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Privacy
DATA PROCESSING POLICY
The methods for some personal data processes used by the Order of Architects, Planners, Landscape Architects and Conservationists of the Province of Milan (the Order) and the Foundation of the Order of Architects, Planners, Landscape Architects and Conservationists of the Province of Milan (the Foundation) are described below.
This includes the processing of the data of users who consult the website www.ordinearchitetti.mi.it and other web services accessible from it. Other websites that may be consulted by the user through links are not included.
Data Controller and Data Protection Officer
For some processes, the controller is:
Order of Architects, Planners, Landscape Architects and Conservationists of the Province of Milan
Via Solferino 19 - 20121 Milan
email: segreteria@ordinearchitetti.mi.it; segreteria@oamilano.it (PEC).
For some processes, the controller is:
Foundation of the Order of Architects, Planners, Landscape Architects and Conservationists of the Province of Milan
Via Solferino 19 - 20121 Milan
email: fondazione@architettura.mi.it; fondazione@oamilano.it (PEC).
The Milan Order has also appointed a Data Protection Officer, who can be contacted either at the secretariat of the Milan Order or by email privacy@ordinearchitetti.mi.it.
Purposes, duration and legal basis of data processing
Processing of browsing data (controller: Order)
The data processed consists of the IP addresses or domain names of the computers used by users of the website, the time of the request and other parameters relating to the user's operating system and IT environment.
The browsing behaviour of visitors to the website is also analysed, e.g. which pages are visited before or after others. The data is collected on cookies and therefore on the legal basis of the consent of the person concerned expressed on the banner or on the specific page of our website (renewal of authorisations is required after 13 months). Assessments are carried out on aggregate data and the data is kept for a maximum of three years.
This data is used on the legal basis of:
- the legitimate interest of the owner and in order to obtain anonymous statistical information on the use of the website and to monitor its correct operation;
- consent of the data subject on the form that opens on the website; this is to obtain further statistical information, even if not based on anonymous data, on the services offered by the Order and the Foundation.
Further details can be found in the Cookie policy.
Access to the personal area - login form (controller: Order)
The website allows registration on the personal area in order to use certain services. Members of the Order will be asked to supply their email address and registration number when signing up, while others will only need to supply their email address. The legal basis for this process is the provision of a service requested by the data subject.
The website tracks those who access the personal area. The legal basis for this processing is the legitimate interest of the website operator because tracking certain user actions can be useful in the event of security issues.
Access data will be kept until the data subject requests otherwise. Tracking data will be kept for a maximum of three years.
Newsletter subscription (controller: Order)
The data processed consists of the email address and other contact details, provided directly by the data subject on our website or by other means.
The legal basis for the processing is consent, which is requested during registration for those using our website and during the confirmation of registration. The data subject may always rescind their consent following the procedure indicated in each email.
The data will be kept until the data subject explicitly requests otherwise.
In order to carry out statistical analyses regarding our newsletters, data on certain actions is collected: opening of the newsletter, use of the proposed links, pages of the site visited. Assessments are carried out on aggregated data and the data is kept for a maximum of three years.
The newsletter service is managed by the Foundation.
Support from helpdesk (controller: Order)
The data is processed by the professionals (e.g. lawyer, tax consultant) who supply "helpdesk" advice to members at their request.
Personal data is used for booking appointments only. Other data which may be supplied during interaction with the helpdesk is not collected and stored.
This data is used on the legal basis of the implementation of contractual measures taken at the request of the data subject.
The data is kept until the end of the meeting.
Management of CVs (controller: to whom they are addressed, Order and Foundation)
Sending CVs by email or contact form to the addresses indicated on this website involves the subsequent acquisition of the sender's address, which is necessary in order to reply to questions or requests, as well as any other personal data entered.
This data is used on the legal basis of the implementation of pre-contractual measures taken at the request of the data subject.
The data is kept for three years after receipt of the CV to allow any further selection and contact activities. The data may be kept longer, for a total of five years, as it is present in the backups.
Management of requests on the DIMMI platform (controller: Order)
Sending data via the DIMMI platform (https://ordinearchitetti.mi.it/it/professione/dimmi) involves the subsequent acquisition of the sender's address, which is necessary in order to reply to questions or requests. This data is used on the legal basis of the execution of pre-contractual measures taken at the request of the data subject.
When using the DIMMI platform, it is possible to agree to receive questionnaires for the assessment of the service. The legal basis for this processing is consent.
The data registered on the DIMMI service is processed on the HubSpot platform (see below).
The data is kept for three years after the service has been provided, to allow for any quality control; the data may be kept longer, for a total of five years, as it is present in the backups.
Platform for job advertisements and job seeking and offering form (controller: Order)
The Order, together with the Foundation, makes job advertisement platform available on https://ordinearchitetti.mi.it/it/professione/cerco-offro
Those offering a job do not necessarily have to supply personal data but must register on the website (with email and, if registered with the Order, registration number); refusal to enter the data requested (personal or otherwise) will make it impossible to publish the job vacancy. The data will remain published for 30 days, unless otherwise requested by the data subject, and then deleted from our archives after a further five months.
The data uploaded onto the platform is published and, therefore, accessible to everyone.
The data is processed on the legal basis of the provision of a service requested by the data subjects.
The data will also be transferred to the Hubspot platform used for aggregate statistics, by age, types of professionals sought and areas of specialisation offered, for example. This processing takes place in relation to the controller's legitimate interest in improving its services.
The email indicated in the ad may be used to send questionnaires to assess the service. This processing takes place with the consent of the data subject.
The data is stored until the expiry date or until the data subject requests otherwise. The data may be kept longer, for a total of five years, as it is present in the backups..
Training courses, evenings, itineraries and events (controllers: Order, Foundation and others)
The data processed is listed below together with the purposes:
- for participants of courses, including webinars, evenings, itineraries and events, the contact data supplied by the subscriber to track attendance; to send organisational communications relating to the event, to request information on satisfaction and to propose similar events.
- for lecturers and professionals, the contact details and CVs necessary for the organisation of the activity and to demonstrate its quality.
For the registration of participants, the sending of organisational communications, the request for information on satisfaction and the proposal of similar events, the controller is the Foundation. Registration takes place via the Foundation's own website.
Evenings, courses, itineraries and events are managed by the Foundation. Registration data is transferred to possible sponsors for the purpose of sending subsequent information (e.g. newsletters) only with prior consent or because they provide the web platforms necessary for participation in the event.
The Foundation and the Order process the data:
- Foundation, in their capacity as controller, to keep track of the activity, send organisational communications, request information on satisfaction, propose similar events and, where appropriate, assess their quality;
- Order, in the case of members of the Order, joint controller with the CNA, which keeps track of the activity of members and assesses the quality of training.
The legal basis for the processing of the data is the fulfilment of an agreement to which the data subject is party, compliance with the regulations on accounting records and the legitimate interest of the data controller (in relation to quality control, the request for information on satisfaction and the proposal for similar events, as also envisaged by Legislative Decree 196 of 2003, article 130, paragraph 4).
The data will be kept for ten years from the termination of the course, evening, itinerary or event (also, in the case of payments, as required by the laws on accounting records); the data may be kept for another year as it is present in the backups.
The Foundation may use the email references of participants in courses, evenings, itineraries and events to promote similar initiatives. In this case, the data will be kept until the data subject requests otherwise (see below). The data subject may always refuse such communications.
Representatives of affiliated bodies, partners and other organisations (controllers: Order and Foundation)
The Order and the Foundation are aware of the contact details of the individuals representing the organisations with which they have relations. This is in order to facilitate relations.
The processing will be carried out on the legal basis of legitimate interest.
The data may be kept for ten years after the termination of the relationship, as it is integrated with the data to be kept in compliance with the terms imposed by the regulations in force.
Data collection on social networks (controllers: Order and Foundation)
The Order and the Foundation (each the controller of the processing carried out on their own channels), process data, as joint controller together with the social network operator (which independently supplies its own policy), of visitors to the pages on the social networks (Facebook, Twitter, Instagram, LinkedIn and YouTube) with the tools made available by the channel operator (which also makes use of cookies and other tracking tools): analysis of visits, interaction with users, forwarding of non-private messages and other activities envisaged by the channel. Processing takes place legally by consent of the data subject, given when registering with the social network, in order to reply to their questions and requests, and in the legitimate interest of the data controller (tracking of interactions with users, assessment of corporate image, marketing). The data is stored by the social network channels in compliance with the rules established by them.
The data will be deleted or the processing will be interrupted (or limited) at the explicit request of the data subject using the functions available on each social channel.
Participation in competitions (controller: Foundation)
Participation in competitions requires that you supply your personal data (e.g.: identification and contact data) to the Foundation. The Foundation will process this data for the following purposes:
1. management of communications with participants;
2. association of the competition material with the participants;
3. assessment of the material, preparation of the ranking and awarding of the prize;
4. display of the material specifying the author;
5. preservation for historical archive;
6. promotion of the competition via presentation of the participants and the winners;
7. transfer of contacts to offer job vacancies, only with prior consent.
The participants may be filmed by video-operators and photographers at competition events/ award ceremonies. Video and photos may be used by the Foundation for the sole purpose of promoting and publicising the competitions and the winners.
The data is processed on the following legal bases:
- fulfilment of a service (participation in the competition) requested by the participant;
- legitimate interest of the controller (quality control, exhibition of the material, promotion of the competition);
- consent (transfer for job offers).
Part of the data (personal data), with participation in the competition, will be made public and kept for an indefinite length of time for the purpose of publicising and promoting the competition.
Contact details will be kept together with the material, so that the author can be contacted if necessary.
The data may be disclosed to sponsors or trade magazines, who will act as independent controllers and will supply their own policy and, if necessary, request consent for further processing.
Please note the following:
- the material may have been published and therefore it may not be possible to satisfy all the requests made by the data subject;
- the editing of the material or transformation into anonymous form, after the prize has been awarded, may require work resulting in consideration of the data subject's requests as "excessive" and therefore the Foundation may charge a reasonable fee or refuse to comply with the request.
Library (controller: Foundation)
You must supply your personal data in order to collect and consult books at the Foundation's library. The Foundation will process this data to:
- track online bookings;
- check the entitlement to borrow books (either as a registered member or as a Friend of the Foundation);
- check the return of the material loaned, send out a reminder in the case of delayed return of the material loaned and impose the fines envisaged in the regulations;
- allow the use of the workstation connected to the network and impose the fines envisaged in the regulations;
The data is processed on the legal basis of fulfilling a service requested by the participant.
The data will be kept for as long as is necessary for the loan.
Sending complaints to the Disciplinary Board (controller: Order)
With regard to the member, the policy is that specific to members of the Order.
With regard to the party presenting the complaint, the data processed is contact data, as specified in the complaint.
The legal basis for the processing is the consent given by the party presenting the complaint when sending the form. Further processing is carried out on the legal basis of fulfilling legal obligations (Royal Decree 2537 of 1925 and subsequent amendments) and on the basis of that specified in the "Rules of Operation of the Disciplinary Board", which can be found on the Order's website.
After sending the complaint, it cannot be cancelled, limited or blocked.
Failure to sign the consent to processing will make it impossible for the Order and the Disciplinary Board to process the complaint, which will in any case be filed in the protocol.
The party presenting the complaint undertakes to process the personal data in such a way as to ensure its protection.
The data will be kept for no more than ten years after the termination of the proceedings.
Analysis of services (controller: Order)
Data collected with regard to browsing the website, registration with the Order and participation in events is processed through the Hubspot service in order to obtain statistics on the services offered by the Order and the Foundation, with a view to improving them.
The data processed is not anonymous (IP addresses and the personal details of registered users are used), but it is not used to profile the data subjects, segment them or analyse their behaviour, but only to obtain more precise data on the services offered (e.g. types of participants in certain events).
This data is used on the legal basis of the legitimate interest of the controller and in order to obtain anonymous statistical information on the use of the services offered.
Disclosure to third parties and transfers to third countries
In order to carry out certain activities relating to the processing of your personal data on our behalf, the Order may disclose part of your data to external companies, particularly IT service providers.
These companies have agreed, by formal contract, that they will only process the data for the purposes necessary.
The Hubspot platform, with registered office in the USA, is used for statistical analysis.
Further transfers abroad are described above with details of the individual purposes.
Rights of the data subject
We remind you that you are granted certain rights by law. In particular:
the right to access your personal data, its correction or deletion and the restriction or blocking of its processing, if this is not prevented by laws or regulations; you may also request its portability (i.e. receive all personal data concerning you in a structured, commonly used and machine-readable format);
the right to withdraw consent to the processing, if this is not prevented by laws or regulations;
the right to send a complaint to the data controller, to its Data Protection Officer (in the case of the Order) or to the national supervisory authority (in Italy this is the Guarantor for the protection of personal data) following the instructions on its website.
To exercise these rights you must use the channels of reference indicated above.
Version of 19 October 2022