Website Privacy Policy
(DATACONTROLLER =) Trust-IT srl, with registered offices in via Francesco Redi, 10, 56124 Pisa (IT), VAT no. and Fiscal Code 01870130505, is committed to protecting the online privacy of the users of this website (“Website”).
As such, this Privacy Policy has been written in order to allow you to understand Trust-IT srl’s policy regarding your privacy, as well as how your personal information will be handled when using the Website. This Privacy Policy will also provide you with information so that you are able to consent to the processing of your personal data in an explicit and informed manner, where appropriate.
In general, any information and data which you provide to Trust-IT srl over the Website, or which is otherwise gathered via the Website by Trust-IT srl, in the context of the use of Website’s services (“Services”) as better defined in Section 3 below, will be processed by Trust-IT srl in a lawful, fair and transparent manner. To this end, and as further described below, Trust-IT srl takes into consideration internationally recognised principles governing the processing of personal data, such as purpose limitation, storage limitation, data minimisation, data quality and confidentiality, data security, transparency, and fairness.
CONTENTS
a. Name, contact details and other Personal Data
b. Special categories of Personal Data
c. Other persons’ Personal Data
4. Grounds for processing and mandatory / discretionary nature of processing
5. Recipients of Personal Data – Data Processors
6. Other Recipients of Personal Data
1. Data controller
Trust-IT srl, as identified at the top of this Privacy Policy, is the data controller regarding all personal data processing carried out through the Website. You can contact Trust-IT srl with any questions related to this Privacy Policy or Trust-IT srl’s personal data processing practices by sending a written communication to privacy@digineb.eu or via the contact forms available on the Website.
2. Personal Data processed
When you use the Website, Trust-IT srl will collect and process information regarding you (as an individual), which allows you to be identified either by itself or together with other information which has been collected. Trust-IT srl may also be able to collect and process information regarding other persons in this same manner if you choose to provide it to Trust-IT srl, also via the Website. Data Subjects should refrain from providing the personal data of other data subjects, and if they decide to provide such information, they are fully responsible for any claims or damages that may arise as a result of the provision of such information, and they fully indemnify Trust-IT srl against any liability.
This information may be classified as “Personal Data” and can be collected by Trust-IT srl both when you choose to provide it (e.g. when you subscribe to the newsletter or request other Services provided by Trust-IT srl over the Website) or simply by analysing your behaviour on the Website.
Personal Data which can be processed by Trust-IT srl through the Website are as follows:
a. Name, contact details and other Personal Data
In various areas of the website – particularly if you decide to create an account– you will be asked to submit information about yourself, such as your name, surname, email address, organisation name, and domain of work/expertise. Mandatory fields will be marked as such in the online registration forms – it is not possible to process your registration if any of the mandatory fields are left incomplete. Not mandatory fields are used for statistical analysis and to provide more specific content.
In addition, whenever you communicate with Trust-IT srl by submitting a general enquiry or a support ticket via the Website, as well as whenever you participate in surveys which may be available on the Website, Trust-IT srl may collect additional information which you choose to provide; additional information to that which is specifically requested should not be provided, e.g., special categories of personal data.
b. Special categories of Personal Data
When signing up for an event via the Website (such as a workshop organised or promoted by the Website), you will also be asked whether you have any special dietary/access requirements which might need accommodation. These Personal Data may potentially qualify as “health data” or “data revealing your religious/philosophical beliefs”, which are special categories of personal data under Art. 9 GDPR and will be processed only with your explicit consent.
Certain website areas may include free text fields, where you can write messages to Trust-IT srl or otherwise allow you to post various types of content on the Website, which may contain Personal Data. Where these fields are completely free, you may use them to disclose (inadvertently or not) more sensitive categories of Personal Data, such as data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. The content you upload in these fields may also (inadvertently or not) include other types of sensitive information relating to you, such as your genetic data, biometric data or data concerning your health, sex life or sexual orientation.
Trust-IT srl asks that you do not disclose any sensitive Personal Data on the Website unless you consider this to be strictly necessary. As it is totally optional to provide this information, if you nonetheless choose to do so, please mind that Trust-IT srl requires your explicit consent to process this sort of Personal Data (which can be provided, e.g., by declaring that you “explicitly consent to the processing of my special categories of personal data for the purpose of assessing my candidacy”).
c. Other persons’ Personal Data
As mentioned in the previous section, certain areas of the Website include free text fields where you can write messages to Trust-IT srl or otherwise allow you to post various types of content on the Website. These messages and content may (inadvertently or not) include Personal Data related to other persons.
In any situation where you decide to share Personal Data related to other persons, you will be considered an independent data controller regarding that Personal Data and must assume all inherent legal obligations and responsibilities. This means, among other things, that you must fully indemnify Trust-IT srl against any complaints, claims or demands for compensation for damages which may arise from processing this Personal Data brought by the third parties whose information you provide through the Website.
As Trust-IT srl does not collect this information directly from these third parties (but rather collects them, indirectly, from you), you must make sure that you have these third parties’ consent before providing any information regarding them to Trust-IT srl; if not, then you must make sure there are some other appropriate grounds on which you can rely to lawfully give Trust-IT srl this information.
d. Browsing data
The Website’s operation, as is standard with any website on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation. While Trust-IT srl does not collect this information to link it to specific users, it is still possible to identify those users either directly via that information or by using other information collected – as such, this information must also be considered Personal Data.
This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your device, the type of device, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on.
These data are used to compile statistical information on the use of the Website, to ensure its correct operation, as well as restore the backup from possible failures of the Website and identify any faults and/or abuse of the Website. Save for this last purpose, these data are not kept for more than 60 business days.
e. Cookies
- Definitions, characteristics, and application of standards
Cookies are small text files that may be sent to and registered on your computer by the websites you visit, to then be re-sent to those same sites when you visit them again. It is thanks to these cookies that those websites can “remember” your actions and preferences (e.g., login data, language, font size, other display settings, etc.), so that you do not need to configure them again when you next visit the website, or when you change pages within a website.
Cookies are used for electronic authentication, monitoring of sessions and storage of information regarding your activities when accessing a website. They may also contain a unique ID code that allows tracking of browsing activities within a website for statistical or advertising purposes. Some operations within a website may not be able to be performed without the use of cookies which, in certain cases, are technically necessary for the website’s operationality.
When browsing a website, you may also receive cookies from websites or web servers other than the website being visited (i.e., “third-party cookies”).
There are various types of cookies, depending on their characteristics and functions, which may be stored on your computer for different periods of time: “session cookies”, which are automatically deleted when you close your browser, and “persistent cookies”, which will remain on your device until their pre-set expiration period passes.
According to the law which may be applicable to you, your consent may not always be necessary for cookies to be used on a website. In particular, “technical cookies” – i.e. cookies which are only used to send messages through an electronic communications network or which are needed to provide services you request – typically do not require this consent. This includes browsing or session cookies (used to allow users to log in) and function cookies (used to remember choices made by a user when accessing the website, such as language or products selected for purchase).
- Types of cookies used by the Website
The Website uses the following types of cookies:
Browsing or session cookies, which are strictly necessary for the Website’s operation, and/or to allow you to use the Website’s content and Services.
Trust-IT srl also uses third party cookies – i.e. cookies from websites/web servers other than the Website, owned by third parties. These third parties will either act as independent data controllers from Trust-IT srl regarding their own cookies (using the data they collect for their own purposes and under terms defined by them) or as data processors for Trust-IT srl (processing personal data on Trust-IT srl’s behalf).
For further information on how these third parties may use your information, please refer to their privacy policies:
Youtube
The list of installed cookies is available in the Cookie Policy on the Website
- Cookies settings
Cookies are manually managed the first time you visit the website via a dedicated form. At any time, registered users can block or delete cookies used on the Website via this form, available under the “My Account” section, or via your browser options. Your cookie preferences will be reset if different browsers are used to access the Website. For more information on how to set the preferences for cookies via your browser, please refer to the following instructions:
You may also set your preferences on third-party cookies using online platforms such as AdChoice.
CAUTION If you block or delete technical and/or function cookies used by the Website, the Website may become impossible to browse, certain services or functions of the Website may become unavailable or other malfunctions may occur. In this case, you may have to modify or manually enter some information or preferences every time you visit the Website.
3. Purposes of processing
Trust-IT srl intends to use your Personal Data collected through the Website for the following purposes:
1. To allow you to create and maintain a registered user profile on the Website, to allow you to participate in different areas over the Website and exchange information/documents with other participants, to assist you in case you lose or forget your login/password details for any of the Website’s registration services, to respond to your enquiries and requests for support, and to provide any other Services which you may request (“Service Provision”);
2. For marketing, promotional and publicity purposes; to send you informative newsletters and other communications (linked to the collaborative areas in which you participate); to carry out direct marketing, market research and surveys, via email, through push notifications / pop-up banners, through the Website’s official social media pages, […], regarding upcoming events organised by the Website, as well as events hosted by selected third parties (“Marketing”);
3. To include information on you as a registered Early Adopter within the Website pages and database (“Early Adopter Members Database”);
4. For compliance with laws which impose upon Trust-IT srl the collection and/or further processing of certain kinds of Personal Data (“Compliance”);
5. For development and administration of the Website, in particular by the use of anonymised data analytics regarding how users make use of the Website to generate statistics and improve our offerings (“Analytics”);
6. To prevent and detect any misuse of the Website or any fraudulent activities carried out through the Website, including by carrying out internal audits (“Misuse/Fraud”).
4. Grounds for processing and mandatory/discretionary nature of the processing
Trust-IT srl’s legal bases for processing your Personal Data, according to the purposes identified in Section 3, are as follows:
1. Service Provision: processing for these purposes is necessary to provide the Services and, therefore, is necessary for performing a contract with you – Art. 6(1)(b) GDPR. It is not mandatory for you to give Trust-IT srl your Personal Data for these purposes; however, if you do not, Trust-IT srl will not be able to provide any Services to you.
2. Events/Webinars: processing for these purposes is generally necessary to allow the Trust-IT srl Team to respond to your request to sign up for an event/webinar and, therefore, is necessary for the performance of a contract with you – Art. 6(1)(b) GDPR. It is not mandatory for you to give Trust-IT srl your Personal Data for these purposes; however, if you do not, Trust-IT srl will not be able to process your registration for an event/webinar.
3. Marketing: processing for these purposes is based on your consent – Art. 6(1)(a) GDPR. It is not mandatory for you to give consent to Trust-IT srl for the use of your Personal Data for these purposes, and you will suffer no consequence if you choose not to give it (aside from not being able to receive newsletters and further marketing communications from Trust-IT srl). Any consent given may also be withdrawn at a later stage (please see Section 8 for more information).
5. Early Adopter Members Database: processing for this purpose is based on your consent – Art. 6(1)(a) GDPR. It is not mandatory for you to give consent to Trust-IT srl for the use of your Personal Data for these purposes, and you will suffer no consequence if you choose not to give it. Any consent given may also be withdrawn at a later stage (please see Section 8 for more information).
8. Compliance: processing for this purpose is necessary for Trust-IT srl to comply with its legal obligations – Art. 6(1)(c) GDPR. When you provide any Personal Data to Trust-IT srl, Trust-IT srl must process it in accordance with the laws applicable to it, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations.
9. Analytics: Information collected for this purpose is used to allow Trust-IT srl to understand how users interact with the Website and to improve the Website accordingly, with the aim of providing a better user experience – Art. 6(1)(f) GDPR. Data are collected in an anonymous way, and no Personal data is transferred to the service provider Google Analytics.
10. Misuse/Fraud: Information collected for this purpose is used exclusively to prevent and detect fraudulent activities or misuse of the Website (for potentially criminal purposes) – Art. 6(1)(f) GDPR.
5. Recipients of Personal Data – Data Processors
Your Personal Data may be shared with the following list of entities (“Data Processors”):
The following entities are engaged to provide or support the Website and Services (e.g., hosting providers, email platform providers, technical maintenance providers, Website administrators and Website user administrators):
TU Delft, Postbus 5, 2600 AA - Delft, The Netherlands, VAT NL001569569B01
COMMpla srl, via Francesco Redi 10, 56124 - Pisa (PI), Italy. VAT no. and Fiscal Code IT 01958380501
Industry Commons Foundation, 7A Centralen, Vasagatan 7, 111 20 - Stockholm, Sweden, organisation no. 8024812599
European Association for Architectural Education, Faculty of Architecture, Campus Sint-Lucas Brussels - KU Leuven, 65-67, Paleizenstraat 1030 - Brussels, Belgium, VAT BE 0432722443
InnovaWood, The European Forestry House 66, Rue du Luxembourg, BE-1000 - Bruxelles, Belgium, CBE: 0828085535
Google Ireland Limited; Gordon House Barrow Street, Dublin 4 DUBLIN, D04 E5W5 Ireland, managing the Google Analytics service for European-based websites.
Mailjet, 4 rue Jules Lefebvre n75009 Paris, managing the newsletter service
Zoom Video Communications, Inc., 55 Almaden Blvd, Suite 600, San Jose, CA 95113, managing webinar service with Personal Data Residency in Europe.
6. Other Recipients of Personal Data
Your Personal Data may be shared with the following list of persons/entities (“Recipients”):
Persons authorised by Trust-IT srl to process Personal Data needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., members of the team operating the Website, and other functions with access to Personal Data processed via the Website);
Public entities, bodies or authorities to whom your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities.
More information on these transfers is available upon written request to the Website Managing Team at the following address: privacy@digineb.eu.
7. Retention of Personal Data
Personal Data processed for Service Provision and Events/Webinars will be kept by Trust-IT srl for the period deemed strictly necessary to fulfil such purposes – in any case, as these Personal Data are processed for the provision of the Services, Trust-IT srl may continue to store this Personal Data for a longer period, as may be necessary to protect Trust-IT srl’s interests related to potential liability related to the provision of the Services.
Personal Data processed for Early Adopter Members Database and Marketing will be kept by Trust-IT srl from the moment you give consent until it is withdrawn. Where it is not withdrawn, consent will be renewed at fixed intervals. Once consent is withdrawn (or not given, following a renewal), Personal Data will no longer be used for these purposes, although it may still be kept by Trust-IT srl in particular as may be necessary to protect Trust-IT srl’s interests related to potential liability related to this processing.
Personal Data processed for Compliance will be kept by Trust-IT srl for the period required by the specific legal obligation or by the applicable law.
Personal Data processed for preventing Misuse/Fraud will be kept by Trust-IT srl for as long as deemed strictly necessary to fulfil the purposes for which it was collected.
More information on applicable retention periods is available upon written request to the Website Managing Team at the following address: privacy@digineb.eu.
8. Data subjects’ rights
As a data subject, you are entitled to exercise the following rights before Trust-IT srl, at any time:
1. Access your Personal Data being processed by Trust-IT srl (and/or a copy of that Personal Data), as well as information on the processing of your Personal Data;
2. Correct or update your Personal Data processed by Trust-IT srl, where it may be inaccurate or incomplete;
3. Request erasure of your Personal Data being processed by Trust-IT srl, where you feel that the processing is unnecessary or otherwise unlawful;
4. Request the restriction of the processing of your Personal Data where you feel that the Personal Data processed is inaccurate, unnecessary or unlawfully processed, or where you have objected to the processing;
5. Exercise your right to portability: the right to obtain a copy of your Personal Data provided to Trust-IT srl in a structured, commonly used and machine-readable format, as well as the transmission of that Personal Data to another data controller;
6. Object to the processing of your Personal Data, based on relevant grounds related to your particular situation, which you believe must prevent Trust-IT srl from processing your Personal Data; or
7. Withdraw your consent to processing (for Marketing, Early Adopter Members Database).
Please note that most of the Personal Data you provide to Trust-IT srl can be changed at any time, including your email preferences, by accessing, where applicable, your user profile created on the Website.
You can also withdraw consent for Marketing (for communications received via email by selecting the appropriate link included at the bottom of every marketing email message received. The same applies to the Website’s newsletter, which you may have subscribed to and receive as a Service.
Aside from the above means, you can always exercise your rights described above by sending a written request to the Website Managing Team at the following address: privacy@digineb.eu.
In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data if you believe that the processing of your Personal Data carried out through the Website is unlawful.
9. Amendments
This Privacy Policy entered into force on 30/06/2023
Trust-IT srl reserves the right to partly or fully amend this Privacy Policy or simply to update its content, e.g., as a result of changes in applicable law. The Website Managing Team will inform you of such changes as soon as they are introduced, and they will be binding as soon as they are published on the Website. The Website Managing Team, therefore, invites you to regularly visit this Privacy Policy to acquaint yourself with the latest, updated version of the Privacy Policy so that you may remain constantly informed on how Trust-IT srl collects and uses Personal Data.