INFORMATION NOTICE FOR SUBSCRIBERS TO THE NEWSLETTER

This information notice is provided pursuant to Article 13 of EU Regulation 679/2016 – “General Data Protection Regulation” (GDPR) to those who subscribe to the newsletter with Aps Vajne, or with any of the entities listed below as joint controllers (Article 26 GDPR), or with any of the entities that have appointed Aps Vajne as data processor (Article 28 GDPR).

Identity of the Joint Controllers

The joint controllers for the purposes set out below are:
• Dhora srl Impresa Sociale, represented by its legal representative pro tempore, with registered office at Via Baldissero 21, Vidracco (TO), together with:
• Aps Talej net, represented by its legal representative pro tempore, with registered office at Via Baldissero 21, Vidracco (TO);
• Associazione Damanhur Alchemy School, represented by its legal representative pro tempore, with registered office at Via Baldissero 21, Vidracco (TO);
• Associazione Templi dell’Umanità, represented by its legal representative pro tempore, with registered office at Via Baldissero 21, Vidracco (TO);
• Selet srl, represented by its legal representative pro tempore, with registered office at Via Baldissero 21, Vidracco (TO);
• and the entities listed at www.damanhur.org/it/privacy.

Under the internal agreement concluded among the Joint Controllers pursuant to Article 26 GDPR, each Joint Controller, at the time of first contact with the data subject, is responsible for providing—directly or through Dhora srl Impresa Sociale or another Joint Controller—an information notice on the processing of personal data to those who wish to receive the newsletter.
Dhora srl Impresa Sociale coordinates compliance with the personal data processing obligations for which it acts as joint controller, as it has the human, technological and organizational resources of a social enterprise managing multiple heterogeneous operational units.
Dhora srl Impresa Sociale has also been appointed as data processor pursuant to Article 28 GDPR by the autonomous controllers listed at the address www.damanhur.org/it/privacy. The processing for which Dhora srl Impresa Sociale has been appointed as data processor is the same processing carried out in its capacity as joint controller.
Furthermore, another processing entrusted to Dhora srl Impresa Sociale in its capacity as data processor is the provision of the information notice on personal-data processing to the data subjects of the individual autonomous controllers.
Finally, Dhora srl Impresa Sociale is responsible for responding to data subjects in case they exercise their rights.
The Joint Controllers ensure the security, confidentiality, and protection of the personal data in their possession at every stage of the processing.

Data Protection Officer

Dhora srl Impresa Sociale has appointed a Data Protection Officer, domiciled for this function at the registered office of Dhora srl Impresa Sociale, Via Baldissero 21, Vidracco (TO).

Source of the Data

The personal data processed are those entered in the newsletter subscription/registration form on the website, at the point of sale, or at the front office of any of the entities listed at www.damanhur.org/it/privacy, or through a website attributable to them.

Purpose of the Processing

The personal data of data subjects may be processed by Dhora srl Impresa Sociale, by the Joint Controllers listed at www.damanhur.org/it/privacy, and by the autonomous controllers that have appointed Aps Vajne as data processor, listed at the same address, for the purpose of sending the newsletter by email.

Legal Basis of the Processing

The legal basis for processing is the consent of the data subject, expressed through an unequivocal positive action consisting of the voluntary and free subscription or registration to the newsletter by entering their email address.

Recipients of the Data

The personal data processed by the Joint Controllers will not be disseminated, nor made known to unspecified parties in any form, including by making them available or merely consultable.
They may, however, be communicated to employees and collaborators, including volunteers, authorized to process data by the Joint Controllers; to consultants; and to other entities or companies related to Aps Vajne or the Joint Controllers, always for the purposes indicated above.
They may also be communicated to parties entitled to access them under laws, regulations, or EU provisions, and—within the limits strictly necessary—to parties who, for the same purposes as above, must supply goods or perform services for the Joint Controller, such as professionals or service companies, for the administration and management of the organization to which they have been duly appointed or authorized to operate.
Furthermore, upon specific request or with the consent of the data subjects, certain personal data (such as name, photographs, or opinions) may be disclosed through publication on websites, newsletters, brochures, publications, periodicals, or press releases, prepared or published by Aps Vajne or the Joint Controllers.

Data Transfer

Should the Joint Controller transfer personal data to third countries or international organizations for the purposes indicated above, you will be informed whether or not an adequacy decision by the European Commission exists.
The Joint Controller reserves the right to use cloud-based services; in such case, service providers will be selected among those offering adequate safeguards, as required by Article 46 GDPR 679/16.

Data Retention

The Joint Controller retains and processes personal data for the time necessary to achieve the purposes indicated.
Specifically, data are retained until the data subject unsubscribes from the mailing list or until the email addresses remain active.

Data Subject Rights

With reference to Articles 15 (right of access), 16 (rectification), 17 (erasure), 18 (restriction), 20 (portability), 21 (objection), and 22 (objection to automated decision-making) of GDPR 2016/679, the data subject may exercise their rights by writing to the address above or to dpo@dhora.it, specifying the subject of the request, the right they intend to exercise, and attaching a copy of an identity document proving the legitimacy of the request.
The Controller particularly reminds that each data subject may exercise the right of objection under the forms and conditions set forth in Article 21 GDPR.

Withdrawal of Consent

Pursuant to Article 7 GDPR 679/16, the data subject may withdraw consent at any time.
Withdrawal of consent, which can be done through the appropriate unsubscribe link at the bottom of each newsletter, will result in the suspension of newsletter delivery.

Refusal to Provide Data

Providing personal data is optional, and failure to provide such data may only result in the inability to receive the newsletter.

Right to Lodge a Complaint

The data subject has the right to lodge a complaint with the supervisory authority of their country of residence.

Automated Decision-Making

The Joint Controllers may carry out processing involving automated decision-making on personal data of natural persons for the purpose of sending selected material and inviting them to targeted events.
Where such processing occurs, the legal basis is the explicit consent of the data subject.

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