PRIVACY POLICY OF THE SITE www.infertilitadicoppia.com

The Centro C.M.R. s.r.l. based in Turin, via Colombo n. 1, VAT number 08487650015, as the Data Controller, informs you that the processing of your personal data will be based on the principles of lawfulness, fairness, transparency, purpose limitation and storage limitation, data minimization, accuracy, integrity, and confidentiality. Your personal data will therefore be processed in accordance with the legislative provisions of the Applicable Regulation and the confidentiality obligations therein provided.

1. DATA CONTROLLER AND DATA PROTECTION OFFICER

The Data Controller is Centro C.M.R. s.r.l. based in Turin, via Colombo n. 1, VAT number 08487650015, whose details are also provided on the website on the Home Page and/or on other web pages of the same. The Data Protection Officer is lawyer Luisa Di Giacomo, with an office in Turin, corso Matteotti n. 44, reachable at the email address digiacomo@luisadigiacomo.it

2. PERSONAL DATA SUBJECT TO PROCESSING

“Personal Data” means any information relating to an identified or identifiable natural person, with particular reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more specific elements of that person's physical, physiological, mental, economic, cultural, or social identity.

The Personal Data collected by the Site are as follows:
a. Navigation Data
The IT systems of the Site collect certain Personal Data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with you, but by its very nature could, through processing and associations with data held by third parties, allow for your identification. This includes IP addresses or domain names of the devices used to connect to the Site, URIs (Uniform Resource Identifier) of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (success, error, etc.), and other parameters related to your operating system and IT environment.
This data is used to obtain anonymous statistical information on the use of the Site and to monitor its correct functioning; to allow – given the architecture of the systems used – the proper delivery of the various functionalities requested by you, for security reasons, and for the verification of responsibility in case of hypothetical computer crimes against the Site or third parties, and is deleted after 7 days; in any case, such data are retained by the Site Owner for the strictly necessary period and in any case in accordance with the current legal provisions.
b. Data Provided Voluntarily
Through the Site, you have the option to voluntarily provide Personal Data such as your name and email address to request information regarding the services provided by the Data Controller, or to contact the Data Controller through the “Contact Us” form, to communicate via email, or to subscribe to the newsletter service (or other similar services). Users are free to provide their personal data, but failure to do so may result in the inability to obtain the requested service. The Data Controller will process this data in compliance with the Applicable Regulation, assuming they refer to you or to third parties who have expressly authorized you to provide them based on a suitable legal basis that legitimizes the processing of the data in question. In this last case, you act as an independent data controller, assuming all legal obligations and responsibilities. In this regard, you grant the broadest indemnity against any dispute, claim, request for compensation for damages from processing, etc., that may be received by the Data Controller from third parties whose Personal Data have been processed through your use of the Site in violation of the Applicable Regulation.
c. Cookies and Similar Technologies
The Data Controller collects Personal Data through cookies. More information on the use of cookies and similar technologies is available here (open cookie policy).

3. PURPOSES, LEGAL BASIS, AND MANDATORY OR OPTIONAL NATURE OF PROCESSING

The Personal Data you provide through the Site will be processed by the Data Controller for the following purposes:
a) response to a request from the data subject, purposes related to the execution of a contract to which you are a party or to the execution of pre-contractual measures adopted at your request (e.g., contact request via the Contact form or email, registration for the newsletter service, etc.); in this case, providing the data is optional, but if it is not provided, it will not be possible to respond to your request or provide the requested service;
b) purposes of research/statistical analysis on aggregated or anonymous data, thus without the possibility of identifying the user, aimed at measuring the functioning of the Site, measuring traffic, and evaluating usability and interest;
c) purposes related to the fulfillment of a legal obligation to which the Data Controller is subject;
d) purposes necessary to ascertain, exercise, or defend a right in court or whenever judicial authorities exercise their judicial functions.

The legal basis for the processing of Personal Data for the purposes referred to in point a) is the provision of a service or the response to a request from the data subject, and therefore consent is not required under the Applicable Regulation. The purpose referred to in point b) does not involve the processing of Personal Data, while the purposes referred to in points c) and d) represent legitimate processing of Personal Data under the Applicable Regulation as, once Personal Data are provided, the processing is indeed necessary to fulfill a legal obligation to which the Data Controller is subject.

4. PROCESSING METHODS

In relation to the purposes mentioned above, processing occurs through manual, IT, and telematic tools with logics strictly related to the aforementioned purposes and, in any case, in a manner that ensures the security and confidentiality of the data themselves and with your commitment to promptly communicate any corrections, modifications, and updates. Such processing may be carried out on behalf of the Data Controller for the purposes and in the manner described above and in compliance with criteria suitable to ensure security and confidentiality, by companies, studios, entities, and external collaborators appointed as Data Processors and only for the processing carried out by them. None of your personal data held by the Data Controller falls under the definition of “Special categories of data” of Art. 9 of EU Regulation 2016/679. If data of this kind are transmitted, in the absence of your explicit written consent, we will take care to delete them immediately.

5. RECIPIENTS TO WHOM YOUR DATA MAY BE COMMUNICATED

Your Personal Data may be shared, for the purposes specified in point 3, with:
a. subjects necessary for the provision of services offered by the Site, including, by way of example, sending emails and analyzing the functioning of the Site, or the management system for newsletters, who typically act as external data processors appointed by the Data Controller;
b. persons authorized by the Data Controller to process Personal Data who have committed to confidentiality or have an adequate legal obligation of confidentiality; (e.g., employees and collaborators of the Data Controller); (a. and b. are collectively referred to as “Recipients”);
c. Judicial authorities in the exercise of their functions when required by the Applicable Regulation.

6. TRANSFERS OF DATA ABROAD

None of your personal data is transferred outside the European Union. The server on which this site is hosted is located within the European Union. The site communicates with a secure protocol (https), so any data you may enter is protected.
The Data Controller ensures that the electronic and paper processing of your Personal Data by the Recipients is carried out in compliance with the Applicable Regulation.
If transfers outside the European Economic Area occur, such transfers will be based alternatively on an adequacy decision or on the Standard Model Clauses approved by the European Commission.

7. DATA RETENTION

The Data Controller will process your Personal Data for the time strictly necessary to achieve the purposes indicated in point 3. By way of example, the Data Controller will process Personal Data for the newsletter service until you decide to unsubscribe from the service. Without prejudice to the above, the Data Controller will process your Personal Data for the time permitted by Italian law to protect its interests (Art. 2947(1)(3) c.c.). More information regarding the retention period of Personal Data and the criteria used to determine this period can be requested by writing to the DPO at the address digiacomo@luisadigiacomo.it

8. YOUR RIGHTS

1. Right of access

You can obtain from the Data Controller confirmation as to whether or not your Personal Data is being processed and, in that case, obtain access to the Personal Data and the information provided for in Art. 15 of the Regulation, including, by way of example: the purposes of the processing, the categories of Personal Data processed, etc. If the Personal Data is transferred to a third country or to an international organization, you have the right to be informed of the existence of adequate guarantees relating to the transfer. Upon request, the Data Controller may provide you with a copy of the Personal Data being processed. For any additional copies, the Data Controller may charge you a reasonable fee based on administrative costs. If the request in question is made by electronic means, and unless otherwise specified, the information will be provided to you by the Data Controller in a commonly used electronic format.

2. Right to rectification

You can obtain from the Data Controller the rectification of your Personal Data that is inaccurate as well as, taking into account the purposes of the processing, the completion of the same, if they are incomplete, by providing an integrative statement.

3. Right to erasure

You can obtain from the Data Controller the erasure of your Personal Data if one of the reasons provided for in Art. 17 of the Regulation exists, including, by way of example, if the Personal Data is no longer necessary for the purposes for which it was collected or otherwise processed or if the consent on which the processing of your Personal Data is based has been revoked and there is no other legal basis for the processing. We inform you that the Data Controller cannot proceed with the deletion of your Personal Data: if their processing is necessary, for example, for compliance with a legal obligation, for reasons of public interest, for the ascertainment, exercise, or defense of a right in court.

4. Right to restriction of processing

You can obtain the restriction of the processing of your Personal Data if one of the hypotheses provided for in Art. 18 of the Regulation occurs, including, for example: in the face of your objection regarding the accuracy of your Personal Data subject to processing or if your Personal Data is necessary for the ascertainment, exercise, or defense of a right in court, although the Data Controller no longer needs it for processing.

5. Right to data portability

If the processing of your Personal Data is based on consent or is necessary for the execution of a contract or pre-contractual measures and the processing is carried out by automated means, you can:
- request to receive the Personal Data you provided in a structured, commonly used, and machine-readable format (e.g., computer and/or tablet);
- transmit your Personal Data received to another data controller without hindrance from the Data Controller.
You may also request that your Personal Data be transmitted by the Data Controller directly to another data controller indicated by you, if this is technically feasible for the Data Controller. In this case, it will be your responsibility to provide us with all the exact details of the new data controller to whom you intend to transfer your Personal Data, providing us with appropriate written authorization.

6. Right to object

You can object at any time to the processing of your Personal Data if the processing is carried out for the performance of a task in the public interest or for the pursuit of a legitimate interest of the Data Controller (including profiling activities). If you decide to exercise the right to object described here, the Data Controller will refrain from further processing your personal data, unless there are legitimate grounds to proceed with the processing (grounds prevailing over the interests, rights, and freedoms of the data subject), or the processing is necessary for the ascertainment, exercise, or defense in court of a right.

7. Right to lodge a complaint with the Supervisory Authority for the protection of personal data

Without prejudice to your right to appeal to any other administrative or judicial authority, if you believe that the processing of your Personal Data by the Data Controller occurs in violation of the Regulation and/or applicable law, you may lodge a complaint with the competent Supervisory Authority for the Protection of Personal Data (www.garanteprivacy.it). Requests should be addressed via email to: digiacomo@luisadigiacomo.it

9. MODIFICATIONS

This Privacy Policy has been in effect since July 2022. The Data Controller reserves the right to modify or simply update its content, in whole or in part, also due to changes in the Applicable Regulation. The Data Controller will inform you of such changes as soon as they are introduced and they will be binding as soon as published on the Site. The Data Controller therefore invites you to regularly visit this section to become aware of the most recent and updated version of the Privacy Policy so that you are always informed about the data collected and how the Data Controller uses it.

The C.M.R. Turin Team

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