Privacy Policy

This Privacy Policy governs the processing of personal data through use of the website available at www.istitutoeuropeodipendenze.it, in accordance with applicable data protection laws, including, in particular, Regulation (EU) 2016/679 (the GDPR).

1. Data Controller

ISTITUTO EUROPEO DIPENDENZE s.r.l. – with registered office in Via Cernaia, 4 20121 Milan, Milan (MI) e-mail: ieud@pec.net (hereinafter also referred to as “IEUD”) – is the Data Controller for the purposes of Regulation (EU) 2016/679 (referred to in this notice as the “Regulation” or “GDPR”), as it determines how and for what purposes users’ personal data are collected and used, as well as the means by which such data are processed and the security measures implemented to ensure their integrity, confidentiality, and availability.

The Data Protection Officer (“DPO”) can be reached at: dpo@ieud.it

2. Purpose and legal basis of data processing

Users’ personal data are processed in order to respond to the requests expressly submitted by them. In particular, the collection and subsequent processing of data are carried out for the purpose of managing the following activities:

• Contacts for digital marketing purposes (website, data collection through telephone contacts made available via the website, data collection through social media pages or applications managed by the Data Controller, requests for information, etc.);
• The processing of users’ health data, including for the purposes of medical evaluations;
• The processing of users’ administrative data, including in connection with the analysis of metabolites in keratin matrix samples;

Personal data provided by the data subject through the form available in the relevant section of the site, through social media pages, or through applications managed by the Data Controller will be processed only after obtaining the data subject’s free and optional prior consent. The legal basis for such processing is Art. 6.1. a) of the Regulation.

Personal Data provided by the data subject via e-mail or telephone will be processed with reference to Art. 6.1. b) and f) of the Regulation which represents the legal basis of processing for these purposes.

Special categories of personal data (sensitive data) and data relating to criminal convictions and offenses provided by the data subject will be processed only with the data subject’s consent, pursuant to Article 9.2.a) of the Regulation. In the absence of such consent, these data cannot be processed.

Personal data provided by the data subject and related to the management of legal, accounting, and tax obligations, if any, is processed legitimately pursuant to Art. 6.1. c) of the Regulation, as the processing is necessary to fulfill the legal obligations to which IEUD is subject.

Consent given by clicking a specific checkbox within a banner may be withdrawn; however, it will not be possible to withdraw its effects on communications that have already been carried out.

IEUD will not use the data provided for purposes other than those related to the purposes identified.

Providing data for these purposes is optional; however, failure to do so would make it impossible to activate the services provided by IEUD.

3. Data processed

The data collected by IEUD for the provision of services may refer to:

• User details (name, surname, residence, e-mail, telephone, etc.);
• Data relating to health status, including medical test results and physical and psychological conditions (such as addictions the data subject may experience, other medical conditions, etc.);
• Data relating to any legal convictions and offenses;
• Tax data (tax code, VAT number, etc.);
• Payment details (Credit Card, IBAN, etc.)

The optional, explicit, and voluntary sending of email messages to the addresses indicated on this site, or the completion of the electronic contact form, results in the subsequent acquisition of the sender’s email address and the other data previously indicated, which are necessary to respond to the requests, as well as any additional personal data included in the message.

4. Processing and storage methods

All processing activities are carried out using electronic or digital tools and, where necessary, may also be performed using paper-based or manual methods.

The data will be processed in ways consistent with the purposes for which they were collected and in compliance with applicable security standards, for the purposes described above or as specified from time to time in any additional privacy notices provided to the user.

Personal data processed for the purposes described above will be retained only for the time necessary to achieve those purposes, in accordance with the data minimization principle set out in Art. 5.1 c) of the Regulation. In any case, as the processing is carried out for the provision of services, IEuD will retain personal data for the period permitted under Italian law in order to protect its legitimate interests (Art. 2946 of the Italian Civil Code and subsequent amendments).

5. Communication and disclosure

Personal data, special category (sensitive) data, and data relating to criminal convictions and offenses will be stored at our premises and will never be disclosed without the individual’s explicit consent. For the aforementioned purposes, the data may be disclosed to the following recipients:

• Governing body of the Institute,
• Authorized persons for processing appointed by the Data Controller,
• Authorized persons for processing by Joint Data Controllers,
• Authorized persons for processing by the Italian Auxological Institute,
• Data Processors who may perform outsourced services in favor of the Data Controller relating to the Processing in question,
• Health facilities where specific treatments and/or analyses can be carried out,
• Public Administrations for the performance of institutional functions within the limits established by law or local regulations,
• Inspection bodies responsible for inspections or checks to all the inspection bodies responsible for assessments and checks concerning the compliance with legal obligations, following inspections or audits.
• Family members, close relatives or legitimate third parties, indicated by the data subject

If personal data are shared with third parties, the same safeguards applied by the Data Controller will be ensured. The personal data collected will not be shared for other purposes nor disclosed.

For purposes related to the provision of the service, data may be made available to third parties acting as independent data controllers, who provide ancillary services necessary to fulfill the individual’s request (for example, Google, ActiveCampaign, etc.).

Data may also be transferred to countries within the European Union or to other countries that the European Commission has determined provide an adequate level of protection, or with which IEuD or its service providers have entered into contractual agreements incorporating standard contractual clauses issued by the Commission, or that otherwise comply with the data protection standards set out in applicable regulations.

6. Rights of the Data Subject

Please be informed that, as a data subject, you may report any use of data that you consider improper or unjustified. You may lodge a complaint with the Italian Data Protection Authority, and you may exercise the rights listed below by submitting a specific request to the Data Controller.

You may exercise the following rights at any time:

• to know whether the Data Controller holds and/or processes personal data relating to them and to access such data in full, including by obtaining a copy (Article 15 – Right of access);
• to request the correction of inaccurate personal data or the completion of incomplete personal data (Article 16 – Right to rectification);
• to request the deletion of personal data held by the Data Controller where one of the grounds provided for by the Regulation applies (Article 17 – Right to erasure);
• to request that the Data Controller restrict the processing to certain personal data where one of the grounds provided for by the Regulation applies (Article 18 – Right to restriction of processing);
• to request and receive all personal data processed by the Data Controller in a structured, commonly used, and machine-readable format, or to request that such data be transmitted to another controller without hindrance (Article 20 – Right to data portability);
• to object, in whole or in part, to the processing of data for the purposes of sending advertising material or conducting market research (so-called consent) (Article 21 – Right to object);
• to object, in whole or in part, to the processing of data by automated or semi-automated means for profiling purposes (Article 22 – Automated decision-making relating to natural persons, including profiling).

Use of Cookies

In accordance with the decision of the Italian Data Protection Authority (the “Authority”) dated May 8, 2014, entitled “Identification of simplified methods for providing information and obtaining consent for the use of cookies” (the “Cookie Decision”), the Data Controller hereby informs you as follows.

What are cookies?

A cookie is a small amount of data, often containing an anonymous unique identifier, that is sent to the user’s browser by a web server and subsequently stored on the user’s computer hard drive. The cookie is then read and recognized only by the website that sent it, or by other websites linked to the first, whenever a subsequent connection is made.
Please note that a browser is the software that allows users to browse the internet by displaying information and transferring it to the computer’s hard drive. If the browser settings are configured to accept cookies, any website may send its cookies to the browser. However, in order to protect privacy, the browser can detect only the cookies sent by that specific website, and not those sent by other websites. In any case, cookies cannot damage the User’s computer.

How cookies are used on this site