This information is provided, in accordance with Article 13 GDPR 679/2016 - "European Regulation on the Protection of Personal Data", to the members and/or volunteers of Aps Vajne, which has contracted a co-ownership agreement of personal data with Entities pursuing the same purposes and using means in common. Accordingly, the purpose of this notice is to inform data subjects about the aforementioned purposes, the means of data processing, and what the regulations require to make it legitimate that certain data provided to Aps Vajne may also be used by one or more of the entities mentioned below as a co-processor (Art. 26 GDPR) or with one of the entities that have designated Aps Vajne as a controller (Art. 28 GDPR).
Identity of the Co-Processors.
The co-processors of the processing having purposes further indicated below are:
- Dhora srl social enterprise, in the person of its legal representative pro tempore, with headquarters at Via Baldissero, 21 in Vidracco (TO), which coordinates the fulfillments for the processing of personal data of which it is a co-processor, as it is better endowed with the human, technological and organizational resources as a social enterprise that manages several heterogeneous operating units among them, together with:
- Aps Talej net, in the person of its legal representative pro tempore, based at Via Baldissero, 21 in Vidracco (TO);
- Damanhur Alchemy School Association, in the person of its legal representative pro tempore, with headquarters at Via Baldissero, 21 in Vidracco (TO);
- Temples of Humanity Association, in the person of its legal representative pro tempore, with headquarters at Via Baldissero, 21 in Vidracco (TO);
- Selet srl, in the person of its legal representative pro tempore, with headquarters at Via Baldissero, 21 in Vidracco (TO);
- the entities listed at www.damanhur.org/it/privacy.
According to the internal agreement, stipulated between the Co-Processors pursuant to Art. 26 GDPR, it is the responsibility of each Co-Processor at the time of the first contact with the data subject, to provide directly or through Dhora srl social enterprise or other Co-Processing Entity, an information on the processing of personal data, thus to clients, potential clients, members, volunteers, guests and visitors, journalists.
Aps Vajne has also been designated as a data controller, pursuant to Article 28 GDPR, by the autonomous data controllers listed at www.damanhur.org/it/privacy. The processing for which Aps Vajne has been designated as a controller is the same processing carried out as a joint controller.
In addition, a further processing entrusted to Aps Vajne in its capacity as data controller is the provision of information on the processing of personal data to the data subjects of the individual autonomous data controllers.
Finally, Dhora srl impresa sociale is responsible for providing feedback to data subjects in the event of the exercise of their rights.
Identity of the Data Protection Officer
The Data Protection Manager is Dr. Enrico Gamberini, for the office domiciled at Dhora srl impresa sociale in Via Baldissero, 21 in Vidracco (TO).
Data Source.
The personal data processed are those provided by the data subject when:
◦ requests for information addressed to any of the subjects listed above, including via email or social-network;
◦ visits to the premises of any of the subjects listed above or as part of cultural, artistic, educational, popular or performance events, fairs, festivals, conventions, markets, etc;
◦ subscription to newsletters and registration to Internet sites;
◦ previous transactions with one or more of the subjects listed above;
◦ purchases made at the point of sale of any of the subjects listed above, or through a website traceable to them.
Purposes of processing.
The personal data of data subjects may be processed by Aps Vajne, other joint data controllers, and autonomous data controllers who have designated Aps Vajne as the data controller to pursue the following purposes:
1) to participate in Damanhur's experiences, through participation in exchange chats on spiritual, artistic, cultural, environmental, ecological, etc. themes; through participation in the various dynamics of training, play, exchange, solidarity, personal growth planning, group dynamics, research on the aforementioned themes and others that fall under an often intra-associative and/or inter-company organization and/or management, which in any case involves at different levels different or all of the co-owners in question, including in streaming connections or publications recorded on online platforms;
2) forwarding to those who have expressed interest in the activities and initiatives, conferences, courses, visits, products, services proposed by any of the entities listed above, inherent communications by various means of communication (telephone, cell phone, email, social networks);
3) to encourage research that interested parties have expressed as welcome or for which groups have been formed, even in whole or in part online, on the topics of philosophy, social experimentation, ecology, welfare, development of human potential, and what is provided for in the Statutes of the Co-owning Entities;
4) promote the activities, initiatives, products and services of the entities listed above;
5) To make requests or process requests received;
6) Exchange information aimed at the execution of business transactions or contractual relationships of various kinds, including pre- and post-contractual activities;
7) perform operations necessary for the fulfillment of orders and other requests;
8) to acquire user data from social profiles, through social login or interaction with the properties of those involved.
The pursuit of the above purposes and the resulting processing of personal data may be carried out independently by Aps Vajne, by Aps Vajne together with one or more of the listed subjects, independently by each of the subjects listed above.
Legal basis for processing
The legal basis legitimizing the processing is:
- Execution of a contract to which the data subject is a party or to the execution of pre-contractual measures taken at the request of the same, with a co-owner or an autonomous owner, for the purposes referred to in points 6) and 7);
- pursuit of the legitimate interest of a co-owner or autonomous owner, for the purposes referred to in point 5);
- consent of data subjects, formulated through free and informed choice of privacy settings on the social networks used, by ticking and signing the desired choice on the paper forms or selecting it on the online forms, for the purposes mentioned in para:
1) because a prudential interpretation and shared by several consultants surveyed, considers the very adherence to an activity of Damanhur, as a philosophical choice falling within the special data under Art.9 GDPR 679/16, which in co-ownership with other non-Third Sector entities, albeit with the same purposes and means, requires the consent of the data subject as the legal basis for the lawfulness of the processing;
2) because promotional and marketing activities;
3) for the same reasons as in point 1);
4) for the same reasons as in point 2);
8) for the same reasons as in point 2).
Recipients of the data
The personal data processed by co-owners or autonomous data controllers will not be disseminated, i.e. they will not be made known to unspecified parties, in any possible form, including making them available or simple consultation. They may, on the other hand, be communicated to workers employed by the joint data controllers or autonomous data controllers, as well as to collaborators or volunteers, as listed above. They may also be communicated, to the extent strictly necessary, to subjects who, for the purpose of processing purchases or other requests or performance of services related to the transaction or contractual relationship with one or more of the listed subjects, must supply goods and/or perform on their behalf performances or services. Finally, they may be communicated to the subjects entitled to access them by virtue of provisions of the law, regulations, EU regulations.
In particular, on the basis of the roles and work duties performed, some workers, collaborators and volunteers have been legitimized to process personal data, within the limits of their competencies and in accordance with the instructions given to them by the respective data controller or co-owner.
Transfer of data
Where the co-owner or autonomous data controller transfers personal data to third countries or international organizations, within the scope of the above-mentioned purposes, you will be informed whether or not an EU Commission adequacy decision exists.
However, they reserve the possibility to use cloud services; in which case, the service providers will be selected from among those who provide adequate guarantees, as provided by Article 46 GDPR 679/16.
Data Retention
The entities listed above as co-owners or autonomous data controllers will retain and process personal data for the time necessary to fulfill the stated purposes. Thereafter, personal data will be retained, and not further processed, for the time stipulated by the current civil and tax regulations.
Rights of the data subject
With reference to Art. 7 of Legislative Decree 196/2003 and Art. 15 - right of access, 16 - right to rectification, 17 - right to erasure, 18 - right to restriction of processing, 20 - right to portability, 21 - right to object, 22 - right to object to automated decision making of GDPR 679/16, the data subject may exercise his/her rights by writing to Dhora srl impresa sociale at the above address, or by email to dpo@dhora.it specifying the co-owner or autonomous owner against whom he or she exercises the right, the subject of his or her request, the right he or she intends to exercise and attaching a photocopy of an identity document attesting to the legitimacy of the request.
Revocation of consent
With reference to Article 6 of GDPR 679/16, the data subject may revoke any consent given at any time.
However, with the exception of points 1), 2), 3), 4), and 8) above, the processing covered by this notice is lawful and permitted, even in the absence of consent, insofar as it is necessary for the performance of a contract to which the data subject is a party (the association relationship or the supply of products or services) with a co-owner or autonomous data controller, or for the fulfillment of his or her requests, or for the pursuit of the legitimate interest of a co-owner or autonomous data controller.
Proposition of Complaint
The data subject has the right to lodge a complaint with the supervisory authority of the state of residence.
Refusal to provide data
Data subjects who make purchases of products or services may not refuse to provide personal data necessary to comply with the Law regulating commercial transactions and taxation.
The provision of additional personal data from them may be necessary to improve the quality and efficiency of the transaction.
Therefore, refusal to provide data required by Law will prevent the fulfillment of orders; while the provision of additional data may affect in whole or in part the fulfillment of other requests and the quality and efficiency of the transaction itself.
Refusal to provide data not necessary for contractual purposes will simply not allow access to services, in compliance with the regulations that require it to access them. For example, receiving a research text in your native language if you do not tell me what your native language is, rather than telling me your birth time if you want astrological calculation of your birth chart, etc.
Automated decision-making processes
Where processing is profiled that consists of automated decision-making processes on the data of natural persons, or of natural persons acting on behalf of legal entities, explicit consent is requested appropriately specified.
* The notice is addressed to members and interested parties who have applied for membership pending official ratification.
