This Privacy Policy dated 27/07/2020 sets out information privacy practices and your rights. We may amend this Privacy Policy at any time and for any reason.

1. Who we are and how to contact us

Area of scientific and technological research of Trieste - Area Science Park with registered office in Padriciano 99, 34149 Trieste, Italy. Hereafter referred to as “Area Science Park”.
The controller for the processing of personal data under this Privacy Notice is Area Science Park.
If you have any questions about this Privacy Notice or about our personal data processing practices, or if you wish to exercise any of your rights as a data subject, you may contact the DPO by sending an email to: rpd@areasciencepark.it or alternatively in writing to the address above.

2. How we collect personal data

Area Science Park obtains your personal data from the following sources:

• All information given to us directly from you, including but not limited to, the following means:
• Details submitted on this platform. 
• Best Practice submission forms.
• Information obtained from third parties in relation to your involvement and activities with Area Science Park (such information will only be obtained where permitted under the original terms of consent).
• Our monitoring of visits to the website through the lawful use recording of IP addresses

3. Types of personal data we collect

The personal data obtained by Area Science Park include, but are not limited to, your contact details such as name, surname, address, city, nation, region, telephone number, e-mail address, sector of interest, organization name.

Among the data processed there may also be the details (or sensitive data) as defined and referred to in section 9 of this Privacy Notice.

4. Purpose and basis for using your personal data

Your personal data are processed by AREA Science Park within the scope of its activities for the following purposes:

1. collecting and showcasing best practices and policies for sustainability and circularity in tourism;
2. carrying out the evaluation of sustainability and circularity in tourism destinations and businesses;
3. identifying institutions interested in replicating the INCIRCLE experience applying the INCIRCLE replication package;

4. to comply with any applicable law, court award, legal procedures, national/community regulatory requirements and anti-money laundering legislation.

It is in our legitimate interest that we use your personal information in such a way as to provide you with a high quality of service.

We may communicate with you via letter, telephone call, email, sms and mms for promotional information and customer satisfaction surveys. Such consent is optional, and your consent will be required.

Public Task - The processing of your Personal Data is necessary for the performance of the public interest tasks of Area Science Park, or in those related to the exercise of the public powers invested to pursue its institutional aims, as expressed in the Statute of the institution.

The transfer of your personal information in relation to points 1) to 4) is not required by law, however, it is necessary for Area Science Park to carry out the related services in accordance with your requirements and requests. Any refusal to provide or process particular data may mean that some or all services of Area Science Park cannot be provided.

In certain situations, we require your consent to process your personal data. In such cases we will seek your consent at the time of provision.

5. Sharing your personal data

In order to carry out the above-mentioned activities, it may be necessary for Area Science Park to share your personal information with the following categories of recipients:

• INCIRCLE project partners and MED Interreg Programme.
• Third parties, such as companies, research centers and public bodies, operating both inside and outside the European Union, involved in various ways in the institutional activities of AREA Science Park.
• Public and private subjects who are required by law to know this information.
• Authorities, such as judicial or administrative, and information systems within public administration.
• Persons holding the right of access.

With specific regard to sensitive and judicial data, they may be disclosed to the subjects and for the purposes identified by the Regulation for the processing of sensitive and judicial data of Area Science Park.

Third parties, investee companies and public and private entities that are required to receive or who may know your Personal Data act as: 1) Data controllers, i.e. subjects that determine the purposes and means of the processing of personal data; 2) Data processors, i.e. subjects that process Personal Data on behalf of the Data Controller or 3) Joint Data Controllers that together with Area Science Park determine the purposes and means of the same.

In exceptional circumstances, we may be required or permitted by law to disclose personal data, for example to law enforcement authorities or to prevent a serious threat to public safety.

6. Storage and retention period

The processing of your personal data is carried out using manual, IT and telematic methods and in a manner such as to safeguard the security and confidentiality of the data.

The retention period of your personal data is based upon the principle of it being held no longer than it is necessary for the purpose for which it was originally obtained. Your personal data will therefore be kept for the entire period necessary to achieve the purposes referred to in Section 4.

Once we have no legal or commercial reasons to retain personal data, and in any case by the end of 2023, they will be securely deleted or destroyed. An assessment of our need to retain data is carried out periodically.

7. Transfer of personal data to a third country or an international organisation outside the European Union

Your personal data is processed by Area Science Park within the territory of the European Union, except where specifically denoted otherwise.

If necessary for technical or operational reasons, Area Science Park reserves the right to transfer your personal data to countries outside the European Union or to international organisations for which, according to the European Commission, exist an adequate level of data protection (adequacy decision) or on the basis of adequate safeguards provided by the country where the data must be transferred or on the basis of a specific exemption provided for in the regulations.

8. Your rights

If you are located in the EU, you have certain rights in relation to your personal data as follows:

• Access: You have the right to obtain access to and a copy of any personal data we hold about you. You also have the right to find out whether your personal data has been transferred to any third party or outside the EU and any safeguards relating to this transfer. If requested, Area Science Park will provide you with a copy of your Personal Data being processed without charge. For any additional copies Area Science Park may charge you a reasonable administration fee. If your request is submitted by electronic means, and unless otherwise instructed, the information will be provided by Area Science Park in an electronic format in common use.
• Rectification: If you consider that any personal data we hold about you are incorrect or incomplete, you have the right to ask us to correct or complete that personal data.
• Erasure: In certain circumstances, you have the right to ask us to erase any personal data we hold about you. Area Science Park will not be able to delete your personal data if the processing of such data is necessary for the fulfilment of legal obligations, for reasons of public interest or use in judicial proceedings.
• Restriction of processing: In certain circumstances, you have the right to ask us not to process your personal data for certain purposes. For example, you contest the accuracy of your personal data; the processing is unlawful and you oppose the erasure of personal data and request the restriction of their use instead; Area Science Park no longer needs the personal data for the purposes of processing, but they are required by you for the establishment, exercise or defence of legal claims; you have objected to processing pending the verification whether the legitimate grounds of Area Science Park override those of you as the data subject.
• Objection to processing: In certain circumstances, you have the right to object to us processing your personal data for certain purposes. You shall have the right to object at any time to processing of your personal data which is based on the principle of public interest or legitimate interest, including profiling based on those provisions. Area Science Park shall no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims. Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for such marketing, which includes profiling to the extent related to such direct marketing. Where personal data are processed for scientific or historical research purposes or statistical purposes, you shall have the right to object to processing of your personal data, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
• Data portability: In certain circumstances, you have the right to request a copy of your personal data in a structured, commonly used and machine-readable format. You may also request that your personal data be transmitted from Area Science Park directly to another person who has the right of processing indicated by you. In this case, you will provide us with all the exact details of the new data controller to whom you intend to transfer your personal data, providing us with specific written authorization.
• Automated decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you in another way. Exceptions to this are:
• It is necessary for entering into, or performance of a contract between you and Area Science Park.
• It is authorised by European or Italian law.
• Area Science Park shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, and at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
• Withdrawing consent: If we are processing your personal data based on your consent, you have the right to withdraw that consent at any time.
• Right to complain to the Regulatory Authority: You have the right, without prejudice, to make a complaint to the regulatory authority on person data or other appropriate administrative or judicial body if it is deemed that the treatment of your data breaches the applicable regulations.

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To make a request pursuant to your rights listed above, please submit your request, marked for the attention of the ‘Data Protection Officer’ via any of the following means:

Email: rpd@areasciencepark.it

Post: Area Science Park, Località Padriciano 99, 34149 Trieste, Italy.

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If requested, Area Science Park will provide you with a copy of the personal data being processed without charge. For any additional copies Area Science Park may charge you a reasonable administration fee. If your request is submitted by electronic means, and unless otherwise indicated, the information will be provided by Area Science Park in an electronic format in common use.

Any communications and actions taken by Area Science Park, in the interest of you exercising your rights above, will be carried out free of charge. However, if your requests are manifestly unfounded or excessive, in particular due to their repetitive nature, Area Science Park may charge you an administration fee or refuse to accede to your requests.

The exercise of the aforementioned rights is subject to the limits, rules and procedures set forth in Regulation (EU) 679/16. In accordance with the provisions of article 12, paragraph 3 of the AREA Science Park Regulations, it will provide the interested party with information concerning the action taken without unjustified delay and, in any case, at the latest within one month of receiving the request. This deadline may be extended by two months, if necessary, taking into account the complexity and number of requests. Area Science Park will inform the interested party of this extension, and of the reasons for the delay, within one month of receiving the request.

By clicking on "accept the privacy policy" declares (for himself and for the interested party, if different) that he has been informed that the data indicated in this form are used exclusively to address this request and that they will be kept for a period of five years, in order to guarantee appropriate proof of the procedure, for any exercise of rights in administrative or judicial proceedings.

 

The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

9. Treatment of particular categories of data

In relation to the processing of special categories of personal data (suitable for revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as processing genetic data, biometric data intended to uniquely identify a natural person, data relating to health or sexual life or sexual orientation of the person) which may be necessary in the pursuit of the purposes referred to in Section 4, explicit consent is required, subject to the specific cases provided for in the Regulation which allow the processing of such personal data even in the absence of consent.

10. Information regarding legal persons, bodies or associations

The use of automated calling or call communication systems without the intervention of an operator and of electronic communications (electronic mail, fax, SMS, MMS or other) for the purpose of promotional activities or the fulfilment of customer satisfaction activities is permissible only with the consent of the parties with a contract for supply of electronic communication services, which includes legal persons, entities and associations. The conduct of these activities in respect of such persons shall be subject to a specific demonstration of consent.