IterCulture APS, with registered office in Via Enrico Fermi 6 – 95019 Zafferana Etnea (CT), VAT no. IT04653220873, as Data Controller, hereby informs you pursuant to Article 13 of EU Regulation 2016/679 (GDPR) that your personal data will be processed according to the following methods and purposes:
IterCulture APS processes personal identification data (such as name, surname, company name, address, telephone number, email address, bank and payment details – hereinafter referred to as “personal data” or “data”) provided upon registration with the Organisation or upon entering into contracts for requested services.
Personal data is processed:
A) Without express consent (Article 6(1)(b) and (c) GDPR), exclusively for the following Service Purposes: i) concluding contracts for the services of IterCulture APS; ii) fulfilling pre-contractual, contractual, and tax obligations arising from existing relationships with you; iii) complying with obligations laid down by law, regulations, European Union legislation, or orders issued by an Authority (such as anti-money laundering regulations); iv) exercising the rights of IterCulture APS, such as the right to defence in legal proceedings.
B) Only subject to specific and separate consent (Article 7 GDPR), for the following Marketing Purposes: i) sending newsletters, commercial communications, and/or advertising material regarding products or services offered by IterCulture APS, as well as conducting customer satisfaction surveys on service quality, via email, post, SMS, and/or telephone calls; ii) sending commercial and/or promotional communications from third parties via email, post, SMS, and/or telephone calls.
The processing of personal data is carried out by means of the operations indicated in Article 4(2) GDPR, namely: collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction. Your personal data is subject to both hard-copy and electronic and/or automated processing. IterCulture APS will process personal data for the time necessary to fulfil the aforementioned purposes, and in any case for no longer than 10 years from the termination of the relationship for Service Purposes, and no longer than 2 years from data collection for Marketing Purposes.
Data may be made accessible for the purposes set out in Sections 2.A and 2.B: A) to employees and collaborators of IterCulture APS in their capacity as authorised persons and/or internal data processors and/or system administrators; B) to third-party companies or other entities (by way of example, credit institutions, professional firms, consultants, insurance companies for the provision of insurance services, etc.) performing outsourced activities on behalf of IterCulture APS, in their capacity as external data processors.
Without requiring express consent (Article 6(1)(b) and (c) GDPR), IterCulture APS may communicate data for the purposes set out in Section 2.A to Supervisory Bodies, Judicial Authorities, insurance companies for the provision of insurance services, and any entities to whom disclosure is mandatory by law for the fulfilment of said purposes. These entities will process the data as autonomous data controllers. Data will not be disseminated.
Personal data is stored on servers located within the Metropolitan City of Catania, therefore within the European Union. Any transfer of data within the EU territory will take place in compliance with applicable legal provisions, subject to the execution of standard contractual clauses provided by the European Commission where required.
The provision of data for the purposes set out in Section 2.A is mandatory. Failure to provide such data will make it impossible to guarantee the Services under Section 2.A. The provision of data for the purposes set out in Section 2.B is optional. You may therefore decide not to provide any data or to subsequently revoke permission to process data already provided; in such cases, you will not receive newsletters, commercial communications, or advertising material relating to the Services offered by IterCulture APS. You will, however, retain the right to the Services outlined in Section 2.A.
As a data subject, you hold the rights set out in Article 15 GDPR, specifically the right to:
i) obtain confirmation as to whether or not personal data concerning you exists, even if not yet recorded, and its communication in an intelligible form;
ii) obtain information regarding: a) the origin of the personal data; b) the purposes and methods of processing; c) the logic applied in the case of processing carried out with the aid of electronic instruments; d) the identification details of IterCulture APS, data processors, and the designated representative pursuant to Article 3(1) GDPR; e) the entities or categories of entities to whom the personal data may be communicated or who may become aware of it in their capacity as designated representatives within the State territory, data processors, or persons authorised to process data;
iii) obtain: a) the updating, rectification, or, where interested, integration of data; b) the erasure, anonymisation, or blocking of data processed in breach of the law, including data whose retention is unnecessary in relation to the purposes for which it was collected or subsequently processed; c) certification that the operations referred to in points a) and b) have been notified, including as regards their content, to those to whom the data was communicated or disseminated, unless this requirement proves impossible or involves an effort manifestly disproportionate to the protected right;
iv) object, in whole or in part: a) on legitimate grounds, to the processing of personal data concerning you, even if relevant to the purpose of collection; b) to the processing of personal data concerning you for the purpose of sending advertising material, direct sales, market research, or commercial communications, through automated calling systems without human intervention, email, and/or traditional marketing methods via telephone and/or postal mail. Please note that the data subject’s right to object to direct marketing through automated methods extends to traditional methods, and that the data subject retains the option to exercise the right to object even partially. Therefore, the data subject may decide to receive only communications via traditional methods, only automated communications, or neither type of communication.
Where applicable, you also hold the rights set out in Articles 16 to 21 GDPR (Right to rectification, right to be forgotten, right to restriction of processing, right to data portability, right to object), as well as the right to lodge a complaint with the Data Protection Authority (Garante per la protezione dei dati personali).
You may exercise your rights at any time by sending a registered letter with return receipt to IterCulture APS, Via Enrico Fermi 6 – 95019 Zafferana Etnea (CT), Italy, via PEC to direzione@pec.iterculture.eu, or via email to iterculture@live.it
The Data Controller is IterCulture APS, with registered office in Via Enrico Fermi 6 – 95019 Zafferana Etnea (CT) and operational headquarters in Via Napoli 17/A – 95127 Catania.
The updated list of data processors is kept at the registered office of IterCulture APS.