The company The Talent Place S.r.l. (“TAP”), with registered office in Milan, Via Cappuccini 14, has drawn up this briefing note according to provisions of Article 13 and following of Law Decree number 196 dated 30 June 2003 -regarding personal data’s protection ("Privacy Code")- in order to describe the management procedures of the website thefundingculture.com (“Website”) as well as the services (“Services”) that the same company made available on the website; in the matter of the processing of personal data of users (“Users”) who consult the website and/or use its services.
This note is also based on the Recommendation no. 2/2001 that the European authorities for personal data protection -gathered by the Group established by Article 29, Directive no. 95/46/EC- adopted on 17 May 2001 to establish the minimum requirements for collecting personal data online. In particular: procedures, timing and nature of the information that data controllers must provide to users when they connect to web pages, regardless of their purpose.
Upon registration, The Company collects personal data, specifically and voluntarily shared by the Users.
Personal data are the information which can identify a specific person, such as: name, username, password, city, e-mail address. These data are necessary to use the Website and are requested to Users when creating an account. The data are always optional, however, when data marked as "mandatory" in the registration form are missing, the required service couldn’t be provided.
The Company may also require some additional (and optional) data to its Users which -with Users’ consent- will be used to provide a better customisation of the service.
Not providing them won’t be in any way detrimental to registration.
The Company will not process any sensitive data such as: personal data that may reveal Members’ racial or ethnic origin, their religious, philosophical or other beliefs; their political opinions; their membership of parties, unions, associations or organisations religious, philosophical, political or trade unions, as well as personal data regarding their health or their sex life. Users are warned off and kindly requested not to provide any sensitive data to The Company.
Procedures and purposes of data handling
Personal information provided by Users will be processed viaIT tools in order to make the website usable.
In addition, with their explicit prior consent, users’ personal data can be handled by The Company also with thepurpose of profiling, through the analysis of tastes, preferences, habits,needs and consumption choices (e.g. through purchased services, consumer habits, levelof satisfaction due to the services, behavioursduring navigation); in order to send informative and or commercial communications, in particular for as concernsthe updates about funded projects.
Even in the case of given consent, informational and / or commercial communications can be stopped at any point after the initial registration, through the special section reserved for Members or via the links available within each communication.
The Company can disclose your personal information to business partners and use them for sending communications as required by law, for information on new services, and for surveys to improve them.
Website navigation and cookies
The site server, also using cookies, automatically records some information on visitors’ computer and about their navigation, such as: the name their Internet providers, site of origin, visited pages, date and duration of the visit, etc. This information will be stored anonymously and used only to provide access to the Website and / or enjoyment of certain services; then they will be deleted or used in aggregate form for the Website’s statistical purposes as well as to track (always inan aggregateform and neverin an individual one) which web pages and what services are most appreciated by users.
These data areused only to obtain anonymous statistical information about the website and to check its correct functioning; they are deleted immediately after processing. Such data could also be used to ascertain responsibility in case of any computer crimes against the the Company or its assignees.
In some areas of the Website, Users may have the opportunity to send items, messages, gadgets or gifts to third parties; in these sections they may be asked to give the address and / or the name of the recipient. The Company uses this information only to comply with the User’s request, and then delete them immediately from its database, without using them any further.
Information to third parties
A cookie is a string of information that the website stores on a visitor’s computer, in order to facilitate his navigation.
Thanks to cookies, User’s recognition on the Website can be facilitated, avoiding, for instance, the need of an authentication process (via "login" and "password") at each access to the Website. Cookies can also allow Users to personalise their use of the website by saving their favourite settings. As mentioned above, cookies can also record certain information about Users browsing; such information is not yet registered in an individual form, therefore it does not interfere with their privacy and confidentiality.
The used cookies are the following session-cookies:
- Name: thefundingculture (Expires At end of session)
- Name: submit_token1 (Expires At end of session)
Session Cookies help to facilitate the distinction among the connected users and to properly handle the features requested by them. The session lasts until the browser is closed and do not need any prior consent.
Targeting Cookies allow to share projects on social networks and to filter information according to your interests.
From browser’s settings, it’s possible to disable cookies or to choose to receive a message before accepting one.
Each user can disable cookies on the software used for Internet navigation (aka "Browser"). Most browsers are set by default to accept cookies, when there aren’t any different instructions from the User.
The Company encourages Users to check their browser’s settings for as concerns cookies and to adjust them accordingly to their preferences; please note that it may be necessary to enable cookies’ reception in order to use some facilities (in such cases, Users will be informed).
Third party cookies
As data controller, the Company saves Users’ personal data in special servers directly or through any person in charge mentioned on the website and performs all the other operations related to data-handling, with the help of the owner’s -or the manager’s- charged employees or through any external appointee during maintenance operations.
Data storage and access
The database is accessible only to authorised persons, through methods that ensure protection and privacy, thanks to security measures which can prevent data loss, illicit or incorrect use and unauthorised access.
The data are kept for the time necessary to put in place those processing operations related to the data of each user, depending on his choices, preferences and instructions.
Data processing (in general)
The Company uses Users’ data in accordance with the choices they made through their consent, at the time of data collecting or subsequently, in order to comply with the law’s obligations, a regulation or an EU directive. Some data are used without requesting a consent- according to provisions of Article 24 of the Privacy Code- to fulfil a specific request made by the User and according to the limitations of the request itself.
Processing operations which require an approval; communication and data disclosure
Only with the express consent of the User, the Company uses his data -with the help of automated tools and without the intervention of an operator- for the same activities mentioned in the previous paragraph and / or for other purposes authorized each time by the User.
Similarly, only with the express consent of the User, the Company may also disclose data to external companies and in particular to their employees in charge of: marketing, IT, public relations, legal and commercial matters. It can also share or communicate User’s data to its business partners – every time clearly indicated or listed on the website- in order to allow them to process data (as owners or managers) with the same methods and the same limitations of the company itself.
Users’ dataare never disclosed without their prior consent, except those which the User voluntarily makes available in any public areas of the site that are publicly accessible.
The Company encourages Users not to provide their personal information in the communal and publicly accessible areas on the Website; it also reserves the right to cancel such data or make them anonymous if they include sensitive data, in accordance with the Article no. 4 paragraph 1 letter d) of the Privacy Code.
In addition, the prior express consent of the Users given, the personal data related to them will be communicated to the Company partners (e.g.: to natural or legal persons in charge of sending promotional material, which are also appointed for data handling) with the aim of sending informative or commercial communications. The data can ultimately be disclosed to public authorities in the presence of a legitimate order given.
Rights of Users
In accordance with the provisions of article no 7 of the Privacy Code, the Company grants the Users the right to modify at any time their preferences about the processing of personal data which concern them.
It also grants the right to get a confirmation on the existence of these data; to know the origin, the content, the purpose and the processing methods as well as the right to request updating, rectification, integration, deleting or blocking of the data that have been processed violating the law.
The Users have the right to object to the processing of their data, as well as to request at any time to stop it when it’s aimed to market researches, sending advertising material, direct sales and to commercial communications.
The rights listed above may be exercised by writing to the person in charge of data processing: email@example.com.
The Company is aware that the Website and its Services may interest an underage audience too.
As concerns personal data collection and processing, the Company does not make any operations of personal data from minors without their parents’ consent.
Therefore, Registration is permitted only to adult members or to those Users who have turned 14 and have their parents’ consent.
Moreover, the Company encourages underage Users’ parents to register as well: in this way, the parents have the opportunity to benefit from the services,being always aware of the initiatives that the Company offers to their children; at the same time, they can check if they meet their expectations and match their models or educational programs.
Owners and people in charge of data processing
The owner of personal data treatment is THE TALENT PLACE SRL (TAP) with registered office in Milano, Via Cappuccini n.14 VAT code number 08318210963, Company’s Register registration number and Tax Code 08318210963, e-mail [firstname.lastname@example.org].
The complete and updated list of the data processors and of the individuals to whom the data are communicated is available upon request to TAP.
Although, in any case, the Company won’t process data differently than how expressly authorized and / or required by each user, this note may change from time to time, to comply with new legal provisions or due to the Company’s new privacy policies.
Each updated version of this briefing note is available on the Website: therefore, the Company invites all Users to periodically visit it, to keep informed about the latest release.