Privacy statement
Version 1.1, 18 February 2005
1. Premise
CIRSFID recognizes that people have a fundamental right to the privacy of their personal data, but it also recognizes that processing such data is a prerequisite for protecting certain further basic rights, too. Hence this disclosure, which explains how your data will be acquired, updated, used, and deleted in your interaction with CIRSFID through the Web sites irnerio.cirsfid.unibo.it. We are making this disclosure pursuant to Italian as well European law and guidelines: pursuant to Article 13 of Legislative Decree No. 196/2003 (on the protection of personal data) and to Recommendation No. 2/2001, on certain minimum requirements for collecting personal data online in the European Union, a recommendation drafted by Working Party 43, established by Article 29 of Directive 95/46/EC.
2. Purpose of Data Collection and Processing
CIRSFID collects your personal data in order to keep you informed, through the Internet, on the activities it carries out and the services it provides in pursuit of its institutional aims.
The data collected for the Irnerius Project service is functional to the service agreement you sign with CIRSFID: it is functional to the pre-contractual activities leading up to the agreement, as well as to the activities through which the agreement is concluded and performed. Performance includes CIRSFID having to identify and authenticate the users entitled to the service, managing the payments charged for the service, and meeting the administrative and bookkeeping obligations incurred under the agreement.
Your personal user data will be processed for these purposes only, and hence will not-without your express consent-be used to do any direct marketing or marketing research or to send you commercial literature and messages.
3. Data Disclosed to CIRSFID
By filling out and sending to CIRSFID the subscription form available on the Irnerius Project Web site, you disclose to CIRSFID personal data and contact information (including an e-mail address) that is subject to the exemption set forth under Article 13, paragraph 2, second parenthetical statement, of Legislative Decree No. 196/2003.
4. Sensitive Data Disclosed without Your Express Consent
Should the personal data you disclose to CIRSFID contain any sensitive or judicial data not accompanied with any specific statement by which you authorize its processing, this data will be deleted or destroyed by CIRSFID.
5. How Your Personal Data Will Be Processed
5.1. The Tools and Supports Used to Process Your Data
Your data will be acquired on paper as well as on digital support, and CIRSFID will process it in compliance with the security measures required by law, using to this end hardware and software tools owned exclusively by, or fully available to, CIRSFID. Some of your data will be processed on a designated server owned exclusively by CIRSFID.
The Irnerius Project Web site has a subscription form that you must fill out to request the service and enable CIRSFID to conclude a service agreement with you as well as to identify you and communicate with you throughout the duration of the service.
5.2. Data Processing Actions and Applets
Processing may consist in any or all of the following: collecting, recording, storing, organizing, selecting, retrieving, modifying, extracting, comparing, interconnecting, blocking, sending, deleting, or destroying data, even data not stored in any database.
The Irnerius Project online service automatically downloads and permanently installs certain applications and applets onto your hard drive, and may automatically update them, too: these applications and applets are designed to interact with your Web browser, and their only purpose is to enable the service described in the agreement you sign with CIRSFID, and specifically to enable you to view the high-resolution images for which you receive a user's licence.
Access to the personal data collected or acquired by CIRSFID in providing any online service hosted on the Web sites irnerio.cirsfid.unibo.it, www.cirfid.unibo.it, irnerio.cirsfid.unibo.it, will be granted to those within CIRSFID who are tasked with running the service or with meeting the obligations incurred under the service agreement or under the law, in which respect access may also be granted to (a) the University of Bologna (or Alma Mater Studiorum) and (b) the banking institutions used to remit payment for the service.
5.3. Data Collected While Surfing
Visiting the Web site hosted by CIRSFID may mean that the site is automatically collecting and processing your navigation data: this data collection and processing serves only the purpose of enabling you to consult the site and making sure that your computer and software are properly set up for the service.
The data collected and processed while surfing may include any of the following: your IP (or Internet protocol) number, the Web pages you access, the Web browser you are using to access them, the last URL (uniform resource locator) address you visited before visiting the Web site hosted by CIRSFID, the number code representing the Web server's response to your request for content, and other information identifying your computer and operating system.
If you access the high-resolution images available on the Irnerius Project Web site, this information too will be collected by the Web server, which will use it to calculate the points in your account and update your balance. The Web server also collects the username and password necessary to authenticate you as a registered user and will update this data should any changes intervene.
Any statistical data that is collected will be processed as aggregate data and will be anonymous.
Finally, your navigation data may be used, should the circumstance arise, to investigate any computer crimes perpetrated against the Web site hosting the Irnerius Project service.
5.4. Persistent Cookies and Session Cookies
The Irnerius Project Web site makes no use of persistent cookies (cookies that stay on your hard drive even after you have closed your browser), but it may use session cookies, which are stored in temporary memory and get erased when you close your browser. Session cookies ensure faster and more secure surfing and contain only a random session-identification number that does not identify you personally.
5.5. Electronic Mail
When you e-mail a message to one of the addresses posted on the CIRSFID Web site, the Web server hosting the site will automatically save and store your e-mail address along with any personal data your message may carry or contain. The e-mail address so acquired is the address that CIRSFID will use to reply to your message.
5.6. Members' Area
The Irnerius Project Web site contains a Members' Area that you can enter by keying in your username and password: this restricted area enables you to access the service for which you have signed an agreement with CIRSFID, and it enables CIRSFID to process your data and authenticate you as a registered user, as well as to deliver the service and maintain the Web site and computer system that runs it.
When you enter the Members' Area, the system will collect and process data about how you logged in, how long your login session lasts, and what content you request. This information is used for the sole purpose of running the service and making it secure.
6. Access to Your Personal Data
You cannot use the Irnerius Project service unless you provide the information requested in the Subscription Form and enable access to the login and session data relating to your stay within the Member's Area of the Web site, and CIRSFID is under no obligation to deliver the service if you do not make this information available to it. No additional information is required for access to the service.
7. Your Rights as a User
Under Article 7 of Legislative Decree No. 196/2003, you have the right to know what source your personal data is being obtained from and how it will get processed and for what purpose, and you have the right to obtain information identifying those who will process your data or may have access to it in carrying out specific functions. You also have the right to have your personal data updated, corrected, completed, or deleted, or to make it unavailable when it is being used for illegitimate purposes or for purposes beyond the scope of those that have been stated. And if anyone is processing your data, you may request and obtain a full or partial restriction on that activity regardless of the purpose for that activity or its method, and hence not only when your data is being used for direct marketing, but also when it's being used legitimately.
8. Who Is Processing Your Data
The entity entitled to process your data and responsible for it is CIRSFID, a University of Bologna research centre with registered offices on Via Galliera 3, Bologna (Italy), post code 40121. You can contact CIRSFID by phone (39-051-277-211), fax (39-051-260-782), or e-mail (irnerio.cirsfid@unibo.it), or you can log onto irnerio.cirsfid.unibo.it. It is your right-under Article 7 of Legislative Decree No. 196/2003-to contact CIRSFID in relation to any matter concerning its use of your personal data.