Pursuant to Article 13 of Italian Legislative Decree No. 196/2003 and Articles 13-14 of Regulation (EU) 2016/679, American International Club of Rome Association (hereinafter referred to as “the Association” or “American International Club of Rome”) wishes to inform you how we collect and use your personal data when carrying out the association services on your behalf or in any other business dealings with you.
1. Data Controller
For the purposes of the GDPR Data Protection Legislation currently, the appointed Data Controller is:
American International Club of Rome Association
Fiscal Code/VAT number 14567171005
Rome Office: 00187 - Rome, Via Sistina 121, Italy
T: +39 3296268509
2. Definition of ‘Personal Data’
Personal Data also includes:
so-called “sensitive” data, i.e. data revealing a natural person’s racial or ethnic origin, religious, philosophical or other beliefs, political opinions, membership of political parties, trade unions, associations or organizations of a religious, philosophical, political or trade union nature, health, sex life, and economic situation;
so-called “judicial” data, i.e. any information revealing official government records (for example, Italian residency; US residency status; visa applications, ect.
3. Nature of the Personal Data Processed and Collection Methods
Please be aware that the Personal Data that the American International Club of Rome may collect include:
Contact details, such as name, surname, job title and/or company position, company address, home address residence – if necessary telephone number, mobile number, fax number, and e-mail address;
Payment data, such as data necessary for processing payments and for fraud prevention, including credit/debit card numbers and other related billing information;
Commercial information, where necessary for the implementation and/or development of a project or contractual relationship;
Information collected from public sources, such as, for example, the information provided by credit agencies; national, European or international databases of government offices; external collaborators holding Personal Data in their capacity as Data Controllers (Google, Facebook, Instagram, etc);
Information on disputes or any judicial and/or administrative proceedings that may concern you or third parties related to you, which may also be relevant for association requests;
Special categories of Personal Data both for the purposes of carrying out the association services entrusted to the Association (for example, American International Club of Rome may collect information about your membership of a professional association or trade union, health, etc.), and in connection with your registration and participation to an event or seminar organized by the Association in particular, on these occasions, American International Club of Rome may ask you to provide information about your health for the purpose of identifying and taking into consideration any disabilities or special dietary requirements you may have. Any use of this information is based on your consent however if you do not provide this information to us we will not be able to take all the necessary precautions;
Your Personal Data may be collected on various occasions, such as when you:
request to join the association, request advice or assistance;
navigate on/interact with our website;
attend seminars/conferences or other events organized by American International Club of Rome;
request association training or make any other job application with us; or
offer to provide your services to the American International Club of Rome.
As a general practice, the American International Club of Rome collects and processes the Personal Data voluntarily provided by you by e-mail or paper and/or by hand, etc., and you will thereby be giving your consent to the processing.
As indicated, on certain occasions (see for example letters d) and e) above), your Personal Data may be collected from public sources and/or third parties and stored or used by us.
4. Purpose of Personal Data Processing
Please be aware that the American International Club of Rome may use your Personal Data for the following purposes only (“Purposes”):
carrying out the association services on your behalf and therefore providing the association advice or association services you requested;
managing and handling the business relationship between you and the Association, including payment processing, billing, and all other necessary support services;
complying with the associated obligations that are binding for American International Club of Rome, which include, for example, record-keeping obligations, anti-money laundering obligations (in particular those set forth by Legislative Decree No. 231/2007 and subsequent amendments) and obligations for the prevention of the use of the financial system for the purpose of money laundering and terrorist financing (such data collection is, therefore, mandatory pursuant to Article 21 of Legislative Decree No. 231/2007 “Customer’s obligations” and subsequent amendments), as well as obligations related to compliance with antitrust regulations;
managing and ensuring your security when accessing our offices, information and communication systems, online platforms, websites, and other systems, including for the purpose of preventing and detecting security threats, fraud or other criminal or harmful activities;
analyzing and improving the American International Club of Rome’s services and communications with you;
for insurance purposes;
Identifying persons authorized to act on your behalf;
for any purpose related and/or ancillary to any of the above, or for any other purpose for which you provided your Personal Data.
Where you have provided specific consent, your Personal Data may also be processed for the following additional purposes (“Additional Purposes”):
communicating the American International Club of Rome’s events such as seminars and other projects;
marketing purposes. These may include mentioning – also anonymously if requested – referring to questions handled by the Association on your behalf in surveys or questionnaires necessary for American International Club of Rome to be considered for nominations or Association awards relating to the excellence of service or client satisfaction or similar in regard to association services the Association provides.
You should be aware that you are entitled to withdraw any consent given for the Additional Purposes at any time by sending a request to the following email address: firstname.lastname@example.org.
5. Association basis for Processing and Consequences of the Refusal to have Personal Data processed
In principle, should you choose not to provide the American International Club of Rome with your Personal Data and/or withhold consent, there will be no detrimental consequences. However, in certain circumstances, if you do not provide Personal Data and/or give consent to the processing of such Personal Data, American International Club of Rome may be unable to operate and perform the association services on your behalf, since, for example, this Personal Data is necessary to process your instructions or orders. In such a case, the Association will contact you immediately to inform you of this.
With particular reference to the data processing for the purposes listed in Article 4 above, please note that the processing of your Personal Data is carried out:
because processing is necessary for the performance of your instructions or for the execution of an agreement entered into with you;
to comply with association obligations;
because processing is necessary for a legitimate interest of the Association or of any third parties that receive your Personal Data, unless your fundamental interests, rights, and freedoms prevail over such interests.
Furthermore, the use of your Personal Data may only be justified for certain additional Purposes when you have provided further express consent.
If you do not give your express consent for Additional Purposes, you will not receive any communication from the American International Club of Rome for these Additional Purposes, nor will your Personal Data be used for these Additional Purposes. In any event, failure to give consent here will not prevent the American International Club of Rome from providing the association services to you.
6. Types of Personal Data Processing
Processing is carried out through the following operations or set of operations: collection, recording, organization, storage, consultation, treatment, alteration, selection, retrieval, comparison, use, interconnection, blocking, disclosure, cancellation, and destruction of Personal Data.
The operations may or may not require the use of electronic or automated means.
Data processing is carried out by the Data Controller and/or by authorized persons expressly indicated to you in your Letter of Engagement.
7. Processing, Communication, and Disclosure of Personal Data
Your Personal Data will be processed by the Data Controller and by the persons authorized to process Personal Data.
For the proper performance of the association services entrusted to us and for administrative, billing and other commercial purposes, your Personal Data may be disclosed - where necessary and on a confidential basis - to external collaborators and service providers, parties operating in the judicial field, adversaries and their counsels, arbitration panels.
In particular, where necessary, we may communicate your Personal Data to:
Current association members by including your personal details (phone number, email, address) in the directory;
Other associations (including American Associations) or advisers, Embassies and event coordinators;
On a confidential basis, we may disclose your Personal Data to:
Third parties in order to improve and promote the Association’s services, as well as for system maintenance;
Companies providing services in the field of anti-money laundering and for other crime prevention purposes;
To administrative/judicial authorities or other parties where it may be reasonably necessary for carrying out the association services entrusted to us;
Service providers, including those external to the Association, on both a national and international level.
American International Club of Rome shall disclose your Personal Data in one or more of the following circumstances only: (i) upon your authorization; (ii) when required by law or applicable regulation, or ordered by a judicial/administrative authority; or (iii) to investigate the existence of any actual or suspected fraudulent or criminal activity.
For more information, please contact the American International Club of Rome at the following email address: email@example.com.
8. Transfer of Personal Data abroad
American International Club of Rome is active on an international level. Therefore, your Personal Data may be transferred abroad, if required for the performance of the Purposes and/or Additional Purposes.
In particular, your Personal Data may be transferred to non-EU countries in respect of which the European Commission has decided, in accordance with Article 45 of Regulation (EU) 2016/679, that the laws in force therein ensure an adequate level of protection of Personal Data.
In the absence of such a decision by the European Commission, your Personal Data may be transferred to non-EU countries only after American International Club of Rome has implemented adequate safeguards on data protection, in accordance with Article 46 of Regulation (EU) 2016/679, for example by adopting standard contractual clauses established by the European Commission (available at the following link: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en).
The Association’s office in Rome ensures and will always ensure an adequate level of protection of your Personal Data. In this regard, we will always ask our suppliers, agents, consultants, etc. to provide equal safeguards for the protection of your Personal Data.
9. Personal Data Storage
American International Club of Rome shall retain the Client’s Personal Data in accordance with the applicable law and for as long as is strictly necessary for the performance of the association services entrusted to us. Upon termination of the engagement, the Association shall retain such Personal Data for as long as is strictly necessary for the purposes of compliance with the applicable civil and accounting laws, and subject to the requirements for carrying out the Association’s professional activity.
10. Security and Transfer of Personal Data
The processing, storage, and treatment of your Personal Data are ensured through appropriate technical and organizational measures to keep your Personal Data confidential and secure in accordance with our internal procedures. Personal Data may be stored on our Personal Data management systems, on those of our suppliers or on paper files.
11. Your Rights
You may at any time exercise the rights you are entitled to under the applicable law. Such rights include:
Receive confirmation that American International Club of Rome is processing your Personal Data and request to access them;
Updating, changing and/or amending your Personal Data;
Request the cancellation, anonymization, blocking of your Personal Data processed in breach of the law;
Request the restriction of processing;
Object to the processing for legitimate reasons;
Receive Personal Data you provided in a structured, commonly used, machine-readable and interoperable format, and request that such Personal Data be transmitted to another data controller without hindrance;
Withdraw the consent for the processing of your Personal Data given for specific purposes;
Refer the matter to the Data Protection Authority.
In order to exercise one or more of the rights listed above, you may send a specific request to the Association:
by post to: American International Club of Rome, 00187 - Rome, Via Sistina 121, Italy; or
by email at: firstname.lastname@example.org.