Privacy Policy | ActionAid International Italia Onlus

Preamble

ActionAid International Italia Onlus (hereinafter, also: “the Organisation” or “AA” or “ActionAid”) cares for the users’ privacy and their rights and, since Internet may put at risk confidentiality of information, it intends to undertake to respect rules of conduct while collecting and processing data, in compliance with Regulation (EU) 2016/679 of the European parliament and of the Council of 27April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing directive 95/46/EC (so-called “GDPR”), which ensure a safe, controlled and confidential navigation in the network.

This policy may change with passing of the time, also as a result of amendments and integrations at a legislative level or as a consequence of our institutional purposes and decisions. So, we invite you to periodically read this section, from time to time.

Principles of ActionAid’s privacy policy

carry out the processing (art. 4, comma 2, GDPR: “any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as 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”) of personal data (art. 4, comma 1, GDPR: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”) only for the purposes and the means explained in information to be provided to the user when accessing a section of our website where you can, directly or indirectly, provide your personal data;
use data which have been spontaneously provided by the user;
use technical cookies to facilitate the navigation in the website and analytics cookies for statistical purposes;
use profiling cookies only if the user has expressed consent;
transmit data to third parties (processors – art. 4, comma 8, GDPR: “a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller”) only for connected purposes to what expressly requested by the user and which we have accurately previously selected;
communicate data to third parties for activities connected to the services asked by the user or whenever required by law, regulation or EU legislation;
if the data subject has given explicit consent (art. 4, par. 11, GDPR: “any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her”), communicate personal data to third parties for their autonomous processing;
reply to the requests of access to data, rectification, right to be forgotten, restriction of processing, data portability or inform about the right to object to data processing. Ensure the data subject the right to object to data processing carried out for marketing purposes, surveys and market research, as well as to object to profiling to the extent that it is related to such direct marketing and inform about the right to lodge a complaint with the supervisory authority;
ensure a correct and lawful processing of your personal data, safeguarding your confidentiality, as well as apply appropriate security measures to protect confidentiality, integrity and availability of such data.

Information to be provided ex art. 13, GDPR and some information on criteria used to determine data storage

As best explained in the sections in which you can provide – directly or indirectly also filling forms displayed – your personal data, such data are used to reply to the users’ requests. All collection activities – and subsequent processing – of data are aimed at pursuing the institutional purposes of ActionAid and, in particular:

manage regular and one-off donations, regardless of the means of subscription (credit card, bank account or else)
reply to request of information on or manage subscription to child sponsorship project
provide you with the newsletter service
analyse and select applicants
manage your subscription to petitions, initiatives or specials appeals and projects
reply to requests of information.

Forms to be filled in – on-line or which can be downloaded – request mandatory and optional data; in case you do not provide mandatory data, your request cannot be fulfilled. So, the user is free to provide personal data requested in forms, or to ask for information or to contact the organisation or for the other purposes mentioned above.

The Controller has implemented appropriate organisational and technical measures for ensuring that only personal data which are necessary for each specific purpose are processed, in compliance with art. 25, GDPR (“Data Protection by design and by default”) which provides that before processing, the controller must implement appropriate technical and organisational measures, such as “pseudonymisation” (art. 4, comma 5, GDPR: “the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person”), which are designed to implement data protection principles, such as data minimisation, in an effective manner and to integrate the necessary safeguards into the processing in order to meet the requirements of GDPR and protect the rights of data subjects. Besides, AA has implemented organisational and technical adequate and preventative measures so that only data necessary for each purpose of processing are processed (principle of “data protection by default”).

Personal data are processed by the Controller with manual, electronic and telematic means and stored in its filing system, with criteria related to the purposes for which data have been collected and in compliance with security measures, for the purposes explained in information to be provided ex art. 13, GDPR. ActionAid does not use data for purposes which are not related to the service subscribed by the user and, anyway, only for the purposes explained in information ex art. 13, GDPR.

Personal data may be transmitted to third parties, autonomous controllers, if this is necessary to fulfil the user’s request (e.g.: banks, credit card circuits to manage donation transactions) o when the communication of data is necessary to comply with laws and regulations.

Personal data will be processed for further purposes only if the user has given explicit consent. They will be processed for fund raising activities o for direct and marketing purposes – with or without “profiling” – (art. 4, par. 4, GDPR – “any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements”), which means according to interests, preferences and actions of the user who has browsed our website, as well as, when the user has filled in the forms, and to surveys and projects. Personal data will be processed to contact the user for promotional, information and institutional purposes and to inform on projects, initiatives, fund raising activities, surveys and market research. Personal data will be stored in our filing system for the period necessary to provide such information service. This legitimate interest is pursued by AA in keeping in touch with the person who has joined our projects, and by doing so, the person has expressed interest in our mission and in being informed on projects which can be supported by the donation or on actions and initiatives that AA considers to be useful to demonstrate its commitment to the realisation of its institutional purposes. The legitimate interest is an alternative condition set out in art. 6, par. 1, letter f), GDPR instead of data subject’s explicit consent.

Data storage for these purposes will cease if the person objects to such processing exercising the rights as described below and ActionAid will put in place adequate measure so that the person is not contacted any more. If wished, personal data will be processed for the said purposes in a customised manner on the basis of characteristics of behaviour, (e.g.: actions joined, geographic criteria, age), interests and preferences as regards our activities (“profiling”, as defined above). This operation will be carried out interconnecting information on the person, so that the person receives contacts of interest and in line with preferences. Data are stored in our filing system as long as the person’s profile is in line with the customised contacts created by interconnecting information at our disposal and, therefore, as long as ActionAid continues its mission with projects, initiatives, actions and activities which invite to awareness (e.g.: petitions, special appeals) and which are considered interesting for the person because they meet characteristics and behaviour and are appreciated by the person. Also, in this case, data storage will cease if the data subject objects to such profiling to the extent that it is related to such direct marketing.

Data storage for administrative, accounting and tax purposes is limited to the period set out in the legislation governing each matter.

In addition, personal data will be communicated to third charities, projects partners, bodies, for their autonomous processing (autonomous controllers) for their institutional purposes: such communication will take place only if the data subject has given explicit consent. Data transfer to third Countries will take place only if the data subject has given explicit consent: this transfer will occur in case of child sponsorship project, to allow the personal contacts between the donor / the sponsor and the beneficiary. In this case, the third parties are entities adhering to our international network or project partners.

Personal data can be communicated to third parties, with prior explicit and specific consent, as described above, for their autonomous processing having the main purpose of promotional contacts. The dissemination of data, with prior user’s consent, may be necessary to fulfil the kind of service or initiative joined by the user (e.g.: list of an on-line petition subscribers).

Personal data will be processed by persons authorised by the Organisation, as per art. 29, GDPR and they carry out activities necessary to pursue the purposes mentioned above; the categories of them are indicated in the information ex art. 13, GDPR. Generally speaking, they are persons in charge of the performance of specific services, administration, information technology, donors care, organisers of fund raising and institutional activities.

Processing carried out for the purposes of the performance of services provided by this website takes place at the Organisation’s headquarter and are performed by the persons authorised to processing. If need be, personal data can be processed by companies which are in charge of the technological management of the website (processors designated pursuant to art. 28, GDPR), at their offices.

ActionAid International Italia Onlus, with offices in Via Alserio 22, 20159 Milano (MI – Italy) (art. 4, par. 7, GDPR: “the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data”), pursuant to GDPR, because it decides in which way and for what purposes, communicated in information to be provided to data subjects, it collects and processes personal data, as well as what means and security measures it implements to ensure the integrity, the confidentiality and the availability of personal data, taking on liability and complying with the provisions laid down in art. 24, GDPR.

You have the right to control your personal data processing. You can exercise the right of access, to rectification, the right “to be forgotten” (erasure), to restriction of processing, to data portability and to object to the processing of your data on legitimate grounds and for marketing purposes and profiling. You can also lodge a complaint with the supervisory authority. Thanks to the exercise of these rights, you will be able to control the use of your personal data also after you have provided them.

Data subjects’ rights

You can exercise these rights, at any time, by sending an e-mail at sostenitori@actionaid.org (or by writing to ActionAid International Italia Onlus – Via Alserio 22, 20159 Milano (MI – Italy)) In the following, the list of your rights:

Right of access (art. 15, GDPR)
The person has the right to obtain from the controller confirmation as to whether or not personal data are being processed and have information on:

the purposes of processing (e.g.: management of a donation);
categories of personal data (e.g.: identification data, behavioural data)
recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing
right to lodge a complaint with a supervisory authority
where the personal data are not collected from the data subject, any available information as to their source;
existence of automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject (e.g.: if the person has a profile created on the basis of donation habits, interconnecting the amount donated with frequency and campaign).

Right to rectification (art. 16, GDPR)
The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Right to erasure (“right to be forgotten”) (art. 17, GDPR)
The person shall have the right to obtain from the controller the erasure of personal data without undue delay and the Controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed
the data subject withdraws consent on which the processing is based and where there is no other legal ground for the processing (e.g.: legitimate interest, contractual or legal obligations)
the data subject objects to the processing and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing for marketing purposes or profiling
personal data have been unlawfully processed
the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.

Right to restriction of the processing (art. 18, GDPR)
The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data
the processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead (e.g.: the person objects to data processing for marketing purposes but only for accounting and administrative purposes)
the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims
the data subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.

Notification obligation regarding rectification or erasure of personal data or restriction of processing (art. 19, GDPR)
The person has the right that the controller communicates to third parties the rectification or the erasure of data or the restriction of processing if personal data have been communicated to such third parties. AA could not fulfil this request if this proves impossible or involves disproportionate effort.

Right to data portability (art. 20, GDPR)
The data subject shall have the right to receive the personal data have been provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:

the processing is based on consent or on a contract stipulated with the data subject or for a third party
the processing is carried out with automatic means.

The data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

Right to object (art. 21, GDPR)
The data subject shall have the right to object, at any time, to processing of personal data which is based on for the purposes of the legitimate interests, including profiling, pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.

Automated individual decision-making, including profiling (art. 22, GDPR)
The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects the person. This right cannot be exercised where the decision:

is necessary for entering into, or performance of, a contract between the data subject and a data controller
is authorised by Union or Member State law to which the controller is subject, and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or
is based on the data subject’s explicit consent.

The person has the right to express a point of view and to contest AA’s decision.

Criteria used to determine the period for which data will be stored

Personal data will be stored in our filing system (art. 4, comma 6, GDPR: “any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis”) with criteria depending on the category of data, the nature of processing and the purposes of data processing. The criteria or the period of storage are described in information to be provided pursuant to art. 13, GDPR, when data are collected.

Generally, these are the criteria determined by AA for data storage:

all data connected to donation are stored as long as the relationship is in course and for the number of years set out in administrative, accounting laws and regulations
all data related to donors or users interested in our mission processed for marketing purposes are stored for the period necessary to provide information service reserved to these persons. This legitimate interest is pursued by AA in keeping in touch with the person who has joined our projects, and by doing so, the person has expressed interest in our mission and in being informed on projects which can be supported by the donation or on actions and initiatives that AA considers to be useful to demonstrate its commitment to the realisation of its institutional purposes. Data storage for these purposes will cease if the person objects to such processing exercising the rights as described in the paragraph “Data subjects’ rights” and ActionAid will put in place adequate measure so that the person is not contacted any more
all data processed for direct marketing with profiling, whose processing is lawful thanks to the data subject’s consent, are stored until the data subject’s profile is in line with the customised contacts created by interconnecting information at our disposal and, therefore, as long as ActionAid continues its mission with projects, initiatives, actions and activities which spur to awareness (e.g.: petitions, special appeals) and which are considered interesting for the person because they meet characteristics and behaviour and are appreciated by the person who has given consent to receive such contacts. Data storage will cease if the data subject objects to such profiling to the extent that it is related to direct marketing.

After the periods stated above, identification data are transformed in anonymous data and used only for statistical reports and analysis which do not allow to trace the identity of the person, but which are useful to improve and adjust our projects, initiatives and actions to achieve our institutional aims. Therefore, personal data, will be destroyed.

Data Protection Officer

The Data Protection Officer is the natural person whom AA involves, properly and in a timely manner, in all issues which relate to the protection of personal data and supports AA to control how to process and protect personal data. Data subjects may contact our Data Protection Officer with regard to all issues related to processing of their personal data and to the exercise of their rights, by e-mail dpo.ita@actionaid.org

Processors

Your personal data can be processed, with manual, electronic and telematic means, directly by AA or by entities which can appropriately ensure, on account of their experience, capabilities and reliability, thorough compliance with the provisions in force applying to processing as also related to security matters. These entities are selected and controlled by AA which has appointed them as “data processor” (art. 4, par. 8, GDPR: “a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller”) and they carry out data processing on AA behalf. Processing by these entities is governed by a contract which is binding on the processor with regard to the Controller and which sets out the subject-matter and duration of the processing, the nature and purpose of the processing, the type of personal data and categories of data subjects and the obligations and rights of the controller. The processor can, if it is authorised in writing by AA, engage other processors, which are contractually bound by the processor appointed by AA: the processor appointed by AA is liable for any violation committed by the other processors and AA has no liability in such cases.

The complete and updated list of processors (and, where appropriate, the other processors appointed by the initial processor, subject to our authorisation) can be asked by dpo.ita@actionaid.org (or by writing to ActionAid International Italia Onlus – Via Alserio 22, 20159 Milano (MI – Italy)).

Communication of personal data

Your personal data will be communicated to third parties, autonomous controllers, for purposes connected to the performance of the services of interests or when this communication is imposed by laws, regulations, as well as to supervisory authorities on their demand. For example, they will be communicated to banks or credit cards circuits for donation transactions or to PayPal. They can be communicated to third parties for their marketing and/or profiling activities or they can be disseminated with the user’s prior consent, as described in the paragraph “Information to be provided ex art. 13, GDPR and some information on criteria used to determine data storage” of this privacy policy.

What cookies are and how they are used by ActionAid

Cookies are small text files transferred and stored by your browser on your computer or mobile device when you visit or interact with a website. They are sent from your device to a web server and relate to your use of the network. Consequently, they allow to know the services, the browsed sites and the options selected by the user. This information is not provided, therefore, spontaneously and directly, but they trace the data collected. Data collected through cookies will be used for technical needs, in order to ensure a smoother, immediate and quick access to the website and its services and facilitate browsing to the user. Cookies can be used, with the user’s explicit consent, to create user’s profiles according to the sections of the website or to the action carried out by the user on this website or browsing the Internet.

Session cookies (which are not permanently stored on your device and are erased by closing the browser) are only used to transmit session identification information (random numbers generated by the server), which is necessary to ensure a safe and effective browsing of the website. Session cookies used by this website avoid using other techniques which are likely to be detrimental to the confidentiality of users’ browsing and do not allow the collection of personal data identifying the user.

Conversely, profiling cookies allow knowing user’s browsing on the network and detecting interests, preferences, needs expressed and allow creating marketing campaigns or creating profiles to better customise promotional, institutional advertisements. You can always set your browser so that you are informed when a cookie is being received and decide whether to accept it or not.

To find out more on our cookie policy and third parties’ cookie policy, click HERE.

Browsing data

The information systems and software procedures relied upon to operate this website acquire personal data as part of their standard functioning; the transmission of such data is an inherent feature of Internet communication protocols.

Such information is not collected in order to relate it to identified data subjects, however it might allow user identification after being processed and matched with data held by third parties.

This data category includes IP addresses and / or the domain names of the computers used by any user connecting with this website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.), and other parameters related to the user’s operating system and computer environment.

These data are only used to extract anonymous statistical information on website use as well as to check its functioning; they are erased immediately after being processed. The data might be used to establish liability in case computer crimes are committed against the website.

Security of your personal data

ActionAid implements appropriate and preventative security measures to protect confidentiality, integrity, completeness and availability of your personal data.

In compliance with the provisions governing data security, ActionAid uses technical, organisational and logistics techniques which are aimed at the minimisation of the risk of damage, loss, whether accidental or not, alteration, unproper or unauthorised use of your personal data.

In particular, ActionAid has implemented organisational and technical measures aimed at ensuring a level of security adequate and appropriate to the risk which may affect individuals’ rights and freedom, including confidentiality of personal data. ActionAid has implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:

“pseudonymisation”(art. 4, comma 5, GDPR: “processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person”) and / or encryption of data
measures which ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services
procedures which ensure to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident
procedures for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.

Such preventative measures are implemented by processors selected by ActionAid to carry out data processing on its behalf.

On the other hand, ActionAid is not to be held liable for untruthful information sent directly by the user (e.g.: correctness of e-mail address or postal address or other identification data), as well as for other information on the user sent by third parties, even with fraud.

Credit card and financial information needed for donations

In case of donation paid with credit card, ActionAid ensures the utmost confidentiality and security. Information on credit card (number, expiration date, data identification’s owner) can be known only by the issuing institution. ActionAid has knowledge of a code (“token”) which does not allow to know the credit card holder’s identity and the credit card details, apart from some exceptions. The same preventative security measures are implemented in case of donation through bank transfer: in this case, it is requested a “random code” when executing a bank transfer.

If the donation is paid with PayPal, the user is redirected to PayPal website and the confidentiality criteria and security measures concern Paypal, with no liability of AA.

Finally, AA cannot be held responsible for unauthorised uses and fraud by third parties carried out on information relating to means used for the payment of the donation.

P3P

This privacy policy can be read in automatic format by the most widespread browsers which implement P3P platform (“Platform for Privacy Preferences Project“) standard promoted by World Wide Web Consortium (www.w3c.org). Any effort will be put in please as to make interoperable the functionality of this website with automatic privacy controls installed in the user’s devices.

Whereas the state of perfection of the current automatic control mechanisms does not make them free from errors and dysfunctions, we would like to make it clear that this document constitutes the “Privacy Policy” of this website and which will be subject to updates.