the user's personal data for the generation of internal statistics and for access and communication security reasons is based on UNINETTUNO's legitimate interests.

4. Duration of data storage.
   The duration of storage of navigation data collected through the use of cookies varies: some are deleted automatically by the system at the end of the session, others are deleted within one day, one year or two years, others are persistent, as better specified at paragraph 2 above.
   The data actively communicated by the user are kept for a maximum of 180 days and if, within this period, the contract is not concluded, they will not be communicated to any other subject and will be deleted, while the personal data necessary to send promotional communications are kept until the termination of the activity or the revocation of consent.
   Finally, the data for the use of online services are stored until the end of the contract relationship and then will be archived until the expiry of the normal barring-periods terms referred to in art. 2946 of the Italian Civil code (10 years) and then deleted.

5. Recipients of the data.
   

   The personal data of concerned person are processed and stored on servers located within the European Union owned by and/or at the disposal of UNINETTUNO and/or of third party companies duly appointed as data processors. Therefore, personal data may be communicated to these managers for the supply of the services entrusted to them.
   The possible transfer abroad of the data in non-EU countries takes place in compliance with the provisions of the EU Regulation 2016/679 (GDPR).

6. Rights of the concerned person.

   Every concerned person has a right to ask for:

   • Access and correction of inaccurate personal data concerning him/her;
   • Integration of incomplete ones;
   • Elimination of personal data in case of they were unlawfully treated or in case their elimination is necessary to comply with a legal obligation;
   • Limitation of the treatment to only personal data related to him of which the concerned person does not deny the accuracy, pending completion of checks on the denied ones and be informed before the above-mentioned limitation is removed;
   • Return of the provided personal data, in a structured format, of common use and readable by an automatic device, or the transmission of them to another holder of the treatment, also in a direct way, if technically feasible. The personal data that were not provided by the concerned person and those treated for the performance of task of public interest or connected to public powers of which the Holder of the treatment is responsible are excluded.

   In addition, at any time, the concerned person has the right to object, pursuant to Article 21 of EU Regulation 2016/679, to the processing of his/her personal data carried out on the basis of a legitimate interest, alleging legitimate reasons related to his/her particular situation.
   All requests can be forwarded to UNINETTUNO at its registered office, or to the following addresses: tel. +39 06 692076.70 | +39 06 692076.71 or e-mail: info@uninettunouniversity.net.
   In the event that the data subject considers that the processing concerning him/her is in breach of EU Regulation 2016/679 or that the Data Controller has not complied with its obligations related to the exercise of the aforementioned rights, he/she has the right pursuant to Article 77 of the same Regulation to lodge a complaint with the Supervisory Authority located in the Member State where he/she normally resides or works, or with the one located in the place where the alleged breach occurred. This is without prejudice to any other administrative or judicial recourse.

7. Person responsible for data protection.
   

   The person responsible for data protection is Lawyer Gaetano Giordano who can be contacted via e-mail at the following address: dpo@uninettunouniversity.net or by tel./fax at the following number: +390637511524. The concerned people can contact him as regards any matters related to the treatment of their personal data and to the exercise of their rights ensuing from the above-mentioned Regulation. He has the duty of confidentiality as regards the performance of his functions.