PRIVACY POLICY PURSUANT TO ART. 13 OF THE GENERAL DATA PROTECTION REGULATION (EU) – GDPR - NO. 2016/679

We recognize the importance of protecting personal data and consider its protection one of the main goals of our activities. Before providing us with any personal data, we invite you to carefully read this privacy policy.

This privacy policy applies to:

• The website www.aloeo.it
• The Facebook page https://www.facebook.com/aloeo.it
• The Instagram page https://www.instagram.com/aloeo/

but not to other external websites that may be accessible via links.

This information is provided pursuant to Article 13 of EU Regulation No. 2016/679 (hereinafter, “GDPR”) to users who interact with the aforementioned websites and social network pages.

Additional information may be provided within the various access channels, based on the topics covered. Other notices may be provided on the website in relation to specific services.

This information is also provided pursuant to Article 13 of the GDPR to users interacting with the above-mentioned social network pages.

Additional information may be provided within the various access channels, based on the topics covered.

Data Controller

The Data Controller of personal data relating to identified or identifiable persons is ALOeO – ASSOCIAZIONE LAUREATI OTTICA E OPTOMETRIA, with registered office at P.zza F. De Andrè n. 1 – 30016 – JESOLO (VE), Italy. Contact: segreteria@aloeo.it

Regarding the Facebook page https://www.facebook.com/aloeo.it, ALOeO – ASSOCIAZIONE LAUREATI OTTICA E OPTOMETRIA is a Joint Controller of statistical data together with Facebook Ireland Limited (“Facebook Ireland”).

Legal Basis for Processing

The Controller processes Personal Data relating to the User in the presence of one of the following legal bases:

• The User has given consent for one or more specific purposes; Note: in some jurisdictions, the Controller may process Personal Data without the User’s consent or other legal bases as specified below, until the User objects (“opt-out”). This does not apply when the processing of Personal Data is governed by European data protection legislation;
• The processing is necessary for the performance of a contract with the User and/or for pre-contractual measures;
• The processing is necessary for compliance with a legal obligation to which the Controller is subject;
• The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;
• The processing is necessary for the legitimate interest pursued by the Controller or by a third party.

It is always possible to request the Controller to clarify the specific legal basis of each processing activity and, in particular, to specify whether the processing is based on the law, on a contract, or necessary to conclude a contract.

Purposes of Processing

The personal data voluntarily provided will be processed for the following purposes:

• Responding to information requests and following up on your inquiries;
• Browsing the website and the mentioned social media pages;
• Interaction with the website www.aloeo.it

Type of Data Processed and Collection Methods

Browsing Data – Log Files

You can access the website without providing any personal data. The IT systems and software procedures used for the operation of this website collect, during normal operation, certain data (whose transmission is implicit in the use of Internet communication protocols) not associated with directly identifiable users. These data include the IP addresses of users connecting to the site, URI (Uniform Resource Identifier) addresses of the requested resources, time of the request, and the numerical code indicating the server response status (successful, error, etc.).

These data are processed only for the time strictly necessary and in accordance with current laws and may be used to ascertain responsibility in case of hypothetical computer crimes against the website.

Data Provided Voluntarily by the User

The voluntary and explicit sending of emails to the addresses indicated on the site or on the social media pages entails the subsequent acquisition of the sender’s/user’s address and data, necessary to respond to the requests and/or provide the requested service. This processing is carried out in accordance with the principles of lawfulness, fairness, transparency, and confidentiality protection, as stated in the GDPR. In particular, the newsletter service entails collection of name, email address, and phone number.

Specific Features and Services

Google Analytics with Anonymized IP (Google Inc.)
Google Analytics is a web analytics service provided by Google LLC or Google Ireland Limited, depending on the user's location.
Google uses the collected personal data to track and examine the use of this site, compile reports, and share them with other Google services. Google may use the Personal Data to contextualize and personalize ads on its advertising network.
This integration anonymizes your IP address. The anonymization takes place within EU member states or other countries adhering to the EEA agreement. Only in exceptional cases will the full IP address be sent to Google servers in the USA.
Personal Data collected: Cookies; Usage data.
Processing location: USA – Privacy Policy – Opt Out; Ireland – Privacy Policy.

Facebook Remarketing
Facebook Remarketing is a service provided by Facebook Inc. that connects this website’s activity with the Facebook advertising network to show you relevant ads based on your activity on this site.
Personal Data collected: Cookies; Usage data.
Processing location: USA – Privacy Policy – Opt Out.

Google Ads Remarketing
Google Ads Remarketing is a behavioral targeting service provided by Google Inc. that connects this website with the Google Ads network and the DoubleClick cookie.
Users can opt out from Google's personalized ad settings at Google Ads Settings.
Personal Data collected: Cookies; Usage data.
Processing location: USA – Privacy Policy – Opt Out.

Google Ads Conversion Tracking
Google Ads Conversion Tracking is a statistics service provided by Google Inc. that connects data from Google Ads with actions on this site.
Personal Data collected: Cookies; Usage data.
Processing location: USA – Privacy Policy.

Optional Nature of Data Provision

Apart from navigation data, providing personal data is optional. However, failure to provide such data may make it impossible to obtain certain services.

Data Processing Methods

Personal data are processed using automated tools only for the time strictly necessary to achieve the purposes for which they were collected, in compliance with the principles of lawfulness, purpose limitation, and data minimization (Art. 5 GDPR), and in accordance with legal requirements. Specific security measures are taken to prevent data loss, unlawful or incorrect use, and unauthorized access.

Disclosure and/or Dissemination of Data

Your personal data will not be disclosed, but may be communicated to companies contractually linked to ALOeO – ASSOCIAZIONE LAUREATI OTTICA E OPTOMETRIA, in compliance with GDPR. Personal data may be disclosed to third parties in the following categories:

• Data Processors;
• System Administrators;
• Authorized Personnel;
• Internet and email service providers.

These subjects act either as Data Processors or as independent Data Controllers. The list of data processors is constantly updated and available at ALOeO’s registered office. Any further communication or dissemination will occur only with your explicit consent.

The data collected will not be subject to public dissemination or profiling.

Data Retention Period

The data collected through the contact request form will be retained only for the time necessary to respond to the user's request and for no longer than 6 months from the last expression of interest by the user.

Automated Decision-Making

The Controller informs users that this website does not use any automated decision-making process, including profiling.

Minors

These social media pages are not intended for minors under 16 years old, and the Controller does not knowingly collect personal information from minors. If such data are inadvertently collected, the Controller will promptly delete them upon request.

Data Subject Rights

Data subjects (i.e., natural persons to whom the data refer) have the right at any time to obtain confirmation of the existence of their data and to know their content and origin, verify their accuracy or request their integration, update, or rectification, as per EU Regulation 2016/679: Articles 15–22 – Data Subject Rights.
They may also request the deletion, anonymization, or blocking of unlawfully processed data and may object to their processing for legitimate reasons.
Requests may be sent to: segreteria@aloeo.it.

• Right to rectification: contact us to modify or correct your data.
• Right to erasure: request deletion of all your data and we will process the request within 30 days.
• Right to portability: we can export your data so that it can be transferred to third parties upon request.
• Right to object: unsubscribe from any specific use of your data at any time (e.g., newsletters, automated emails).
• Right of access: you can request access to your data and ask how we use it.
• Right to restriction: you may ask us to suspend the processing of your data for legitimate reasons.

Details on the Right to Object

If Personal Data are processed in the public interest, in the exercise of official authority, or for the legitimate interest of the Controller, data subjects have the right to object for reasons related to their particular situation. If data are processed for direct marketing purposes, data subjects may object without providing any reason. To find out whether data are processed for direct marketing, refer to the relevant sections of this document.

How to Exercise Your Rights

To exercise their rights, data subjects can contact the Controller using the contact details provided in this document. Requests are processed free of charge and handled as quickly as possible, within one month at the latest.

ADDENDUM
1. Joint Controllership of Facebook Insights Data

For Facebook Pages, Facebook provides Page Insights, a feature that offers aggregated data to help understand how people interact with Facebook Pages.
Regarding the Facebook page https://www.facebook.com/aloeo.it, ALOeO – ASSOCIAZIONE LAUREATI OTTICA E OPTOMETRIA is a Joint Controller of Insights data together with Facebook Ireland Limited (“Facebook Ireland”).
This link provides the Page Insights Controller Addendum outlining the division of responsibilities between Facebook Ireland and ALOeO as the Page Administrator.

This page includes Facebook’s Data Policy, including:

• Types of information collected by Facebook
• How Facebook uses that information
• How the information is shared
• Legal bases for data processing
• How to exercise GDPR rights
• Facebook Ireland's contact details for data protection matters
• Facebook Ireland’s Data Protection Officer
• Facebook visitors’ rights under the GDPR
• Data retention periods

This page contains Facebook’s cookie policy.

OTHER INFORMATION ABOUT THE CONTROLLER'S SOCIAL MEDIA CHANNELS

Instagram

ALOeO – ASSOCIAZIONE LAUREATI OTTICA E OPTOMETRIA manages the Instagram account at https://www.instagram.com/aloeo/
This page contains Instagram’s privacy policy.
This page contains Instagram’s cookie policy.

Company Information

ALOeO – ASSOCIAZIONE LAUREATI OTTICA E OPTOMETRIA - P.zza F. De Andrè n. 1 – 30016 – JESOLO (VE), Italy – Tax Code: 92027930129 – VAT: 04180400279 – Email: segreteria@aloeo.it

I, the undersigned, confirm that I/my organisation will organise the ECOO autumn General Assembly and related meetings in full compliance with the General Data Protection Regulation 2016/679 (“GDPR”) and following the guidance document produced by ECOO on the key criteria for its meetings. The organisation of the ECOO autumn General Assembly and related meetings requires the collection and processing of personal and sensitive data of registering individuals.

The personal data collected during registration is:

• Full name
• Organisation
• Address E-mail
• Country Phone number

The sensitive data collected is:

• Dietary requirements
• Any other special requirements

The legal basis for collecting this information is “Consent” as per Article 6 of the GPDR. During the autumn General Assembly and related meetings, the organiser will collect the data directly via their own registration system and act as the “Data Controller”. The participation list containing: country, full name, organisation and e-mail of the registered individuals will be shared with ECOO (“Data Processor”) for the purpose of ECOO communicating with its registered members and other participants on the content of the meetings.

With this agreement the organising party agrees to:

• Put in place a Data Privacy Policy that is made available to individuals upon registration.
• Respect the rights of the individual to access, rectify, update and delete its data.
• Not to disclose any data received for the purpose of the organisation of the meetings to any third parties, in particular for marketing or promotional purposes.
• Have in place a Data Protection Breach Policy.
• Be open and honest with Data Subjects on the data held and processed.
• Safeguard the data held.
• In line with ECOO’s Retention and Destruction Policy, delete the Registration Database and any personal or sensitive data stored elsewhere at the latest six months after the meetings.
• Ensure that any third parties involved in the running of the event (e.g. hotels) fully abide to the requirements of this agreement.
• Treat sensitive data in full confidentiality, in respect of the individual’s privacy and only for the required purpose.