Information on the processing of personal data

The Data Controller uses personal identification data, contact data, and data related to religious beliefs. The processing of your personal data is carried out in compliance with the legal framework, Italian and European, for the protection of personal data. Your data are processed in both paper and electronic format. The foundation does not put in place any automated decision-making process.

Your personal data (hereinafter referred to collectively as “personal data” or “data”) are processed for the following purposes:

1. To manage your financial support to the Fondazione OFM Fraternitas (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.
2. To send you information and promotional material about the activities of the Fondazione OFM Fraternitas by ordinary correspondence, e-mail messages, sms, mms, WhatsApp, Facebook or telephone communications (also aimed at subscribing to the newsletter of the Fondazione OFM Fraternitas, to request donations , upon request for the participation in institutional campaigns, invitations to join events organized by the OFM Fraternitas Foundation and similar communications).
3. Manage the activities – administrative-accounting or otherwise – necessary to execute the contract to which you are a party (specifically, any donations in any form made).

The legal basis for the processing of your personal data for the purposes referred to in points a. and b. above is the legitimate interest of Fondazione OFM Fraternitas in processing the personal data of its supporters in order to effectively pursue its statutory purposes (Article 6, paragraph 1, letter (f) of the GDPR). This legitimate interest consists in maintaining a constant relationship with the data subject, in order to keep them informed about awareness-raising actions that are considered useful to demonstrate the foundation’s ongoing commitment to carrying out its non-profit activities. This legitimate interest is permitted, under applicable law, as an alternative mechanism to the explicit consent of the data subject. This legitimate interest is acquired by the foundation (and balanced by full respect for the fundamental rights and freedoms of the individual, which always prevail over the legitimate interest of the data controller) to the extent that, through their actions, the individual has demonstrated an interest in and agreement with the principles of the Fondazione OFM Fraternitas.

Limited to the activities – of an administrative-accounting or other nature – necessary to perform the contract to which you are a party (specifically, any donations in any form made), the legal basis for the processing of your personal data for the purposes referred to in c. above is the need to perform a contract to which you are a party or pre-contractual measures taken at your request pursuant to Article 6(1)(b) GDPR or to comply with legal obligations. The Foundation will not use your personal data for purposes other than those indicated.

In order to answer your questions and/or provide you with what you have requested, the provision of personal data is necessary: without it, Fondazione OFM Fraternitas will not be able to answer you and/or provide the services you have requested.

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 ETS, 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.

In particular, the taxpayer’s personal data, when complete with Tax Code, are transmitted to the Revenue Agency for the purpose of the pre-filled declaration. The taxpayer may exercise the right to object to the sending of data on liberal disbursements to the Agency as provided for in the order of the Director of the Revenue Agency of February 9, 2018.

Your data will not be transferred outside the European Union.

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 Fondazione OFM Fraternitas 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 Fondazione OFM Fraternitas 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 Fondazione OFM Fraternitas 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 Fondazione OFM Fraternitas 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.

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).
• Right of rectification: the data subject has the right to obtain from the data controller the rectification of inaccurate personal data concerning him/her without undue delay. In addition, he/she has the right to obtain the integration of incomplete personal data, including by providing a supplementary declaration. In this case, the data controller will be obliged to inform each recipient to whom the personal data have been transmitted about any rectification.
• 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 Fondazione OFM Fraternitas ETS 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.
• Right to restrict processing: if the data subject deems it appropriate, he/she may request the restriction of the processing of personal data concerning him/her and limit its processing in the future. In such a case, the data controller will notify each of the recipients to whom the personal data have been transmitted of any processing restrictions, unless this proves impossible or involves a disproportionate effort.
• Right to object to processing: the data subject has the right to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her.
• Right to revoke consent: in the case of consent-based processing, the data subject may revoke the consent given for the processing. However, this act will not affect the validity of the processing carried out by the owner up to that point.
• Right to lodge a complaint with the Supervisory Authority: where the data subject believes that his or her data has been processed unlawfully and violates the rules and principles on the protection of personal data, he or she has the right to apply to the Supervisory Authority (Privacy Guarantor – Garante Privacy) to lodge a complaint, in accordance with the procedures defined by the latter.

You can exercise the rights recognized to you at any time by sending:

• an e-mail to the address fondazione@ofmfraternitas.org;

or a registered letter with return receipt to Fondazione OFM Fraternitas ETS, with registered office in Via di Santa Maria Mediatrice, 25 – 00165 Rome.