Information for the processing of personal data
(pursuant to European Regulation No. 679/2016 and Legislative Decree 196/03 and subsequent amendments)
The Data Controller is the Order of Friars Minor (OFM) with headquarters in the General Curia of the Friars Minor in Via di Santa Maria Mediatrice, 25 – 00165 Rome. In case of doubts or further information on privacy, please contact the following e-mail address: firstname.lastname@example.org .
The categories of personal data
The data being processed can be traced back to the following categories:
- personal data (name and surname);
- contact details (email);
- Bank details (bank details).
Purpose of processing and legal basis
Personal data is processed for the following purposes:
- a) Manage the donation to the OFM (through regular and/or one-off donations, made in various ways eg, credit card, postal order, PayPal or other);
- b) Send informative and promotional material on OFM activity via e-mail messages or similar communications;
- c) Manage the activities - of an administrative-accounting nature - necessary to execute the donation contract in any form carried out,
- d) reply to the message or request for information,
The legal basis for the processing of personal data for the purposes referred to in points a) and b) above is OFM's legitimate interest in processing the personal data of its supporters in order to effectively pursue its statutory purposes. This legitimate interest consists in keeping the relationship established with the interested party constant, to keep him informed about the awareness-raising actions that it is considered useful to make known in order to demonstrate one's constant commitment to carrying out one's non-profit activities.
Limited to the activities - of an administrative-accounting nature - necessary to execute the donation contract in any form carried out, the legal basis of the processing is the need to execute a contract of which the interested party is a part or of pre-contractual measures adopted at the request of the same or to comply with legal obligations.
The legal basis for the purpose d) is the consent of the interested party.
The technical (and equivalent) cookies referred to in letter e) do not need to acquire the consent of the interested party.
Subjects or categories of recipients of personal data and data transfer abroad
The data may be made accessible, for the purposes listed, to authorized subjects or to subjects appointed as data processors, always in compliance with the purpose principle. The personal data collected will be made available to persons authorized by OFM pursuant to art. 29 of the GDPR who carry out processing activities that are essential for the pursuit of the purposes indicated above. Specifically, these are the people appointed by the Data Controller to provide specific services, administration, management of information services, relations with actual and potential donors, organizers of information campaigns on OFM projects and institutional activities. The Managers are individuals with experience, technical skills, professionalism and reliability,
The complete and updated list of data processors can be requested at the address email@example.com ; or alternatively, by writing to the Order of Friars Minor, with registered office in Via di Santa Maria Mediatrice, 25 – 00165 Rome.
Always in compliance with the principles of treatment and for the purposes indicated, the data could be made available to the following third parties, legally independent from the Data Controller, who provide services instrumental to the pursuit of the aforementioned purposes and operate within the European Union:
- subjects external to the OFM that perform banking and financial intermediation services, transport and sorting of communications to the public, e-mailing services, archiving of documentation, consultancy, insurance, promotion and fundraising, "aggregated" territorial organizations that locally implement the OFM program.
- to identified subjects for whom the communication is necessary to fulfill an obligation established by law, by a regulation or by community legislation.
In particular, the taxpayer's personal data is sent to the Revenue Agency for the purposes of the pre-compiled declaration. The taxpayer can exercise the right to oppose the sending to the Agency of data relating to donations as required by the provision of the Director of the Revenue Agency of 9 February 2018.
The data will not be transferred outside the European Union.
Methods of processing and storing data
The Order of Friars Minor will process personal data for the time necessary to fulfill the aforementioned purposes according to variable criteria according to the category of data, the nature of the processing and the purposes of the processing itself. In principle, OFM will establish the retention policy based on the following assessments:
- All data with respect to the various forms of donation are kept as long as the relationship remains active and in any case no later than 10 years from the date of each manifestation of support of the OFM (typically of an economic nature), or until the moment in which you decide to exercise the right to cease supporting OFM and request the deletion of the data, unless an obligation established by law, regulation or community legislation imposes the conservation or exercise of a right (or in any case a legitimate interest ) of the OFM itself does not require its conservation.
- All data of donors or those interested in our activity processed for information/promotional purposes are kept for the time period necessary to provide the information services reserved to said persons. This right and interest in information arise upon joining any initiative which demonstrates the sharing of the principles of OFM by the interested party, whether this involves a donation or an action of interest and participation in the institutional activities of the OFM. This period is justified by OFM's legitimate interest in keeping the relationship established with the person constant in order to keep them informed on which projects could be financed with the contribution of donors or on awareness-raising actions which it is deemed useful to make known in order to demonstrate one's constant commitment to the realization of their projects within the scope of their institutional goals. The retention period is extended as long as the person's interest in staying in contact with the OFM persists: if he is no longer interested, it is sufficient to communicate it through the methods set out in the Paragraph "Rights of the interested parties" and OFM will adopt the appropriate technical and organizational measures to no longer disturb the person.
- The retention time for the personal data referred to in letter d) will be kept for the time strictly necessary to carry out the specified activities.
- The retention time for the personal data referred to in letter e) will be kept for the time strictly necessary to carry out the specified activities. Upon expiry, the data will be deleted or anonymized, unless there are other purposes for their conservation.
Once the relative retention periods have elapsed, the personal data will be definitively canceled and will no longer be processed.
Rights of interested parties
The interested party may exercise their rights, listed below, at any time, in accordance with the provisions of EU Regulation 679/2016 and the national legislation in force:
- Right of access : the interested party has the right to obtain confirmation as to whether or not personal data concerning him is being processed and, if so, to obtain access to personal data. At any time you can request access to the following information: the purposes of the processing, the categories of data processed, the recipients to whom the personal data are or will be communicated, the data retention period, the existence of rights in your favor , the origin of the data and the possible existence of an automated process.
- Right of rectification : the interested party has the right to obtain from the data controller the rectification of inaccurate personal data concerning him without unjustified delay. Furthermore, you have the right to obtain the integration of incomplete personal data, also by providing a supplementary declaration. In this case, the data controller will have the obligation to inform each recipient to whom the personal data have been transmitted of any corrections.
- Right of cancellation : the interested party has the right to obtain the cancellation of personal data concerning him without unjustified delay and request cancellation. Furthermore, if your data has been made public, the holder will delete them and will take reasonable measures, including technical ones, to inform the data controllers who are processing the personal data of the interested party's request to delete any copy of his personal data. OFM will take all appropriate technical and organizational measures to stop disturbing you.
- Right to limitation of treatment : if the interested party deems it appropriate, he can request the limitation of the processing of personal data concerning him and limit its treatment in the future. In this case, the data controller will inform each of the recipients to whom the personal data have been transmitted of any limitations on the processing, unless this proves impossible or involves a disproportionate effort.
- Right to object to processing : the interested party has the right to object at any time, for reasons related to his particular situation, to the processing of personal data concerning him.
- Right to revoke consent : in the case of treatment based on consent, the interested party may revoke the consent given for the treatment. However, this act does not affect the validity of the treatment carried out by the owner up to that moment.
- Right to lodge a complaint with the Supervisory Authority : where the interested party believes that his data have been processed unlawfully and violate the rules and principles regarding the protection of personal data, he has the right to contact the Supervisory Authority (Guarantor Privacy) to lodge a complaint, according to the methods defined by the latter.
You may exercise your rights at any time by sending:
- an email to firstname.lastname@example.org ;
- or a registered letter with return receipt to the General Curia of the Friars Minor, with registered office in Via di Santa Maria Mediatrice, 25 – 00165 Rome.