- General information about the site
1.1. The site presents the activities and services of the Shifting Lab project, owned by the Associazione Shifting Lab ETS, with registered office in via del Pellegrino 16, 50139, Florence.
1.2. This information is also provided for the purposes of Article 13 of EU Reg. 2016/679 (GDPR – General Data Protection Regulation), relating to the protection of individuals with regard to the processing of personal data and the free movement of such data, as well as for the purposes of Article 13 of Legislative Decree no. 196/2003 (Personal Data Protection Code), and subsequent amendments or additions, for persons interacting with the site of the Association SHIFTING LAB, which can be reached at the address corresponding to the home page www.shiftinglab.com
1.3. This policy and the information contained therein are provided only for www.shiftinglab.com and not for other websites that may be consulted by the user through links contained therein.
1.4. The purpose of this policy and the information contained in it is to provide indications regarding the types of data processed, the processing methods, the data storage periods, the nature of the information and any other relevant aspects that the data controllers must disclose to users connecting to the web pages of www.shiftinglab.com, regardless of the purpose of the connection itself, in accordance with Italian and European legislation.
1.5. The website www.shiftinglab.com is aimed at users over 16 years old, pursuant to art. 8, par. 1 EU Reg. 2016/679. By connecting to the website www.shiftinglab.com and providing his/her own data, the person concerned, i.e. the person to whom the data refer, declares to be over 16 years of age.
II – SUBJECTS INVOLVED IN DATA PROCESSING
- Data controller
2.1. The data controller is the natural or legal person, public authority, service or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. This entity is also required to identify and adopt appropriate technical and organisational measures to ensure a level of security of the personal data it processes that is appropriate to the risk generated by the processing operations carried out.
2.2. With regard to this website, the data controller is the Associazione Shifting Lab ETS: for any clarification or exercise of your rights, you may be contacted at the following email address: firstname.lastname@example.org.
- Responsible for data processing
3.1. The controller is the natural or legal person, public authority, service or other body which processes personal data on behalf of the controller.
3.2. Pursuant to Article 28 of EU Regulation No. 2016/679, the controller may appoint one or more data processors for the website www.shiftinglab.com from among the entities that may have access to the personal data of the data subjects, i.e. third-party service providers such as, for example, connectivity providers, hosting, domain registration, couriers, IT companies as well as the software provider dealing with the service of sending newsletters and commercial communications.
3.3. The list of all the Data Processors is available to users of the site upon request.
- Place of data processing
4.1. Personal data are recorded and stored on electronic databases owned by the owner and the data processing generated by the use of www.shiftinglab.com takes place at the registered office/operative headquarters of the owner located in via del Pellegrino 16, 50139, Florence.
4.2. If necessary, the data connected to the newsletter service may be processed by the data controller or by persons appointed by it pursuant to Article 4 no. 10 of EU Reg. 2016/679 for this purpose at the premises referred to in the preceding paragraph.
III – DATA PROCESSED
- Types of data processed and methods of data processing
5.1. Like all websites, this site also makes use of log files in which information collected automatically during user visits is stored. The information collected is as follows:
5.1.1. the addresses in URI (Uniform Resource Identifier) notation of the resources requested;
5.1.2. the time of the request;
5.1.3. the method used to submit the request to the server;
5.1.4. the size of the file obtained in response;
5.1.5. the numerical code indicating the status of the reply given by the server;
5.1.6. other parameters relating to the user’s operating system and computer environment.
5.2. The information referred to in paragraph 5.1 is processed automatically and collected in an exclusively aggregate form for the purpose of processing anonymous statistical information on the use of the site and to verify the correct functioning of the site, as well as for security reasons. This information will be processed according to the legitimate interests of the owner and deleted within 90 days.
5.3. In addition to the information referred to in paragraph 5.1 above, the following personal data may also be collected from this site:
5.3.1. e-mail address (in the event that the data subject subscribes to the service of sending newsletters by filling in the appropriate form or requesting information via contact form);
5.3.2. User’s name and surname (in the event that the data subject subscribes to the newsletter service by filling in the relevant form or in the event that the data subject requests information through a contact form), also possibly contained in the company name;
5.3.3. telephone contact and other personal data provided by the user (in the event that they are voluntarily provided by the user when requesting information via contact form);
5.3.4. IP (Internet Protocol) address exclusively for the purposes referred to in art. 5.6 below.
5.4. The personal data referred to in paragraph 5.3. will be processed by means of the operations indicated in Article 4 n. 2) GDPR and precisely: collection, recording, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, deletion or destruction of data.
5.5. The personal data referred to in paragraph 5.3, also of an identifying nature, are collected and processed in automated form, for the purposes referred to in Article 6 below.
5.6. The information referred to in paragraph 5.1. may be used to ascertain responsibility in case of commission of computer crimes to the detriment of this site, like the personal data referred to in paragraph 5.3.6. which are processed exclusively for this purpose.
5.7. For security purposes (spam filters, firewalls, virus detection), the automatically recorded information and data referred to in paragraph 5.1. may be used to block attempts to damage the site or other harmful or criminal activities, according to the legitimate interests of the owner and in accordance with current legislation.
5.8. In case of sending Curriculum Vitae for a possible working relationship or collaboration requests, the data is understood to be voluntarily provided by the user at the time of the service request. The Curriculum Vitae will be examined and, should they be saved or in any case retained for future working collaborations, a special briefing note will be provided by the SHIFTING LAB Association to the user in accordance with the regulations in force.
5.9. The information that the users of the website will decide to make public through the services and tools made available to them are provided by the user consciously and voluntarily, thus exempting this website as well as the SHIFTING LAB Association from any liability regarding possible violations of the law. It is up to the user to verify that he/she has permission to enter personal data of third parties obtained, published or shared through this website and guarantees that he/she has the right to communicate or disseminate them; it is also up to the user to verify that he/she has permission to enter any content protected by national and international regulations.
- Purposes of the processing and data retention period
6.1. Personal data collected by the website are used for the following purposes:
6.1.1. execution of a contract concluded between the user and SHIFTING LAB or fulfilment of pre-contractual information obligations;
6.1.2. provision of services provided by the site;
6.1.3. posting of comments/opinions/contents on the website by the user, in response to content posted by SHIFTING LAB on the same site;
6.1.4. sending newsletters to the user at the address provided by the user by filling in the form on the website;
6.1.5. sending advertising and commercial communications on products and services provided / offered by SHIFTING LAB;
6.1.6. fulfillment of obligations imposed by law (accounting, tax, etc.).
6.2. The storage of information referred to in art. 5.1. will be carried out for the period strictly necessary to achieve the above purposes and in any case not longer than the termination of the same purposes, with cancellation of the same within 90 days of collection.
6.3. The personal data referred to in Art. 5.3. will be kept for the period of time strictly necessary to achieve the purposes indicated in paragraph 1. above and in any case not longer than the end of the same purposes, with the exception of cases where it is necessary to keep them due to legal obligations. The data may also be kept for the time necessary by the Data Controller or by any designated Managers to ascertain, exercise or defend their rights in court, within the limitation period of any civil or criminal actions that may be filed against them.
6.4. In case of processing of personal data as per Art. 5.3. based on the user’s consent, SHIFTING LAB may store the personal data until the revocation of the said consent.
6.5. Data used for security purposes according to the previous art. 5.7. shall be kept for the time strictly necessary to achieve this purpose and in any case deleted within 60 days.
- Legal basis of processing operations
7.1. The legal basis for the processing of personal data indicated in Art. 5.3. is the execution of a contract for the purpose indicated in Art. 6.1.1. which is concluded according to the applicable law and in the manner of the General Terms and Conditions of the contract with SHIFTING LAB or the fulfilment of obligations of a pre-contractual nature, which arise between SHIFTING LAB and the user as a result of contacts aimed at assessing the possible conclusion of a contract between them concerning the services provided by the same Association.
7.2. The legal basis for the processing of personal data indicated in Art. 5.3. is the execution of a contract for the purpose indicated in Art. 6.1.2. which is concluded according to the current legal regulations, also possibly in the manner of the General Terms and Conditions with SHIFTING LAB.
7.3. The legal basis for the processing of personal data for the purpose indicated in Art. 5.3. is the consent of the user (data subject), which is completed by entering a comment on a post on the website www.shiftinglab.com.
7.5. The legal basis for the processing of personal data indicated in Art. 5.3. for the purpose indicated in Art. 6.1.5. is the consent of the user (data subject), which is given on the occasion of the conclusion of a contract between SHIFTING LAB and the user or by filling out the form dedicated to advertising and commercial communications on the website www.shiftinglab.com.
7.6. The legal basis for the processing of personal data indicated in Art. 5.3. for the purpose indicated in Art. 6.1.6. is the fulfillment of a legal obligation to which the owner is subject.
- Plugin Social Network
8.2. The collection and use of information obtained through the cookies of these social networks are governed by their respective privacy policies, which please refer to:
8.2.1. Facebook: https://www.facebook.com/help/cookies
8.2.2. Twitter: https://support.twitter.com/articles/20170519-uso-dei-cookie-e-di-altre-tecnologie-simili-da-parte-di-twitter
8.2.4. Pinterest: https://about.pinterest.com/it/privacy-policy
8.2.5. AddThis: http://www.addthis.com/privacy/privacy-policy
8.2.6. Linkedin: https://www.linkedin.com/legal/cookie-policy
8.2.7. Vimeo: https://vimeo.com/cookie_policy
8.2.8. Foursquare: https://it.foursquare.com/legal/cookiepolicy
- RIGHTS OF THE USER
- Rights of the data subject
9.1. Article 13(2) of EU Reg. 2016/679 lists the user’s rights.
9.2. The website www.shiftinglab.com therefore intends to inform the user about the fact that the user has the rights referred to in Articles 13(2)(b) and (d), 15, 16, 17, 18, 19 and 21 GDPR and precisely the rights to:
9.2.1. obtain confirmation of the existence or otherwise of data concerning him/her, even if not yet recorded, and its communication in intelligible form;
9.2.2. to obtain an indication of: a) the origin of the data; b) the purposes and methods of processing; c) the logic applied in the event of processing carried out with the aid of electronic instruments; d) the identity of the owner, the data protection officer, the managers and the representative appointed under Article 3, paragraph 1, GDPR; e) the subjects or categories of persons to whom the data may be communicated or who can learn about them as appointed representative in the State and managers;
9.2.3. obtain: a) the updating, rectification or, when interested, the integration of data; b) the cancellation, transformation into anonymous form or blocking of personal data processed in violation of the law, including data whose retention is not necessary for the purposes for which the data were collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected;
9.2.4. to oppose, in whole or in part, for legitimate reasons, the processing of Data concerning you, even if pertinent to the purpose of collection;
9.2.5. where applicable, you also have the rights referred to in Articles 16 – 21 GDPR (Right to rectification, right to be forgotten, right to restriction of processing, right to data portability, right to object), as well as the right to complain to the Supervisory Authority;
9.2.6. revoke at any time its own consent that may have been given.
9.3. Requests may be addressed to the data controller, without formalities or, alternatively, using the template provided by the Guarantor for the Protection of Personal Data, or by sending an email to: email@example.com.
9.4. If the processing is based on art. 6, par. 1, lett. a) – express consent to use – or art. 9, par. 2 lett. a) – express consent to the use of genetic data, biometric data, data concerning health, data revealing religious or philosophical beliefs or trade union membership, data revealing racial or ethnic origin or political opinions – you have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on the consent given before the withdrawal.
9.5. Similarly, in the event of a breach of the regulations, the user has the right to lodge a complaint with the Garante per la Protezione dei Dati Personali, as the authority responsible for controlling processing in Italy.
9.6. For a more detailed examination of your rights, see Articles 15 et seq. of EU Regulation 2016/679 and Article 7 of Legislative Decree 196/2003 and subsequent amendments and additions.
V – NATURE OF CONSENT
- Nature of Consent
10.1. Il conferimento dei dati personali di cui all’art. 5.3. è facoltativo per l’adempimento for the purposes of art. 6.1.3. Any refusal to provide the email address will make it impossible to publish the comment/opinion/content referred to in the same art. 6.1.3. The user may, however, continue to use the services referred to in the purposes indicated in Articles 6.1.1 and 6.1.2.
10.2. The provision of personal data referred to in art. 5.3. is compulsory for the fulfilment of the purposes referred to in art. 6.1.1. and 6.1.2. Any refusal to provide such data will make it impossible for the owner to provide the services referred to in Articles 6.1.1. and 6.1.2.
10.3. The provision of personal data referred to in art. 5.3. for the fulfillment of the purposes referred to in Articles 6.1.4. and 6.1.5. is optional. The interested party may therefore decide not to provide any data or subsequently deny the possibility of processing the data already provided for such purposes: in this case the owner will not be able to fulfill the purposes referred to in Articles 6.1.4. and 6.1.5.. The user can still continue to use the services referred to in the purposes indicated in Articles 6.1.1. and 6.1.2.
10.4. The provision of personal data referred to in art. 5.3. is compulsory for the fulfilment of the purposes referred to in art. 6.1.6. Any refusal to provide such data will make it impossible for the owner to fulfill the legal obligations referred to in ‘art. 6.1.6. and, consequently, to provide the services referred to in the same Articles. 6.1.1. and 6.1.2.
VI – DATA TRANSFER TO NON-EU COUNTRIES
- Transfer of data of the data subject to countries outside the EU
11.1. This website may share some of the data collected with services located outside the European Union area, to the US territory. The transfer is authorised and strictly regulated by Article 45(1) of EU Reg. 2016/679 as well as EU Commission Implementing Decision 2016/1250, given that the companies to which the data may be transferred adhere to the Privacy Shield.
11.2. No data will ever be transferred to third countries that do not comply with the conditions set out in Articles 45 et seq. of EU Reg. 2016/679.
VII – DATA SECURITY
- Personal data security measures adopted
12.1. This website processes user data in a lawful manner and in compliance with the GDPR as well as current Italian legislation (Legislative Decree no. 196/2003 and subsequent amendments or additions), adopting security measures appropriate to the mapped risk profiles, aimed at avoiding personal data violations, in the form of unauthorised access, disclosure, modification or destruction of data. The processing is carried out by means of computer and/or telematic tools, with organisational methods and according to logics strictly related to the purposes indicated in the previous art. 6.
12.2. In addition to the data controller, categories of persons authorised to process personal data involved in the organisation and management of the site (administrative and commercial staff, marketing staff, lawyers, system administrators, etc.) or external parties responsible for outsourcing services to the data controller (such as technical service providers, hosting providers, IT companies, communications agencies) may have access to the processed data and are appointed, when necessary or appropriate, as external data processors.
12.3. The list of external data processors, as well as the list of internal data processors of the SHIFTING LAB Association, will be kept updated and can be requested at any time by writing to: firstname.lastname@example.org.
VIII – COOKIES
- Type of cookies
13.2. A cookie consists of a small amount of data transferred to the browser used by the user by a web server and can only be read by the server that carried out the transfer. It is not executable code and does not transmit viruses.
- Technical cookies
14.1. Technical cookies allow navigation on the site and facilitate access and secure use of the same by the user. They are necessary for the transmission of communications over an electronic network or for the supplier to provide the service requested by the customer.
14.3. The cookies that are inserted into the browser and retransmitted through the Google Analytics service (collected at the behest of the owner of the site in a totally anonymous form) or others with similar functions are to be considered of a technical nature when used for site optimisation purposes directly by the owner of the site; in this case, thanks to them, only aggregate and anonymous information may be collected on the number of users and how they visit the site. Under these conditions, analytics cookies are subject to the same rules on information and consent as technical cookies.
14.4. From the point of view of duration, two types of cookies can be distinguished: temporary cookies that are automatically deleted at the end of the browsing session and are used to identify the user, so as to avoid logging in each time a page is visited; permanent cookies that remain active in the browser used by the user until the pre-set expiry date (by the third party supplier of the cookie or by the owner of the site that adopts it) or when the user deletes them.
14.5. The site may install session cookies in the browser used by the user, which allow the user to access and remain in the private area of the site as an authenticated user.
- Third-party cookies
15.1. According to their origin, cookies are distinguished between those directly sent to the browser used by the user from the site being visited and those set by third parties.
15.2. The majority of third party cookies are tracking cookies used to identify the online behaviour of users, understand their interests and therefore personalise the advertising proposals directed to them.
15.3. Third party analytical cookies may be installed: they are used to detect information about the users’ behaviour on the site. The data is collected anonymously in order to monitor performance and improve the usability of the site, as described in art. 14.3 above.
15.4. The use of these cookies is governed by the rules prepared by the third parties themselves, therefore, users are invited to read the privacy notices and instructions for managing or disabling cookies published on the relevant web pages.
- Profiling cookies
Profiling cookies are those aimed at creating user profiles that are subsequently used to send advertising messages in line with the preferences expressed by the same while browsing the web.
In the case of the use of this type of cookie by the owner, the user must give explicit consent.
16.3. Article 22 of EU Reg. 2016/679 and Article 122 of Legislative Decree no. 196/2003 (Privacy Code) will apply.
16.4. The Owner’s website does not use profiling cookies.
- Support in configuring the browser used by the user
17.1. The user can also manage cookies through the settings of the browser used. By deleting cookies from your browser, you may be able to remove the preferences you have set for the site or experience slowdowns, problems or the inability to access certain services.
17.2. To receive further information and obtain support on this point you can visit the specific page of the main browsers available:
17.2.1. Internet Explorer and Edge: https://support.microsoft.com/it-it/help/17442/windows-internet-explorer-delete-manage-cookies
17.2.2. Firefox: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie
17.2.3. Safari: https://support.apple.com/kb/ph21411?locale=it_IT
17.2.4. Chrome: https://support.google.com/accounts/answer/61416?hl=it
18.1. All texts, graphic components, sound files, videos, images, animations and more generally all information contained in this website are property of the SHIFTING LAB Association and are protected by the international copyright laws and by the other laws in force on the protection of intellectual property.
18.2. None of the contents referred to in the previous paragraph may be copied, modified or resold, in whole or in part, for profit or for any other purpose.
- USE OF THE SITE BY USERS
- Content on the site and disclaimer of liability
19.1. The SHIFTING LAB Association does not take any responsibility for any malfunctioning of the website www.shiftinglab.com or for damages – of any kind – that may occur to users due to the access to the same website or in any case of the contact with it, or for those that may arise from third party websites whose internet address can be reached from the same through links. With reference to the latter, SHIFTING LAB has no responsibility, as the connection to them through links is a facilitation to network users. The fact that the website www.shiftinglab.com provides these links does not imply approval of the sites themselves: the SHIFTING LAB Association is not responsible for their quality, contents and graphics. The Association is not responsible for the information obtained by the user through access to sites linked to www.shiftinglab.com. Therefore, the completeness and accuracy of the information is the responsibility of the owners of the sites accessed under the conditions provided by them.
19.2. SHIFTING LAB Association makes every reasonable effort to ensure that the materials and contents published on this website are adequately assessed and analysed, as well as processed with the utmost care and updated when necessary. At the same time, however, errors or omissions are possible: SHIFTING LAB therefore declines any form of liability for damages that users may suffer as a result of any errors, inaccuracies and omissions in the contents of the website, as well as the use that third parties may make of them. Moreover, SHIFTING LAB disclaims any form of liability for damages that users may suffer due to any errors, inaccuracies and omissions in the contents of third party websites, whose Internet address can be reached through links available on this website.
19.3. Objects, products, programs, etc. that may be present on this website for downloading (e.g. technical documentation, commercial documentation, software, etc.), unless otherwise indicated, are freely available to users under the conditions set by SHIFTING LAB, which does not take any responsibility for the content of the documents or the characteristics of the documented products, nor for the functioning of the programs.
- AMENDMENTS TO THIS DOCUMENT