PRIVACY POLICY

DATA PROTECTION POLICY ON PERSONAL DATA PROCESSING

As per Article 13 of EU Regulation 2016/679 (“Regulation”)

With this document, as per Art. 26 of the Regulation, as “Joint Data Controllers” Ca’ Foscari University of Venice and Fondazione Ca’ Foscari give you information on the processing of personal data collected as part of your enrolment and participation in a 1st- and 2nd-level University Master’s Programme or “Lifelong Learning” Courses provided by the Ca’ Foscari Challenge School. In this document, the Programme and Courses are referred to jointly as “Master’s Programmes” and their activities are managed by the Joint Data Controllers.
You may register by filling out the relevant forms which are available at: https://www.cafoscarichallengeschool.it/ (here, the “Site“) where you can also request information or subscribe to the newsletter. 

1. WHO WE ARE – JOINT DATA CONTROLLERS

The Joint Data Controllers are:

• Ca’ Foscari University of Venice, with registered office at Dorsoduro 3246, 30123 Venezia (here, the “University”);
• Fondazione Ca’ Foscari, with registered office at Dorsoduro 3859/A, 30123 Venezia (here, the “Fondazione”).

2. DATA PROTECTION OFFICERS

The University has appointed a “Data Protection Officer”, who can be contacted by writing to dpo@unive.it or to the surface postal address: Università Ca’ Foscari Venezia, Responsabile della Protezione dei Dati, Dorsoduro n. 3246, 30123 Venezia (VE).
The Fondazione has appointed a “Data Protection Officer”, who can be contacted by emailing to dpo.fcf@unive.it or writing to: Fondazione Ca’ Foscari, Dorsoduro 3859/A, 30123 Venezia, Italy.

3. CATEGORIES OF PERSONAL DATA

To enrol in a Master’s Programme, you will be asked to provide the following personal data:

• Personal and contact details: information on your name, surname, place/date of birth, tax code, address, landline/mobile phone number/s, email address, and a copy of a valid identity document (the latter only for enrolment in First and Second Level University Master’s Programmes);
• Data on any specific learning disorders or disabilities;
• Payment details: bank details, credit cards, VAT number if applicable;
• Other personal data:your previous university and professional career (academic qualifications, employment status, profession, company or body for which you work), how you came to know of Ca’ Foscari Challenge School, and your topics of interest);
• Site Use: information on how you use the site, open or forward our communications, including information collected by cookies (you can find our Cookie Policy, which regulates the details);
• Image/Voice: information about your image and voice collected through audio-visual recording devices.

4. THE PURPOSES YOUR PERSONAL DATA MAY BE USED FOR

The Joint Data Controllers jointly define the methods and purposes of processing your personal data while the legal bases that legitimise the processing are different as they depend on the division of the tasks between them, as outlined below.
Providing your personal information is optional, however, should you not do so, we will be unable to deliver the services that you may require of us based on the following needs: 

• Enrolment and management of First and Second level University Master’s Programmes

The University processes your personal data so that you can enrol in, and participate, in Level I and Level II University Master’s Courses.
The legal basis for the processing is given in Article 6.1(e) of the Regulation (“performance of a task carried out in the public interest”). If, to take part in these Master’s courses, you provide the University with information on your health (e.g. a disability or specific learning disability), such information will be processed for the sole purpose of allowing you to take advantage of support, services and specific facilities. The legal basis for such processing is Article 9.2.(g) of the Regulation (“reasons of overriding public interest”).  
Right of opposition: you may oppose the above processing at any time by writing to the University’s Data Protection Officer at the contact details above. The University will then refrain from any further processing of your personal data, unless there are compelling reasons that justify continuation.

• Sending of Institutional Communications 

The University may also send you (to the email address given when registering in the Master’s Programme), communications and newsletters concerning its institutional work of teaching, research and third mission. The legal basis for such processing is Article 6.1(e) of the Regulation (“performance of a task carried out in the public interest”).
Right of opposition: you may oppose the sending of communications concerning the institutional work of teaching, research and the third mission by using the appropriate link at the bottom of each communication, or by writing to the University’s Data Protection Officer at the addresses given above. The University will then refrain from any further processing of your personal data unless there are compelling reasons that justify continuation.

• Management of replies to requests for information on the Master’s Programmes

The Fondazione will process your personal and contact data collected through the information request form on the Site, or through the contacts indicated in it, in order to allow you to receive information about the Master’s Programme, or other initiatives in which you have expressed an interest.
The legal basis for such processing is Article 6.1.b) (“performance of pre-contractual measures)”.

• Enrolment in, and management of Lifelong Learning (“Post-Graduate”) courses

The Fondazione processes your personal and contact data so that you can enrol and participate in Lifelong Learning courses. 
The legal basis for this processing is given in Art. 6.1.(b) of the Regulation (“performance of a contract to which the Data Subject is party”).

• Sending promotional messages regarding products and services similar to the Master’s Programme as per Art. 130, paragraph 4, of the Privacy (data-protection) Code.

The Fondazione may process your personal and contact data, with particular reference to your e-mail address, to send you promotional messages on courses and services similar to those you have enrolled in. We will formulate these messages by using other personal data that you may have provided us. The legal basis for this processing is Article 6.1.f) of the Regulation (“legitimate interest” of Fondazione to maintain an effective relationship with you). 
Right to opposition: you may oppose the above-mentioned processing at any time by writing an email to the Fondazione to: corsi.challengeschool@unive.it.
The Fondazione will then refrain from any further processing of your personal data unless there are compelling reasons that justify continuation.

• Marketing communications 

Subject to your specific consent, the Fondazione may process your personal and contact data to send you promotional communications on initiatives regarding Master’s Programmes, other courses, seminars and events, also by sending you the newsletter you have subscribed to using automated methods (e-mail, SMS, MMS, chat, instant messaging, social networks, other mass-messaging tools, etc.). 
The legal basis for this processing is Art. 6.1.(a) of the Regulation (“consent of the Interested party”).
This consent may be revoked at any time, effective from subsequent processing.

• Customer satisfaction surveys

Your personal and contact data, in particular your e-mail address, may also be used by the Fondazione for carrying out surveys on your level of satisfaction. The results of surveys, which are collected by completing questionnaires, will be processed by the Fondazione completely anonymously i.e. without the possibility of tracing these results to you as an individual. Only if you wish to be contacted to receive feedback from the Fondazione, you may make the completed questionnaire recognizable using the special function provided.
The legal basis for such processing is given in Art. 6.1.f) (“legitimate interest” of Fondazione to maintain a high standard of quality of the services it provides and to meet its users’ needs.)

• Defence of rights in the event of court, administrative or out-of-court proceedings, and in the case of disputes arising over the services provided

Your Personal Data may be processed by the Joint Data Controllers to uphold their rights, or to take legal steps, or to even submit claims against you or third parties.
The legal basis for such processing is given for the University by Article 6.1.e) of the Regulations (“performance of a task in the public interest”) and for the Fondazione by Article 6.1.f) (“legitimate interest” to exercise or defend its rights in court). 

• Reasons relating to legal obligations, regulations, or EU legislation, with provisions/requirements of legally empowered authorities and/or supervisory and control bodies.

To fulfil their own obligations, the Joint Data Controllers may process your Personal Data, the legal basis for which is Article 6.1.c) (“legal obligation”).
During the course lessons and events organised by Ca’ Foscari Challenge School, photographs or films may be taken, so your image/voice may be recorded and processed by the Joint Data Controllers. Specific information on this type of processing will be provided to you by way of a special consent form that will be given to you during the class or event.

5. RETENTION TIMES

We will retain your Personal Data for only as long as is strictly necessary to fulfil the purposes for which they were collected, or for any other legitimate related purpose. Therefore, if personal data are processed for two different purposes, those data will be retained until the purpose with the longer retention period ceases. Your Personal Data that are no longer needed, or for which there is no longer a legal basis for their retention, will be made irreversibly anonymous (and thus can be retained) or else securely destroyed. 
Below are the retention times regarding the different purposes listed above:

• Subb a and b purposes for first- and second-level university Master’s Programmes: indefinite retention as they are necessary to reconstruct the student’s career; 
• Purpose sub c): retention for 3 months;
• Purpose sub d) for Lifelong Learning courses: retention for the full duration of the contract and, in any case, for no longer than the following 10 years, so as to verify any pending issues including accounting documents (e.g. invoices);
• Purpose sub e): retention for 24 months from the last interaction with Fondazione or until you exercise your right to opposition;
• Purpose sub f): retention for 24 months after collection;
• Purpose sub g): the questionnaires will be kept in anonymous form and the results analysed in aggregate form. If you have chosen to be recognisable, your personal and contact data will be kept for this purpose only for the time necessary to contact you again. Afterwards, the questionnaire will be made anonymous;
• Purpose (h): retention for as long as this requirement can be pursued;
• Purpose (i): retention related to legal obligations.

6. RECIPIENTS AND CATEGORIES OF RECIPIENTS OF PERSONAL DATA

The personal data collected will be processed by the personnel and collaborators of the Joint Data Controllers acting on specific instructions which regard the purposes and methods of processing. The data can also be collected and processed by subjects who provide ancillary services to the Joint Data Controllers appointed as Data Processors.

An updated list of the University’s Data Controllers is available at: https://www.unive.it/pag/34666/. 
If you wish to see the list of Data Controllers and other subjects to which we disclose data, you may write to: privacy.fcf@unive.it. 

7. RIGHTS OF THE DATA SUBJECT AND HOW TO EXERCISE THEM

If the requisites provided by the Regulation are met, you have the right to ask us:

• access to your personal data;
• a copy of the Personal Data you have provided us (“portability”);
• the rectification of data in our possession;
• the cancellation of any data for which we no longer have any legal basis for holding/processing;
• the revocation of your consent if the processing is based on consent;
• the limitation of how we process your personal data within the limits provided by data-protection legislation.

Right to opposition: in addition to the rights listed above, you have the right to oppose the processing of your Personal Data at any time for reasons related to your particular situation. You also have the right to opposition at any time if your Personal Data is processed for marketing purposes. 
The exercising of these rights is not subject to cost nor to any formal constraints, but it is subject to certain exceptions aimed at safeguarding the public interest (e.g. the prevention or identification of crimes) and our interests (e.g. maintaining professional secrecy). Should you exercise any of the above rights, it will be our responsibility to verify that you are entitled to exercise them, and we will normally respond within one month.
The request may be made without any formalities by directly contacting:

• for the University, the Data Protection Officer at dpo@unive.it, or by posting a letter to: Università Ca’ Foscari Venezia – Responsabile della Protezione dei Dati, Dorsoduro 3246, 30123 Venezia. You can also write an email to the University at: protocollo@pec.unive.it ;
• for the Fondazione, the Data Protection Officer at the e-mail addresses privacy.fcf@unive.it and dpo.fcf@unive.it.

If you believe that the processing of personal data relating to you has been carried out in breach of the provisions of the Regulation, you have the right to lodge a complaint with the Personal Data Protection Authority using the references available on the website www.garanteprivacy.it, or to take legal steps.

Data di pubblicazione dell’informativa: 24 agosto 2020