PRIVACY POLICY PURSUANT TO APPLICABLE LEGISLATION ON PERSONAL DATA PROTECTION

International Agency for the Prevention of Blindness-IAPB Italy – www.iapb.it

IAPB Italy, with its registered office in Via U. Biancamano 25 – 00185 Rome (hereinafter, “Controller”), as data controller, informs you – pursuant to art. 13 D.Lgs. 30.6.2003, no. 196 (hereinafter, “Data Protection Code“) and art. 13 EU Regulation no. 2016/679 (hereinafter, “GDPR“) – that your data will be processed in the described manner and for the following purposes:

1. INFORMATION WE MAY COLLECT FROM YOU

The Controller collects and processes personal data (such as name, surname, address, telephone number, e-mail, bank and payment details) – hereinafter, “personal data” or even “data” – which you have provided at the time of registering to the Controller’s site or subscribing to any of its services.

2. PURPOSES OF PERSONAL DATA PROCESSING

Your personal data are processed:

2.A) without your express consent art. 24 lett. a), b), c) of the Data Protection Code and art. 6 lett. b), e) of [GDPR] for the following Service Purposes: the Company processes the personal data provided by you or already in its possession, to finalise, manage and perform the activity requested by you. For instance: participation in the Forum “Ask the ophthalmologist”, phone calls to our toll-free number 800-068506 [available from Italy only, otherwise call + 39 06 36004929 from abroad], participation in development projects and/or mini-projects, donations, legacies, devolution of the 5xmille to IAPB with your tax return;

2.B) with your express consent only (articles 23 and 130 of the Data Protection Code, article 7 of GDPR), for the following Marketing Purposes: to send you by email, mail and/or sms and/or telephone, newsletter, any commercial and/ or promotional communications on projects, events, activities or services offered by the Controller. In such cases, the provision of your personal data will be optional and your refusal will not have any consequences on the legal relationships already existing or being established, thus precluding only the performance of the activities indicated in this point

3. HOW DO WE PROCESS YOUR DATA?

The processing of your personal data is carried out by means of the operations indicated in art. 4 of the Data Protection Code and art.4 no. 2) of GDPR and more precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, usage, interconnection, blocking, communication, cancellation and destruction of data. Your personal data is subjected to both paper based and electronic and/or automated processing.

The Data Controller will process personal data for the time necessary to fulfill the aforementioned purposes and in any case for no more than 10 years from the termination of the Service Finality relationship and for no more than 6 years from the collection of data for Marketing Purposes.

4. WHO CAN ACCESS YOUR PERSONAL DATA?

Your data may be made accessible for the purposes referred to in art. 2.A and art. 2.B to anybody who, within the Company, and within parent companies, affiliated companies or subsidiaries of IAPB Italy, need them in consequence of their tasks or company role. These subjects, whose number will be as limited as possible, will be appropriately trained in order to avoid losses, destruction, unauthorized access or unauthorized processing of the data.

Furthermore, data may be disclosed to: (i) institutions, authorities, public bodies for their institutional purposes; (ii) professionals, independent collaborators, also in associated form; third parties and suppliers used by the Controller for the provision of services of a commercial, professional and technical nature, which may be useful to the management of the Site and related functionalities (eg. IT service providers and Cloud Computing), to the pursuit of the purposes specified above and the services requested by the user; (iii) third parties in the case of mergers, acquisitions, sale of company or business units, audits or other extraordinary transactions; (iv) the corporate SB [[Supervisory Body]], domiciled with the Controller, for the pursuit of its supervisory activities and the implementation of the IAPB Italy Code of Conduct. These subjects will only receive the data necessary for the relevant functions and will undertake to use them only for the purposes indicated above and to treat them in compliance with the applicable privacy legislation. The data can also be communicated to the legitimate recipients according to the applicable legislation. With the exception of the aforementioned, the data is not shared with third parties, natural or legal persons, who do not perform any commercial, professional or technical function for the Controller and will not be disclosed. The subjects who receive the data treat it as Controllers, Managers or subjects authorized to process it, depending on the case, for the purposes indicated above and in compliance with the applicable law on privacy.

Regarding the possible transfer of data to Third Countries, including countries that may not guarantee the same level of protection as the applicable legislation, the Data Controller declares that the processing will take place according to one of the methods allowed by the Regulation, such as for example the user’s consent, the adoption of Standard Clauses approved by the European Commission, the selection of subjects belonging to international programs for free circulation of data, (eg. EU-USA Privacy Shield) or operating in countries considered safe by the European Commission.

5. WHO WILL YOUR PERSONAL DATA BE SHARED WITH?

Without the need for express consent ex art. 24 lett. a), b), d) of the Data Protection Code and art. 6 lett. b) and c) of [GDPR], the Data Controller may share your data for the purposes referred to in art. 2.A to companies providing IT and archival services, or other technical/organizational services as well as to those subjects to whom the communication is mandatory by law for the accomplishment of said purposes. These subjects will process the data in their capacity as independent data controllers. Your information will not be disseminated.

6. HOW DO WE STORE YOUR PERSONAL DATA?

Personal data is stored on servers located within the European Union. In any case, it is understood that the Data Controller, if necessary, will have the right to move the servers even outside the EU. In this case, the Data Controller hereby ensures that the transfer of data outside the EU will take place in accordance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses provided by the European Commission.

7. WHY DO WE COLLECT YOUR PERSONAL DATA AND WHAT HAPPENS IF YOU REFUSE TO PROVIDE IT?

The provision of data for the purposes referred to in art. 2.A is mandatory. In their absence, we can not guarantee the services listed in art. 2.A.
The provision of data for the purposes referred to in art. 2.B is optional. You can therefore decide not to provide any data or to subsequently deny the possibility to process data already given: in this case, you will not be able to receive newsletters, commercial and promotional communications concerning the Services offered by the Data Controller. However, you will continue to be entitled to the Services referred to in art. 2.A.

8. WHAT ARE YOUR RIGHTS?

In your capacity as an interested party, you have the rights set forth in art. 7 of the Data Protection Code and art. 15 of GDPR. Precisely, you have the right to:

i. obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;

ii. obtain the indication: a) of the origin of personal data; b) of the purposes and methods of the processing; c) of the logic applied in case of processing carried out with the aid of electronic instruments; d) of the identification details of the controller, the managers and the designated representative pursuant to art. 5, paragraph 2 of the Data Protection Code and art. 3, paragraph 1, of GDPR; e) of the subjects or categories of subjects to whom the personal data may be shared with or who may become aware of it as a designated representative in the territory of the State, of managers or agents;

iii. obtain: a) the update, rectification or, when you have an interest in it, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data was collected or subsequently processed; c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards to their content, of those subjects with whom the data has been shared or disseminated, except in the case where this proves to be impossible or involves a use of means manifestly disproportionate to the protected right;

iv. to object, in whole or in part: a) for legitimate reasons, to the processing of personal data concerning you, even if pertinent to the purpose of the collection; b) to the processing of personal data concerning you for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by e-mail and/or through traditional marketing methods by telephone and/or paper mail. It should be noted that the right of opposition of the interested party, set out in point b) above, for direct marketing purposes through automated methods extends to traditional ones and that in any case the possibility remains for the data subject to exercise the right of opposition also only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or none of the two types of communication.

Where applicable, the data subject also has the rights referred to in Articles 16-21 of GDPR (right of rectification, right to be forgotten, right of limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.

9. HOW CAN YOU EXERCISE YOUR RIGHTS?

You can exercise your rights at any point by getting in touch with us:

➢ by email: sezione.italiana@iapb.it
➢ by post: IAPB Italia onlus – Via U. Biancamano, 25 – 00185 Rome, Italy
➢ by phone: +39 06 36004929 (fax 06 36086880)

10. DATA CONTROLLER AND DATA PROCESSORS

The Data Controller is IAPB Italy, with its registered office in Via U. Biancamano, 25 – 00185 Rome, Italy;
the updated list of data processors is kept at the Data Controller’s headquarters.

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The normative reference is to the “Individuazione delle modalità semplificate per l’informativa e l’acquisizione del consenso per l’uso dei cookies” (Identification of the simplified procedure for the policy and acquisition of consent for the use of cookies) of 8th May 2014 (published on the Gazzetta Ufficiale, n. 126 of 3rd June 2014).

· For further information: website of the “Garante per la Privacy” (Italian Data Protection Authority).
· Read the EU Regulation

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In the case of internet based publications, the original page which is being quoted should always be linked (however, it is forbidden to publish any content without prior consent: a written request should be sent to sezione.italiana@iapb.it). (Read all our Disclaimer)

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GENERAL CONDITIONS FOR CONSULTATION OF THE WEBSITE WWW.IAPB.IT

Warranties, privacy regulations and limitations of liability

Every visitor is asked to carefully read the followings conditions of use or consultation of this website (www.iapb.it). The fact of continuing in the use of, or in the consultation of the website itself, constitutes complete and tacit acceptance of the following conditions and other applicable regulations by the visitor.

1. The entire content of this website is protected by copyright. No part of this website may be reproduced, re-transmitted or otherwise used without the written consent of the international Agency for the Prevention of Blindness-IAPB Italy, if not for the exclusive purposes of personal knowledge, non-profit popularization and research.
In all cases of publication, texts can be quoted using quotation marks, while the source (the International Agency for the Prevention of the Blindness-IAPB Italy) must be explicitly specified, clearly stating at the same time the original internet address (www.iapb.it) in the context used or in the bibliography. In the case, however, where texts are used on other websites, you must always insert a link to the web page of the IAPB Italy from which the material was drawn (it is forbidden to freely reproduce these pages without express authorization [the requests for permission to reproduce the contents will be sent to [sezione.italiana@iapb.it]]).

2. Every reasonable effort is made to insert accurate and up-to-date information and data on the website. However, the International Agency for the Prevention of Blindness-IAPB Italy declines any responsibility in respect to the correctness of the data found within, and its use for any purpose; it specifies, in fact, that the information on this website is merely indicative and can not, and must not, replace any medical therapy. In all cases it is always advisable to consult a trusted ophthalmologist and follow the therapy prescribed after an eye exam.

3. Access to data, its use and content are intended to be at the user’s own risk. The International Agency for the Prevention of Blindness-IAPB Italy will not under any circumstance be held responsible for any special damage (direct, indirect or consequential and of any kind) deriving from the use or reliability of the available data.
The documentation on pharmaceutical products is not an alternative to the consultation of a physician or other qualified health professional. Furthermore, the opinions expressed on the website do not necessarily reflect the positions of all the members of the IAPB Italy. A visitor/user who wishes to receive advice on a specific health problem should therefore always consult their own doctor.
The documents and their related graphics published on this website may contain technical inaccuracies or typos. The International Agency for the Prevention of Blindness-IAPB Italy can make improvements or changes to the published information at any time.

4. Links to third-party websites lead out of this website and are outside the control of the International Agency for the Prevention of Blindness-IAPB Italy. Links to third-party websites are provided solely for visitor’s convenience and the inclusion of any third-party link does not imply the endorsement of the external website by the International Agency for the Prevention of Blindness-IAPB Italy. In particular, the information featured in the external website may not comply with the Legislative Degree no. 541/92, which regulates the advertising of medical products for human use.

5. If a visitor/user of this website wishes to forward questions, comments, suggestions and the like relating to the documents published on this same website, the content of the data will be considered unconfidential for the purpose of study, research and publication. However, the identity of the person will not be disclosed: it is “anonymized” in compliance with the law on privacy.

6. Visits to this website can be tracked. The international Agency for the Prevention of Blindness-IAPB Italy will have the right to use such recordings for statistic evaluations, in order to ensure continuity of service and for the improvement of its websites. Please, do not use this website if you are in disagreement with this practice.

7. This website can be publicly accessed without automatically downloading undesired files (such as cookies or spywares). For those sections which are subject to the registration of personal data, please refer to the legislation regarding the protection of privacy [See [EU Regulation no. 679/2016 and Legislative Decree no. 196/2003]].

8. On the basis of what was written by the Italian Privacy Authority in the “Guidelines on the processing of personal data for the purpose of publication and dissemination in websites exclusively dedicated to health” [Published in the Italian Official Gazette no. 42, February 20, 2012]], the International Agency for the Prevention of Blindness-IAPB Italy draws the attention of the user to the risk that by entering sensitive data linked to identifying data on this website, they can be identified with their own specific pathology. This warning is also intended to indicate the necessary measures to protect one’s own and others’ privacy in the [forum of the www.iapb.it website. Therefore the International Agency for the prevention of Blindness-IAPB Italy specifies the following:

a) the name and surname are not requested during the registration procedure: it is possible to maintain anonymity by simply using a nickname as a username, which prevents personal identity from being traced;
b) a user’s e-mail address is not automatically published;
c) with regard to the contents entered by the user, it is recommended to:

I) reflect on the opportunity to insert, or not, personal data (including the e-mail address) that can reveal, even indirectly, their identity. Consider, for instance, the case in which the user, in detailing their own experience or describing their state of health, includes references to places, people, circumstances and contexts that also indirectly allow their identity to be traced;
II) pay particular attention to the possibility of inserting, in their own interventions (posted on the various areas dedicated to health), data that can also indirectly reveal the identity of third parties such as, for instance, other people who share the same pathology, human experience or medical path of the post’s author;
III) be fully aware that the text published in the forum of this website (i.e. what is posted) is automatically indexed by Google and other search engines. Therefore, if you do not want this to occur, you can use the same service of ophthalmological consultation by sending your request exclusively by e-mail to info@iapb.it. This way, the International Agency for the Prevention of Blindness-IAPB Italy gives the user the full right to opt between a confidential request (strictly personal) and a request which will be published on the forum and that can be consulted by everybody.