The Fondazione 1563 per l’Arte e la Cultura della Compagnia di San Paolo (hereinafter also referred to as the 1563 Foundation) and Fondazione Museo Nazionale dell’Ebraismo Italiano e della Shoah (hereinafter also referred to as MEIS Foundation) have organised a cycle of webinars as part of their project ”REMEMBR-HOUSE: An educational KIT to raise awareness on the Holocaust and promote knowledge of civil rights and EU values” (hereinafter the Project ).The 1563 Foundation and the Meis Foundation have undersigned a Joint Controllership Agreement pursuant to article 26 of EU Regulation 679/2016, jointly determining the purposes and means of processing of personal data in relation to the Project. The present information on data processing includes all the manners and ways data will be gathered during and for webinar events, registering through the ZOOM platform and/or third party platforms and sub-platforms.
The Data Controllers are:
The Fondazione 1563 per l’Arte e la Cultura della Compagnia di San Paolo in the person of its pro tempore legal representative Piero Gastaldo, with registered office at Corso Vittorio Emanuele II, 75, Tax Code 97520600012 – contact e-mail: privacy@fondazione1563.it, and
The Fondazione Museo Nazionale dell’Ebraismo Italiano e della Shoah (hereinafter also referred to as Fondazione MEIS) Tax Code 93072970382 and VAT No. 01938920384 registered office in Ferrara, at Via Piangipane, 79-83, in the person of its pro tempore legal representative – contact email: privacy@meisweb.it
Processing purposes: data are processed in the context of everyday activities: institutional obligations, cultural production/archiving for historical and scientific research purposes, pre-contractual measures, implementation of legal obligations, contractual, administrative, accounting, banking, insurance obligations.
The 1563 Foundation and the Meis Foundation are Joint Data Controllers for the following:
Processing Purposes:
- Enable participant registration to the specific event;
- Perform management, accounting, administrative and account reporting activites, any contractual obligation including the publication of data in aggregate form on the EU Portal, and the delivery of the copy of attendance registers, management, rendering of accounts, administrative reports and insurance obligation to the relevant EU Agency;
- Recording and publishing the webinar on external media, such as the Internet or Social Media pages.
At the time of registration, Participants GRANT the Controller and Joint Controllers the right to film and/or record his/her image, voice, name, intervention and performance during the webinar meetings, and to use recording and filming means of authorised third parties/Processors/Sub-controllers, by photographic and phonographic means on digital or any other current support. The undersigning of the present disclaimer is voluntary but necessary to attend and participate in the webinar meetings. The Controllers/Joint Controllers retain the right to use and publish such videos, images and recordings, even after two years from the event, as part of communications to the press, for editorial purposes or disseminated on institutional social networks and websites, in any venue permitted by law, by any means known or to be invented in the future, within the limits of the law, of all copyrights, rights granted and in any case of any other right relating to the image and in full respect of the dignity and decorum of the subject filmed.
Applications/requests to participate in the events will entail the collection/gathering and subsequent processing of personal data provided directly by the interested parties and strictly necessary to attend and/or partake in the event: first name, family name, organization, e-mail address, country of residence, gender and age.
Specific data, such as the body or agency users belong to, may indirectly require processing data referred to distinctive groups or categories such as ethnicity or religious beliefs. The processing of the above data will require users’ consent, that will be granted by filling in the data in the registration form.
During the webinar, names as well as images and audio-recordings maybe included (recorded).
Legal basis for processing:
- pre-contractual measures/contractual obligations for the purposes listed in point 1;
- fulfilment of legal obligations for the purposes listed in point 2;
- consent the relevant participant will have indicated by sending the participation form and when accessing the online platform.
Withdrawal of Consent
Interested parties may withdraw the consent granted for the aims in 3 at any time. Following withdrawal of consent, the data controller will cease to process such data as well as removing, obscuring, or masking previously published images where possible.
Data processing methods: the data will be processed using manual, computerised and telecommunication tools for reasons strictly related to the purposes themselves and, in any case, in order to guarantee the security and confidentiality of the data.
Nature of Data Provision
Data provision is required to enable registration and participation to the event. Data provision for the aims listed in point 3 is optional. If the interested parties do not wish to be filmed, they may freely disconnect video and audio recording from their devices.
List of the subjects that may receive data:
In the interest of the 1563 Foundation:
- Fondazione Compagnia di San Paolo (Joint Controllership Agreement pursuant to article 26 , EU Regulation 679/2016 consistently with governance principles regarding Internal Audit activities)
- Prisma – Progetti, Innovazione, Soluzioni e Management S.c.a.r.l. (External data processing company operating under a service provision agreement)
- Suppliers, professionals, including those working in associated form(e.g. to fulfil legal/judicial, tax-related or accounting obligations), if necessary appointed as external data processors.
- Local Authorities and Public Bodies
In the interest of the MEIS Foundation
- Suppliers, professionals, including those working in associated form(e.g. to fulfil legal/judicial, tax-related or accounting obligations), if necessary appointed as external data processors.
- Local Authorities and Public Bodies
Under the Joint Data Controller Agreement
- Prisma – Progetti, Innovazione, Soluzioni e Management S.c.a.r.l. (External data processing company operating under a service provision agreement)
- Alicubi Srl (external data processor in respect of the Project website creation assignment) Relevant EU Agency for the Project
- Designated Persons pursuant to article 2(14) of Legislative Decree 196/2003, as amended by Legislative Decree 101/2018. 101/2018
- Authorized Persons pursuant to article 29 GDPR
Data retention period: the data will be retained until the purposes for which they were collected have been achieved, for ten years as allowed by current tax, civil, anti-money laundering laws, or until the validity of the contractual obligations referred to in the Project and the related statute of limitations/forfeiture terms have expired, without prejudice to the legitimate interest of the Data Controller, legal obligations.
Personal data may be retained for longer periods provided that they are processed exclusively for storage purposes in the public interest, for historical or scientific research or for statistical purposes, in accordance with Article 89(1), without prejudice to the implementation of technical and organizational measures required by EU Regulation 679/2016 and current sector legislation protecting the rights and freedoms of the data subject (“storage limitation”).
Data transfer
The data are stored on the servers of the respective Data Controller, or at third-party companies appointed as external data processors, processing the data on behalf of the individual Data Controller, whose servers are located within the European economic area. In the event of transfer outside the EU, the standard contractual clauses will be signed as required by Decision 2021/914/EU, the provisions of the Italian Data Protection Authority (Garante per la protezione dei dati personali) and article 46 of EU Regulation 679/2016.
Rights of the data subject: You can contact the Data Controller at the above email address to exercise your rights, as provided for by EU Regulation 679/2016 and Legislative Decree 196/2003, as amended and supplemented, and therefore: request access to personal data, rectify or delete data, restrict or object to data processing. You can also exercise the right to data portability or the right not to be subjected to a decision based solely on automated processing.
Data may be communicated through the above listed channels.
Rights of the data subject: You can contact the Data Controller at the above email address to exercise your rights, as provided for by EU Regulation 679/2016 and Legislative Decree 196/2003, as amended and supplemented, and therefore: request access to personal data, rectify or delete data, restrict or object to data processing. You can also exercise the right to data portability or the right not to be subjected to a decision based solely on automated processing.
Under the Joint Controllership Agreement, Fondazione MEIS has assumed the role of coordinator so you may use the following contact address: privacy@meisweb.it. If the processing is based on article 6(1)(a) or – without prejudice to the application of article 9(2)(j), on article 9(2)(a), you are entitled to withdraw your consent at any time without prejudice to the lawfulness of the processing based on the consent given before the revocation.
You are also entitled to lodge a complaint with a supervisory authority.
Finally, we inform you that your data will be:
- processed lawfully, fairly and transparently;
- collected for the explicit and lawful purposes specified above, and subsequently processed in a way that is not incompatible with these purposes;
- appropriate, relevant and limited to what is required for the purposes for which they are obtained and processed (“data minimisation”);
- accurate and, if necessary, updated, deleted and/or corrected;
- processed in such a way as to guarantee adequate security of the personal data – including protection, through appropriate technical and organizational measures – in order to protect them from unauthorised or unlawful processing and from accidental loss, destruction or damage.
The information referred to in this document and any communications and actions undertaken pursuant to articles 15 to 18 and articles 20 and 21 of EU Regulation 679/2016 is free.
If the requests of the interested party are manifestly unfounded or excessive, in particular due to their repetitive nature, the Data Controller may:
- charge a reasonable fee to cover the administrative costs incurred in providing the information or communication or taking the requested action; or
- refuse to fulfil the request. The burden of demonstrating the manifestly unfounded or excessive nature of the request falls on the Data Controller.