Privacy Policy

Privacy policy under the provisions of Article 13 of European Union GDPR – General Data protection Regulation (679/2016/EU).

This privacy policy refers to the PMI Network website, developed by Politecnico di Milano (“Polimi”) for the PMI Network project funded by the (Interreg V-A) IT-CH – Italy-Switzerland programme.

Introduction

This page describes how the PMI Network website is managed under the provisions of Article 13 and Article 14 of European Union GDPR – General Data protection Regulation (679/2016/EU) in relation to the processing of the personal data of its users.

This privacy policy provides information to those who interact with the PMI Network service, which can be accessed electronically and pertains to the domain: pminetwork.polimi.it. This privacy policy is issued solely in relation to the PMI Network website.

Purpose of the personal data processing

Personal data is processed according to all purposes related to design and delivery of PMI Network, that include:

  • purposes related to monitoring, analyzing and assessing the use of the service;
  • purposes related to teaching and learning.

Data processing procedure

In relation to the stated purposes, the data processing is carried out with digital tools. In any case the protection is ensured by password.

Data Controller: Politecnico di Milano – Directorate General upon authorisation of the pro-tempore Rector dirgen@polimi.it
Piazza Leonardo da Vinci 32 – 20133 Milan Italy
Phone +39 0223992243
PEC: pecateneo@cert.polimi.it

Data Protection Officer: privacy@polimi.it – phone: +39 0223999378

This privacy policy is organized as follows:

  1. Information that PMI Network collects from you (including Personal Information)
  2. Cookies and tracking technologies on PMI Network
  3. Third Party Cookies
  4. How your information is used
  5. How your information is shared
  6. How to manage your personal information
  7. Storage & security
  8. Privacy policy updates
  9. Contact information

Information that PMI Network collects from you (including personal information)

PMI Network directly collects information when you:

  • enroll in the activities proposed on PMI Network website;
  • send email messages to the contact email of the PMI Network website.

PMI Network also indirectly collects usage information about your visit to the PMI Network website, as explained in the section below titled Cookies and tracking technologies.

Cookies and tracking technologies on the PMI Network website

PMI Network uses Cookies and other common Tracking Technologies on the PMI Network website and in email communications to help PMI Network better understand your use and needs of the PMI Network website, and how PMI Network can improve. For example:

  • based on your cookie settings, PMI Network tracks information indicating, among other things, which pages of the PMI Network website were visited, the order in which they were visited, when they were visited, and which hyperlinks and other user interface controls were used;
  • PMI Network may log the IP address, operating system, and browser software (including mobile use and device type when you use PMI Network native mobile apps) you used when accessing the PMI Network website, and PMI Network may be able to determine from an IP address your Internet Service Provider and the geographic location of your point of connectivity;
  • Tracking is performed via Google Analytics based upon anonimyzation of IP addresses;
  • PMI Network may track and collect information from emails that PMI Network sends to you, for example whether you opened the email or clicked on any links from the email.

PMI Network uses Cookies and other Tracking Technologies for the following purposes:

  • when necessary for system administration, security, and integrity to ensure the PMI Network website works properly for you. Without these technologies, the PMI Network website may not function correctly;
  • to enable analytics, performance and functionality, to help PMI Network gather information about how visitors use the PMI Network website and monitor PMI Network website performance, and to enhance your experience by recognizing and remembering whether you have visited the PMI Network website before and may have any personal preferences.

You have some options for managing Cookies and other Tracking Technologies. These include modifying your browser settings: You should be able to control how and whether your web browser accepts Cookies by adjusting its privacy and security settings. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new Cookies, how to receive notification of new Cookies, and how to disable existing Cookies. If you reject PMI Network’s Cookies, many functions and conveniences of the PMI Network website may not work properly.

Third party cookies

Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You may also deactivate Google Analytics by installing a so called browser-input-group-addon, which is provided by Google under the following address: http://tools.google.com/dlpage/gaoptout?hl=en.
Please note that this website extended Google Analytics for the code “gat._anonymezlp();” to ensure an anonymised recording of IP-addresses (IP masking).

More information on Google Inc. and Google Analytics can be found here: http://www.google.com/intl/en/policies/terms/.
Google’s privacy policy can be found here: http://www.google.com/intl/en/privacy/privacy-policy.html.

How your information is used

Your data is processed in accordance with Polimi policies; PMI Network uses information, including Personal Information, to carry out the following purposes:

  • organise and provide the online activities;
  • improve PMI Network service;
  • communicate with you;
  • track PMI Network website usage against goals and mission.

PMI Network may also seek your consent for additional uses of information, including Personal Information, and will use it only for the purpose described to you. All use of Personal Information is subject to applicable law.

How your information is shared

PMI Network may share information, including Personal Information, only as needed to fulfill the relevant purpose(s), with the following third parties:

  • staff authorised to process personal data;
  • European Union;
  • PMI Network project partners;
  • subjects that provide outsourcing services or acting as technicians operating the PMI Network equipment and service programs;
  • entities / authorities for issuing public key certificates.

How to manage your personal information

Delete Personal Information

To request deletion of your Personal Information, you should send a request to privacy@polimi.it. Because deletion on the PMI Network system is a permanent action and cannot be reversed, PMI Network may ask you to complete a process that aims to confirm your authority to manage data affected by your request.

Polimi will permanently remove you from PMI Network email lists.

Polimi will permanently delete your Personal Information from the PMI Network website.

PMI Network will retain and use Personal Information as necessary to comply with its legal obligations, enforce its agreements, and as otherwise permitted by applicable law.

Data retention

PMI Network will retain your Personal Information for as long as needed to provide you with services. Your Personal Information may be retained for a maximum of 2 years.

Storage & security

PMI Network stores information, including Personal Information, on its own servers located at Polimi. Polimi controls its own copy of information collected through the PMI Network website and has an information security program designed to protect information in its possession or control. This is done through a variety of privacy and security policies, processes, and procedures. Polimi uses administrative, physical, and technical safeguards that reasonably and appropriately protect the confidentiality, integrity, and availability of the information that it collects, receives, stores, or transmits. Nonetheless, no method of transmission over the Internet, or method of electronic storage, is 100% secure; and therefore, Polimi cannot guarantee its absolute security. While Polimi works hard to ensure the integrity and security of its network and systems, Polimi cannot guarantee that its security measures will prevent “hackers” or other unauthorized persons from illegally accessing or obtaining information.

If Polimi learns of a security breach involving its copy of your Personal Information, Polimi may attempt to notify you electronically so that you may take appropriate protective steps. By using the PMI Network website or providing Personal Information to PMI Network, you agree that PMI Network can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the PMI Network website. If a security systems breach occurs, PMI Network may post a notice on the PMI Network homepage (https://www.pminetwork.polimi.it/) or elsewhere on the PMI Network website and may send an email to you.

Privacy Policy updates

This privacy policy will be reviewed and updated from time to time. When changes are made, the privacy policy will be labeled as “Revised (date),” indicating that you should review the new terms, which will be effective immediately upon posting on this page, with an updated effective date. By accessing the PMI Network website after any changes have been made, you accept the modified privacy policy and any changes contained therein. In case you miss the notification referenced above, be sure to return to this page periodically to ensure familiarity with the most current version of this privacy policy.

Contact information

If you have privacy concerns, have disclosed data you would prefer to keep private, or would like to access the Personal Information that PMI Network maintains about you, please contact the Data Protection Officer at privacy@polimi.it or phone +39 0223999378.

If you consider the answer provided to be unsatisfactory, you may lodge, free of charge, a complaint with the Italian Authority for Data Protection – Garante per la protezione dei dati personali (www.garanteprivacy.it).

Effective date: February 10, 2020