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Information notice on the processing of navigation Data and cookies

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1. Introduction

Pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter also "GDPR"), Università Cattolica del Sacro Cuore, in its role as Data Controller (hereinafter also referred to as "University" or "Data Controller"), intends to provide users with all useful information regarding the characteristics of the processing carried out by the University in relation to navigation data on the website www.unicatt.it.

The information notice is rendered for all the websites of the unicatt.it, unicatt.eu, cattolicanews.it, sites related to the aforementioned domains that are used to collect data via forms and not even for other websites possibly consulted by the user through links.

2. Identity and contact details for the Data controller

The Data Controller of the data concerning users is Università Cattolica del Sacro Cuore, with registered office in Largo Agostino Gemelli 1, 20123 Milan, tel. (+39) 027234.1

3.  Categories of personal data

Università Cattolica del Sacro Cuore, as Data Controller, collects the following data:

  • website navigation data: the computer systems and software procedures used to operate the site acquire, during their normal operations, some personal data whose transmission is implicit in the use of Internet communication protocols. This category of data includes user identification data, for example, IP addresses and computer domain names of computers and terminals used by users, URI/URL (Uniform Resource Identifier/Locator) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the reply given by the server (successful, error, etc.) and other parameters relating to the operating system and the user's computer environment;
  • data relating to the use of the website by the user, through the use of technical cookies.
  • website navigation data collected through Google Analytics with IP anonymization by adopting all useful measures to reduce the possibility of identification of users who connect; for example: type of device used to connect, city from which you connect, duration of visit to a site, etc.;
  • website navigation data collected by third-party tracking tools;
  • data provided voluntarily by the user - identification information - for access to certain services offered through the website, for which please refer to the specific information in the relevant sections.

As far as the use of cookies is concerned, please refer to the specific sections of this policy.

4. Purpose of the processing and legal basis

The University processes personal data for the following purposes:

  • manage the correct use of the website and the correct functioning of the services offered;
  • obtain statistical information on the use of services (most visited pages, number of visitors per hour or per day, geographical areas of origin, etc.);
  • improve the service for users, making the use of the site more effective and/or enabling certain interaction features with other websites and social networks;
  • assessing the effectiveness of institutional communication activities and/or conferring knowledge and visibility to institutional activities and/or content on issues of public and social interest;
  • release and manage the credentials, IT resources and online services made available to potential students, participants in the initiatives and / or users;
  • ascertain whether users have acted unlawfully to the detriment of third parties or to the detriment of the University;
  • comply with European and national regulations, provisions of Public Administrations and/or Supervisory Authorities.

The legal basis of the processing is constituted by the consent of the interested party, expressed during the browsing experience and manifested during the consultation of the website, by the execution of the contract that data subject is possibly part.

The optional, explicit and voluntary sending of e-mails, messages or any type of communication addressed to the University's contact details indicated on the pages of the website, entails the subsequent acquisition of the sender's address or any other personal data that will be used to respond to requests. It is ensured that this treatment will be based on the principles of correctness, lawfulness, transparency, and protection of confidentiality pursuant to Article 13 of the GDPR 2016/679.

Specific summarised information is displayed on the pages of the websites set up for particular services on request.

5. Processing methods

Personal data are processed both in paper and electronic form (servers, cloud databases, application software, etc.). The University stores the user's personal information in accordance with certain fundamental criteria outlined below: referring in particular to the purposes of collection, the terms provided for processing for marketing purposes and the statute barred limitations dictated by law.

Apart from what specified for website navigation data, the user is free to provide personal data contained in the forms on the University website or indicated during contacts to request information material, other communications or to access specific services. Failure to provide such data may make it impossible to obtain what has been requested.

Some pages on the University website may contain links to other websites that are not operated by Università Cattolica del Sacro Cuore. The University does not share personal information with such websites. The University is not responsible for the content, security, or privacy measures implemented by other sites and expressly refuses all liability.

6. Subject categories that the Data can be communicated to and Data tranfer

The data collected may be processed by employees and external companies that collaborate with the University, respectively as data processors and controllers. The list of designated data processors is constantly updated and available at the University's offices.

This data will not be disclosed, but in the case of third-party cookies may also be transferred outside the European Union by and under the exclusive control of the companies that manage and install them.

7. Data Protection Officer

The University has appointed a Data Protection Officer (D.P.O.), e-mail dpo@unicatt.it.

8. Rights of the Data subject

As an interested party, the user has the right to:

  • Ask the Data Controller for access to the data, their cancellation, the rectification of inaccurate data, the integration of incomplete data, as well as the limitation of processing in the cases provided for by Article 18 of the GDPR;
  • Oppose, at any time, in whole or in part, the processing of Data necessary for the legitimate pursuit of the interest of the Data Controller;
  • In the event that the conditions for the exercise of the right to portability set forth in Article 20 of the GDPR are present, receive in a structured, commonly used and machine-readable format the data provided to the Data Controller, as well as, if technically feasible, transmit it to another Data Controller without hindrance;
  • Withdraw the consent given at any time;
  • Complain to the competent Supervisory Authority.

These rights may be exercised by registered mail, addressed to Università Cattolica del Sacro Cuore, General Management-Directorate - Privacy, Largo Agostino Gemelli 1, 20123, Milan, or by e-mail at dpo@unicatt.it.

Warning for children under the age of 14
Minors under the age of 14 may not provide personal data. The University shall in no way be held responsible for any collection of personal data, nor for any misrepresentation, provided by the minor, and in any case, should the use of such data be detected, the University will facilitate the right of access and cancellation forwarded by the legal guardian or the person exercising parental responsibility.

Cookies

9. What are cookies

The management of the University's institutional website employs a technology called "cookies" together with other tracking tools (such as web beacons). Their use is mainly aimed at investigating how the website is used by users (most used pages, time spent, etc.), improving the website performance, facilitating and enhancing the user experience.

Cookies are small text strings that websites visited by the user send to the computer and any device used to access the Internet (such as smartphones and tablets), where they are stored and then transmitted to the same websites the next time the same user visits.

Cookies can be stored permanently and have a variable duration (the so-called persistent cookies - e.g. in order to automatically access a reserved area, users can choose to have their User-ID and password stored in one of these files), but they can also disappear when the browser is closed or have a limited duration (the so-called session cookies).

Cookies can be installed by the website you are visiting (the so-called first party cookies), but also by other websites (the so-called third-party cookies) and are used to perform computer authentication, session monitoring and storage of information regarding the activities of users who access a particular site.

The cookies, as indicated by the Guidelines cookies and other tracking tools of the Italian Data Protection Authority, can be classified into two macro-categories:

  • technical cookies, used for the sole purpose of "carrying out the transmission of a communication on an electronic communication network, or to the extent strictly necessary for the provider of an information society service explicitly requested by the contracting party or user to provide such service" (see article 122, paragraph 1 of the Code);
  • profiling cookies, used to trace determined, identified or identifiable subjects, specific actions or recurring behavioural patterns in the use of the functions offered (patterns) in order to group the various profiles within homogeneous clusters of different sizes, so that it is possible for the Data Controller, among other things, to modulate the provision of the service in an increasingly personalised manner beyond what is strictly necessary for the provision of the service, as well as to send targeted advertising messages, i.e. in line with the preferences expressed by the user when surfing the web.

It is not necessary to obtain the user's consent for the installation of technical cookies. Cookies can be installed directly by the operator of the website or by a different website that installs them through the first one (the so-called "third party" cookies).

Users can obtain more detailed and updated information on the duration, as well as any other relevant information in the privacy policies of the respective third-party providers (through the links provided) or by contacting the Data Controller.

A list of the cookies used is available on the Privacy Preference Centre (SETTINGS button on the cookie banner and/or Cookies Settings link).

The cookies mangement may involve the transfer of data to countries outside the European Union for which there is not a decision of adequacy recognised by the European Commission (Art. 45 of EU Regulation 2016/679). If you provide consent to the use of analytical and/or profiling cookies, you also agree, where necessary, to such transfer.

10. Technical cookies

The website uses the following types of first-party technical cookies:

  • Session cookies: fundamental to allow the user to move normally within the website and correctly use the relative services. Since they are not stored on the user's computer, they disappear when the browser is closed;
  • Functionality cookies: aimed solely at improving and speeding up navigation on the website, by storing certain choices made by the user (such as language preferences).

They are therefore tools used by the Data Controller to guarantee, for example, efficient navigation, session stability, log-in permanence and pre-selection of the chosen navigation country. They also serve to remember, in an anonymous form, the choices made by the user regarding the display of certain elements of the page, such as information and communication banners.

As already stated, the use of technical cookies and the performance of processing related to them does not require the user's prior consent.

In any case, it remains possible for the latter to prevent the installation of such cookies at any time through the settings of their browser, as indicated later in this policy, knowing that such a choice could, however, complicate, slow down and sometimes block navigation on the website and, more generally, on the Internet.

11. Analytical cookies

The Site also uses both cookies installed directly by the Data Controller and cookies installed by third parties. More specifically, these are:

Measurement and performance

The Site also uses cookies for anonymous statistics. These are Google Analytics cookies through which are collected, in an aggregated and anonymous way, information on how the Site is used by users (number of visitors, pages visited, dwell time, etc.). This information is generally used to improve the functionality of the Site, allowing, for example, to record any errors detected by users and ensure, therefore, a smoother and more immediate navigation.

  • Google Analytics with anonymized IP (Google Ireland Limited)
    Google Analytics is a web analysis service provided by Google Ireland Limited ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website by anonymizing your IP address in accordance with the requirements of the Italian Data Protection Authority. Read further information for the protection of privacy.
    Personal data processed: Cookies and Usage Data.
    Place of processing: Ireland - Privacy Policy - Opt Out.
12 Profiling and other cookies

The Website uses Tracking Tools to monitor and analyse traffic data and to provide customised commercial content based on the User's behaviour, as well as to manage, distribute and optimise advertisements on external sites and platforms.

Advertising, remarketing and behavioral targeting

This type of service allows, by tracking tools, User Data and Data on the use of this Website by the User to be utilized for advertising communication purposes.
This does not mean that all Personal Data is used for this purpose. Information and conditions of use are shown below.
Some of the services may use Tracking Tools to identify the User or use behavioral targeting technique, i.e. displaying advertisements tailored to the User's interests and behavior, including those detected outside this Website. Some services offer a remarketing option based on lists of email addresses that are acquired and subsequently managed by the University.
For more information, please check the privacy policies of the relevant services.

  • Advertising Services Facebook and Instagram (Meta Platforms, Inc. già Facebook, Inc.)
    This services enable the use of a range of advertising products, such as showing advertisements to people who have already visited the University website when they are on Facebook or a digital platform supported by Facebook Advertising.
    Personal data processed: Cookies and Usage Data.
    Place of processing: United States of America – Privacy Policy Facebook / Privacy Policy Instagram.
  • Google conversion tracking (Google Ireland Limited)
    Google conversion tracking is an analytics service provided by Google Ireland Limited that connects data from the Google Ads advertising network with actions performed on this Website.
    Personal Data processed: Cookies and Usage Data.
    Place of processing: Ireland – Privacy Policy.
  • LinkedIn conversion tracking (LinkedIn Corporation)
    LinkedIn conversion tracking (LinkedIn Insight Tag) is an analytics and behavioral targeting service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on this Website. The LinkedIn Insight Tag tracks conversions that can be attributed to LinkedIn ads and enables to target groups of Users on the base of their past use of this Website. Users may opt out of behavioral targeting features through their device settings, their LinkedIn account settings or by visiting the AdChoices opt-out page.
    Personal Data processed: device information, Tracker and Usage Data.
    Place of processing: United States of America – Privacy Policy.
  • Google Ads (Google Ireland Limited)
    The service uses cookies and other advertising technologies, e.g. to publish and display advertisements, personalise advertisements, limit the number of views of an advertisement for a user, deactivate advertisements that you do not want to receive, and evaluate the effectiveness of advertisements.
    Google Ads is a service provided by Google Ireland Limited that connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie. Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.
    Personal Data processed: Cookies and Usage Data.
    Place of processing: Ireland – Privacy Policy – Opt Out

Generally, services of this type offer the possibility to disable such tracking. Users may also opt-out of certain advertising features through the corresponding device configuration options, such as mobile device advertising configuration options or generic advertising configuration.

In addition to the opt-out features provided by the reported services, Users may opt-out by visiting the Network Advertising Initiative's opt-out page. Moreover any opt-out functionality provided by any of the services listed in this document, the User can read more about how to disable interest-based advertisements in the "How to disable cookies" section in this document.

13. How to disable cookies

Considering that most browsers are programmed to accept cookies automatically, the user may choose not to receive them, especially when the third party involved does not give the opportunity to properly opt-out, even by accessing the browser settings and disabling their use, according to the procedures described at the following addresses:

In any case, it should be noticed that disabling cookies may complicate Internet navigation or prevent users from moving freely from one page to another, enjoying all the website functions.

For further information on cookies, please visit www.youronlinechoices.com (limited to the services surveyed by this platform), to obtain information on how to delete or manage cookies according to the browser used and to set preferences for the use of third-party cookies.

In addition, whenever the use of Cookies is dependent on consent, the User can give or revoke such consent by setting their preferences within the cookie policy. In particular, it is possible to change consent to cookies by clicking on the "Cookie settings" link at the bottom of each page of this Website.

Users can also remove previously saved cookies and/or tracking tools using special browser or device functions.

Other tracking tools in the browser's local memory can be removed by deleting the browsing history.

With regard to third party cookies, Users may manage their preferences and revoke their consent by visiting the relevant opt out link (if available), using the tools described in the third party's privacy policy or contacting the third party directly.

Users may also manage certain cookies and tracking tools for mobile applications by turning them off through appropriate device settings, such as mobile advertising settings or tracking settings in general (Users may consult their device settings to find the relevant one).

For more information, check out the following sites:


Updated on: 6 September 2022