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Privacy Policy on the Website’s usage


Introduction
Fondazione Internazionale Menarini (“Fondazione”) takes your privacy very seriously, and commits to respect it in accordance with the applicable law (D. lgs. 196/2003 – Privacy Code and Regulation 2016/679/EU).

This document (“Privacy Policy”) provides information on the processing of all personal data collected by Fondazione through this website (“Website”, or “Site”), and constitutes an information notice pursuant to the mentioned legal instruments. In the sections of the Website where personal data are collected, a specific information notice is normally provided, which must be understood as being supplemented by this Privacy Policy.

Data Controller 
The Data Controller is Fondazione Internazionale Menarini  headquartered in Strada 6 - Edificio L, Centro Direzionale Milanofiori, 20089 Rozzano, Milano, Italy, ph. +39-0255308110, (the “Data Controller” or “Fondazione”).

Purposes and methods of the personal data processing 
The Data Controller may process your personal data for the following purposes: management of the requests submitted through the Website, management of the functions and services available on the Website, management of the registration and of access to the Site’s restricted access area, fulfilment of the legal obligations stemming from laws, regulations, EU law, etc.. 

Furthermore, but only with your additional, optional consent, your data may be used also to  1) send institutional communications (including Fondazione’s Newsletter); or to 2) send the journal “Minuti –Scientific Edition” and/or “Minuti –Artistic Edition”, which include advertising of pharmaceutical products and are therefore restricted to professional allowed to prescribe pharmaceutical products pursuant to the Italian Legislative decree 219/2006.
Provision of Personal Data
Some of your personal data are necessary to manage the communications and the requests you submit. Such type of data are marked by an asterisk [*], which means that providing them is necessary to enable Fondazione to handle the query –otherwise, we would not be allowed to process it. Conversely, submitting data not marked by an asterisk is optional: if you do not wish to submit them there will be no consequence.


Categories of processed personal data
The data that may be processed are:

1) the personal data which you may provide when you interact with our Website and/or request some services (including registration to restricted access areas, participation to prize contests or other initiatives, use of Apps, information requests and other communications, including those submitted by means of our contact forms, etc.);

2) Cookies and navigation data, as specified under the following section.

Navigation data and cookies
When you simply visit our Website (i.e. without sending any communication or using any of the services/functions available) we will only process your navigation data, i.e. the data transmitted to the Website and required to operate the computerised systems set up for the Website’s management, as well as Internet communication protocols. By way of example, the IP addresses or the domain names of the computers used to visit the Website and the other parameters relating to the operating system used to connect to the Website all fall in this category. Fondazione collects such and other data (for example, the number of visits and the time spent on the Website) for truly statistical purposes and in an anonymous manner in order to monitor the functioning of the Website and to improve it. In principle, the data in question are neither collected to be associated with other information of yours nor do they make your identification; however, due to their nature, such data may potentially lead to your identification if processed and associated with other data held by third parties. For this reason, navigation data are immediately de-identified after processing and may only be retrieved by Fondazione to ascertain, as well as identify the authors of, potential IT-related offenses committed to the detriment of the Website or through the Website. Notwithstanding the latter exception, navigation data as described above are only kept for a limited time, in compliance with the applicable legal provisions.

The Website uses cookies. By surfing on the Website, you consent to the use of cookies in line with this Privacy Policy.

Cookies are small files memorised on the hard disk of your computer. There exist two macro-categories of cookies:  technical and profiling cookies.

Technical cookies are necessary to ensure the correct functioning of websites and to enable you to browse the Website; without them, you would be unable to correctly view the Website’s pages or to use some of its services. 

Profiling cookies are designed to create user profiles with the aim of sending commercial ads in line with the preferences expressed when surfing the internet.


Cookies –whether “technical” or “profiling”- may further be classified as:

- “session” cookies, which are deleted as soon as the browser is closed;
- “Persistent” cookies, which are stored in the browser for a certain timeframe; such cookies are used, by way of example, to  recognize the device which logs on to a website, speeding up the user’s authentication process;
- “proprietary” cookies, created and managed directly by the entity that runs a given website;
- “third-party” cookies, created and managed by entities other than that which runs a given website.

The types of cookies used on the Website.
The Website uses both technical and profiling cookies, and specifically the following categories:
(i)  “proprietary” cookies, both session and persistent, required for purposes of internal security and system administration and/or to make navigation on the Website possible;

(ii) persistent, third party cookies, used by the Website to send statistical information to the system Google Analytics, through which Fondazione may perform statistical analyses of access/visits. These cookies are used only for statistical purposes, and are able to collect only aggregated information. By using a session and a persistent cookie (which expire as soon as the browser is closed), Google Analytics also creates a register, where the timing of the beginning and end of all visits to the Website is recorded. To inhibit Google from tracking down such information and the subsequent processing, you may download a browser plug-in from the following URL: 
https://tools.google.com/dlpage/gaoptout?hl=en-GB 

The majority of cookies on the Website may be disabled by changing your browser’s settings or by following the instructions available on the websites of the companies which manage the cookies. In any case, please be aware that disabling cookies may impair your ability to use the Website and/or to take advantage of the available functions and services. 



In the following table we provide the details of the cookies installed on our Website. Beside each “third party cookie” a link to the privacy policy of the cookie’s manager/originator is displayed:

COOKIES TYPE PURPOSE PRIVACY POLICY
www.fondazione-menarini.it First Party - Session and persistent Cookies required to make navigation on the Website possible, for internal security and administration purposes, as well as to memorize the language selected by the user This document
google.it
google.com
Third Party - persistent Cookie for the Google Analytics service https://www.google.com/analytics/learn/privacy.html?hl=it
http://www.google.com/policies/privacy/
https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage#gajs
https://tools.google.com/dlpage/gaoptout
https://support.google.com/analytics/answer/6004245
www.vimeo.com Third Party - persistent Cookies required to enable users to view multimedia contents https://vimeo.com/privacy#cookies

How to disable cookies in your browser’s settings


A guide to manage cookies in the most common browsers is provided below 


Chrome

  1. Select the menu located top right of the browser’s instrument bar
  2. Select Settings
  3. Select the link Show advanced settings
  4. In the Privacy section, select content settings
  5. Under the Cookie section, modify the following settings according to the desired managing of cookies:
    • Allow data to be saved on local
    • Memorize data only until the browser is closed
    • Block sites from setting any data
    • Block third party cookies and site data
    • Manage exceptions for some internet sites
    • All cookies and site data

For further information, visit the dedicated internet page (link: https://support.google.com/accounts/answer/61416?hl=en )

Mozilla Firefox

  1. Select the menu located top-right of the browser’s instrument bar
  2. Select Options
  3. Select the Privacy panel
  4. In the Tracking section, select the relevant button if you want to inform the websites that you do not wished to be tracked
  5. In the History section, select the option Use Customized Settings from the drop-down menu and modify the following settings according to the desired managing of cookies:
    • Accept cookies (by selecting the relevant button);
    • Accept cookies from third parties (by selecting one of the following options from the drop-down menu: always, from already visited sites, never)
    • Keep until (select one of the following options from the drop-down menu: until they expire, until Firefox is closed, or ask every time).
  6. In the History section it is also possible to select the button Show cookies if you want to remove the cookies that are present in your computer.

For further information, please visit the dedicated Mozilla webpage (https://support.mozilla.org/t5/Protect-your-privacy/Enable-and-disable-cookies-that-websites-use-to-track-your/ta-p/2784 )

Internet Explorer

  1. Select the Tools button
  2. Select Internet options
  3. Select the Security tab
  4. In the drop-down menu, select one of the options to customize the settings according to the desired managing of cookies:
    • Block all cookies
    • High
    • Medium-high
    • Medium
    • Low
    • Accept all cookies
  5. Select the button Sites if you want to specify which sites may always or never use cookies; this can be done by typing in the website address in the Web Address box and by selecting the Block or Allow buttons.

For further information, please visit the dedicated Microsoft Webpage ( https://support.microsoft.com/en-us/help/196955/how-to-set-and-customize-cookies-settings-in-internet-explorer-5 )

Safari

  1. Launch Safari
  2. Click on Safari
  3. Select Preferences and then Privacy
  4. In the Block Cookies section, select the preferred cookie management option.
  5. To see which sites have stored cookies on your computer click on Details

For further information, please visit the dedicated Apple page ( https://support.apple.com/kb/PH19214?viewlocale=en_US&locale=it_IT )

Opera

  1. Launch Opera
  2. Select Settings from the main menu top-left of the screen
  3. Select Privacy and Security
  4. In the Cookies section, select one of the following options:
    • Accept cookies –allows cookies to be stored on your computer
    • Delete new cookies when exiting Opera
    • Never accept cookies
    • Accept cookies only from the site I visit
    • Ask me before accepting cookies
  5. By selecting the button Manage cookies it is possible to remove the cookies that are stored on your computer

For further information, please visit the dedicated Opera page. (http://www.opera.com/help/tutorials/security/cookies/)



Links to other Websites
The Website may include links to other sites (so-called “third party sites”). Fondazione does not perform any access or control on cookies, web beacons and other tracking technologies that may be used by third party sites to which you may access from the Website; it does in no way control the contents and materials published on, or obtained from, third party websites; and it does not control how your personal data are processed by such websites -thus, Fondazione expressly declines any liability/responsibility whatsoever which may arise in connection to all these circumstances. You should check the privacy policies of the third-party sites to which you connect through the Website and make yourself aware of the conditions applicable to the processing of your personal data. The present Privacy Policy only applies to the Website as defined above.


Retention and Storage of Personal Data
Fondazione ensures that the settings of its IT systems and programs are designed to minimise the use both of personal data and of any other information which may lead to your identification; all these sets of data are processed exclusively to achieve the goals for which they were obtained at the time of collection; in any event, the criteria used to determine the data’s storage period are based on the deadlines prescribed by the law, as well as on the principles of data minimisation and efficient management of our data bases. 



Security and quality of personal data
Fondazione undertakes to protect the security of your personal data and to implement the safety measures established by the Privacy Code (with particular, but not exclusive, reference to Annex B to the Privacy Code -“Technical Disciplinary Guidelines on minimum security measures”-) and by all other applicable legal provisions in order to prevent data loss, illegal or illicit use and/or unauthorised access to your data. Fondazione implements appropriate technical measures, such as multiple, advanced safety technologies and procedures, to protect your personal data: for example, storing the data on servers located in rooms with restricted access and subject to controls. You may help Fondazione to keep the data up to date by informing it of any change to your own address, professional qualifications, contact information, etc.



Access to personal data

Those allowed to process your data belong to the following categories: administrative services employees, IT staff and all those other employees who need to process them by reason of their professional duties.
Data may be communicated – even in countries outside the EU (“Third Countries”)- to companies of the Menarini Group for the same purposes as stated above and/or for administrative purposes, pursuant to art. 34.1-ter of the Privacy Code, art. 6.1.f and the 48th Recital of the Preamble of Regulation 2016/48//EU.

Moreover, Data may be communicated -also in Third Countries- to (i) institutions, authorities, public entities for purposes pertaining to their institutional objectives; (ii) professionals, independent collaborators (including those working in partnership); other individuals/entities to which the Data Controller outsources technical or commercial services required to run the Website and its functions (such as IT and Cloud Computing service providers), to pursue the above-mentioned purposes and to provide the services requested by users; (iii) third parties in case of mergers/acquisitions, audits and other extraordinary operations. Such individuals/entities will access only the personal data required to perform the relevant operations and will process them in accordance with the applicable Privacy Laws. Furthermore, data may be communicated to other recipients as permitted by the applicable laws and regulations. With the exception of the above, personal data are not shared with other Third Parties –whether legal or natural persons- which do not perform any commercial, professional or technical task on behalf of the Data Controller; in addition, data will not be disseminated. Data recipients will process data in the capacity of data controller, data processor or person in charge of the processing, as the case may be, for the above specified purposes and in accordance with the applicable Privacy Laws.


As far as the potential transfer towards Third Countries is concerned --including transfers to Third Countries which may not ensure the same level of protection afforded by the Privacy Laws- the Controller informs that processing will take place in accordance with one of the methods allowed by the law, such as, for example your consent, the adoption of Model Contract Clauses approved by the European Commission, the selection of transferees which subscribed to programs pertaining to the free movement of data (e.g. the EU-USA “Privacy Shield”) or which operate in countries considered as safe by the European Commission.


User’s rights
You may at any time exercise the rights afforded by art. 7 of the Privacy Code and by arts. 15 (and following) of Regulation 2016/679/EU, such as, by way of example, receive the updated list of those who may access your Data; receive confirmation any of your personal Data is being processed by the Controller; verify their content, origin, exactness, location (including, where applicable, the Third Countries where the data might be), ask that the data are supplemented, updated, deleted, anonymised, frozen (if processed against the law), or to oppose to their processing for direct contact activities (including by restricting contacts to some contact methodologies) and oppose to their processing for legitimate reasons. At any time, you may withdraw the consent you have previously conferred (without prejudice for the legitimacy of the processing activities performed before the consent’s withdrawal) and/or notify your concerns about particular personal situations which you consider as inappropriate or unjustified based on your relationship with the Company or to lodge a complaint with the Italian Data Protection Authority (“Autorità Garante per la Protezione dei Dati Personali”) or other competent Supervisory Authority.
For any requests concerning the processing of personal data by the Company, the rights afforded by the applicable law or the updated list of individuals/entities which have access to the data, you may contact the Data Controller at the addresses indicated above.


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Fondazione Internazionale Menarini
Fondazione Menarini, Centro Direzionale Milanofiori 20089 Rozzano (MI) - Edificio L - Strada 6
Tel. +39 02 55308110 Fax +39 02 55305739 C.F. 94265730484