PRIVACY POLICY OF PROJECT OPTIMA-PROJECT
This privacy notice provides information to individuals whose data are collected through the website
http://www.optima-project.eu/ controlled and/or operated by CNC, and those individuals whom CNC
encounters in conducting its activities, such as participants to CNC events, representatives of CNC members
and public institutions and authorities, specialists in the fields of European and public affairs, transport and
railways, UNIFE contacts and other people with whom UNIFE has a relationship (hereinafter each referred
to as an “Individual”), regarding how their personal information is collected and processed by CNC or
within its affiliated entities, in compliance with the applicable data protection laws, in particular the
European Regulation 2016/679 of 27 April 2016 called the General Data Protection Regulation (hereinafter
“GDPR”).
This privacy notice explains why and how personal information about Individuals (hereinafter “Personal
Data”) is collected, what Personal Data is processed, who has access to Personal Data, how Personal Data is
protected, how long Personal Data is retained, the rights of the Individuals and who to contact for further
information. This notice is without prejudice to specific provisions set out in other related documents or any
contract entered into between CNC and the Individual concerned or his/her organisation.
- Why CNC processes PERSONAL DATA?
CNC(CENTRO NUOVA COMUNICAZIONE SRL), whose registered offices are located at VIA
ALESSANDRINI 17, 40126 BOLOGNA, ITALY, VAT number 01752891208, keeps and processes
Personal Data, whether or not in electronic form, for administrative, marketing and customer/supplier
management purposes, especially in light of the following non-exhaustive activities:
responding to any communication, inquiry or request which an Individual submits to CNC;
managing relationships and maintaining contact with the Individuals;
introducing the Individuals to other Individuals during projects of CNC events;
negotiating and executing agreements;
processing information relating to a proposed or actual purchase or sale of products or services by CNC,
including sending statements and invoices;
improving CNC’s products and/or services;
providing the Individuals with newsletters and marketing communications and/or any other information
relating to the activities of CNC, and/or conducting surveys and market research;
legal and/or regulatory compliance, including dispute resolution. - What are the legal grounds for processing the PERSONAL data?
These data are processed on one or more of the following legal grounds:
The consent of the Individual concerned (e.g. for responding to a survey);
In view of the entering into and the performance of a sales contract or another contract with the Individual
or his/her organisation, including the invoicing process;
To comply with legal obligations applicable to CNC (e.g. regarding tax matters, etc.);
In the framework of the legitimate interests of CNC and/or a third party, but which CNC believes also
benefit the Individuals, such as, but not limited to, direct marketing and data analytics. - Which categories of personal data are processed?
Cookie policy
- GENERAL
1.1 This cookie policy (“Cookie Policy”) governs the use of cookies and similar technologies as part
of your use of our website (https://www.optima-project.eu/ (the “Website”)). This processing is
undertaken by UNIFE as responsible party, with registered office at Avenue Louise 221, 1050
Brussels, BELGIUM (“Company”, “we”, “us”, “our”), registered under the number BE0453405417
in compliance with applicable data protection legislation.
1.2 Cookies are small text files that are stored on a device’s hard drive and contain certain
information and sometimes personal data. When you use our website, we also collect and process
other personal information other than through cookies and similar technologies. If you want to
know more, please read our Privacy Policy (https://www.optima-project.eu/privacypolicy.pdf).
1.3 By continuing to use our website or by clicking “Agree” after you have been notified of the use
of cookies and similar technologies, you acknowledge that you have read this Cookie Policy
carefully and that you agree to it without reservations. As set out in this Cookie Policy, you can
change your cookie preferences at any time.
1.4 We reserve the right to change, supplement or replace this Cookie Policy from time to time. Such
changes, additions or substitutions will be brought to your attention via our website. If you do
not agree with these changes, additions or substitutions, we ask you to send an e-mail to
dpo@unife.org. If we do not receive notice from you within three (3) working days after the
changes, additions or substitutions have been notified via our website, you will be deemed to
have accepted all changes, additions, or substitutions. - WHAT TYPES OF COOKIES ARE THERE?
2.1 There are different types of cookies. Some are necessary to enable the proper functioning of a
website, others serve to improve and/or simplify its use:
2.1.1 Strictly necessary cookies;
2.1.2 Functional cookies;
2.1.3 Authentication cookies;
2.1.4 Performance cookies;
2.1.5 Targeting/Third-party cookies;
2.2 Strictly necessary cookies are necessary for the functioning of the websites of UNIFE. These
cookies do not collect any information about the user that can be used for marketing purposes
and are essential to enable use the websites of UNIFE. Such cookies are exempt from the
requirement for consent, in accordance with article 129 of the law of 13 June 2005 on electronic
communications.
2.3 Functionality cookies make it possible to memorise the user’s connection data, secure the user’s
connection to the websites of UNIFE and provide live assistance. These cookies do not collect
any information about the user that can be used for marketing purposes. These cookies are also
exempt from the consent requirement.
2.4 Authentication cookies enable users to identify themselves and access secure content. These
cookies do not collect any information about the user that can be used for marketing purposes.
These cookies are also exempt from the consent requirement.
2.5 Performance cookies enable UNIFE to collect information about how users browse the websites
of UNIFE, and to adapt and improve its websites if necessary. UNIFE is not able to identify the
users using this type of cookie, and all the data collected by these cookies is processed
anonymously. These cookies do not collect any information about the user that can be used for
marketing purposes. These cookies are placed and used with the user’s consent.
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2.6 Targeting/Third-party cookies. UNIFE sometimes conducts advertising campaigns, often using
third parties who can sometimes place cookies (or similar technologies) to assess with the
success of the campaign or to display a targeted advert t tailored to a user’s interests or to limit
the number of views per user. For example, links to the social networks or to videos on YouTube
-who are third parties- can, if appropriate, place cookies on the websites of UNIFE. These cookies
are placed and used with the user’s consent.
2.7 If a user refuses the use of this type of cookie, only those pages and services that do not need
these cookies can be displayed, viewed and used. The parts of the website of UNIFE that allow
the inclusion of third-party content – and therefore of third-party cookies – will no longer be
accessible and a message will inform users of this.
2.8 A distinction must also be made between:
2.8.1 Session cookies; and
2.8.2 Permanent cookies.
2.9 Session cookies are automatically deleted from the computer’s hard disk or the memory of a
user’s browser when they disconnect and/or close the browser.
2.10 Permanent cookies are stored on the computer’s hard disk or the memory of a user’s browser
for a limited time (minutes, days or years) after the disconnection or the closure of the browser. - WHAT & WHY WE PROCESS
3.1 The table below shows in detail the cookies used on the website of UNIFE and the cookies used
by third parties.
3.2 When visiting and using our website, we place cookies or use similar technologies through which
we collect and process personal data pertaining to you. Such cookies and similar technologies
include:
NAME TYPE ORIGIN DURATION LIFESPAN
ASP.NET_Session
Id
Authentication First party Session 1 hour
Google Analitycs Necessary Third party Permanent 1 day / 30 days
Site Cookie
(Consensus
request)
Functional First party Permanent 30 days
3.3 You can prevent cookies from being placed, or delete already placed cookies, by adjusting your
settings in your browser. Help with adjusting these settings can be found on the website of the
browser you use. Keep in mind that not allowing cookies when visiting the website may lead to
some or all of the website functions not working properly. - TO WHOM WE SEND
4.1 We will share your personal data only with the following categories of recipients: CENTRO
NUOVA COMUNICAZIONE SRL. We may rely on third party processors to provide you the website.
We will ensure that third party processors are only allowed to process your personal data on
behalf of us upon written instruction of us. We warrant that all third-party processors are selected
with due care and are trained to be aware of the safety and integrity of your personal data.
4.2 We may send anonymized and/or aggregated data to other organizations that may use those
data for improving products and services as well as tailor the marketing, displaying and selling
of those goods and services.
3 - WHERE WE PROCESS
5.1 We and our third-party processors will only process your identifiable personal data in the EEA.
We may transfer your anonymized and/or aggregated data to organizations outside of the EEA.
Should such transfer take place, we will ensure that there are appropriate safeguards in place to
ensure the safety and integrity of your personal data as well as all rights with respect to personal
data you might enjoy under applicable mandatory law. - HOW WE PROCESS
6.1 We will do our utmost best to process only those personal data which are necessary to achieve
the purposes listed in this Privacy Policy. We will process your personal data in a lawful, fair and
transparent manner. We will do our utmost best to keep the personal data accurate and up to
date.
6.2 Your personal data are only processed for as long as needed to achieve the purposes listed in
this Privacy Policy or up until such time where you withdraw your consent for processing them.
Note that withdrawal of consent may imply that you can no longer you the whole or part of the
website. If you have registered with our website, we will delete your personal data if you delete
your profile, unless a legal or regulatory obligation or a judicial or administrative order prevents
us to do so
6.3 We will take the appropriate technical and organizational measures to keep your personal data
safe from unauthorized access or theft as well as accidental loss, tampering or destruction.
Access by our personnel or personnel of our third-party processors will only be on a need-toknow basis and subject to strict confidentiality obligations. You understand, however, that safety
and security are best efforts obligations only which can never be guaranteed. - YOUR RIGHTS
7.1 You have the right to request access to all personal data processed by us pertaining to you.
Subsequent requests for access addressed to us that are manifestly submitted for causing
nuisance or harm to us, will not be dealt with.
7.2 You have the right to ask that any personal data pertaining to you that are inaccurate, are
corrected free of charge. If you have registered with our website, you can correct a lot of these
data yourself via your profile. If a request for correction is submitted, such request shall be
accompanied of proof of the flawed nature of the data for which correction is asked.
7.3 You have the right to withdraw the permission you have given us, but this withdrawal will not
affect the data that we have already collected through cookies or similar technologies based on
your prior consent. If you no longer want us to collect data via cookies or similar technologies,
you can change your browser settings at any time or delete your cookies.
7.4 If the intended processing is qualified as direct marketing, you have the right to oppose such
processing free of charge and without justification.
7.5 You have the right to request that personal data pertaining to you be deleted if they are no
longer required in light of the purposes outlined in this Privacy Policy or if you withdraw your
consent for processing them. However, you need to keep in mind that a request for deletion will
be evaluated by us against legal or regulatory obligations or administrative or judicial orders
which may contradict such deletion.
7.6 Instead of deletion you can also ask that we limit the processing of your personal data if and
when (a) you contest the accuracy of that data, (b) the processing is illegitimate or (c) the data
are no longer needed for the purposes listed but you need them to defend yourself in judicial
proceedings.
7.7 If you wish to submit a request to exercise one or more of the rights listed above, you can send
an e-mail to dpo@unife.org. Such request should clearly state which right you wish to exercise
and the reasons for it if such is required. It should also be dated, signed and accompanied by a
digitally scanned copy of your valid identity card proving your identity.
7.8 We will promptly inform you of having received this request. If the request proves valid, we shall
honour it as soon as reasonably possible and at the latest thirty (30) days after having received
the request.
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7.9 If you have any complaint regarding the processing of your personal data by us, you may always
contact us via the e-mail address dpo@unife.org. If you remain unsatisfied with our response,
you are free to file a complaint with the competent data protection authority (list of DPA per
country: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080).
7.10 Where your personal data is processed based on consent or on a contract and the processing is
carried out by automated means, you will have the right to receive the personal data concerning
yourself, which you provided to us, in a structured, commonly used and machine-readable format
and, where technically feasible, you will have the right to directly transmit those data to another
service provider.