Purpose of the processing and legal basis
Your personal data (hereinafter referred to collectively as “personal data” or “data”) are processed for the following purposes:
- To manage your financial support to the OFM Fraternitas Foundation (through, inter alia, regular and / or one-off donations, made in various ways eg, credit card, direct debit, postal order, PayPal or other) and any related services and benefits to such support.
- To send you information and promotional material about the activities of the OFM Fraternitas Foundation by ordinary correspondence, e-mail messages, sms, mms, WhatsApp, Facebook or telephone communications (also aimed at subscribing to the newsletter of the OFM Fraternitas Foundation, to request donations , upon request for the participation in institutional campaigns, invitations to join events organized by the OFM Fraternitas Foundation and similar communications).
Registration on the site to use the services provided by the Foundation
The legal basis for the processing of your personal data for the purposes referred to in points 1 and 2 above mentioned is the legitimate interest of the OFM Fraternitas Foundation in processing the personal data of its supporters in order to effectively pursue its statutory purposes (Article 6, paragraph 1, letter (f), GDPR, considering C47 and Opinion 6/2014 of the Working Party, paragraph III.3.1). This legitimate interest consists in maintaining constant the relationship established with the interested party, to keep him/her informed about the awareness-raising actions considered useful to show his/her own constant commitment to the realization of his/her non-profit activities. Such a legitimate interest is allowed, pursuant to applicable law, as an alternative mechanism to the explicit consent of the interested party. This legitimate interest is acquired by the foundation (and counterbalanced by full respect for the fundamental rights and freedoms of the person, which always prevail over the legitimate interest) to the extent that, through their actions, the person has shown the personal interest in and shares the principles of the OFM Fraternitas Foundation.
Limited to the activities – of an administrative-accounting or other nature – necessary to execute the contract of which you are a part (specifically, any donations in any form made), the legal basis for the processing of your personal data for the purposes referred to in point 1 is the need to execute a contract of which the interested party is a party or pre-contractual measures adopted at the request of the same pursuant to art. 6, paragraph 1, letter (b), GDPR.
The legal basis for the processing of your personal data for the purposes referred to in point 3 above (i.e., registration on the foundation’s website) is your explicit consent. Under no circumstances the OFM Fraternitas Foundation does proceed with the profiling of your personal data or carry out any automated decision-making process.
FondazioneOFM Fraternitas will not use the data provided for purposes over the aforementioned purposes, and, in any case, only within the limits indicated from time to time in the information to be provided pursuant to art. 13, GDPR.
To answer your questions and / or to provide you with what you requested, the provision of personal data is necessary: in the absence of the OFM Fraternitas Foundation, it will not be able to answer and / or provide the services requested. The provision of personal data for information / promotional purposes is entirely free and optional. Failing that, however, the OFM Fraternitas Foundation will not be able to inform you about the initiatives, projects and activities of the foundation itself.
Processing methods and criteria for defining the retention period
The processing of your personal data is carried out in compliance with the Italian and European regulatory framework for the protection of personal data. Your data are processed both in paper and electronic format.
Fondazione OFM Fraternitas will process your personal data for the time necessary to fulfill the aforementioned purposes according to variable criteria depending on the category of the data, the nature of the processing and the purposes of the processing itself. As a matter of principle, the OFM Fraternitas Foundation will establish the conservation criteria according to the following evaluations:
- all data with respect to the various forms of donation are kept as long as the relationship remains active and, in any case, no later than 10 years from the date of each support event for the foundation (typically economic), or until the moment in which you decide to exercise the right to cease the support for the OFM Fraternitas Foundation and request the cancellation of the same data, unless, of course, any obligation established by the law, regulation or a community legislation which does not require its conservation (in the latter case it is understood that the data processing will take place only in order to fulfill the legal obligation and no longer for the purposes referred to in this information), or in the exercise of a right (or in any case a legitimate interest) of the foundation itself which does not require its conservation.
- all data of donors or interested parties in our business processed for information / promotional purposes are kept for the time period necessary to provide the information services reserved for those persons. This right and interest in information arise upon joining any initiative that demonstrates the OFM Fraternitas Foundation’s principle sharing by the interested party, whether this involves a donation or it is an action of interest and participation in the institutional activities of the foundation. This period is justified by the legitimate interest of the OFM Fraternitas Foundation in maintaining constant the relationship established with the persons in order to keep them informed on which projects could be financed with the contribution of donors or about the awareness-raising actions considered useful to inform about and demonstrate the constant commitment to the realization of its projects within the aims of its institutional purposes. The retention period is extended as long as the person’s interest in contact with the foundation persists: if he/she no longer has an interest, it is sufficient that it is communicated through the procedures set out in the Paragraph “Rights of the interested parties” and the foundation will adopt the appropriate technical and organizational measures to no longer disturb the person. In the event that the “legitimate interest” mechanism is not applicable and the consent of the interested party has been requested (e.g., registration on the foundation’s website), the retention criteria described above will still be applied.
Once the relative retention periods have elapsed, the personal data will be definitively deleted and will no longer processed.
Subjects or categories of recipients of personal data
Your data may be made accessible, for the purposes listed, to persons in charge or otherwise authorized, or to persons legally autonomous with respect to the Data Controller, appointed as Managers, always in compliance with the principle of purpose.
The personal data collected will be made available to persons authorized by Fondazione OFM Fraternitas pursuant to art. 29, GDPR that carries out processing activities that are essential for the pursuit of the purposes indicated above. Specifically, these are the persons appointed by the Owner to provide specific services, administration, management of information services, relations with actual and potential donors, organizers of information campaigns on the projects and institutional activities of the foundation.
The Managers are third parties who, with experience, technical skills, professionalism and reliability, carry out processing operations on our behalf, in compliance with the security and confidentiality of the information and constantly monitored by us in their work. The complete and updated list of the data processors can be requested at the address Fondazione@ofmfraternitas.org; or alternatively, by writing to Fondazione OFM Fraternitas Onlus, with registered office in Via di Santa Maria Mediatrice, 25 – 00165 Rome.
Always in compliance with the principles of processing and for the purposes indicated, your data could be made available to the following third parties, legally autonomous with respect to the Data Controller, who provide instrumental services to the pursuit of the aforementioned purposes and operate within the European Union :
- subjects external to the foundation who carry out banking and financial intermediation services, transport and sorting of communications to the public, e-mailing services, archiving of documentation, consultancy, insurance, promotion and fundraising, “aggregated” territorial organizations that implement the program locally of the foundation.
- to identified individuals for whom the communication is necessary to fulfill an obligation established by law, by a regulation or by community legislation.
Your data will not be subject to disclosure.
Your data will not be transferred outside the European Union.
Place of data retention
Personal data will be stored in digital form on servers located at the headquarters of the Fondazione OFM Fraternitas Onlus in Rome (Italy) and / or on cloud servers of third party suppliers in accordance with the requirements of the GDPR and in any case within the European Union.
Owner of the treatment
FONDAZIONE OFM FRATERNITAS ONLUS, with registered office in Via di Santa Maria Mediatrice, 25 – 00165 Rome is the data controller (Article 4, paragraph 7, GDPR: “the natural or legal person, public authority, service or other body that, individually or together with others, determines the purposes and means of personal data processing of personal data “), pursuant to and for the effects of the GDPR, since it decides how and for what purpose to collect and use the personal data provided by the interested party, as well as which tools to process them with and which security procedures to activate to guarantee their integrity, confidentiality and availability.
Rights of interested parties
You, as an interested party, have the right to exercise the rights referred to in articles 15 to 22 of EU Regulation 2016/679.
In particular, it will be your right to ask the Fondazione OFM Fraternitas to access your personal data, to request the rectification or cancellation of the same or the limitation of processing or to oppose their processing, in addition to the right to portability. It is your right also to lodge a complaint to the Supervisory Authority which for Italy is the Guarantor for the Protection of Personal Data, based in Piazza di Monte Citorio 121, 00186 Rome, using the appropriate form downloadable from the site of the guarantor (www.garanteprivacy.it).
If you are no longer interested in receiving information about our business and our projects, you can communicate it to us and ask for the cancellation of your data at any time using the methods indicated below; the OFM Fraternitas Onlus Foundation will adopt all the appropriate technical and organizational measures so to not be of disturb anymore. If the processing of your data is based on your consent, you have the right to withdraw the consent given at any time.
You can exercise the rights recognized to you at any time by sending:
- an e-mail to the address firstname.lastname@example.org;
- or a registered letter with return receipt to Fondazione OFM Fraternitas Onlus, with registered office in Via di Santa Maria Mediatrice, 25 – 00165 Rome.
The present information may undergo changes over time, also due to additions and legislative and regulatory changes on the subject or due to our institutional decisions. Therefore, we invite you to periodically consult this section of our site.