The International Telematic University UNINETTUNO (hereinafter simply ‘UNINETTUNO’), with registered office at Corso Vittorio Emanuele 39, Rome (tax code 97394340588), in the capacity of ‘Data Controller’, hereby communicates, pursuant to Article 13 of REGULATION (EU) 2016/679, the following information on processing of the personal data of users of its website and the services accessible via the following web addresses: https://www.uninettunouniversity.net and https://www.uninettuno.tv.

• Type of data processed and methods and purposes of processing. Browsing and accessing the UNINETTUNO website may result in processing of the following data indirectly or directly relating to the user. 1.1)Browsing data: this is technical information automatically acquired by the computer system during browsing, via communication protocols. This information is only used to gather anonymous statistical data on use of the website and to monitor its function. It is not associated with identifiable users but could permit indirect identification of the user through association with data held by third parties. 1.2)Data actively communicated by the user: this is personal data on the user entered into the information request form. This data is used to process the request and respond to the user. Contact details (email address and telephone number) may only be used to send promotional messages and other direct marketing communications regarding UNINETTUNO’s activities subject to express consent from the user (indicated by checking the box on the information request form). 1.3)Data for use of online services: this is personal data on the user requested in order to register them and for digital authentication to enable them to access the restricted area of the website and use the relative services. Data relating to login credentials is recorded to permit performance of the automated authentication procedure, while information on the date and duration of logins is recorded for security reasons.

• Use of technical and necessary cookies. Collection of browsing data requires use of cookies. Cookies are short strings of text sent to the user’s device (PC, notebook, smartphone, tablet, etc.) during access to the website and sometimes stored in the browser and then sent back the next time the user accesses the website. The UNINETTUNO website uses ‘technical cookies’ (i.e., for electronic communication of the information and services requested by the user) to ensure normal browsing and use of the services, according to the selected criteria (such as the chosen language). Their effectiveness is, in most cases, limited to the duration of the browsing session. Use of these cookies does not require the data subject’s consent. The UNINETTUNO website also uses Matomo analytics cookies for collecting data, in aggregate form, on the number of users who have visited the website and their access methods in order to generate internal statistics on use of the website for the purpose of improving the services it offers. Their effectiveness is limited to one day in the case of ‘_pk_ses#’ cookies and one year from installation in the case of ‘_pk_id#’ cookies. In both cases, the data collected is not shared with third parties. Use of these cookies, once again, does not require the data subject’s consent. Finally, the UNINETTUNO website uses Google Inc. cookies to perform the CAPTCHA test. These cookies are necessary for in order to implement the security measure known as Challenge-Response authentication: the CAPTCHA test protects the Data Controller from spam by asking the user to take a simple test to prove they are a person and not a computer. The effectiveness of Google Inc. cookies is limited to the duration of the browsing session on the website in the case of ‘rc::c’ cookies and persistent in the case of ‘rc::a’ cookies. Use of these cookies does not require the data subject’s consent. No promotional or advertising cookies (so-called ‘profiling cookies’) are used, including third-party ones.

• Legal basis for data processing. Processing of the user’s personal data, to enable browsing within the UNINETTUNO website and to send requests, is necessary and instrumental to use of the online services. It is therefore necessary for fulfilment of a contract with the data subject or for implementation of pre-contractual measures taken at the data subject’s request. For this reason, this processing does not require the data subject’s consent. Processing of the user’s personal data for promotional and direct marketing purposes is subject to the data subject’s consent. This consent is voluntary and does not affect access to the website or requests for information, and can be withdrawn at any time via UNINETTUNO’s communication channels. Finally, processing of the user’s personal data for generation of internal statistics and for safe browsing is based on the legitimate interests of UNINETTUNO.

• Data retention period. The retention period of browsing data collected using cookies varies: some is automatically deleted by the system at the end of the session, some is deleted after one day or one year, and some is persistent, as explained in more detail in point 2, above. Data actively communicated by the user is stored for a maximum period of 180 days and, if a contract is not concluded within this time, will not be shared with any other party and will be deleted. Personal data necessary for sending promotional communications, on the other hand, is stored until completion of the activity or withdrawal of consent. Finally, data for use of the online services is stored until the end of the contract and subsequently archived until expiry of the ordinary limitation period pursuant to Article 2946 of the Italian Civil Code (10 years) and then deleted.

• Data recipients. The data subject’s personal data is processed and stored on servers located in the European Union owned by and/or in the possession of UNINETTUNO and/or third-party companies duly appointed as Data Supervisors. Personal data may therefore be communicated to these Data Supervisors for provision of the services entrusted to them. Any transfer of the data abroad to non-EU countries shall take place in compliance with the provisions of Regulation (EU) 679/2016 (GDPR).

• Rights of the data subject. All data subjects have the right to request:

• access and rectification of inaccurate personal data concerning them;

• completion of incomplete data;

• erasure of the data where it has been unlawfully processed or where erasure is necessary for compliance with a legal obligation;

• restriction of processing to personal data concerning them and whose accuracy is not contested by the data subject, pending verification of accuracy of contested personal data, and being informed before the said restriction is lifted;

• receipt of personal data which they have provided, in a structured, commonly-used and machine-readable format, or having the personal data transmitted directly from one controller to another, where technically feasible. This right shall not apply to personal data not provided by the data subject or to personal data processed for performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller.

Data subjects also have the right to object, pursuant to Article 21 of Regulation (EU) 679/2016, at any time to processing of personal data concerning them which is based a legitimate interest, citing legitimate grounds relating to their particular situation. All such requests may be communicated to UNINETTUNO at its registered office or on the telephone numbers +39 06 6920 7670 | +39 06 6920 7671 or at the email address info@uninettunouniversity.net. If the data subject considers that the processing of personal data concerning them infringes Regulation (EU) 679/2016 or that the Data Controller has not fulfilled its obligations in relation to exercise of the above-mentioned rights, they have the right, pursuant to Article 77 of the said Regulation, to lodge a complaint with the supervisory authority in the Member State of their habitual residence, place of work or place of the alleged infringement. This is without prejudice to any other administrative or judicial remedy. Data Protection Officer. The Data Protection Officer responsible for protection of the personal data is Mr Gaetano Giordano, who may be contacted at the email address: dpo@uninettunouniversity.net or by tel./fax on the number +39 06375 11524. Data subjects may contact him with any questions relating to processing of their personal data and exercise of the rights under the above-mentioned Regulation, and he is bound to confidentiality concerning performance of his duties.