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Privacy Policy

The Think Tank ECCO Associaizone (ECCO) considers confidentiality and the protection of private information a priority.

On 25 May 2018, the new European Regulation No. 679/2016 (commonly known as the “GDPR”) came into effect regarding the protection of personal data. In order to ensure compliance with the GDPR and operate transparently, we invite you to review the general notice on how your personal data will be processed by clicking here.

ECCO processes data solely for the purpose of pursuing and fulfilling its statutory objectives and activities, namely producing scientific studies and analyses, providing recommendations to public decision-makers, and engaging with its stakeholders to highlight best practices through public initiatives.

Below, you will find all the details regarding the processing of your personal data.

We are available to answer any of your questions.

You can find all the ways to contact us at this link: info@eccoclimate.org

Last updated: 8 March 2021

PRIVACY NOTICE

This privacy notice allows you to understand, even before accessing the various sections of the website, how ECCO will process your personal data, whether provided directly by you (such as name, surname, email address, etc.) or collected in other ways by ECCO as described in the section “What Personal Data we process and how we collect it” (hereinafter collectively referred to as “Personal Data”).

You must review this notice before providing your Personal Data.

Identity and contact details of the data controller

The Data Controller is the Think Tank ECCO Association (hereinafter referred to as “ECCO” or the “Controller”), headquartered at Via Cola Montano 8 – 20100 Milan / Operational Office: C/O WWF Italy, Via Tommaso da Cazzaniga, 20121 Milan, Tax Code: 97883510154 – email: info@eccoclimate.org – www.eccoclimate.org

ECCO will process your Personal Data in compliance with EU Regulation No. 2016/679 and the national legislation on personal data protection (hereinafter referred to as the “Privacy Law”).

What Personal Data we process and how we collect it

Your browsing of the Website may involve the collection and subsequent processing of your Personal Data by ECCO. Indeed, when connecting to the Website, the IT systems and software procedures used for its operation automatically and indirectly provide and/or acquire certain information (such as, for example, “cookies,” as specified in the “Privacy Notice – Cookies” at the end of this notice, IP addresses, domain names of the computers used by users connecting to the Website, URL addresses of requested resources, server request times, etc.).

Any requests for information or services from you may also involve the collection and subsequent processing of your Personal Data (such as name, surname, email address, etc.).

In particular, the collection of your Personal Data may occur:

– Through your completion of online forms; and

– Through the publication of Contributions (as defined below), which may include your Personal Data directly provided by you on social networks independently managed by third parties, such as, for example, Twitter and LinkedIn (hereinafter referred to as “Social Networks”).

“Contributions” refers to images, comments, slogans associated with the Website’s content, and any other information conceived and published by you on ECCO’s Social Network pages, including any profile picture you provide.

If you choose to subscribe to the newsletter service or send a request via the “Contact Us” section of the Website, providing some Personal Data is necessary for ECCO to meet your needs. The relevant fields of the registration form are marked with an asterisk or otherwise indicated as mandatory.

Providing Personal Data that is not marked with an asterisk or otherwise designated as mandatory is entirely optional, and failure to provide, partial provision, or inaccurate provision of such Personal Data has no consequences. However, failure to provide, partial provision, or inaccurate provision of Personal Data marked with an asterisk or otherwise designated as mandatory will prevent the requested service from being performed. If you omit one or more mandatory Personal Data fields, an error message will appear from ECCO listing the missing required Personal Data.

Purpose and legal basis for processing your Personal Data

Depending on the needs expressed by you while accessing various sections of the Website (unless specific Personal Data is required for individual initiatives, for which specific notices will be published on the Website from time to time), the purposes for processing your Personal Data and the respective legal bases are indicated below.

Your Personal Data will be processed for the following purposes exclusively with your consent, which may be withdrawn at any time by submitting a request to the Controller through the “Contact” section of the Website or, in the case of newsletters, using the unsubscribe link at the bottom of each email newsletter.

a) Managing and responding to your requests

You may choose to consent to the processing of your Personal Data for ECCO’s management and response to your requests regarding ECCO’s services, initiatives, or the Website (“Contact Us” section). Your consent is required when submitting a request. If you choose not to consent to the processing of your Personal Data for this purpose, your request cannot be processed.

b) Receiving the newsletter

You may choose to subscribe to ECCO’s newsletter service by providing the necessary consent. Your consent is required at the time of newsletter subscription.

Additionally, even without your consent, ECCO may process your Personal Data for the following purposes:

  1. Managing activities related to your use of the Website, including your publication of Contributions on ECCO’s Social Network pages (as this processing is necessary for the performance of a contract or pre-contractual measures);
  2. Managing and fulfilling legal obligations (e.g., accounting, administrative, tax-related obligations);
  3. Managing disputes and potential litigation (as this constitutes a legitimate interest of the Controller).

How we process your Personal Data

Your Personal Data will be processed primarily in an automated manner, but also in paper format, with logic strictly related to the stated purposes, through ECCO’s databases, electronic platforms managed by ECCO or third-party external data processors, and ECCO’s IT systems and those of third parties.

The Controller has assessed the security level as adequate, considering risks arising from loss, destruction, modification, unauthorised disclosure, accidental or illegal access, misuse, or alteration of your Personal Data. Specifically:

  • Appropriate security measures have been adopted to mitigate risks;
  • Your Personal Data is stored on servers located in the European territory, subject to advanced and daily backup systems.

Where we process your Personal Data

Your Personal Data is primarily processed at the offices of the Data Controller and in locations where the Data Processors operate. For further information, please contact the Data Controller using the details provided in the “Identity and Contact Details of the Data Controller” section.

How long we retain your Personal Data

To ensure compliance with the principles of necessity and proportionality in processing, the Data Controller has defined different retention periods for Personal Data based on the specific purposes pursued:

(i) For handling and responding to your requests related to ECCO, ECCO initiatives, or the Website (as per the “Contacts” section of the Website), your Personal Data will be retained for the time strictly necessary to process your request.

(ii) For sending newsletters, your Personal Data, excluding contact details, will be retained for a maximum period of five years.

(iii) For managing activities related to your use of the Website, including your publication of Contributions on ECCO’s Social Network pages, your Personal Data will be retained for the time strictly necessary to provide the requested service.

(iv) For managing and fulfilling legal obligations (accounting, administrative, tax-related, etc.), your Personal Data will be retained for the time strictly necessary for such purposes.

(v) For handling disputes and potential legal proceedings, your Personal Data will be retained for the time strictly necessary for such purposes and, in any case, no longer than the applicable statutory limitation periods.

Who receives your Personal Data

Your Personal Data may be disclosed to and processed by:

(i) Legal entities or individuals acting as external data processors, carrying out outsourced activities on behalf of ECCO or ECCO’s external data processors (including service providers for assistance, communication, promotion of initiatives, advertising agencies, IT service providers, website managers, electronic platform operators, partners, and professional firms).

(ii) Employees and/or collaborators of the Data Controller (including system administrators) who, under the direct authority of the Data Controller, are authorised to process your Personal Data.

(iii) Employees and/or collaborators of external data processors (including system administrators) who, under the direct authority of the external data processors, are authorised to process your Personal Data.

Your Personal Data will not be disclosed to third parties except where it is necessary for ECCO to share it with consultants to protect its rights. It will not be publicly disseminated.

Minors

Minors under the age of 16 must not provide information or Personal Data to ECCO without the consent of those holding parental responsibility over them. Without such consent, minors will not be able to submit requests through the Website or subscribe to the newsletter service.

ECCO encourages those with parental responsibility to inform minors about the safe and responsible use of the Internet and the Web and to follow the procedures outlined during the request submission and newsletter subscription process for individuals under 16.

Identity and contact details of data processors

The complete list of Personal Data Processors is available upon request by contacting the Data Controller using the details provided in the “Identity and Contact Details of the Data Controller” section.

Your rights regarding the processing of your Personal Data

Privacy regulations grant you, as the data subject, several rights. In particular, you have the right to:

  1. Obtain confirmation from the Data Controller as to whether or not your Personal Data exists, even if not yet recorded, and receive it in an intelligible form, as well as access your Personal Data (obtaining a copy) and related information (including the purposes of processing, categories and source of the Personal Data, categories of recipients to whom it has been or may be disclosed, retention period (where possible), and your rights).
  2. Obtain the rectification of your inaccurate Personal Data and the completion of any incomplete Personal Data.
  3. Request the deletion of your Personal Data without undue delay, including when it is no longer necessary for the purposes for which it was collected or when there is no longer a legal basis for processing it.
  4. Request the anonymisation or blocking of your unlawfully processed Personal Data, including data that does not need to be retained in relation to the purposes for which it was collected or subsequently processed.
  5. Request the restriction of the processing of your Personal Data, including when you contest its accuracy or object to its processing, for the period necessary to carry out relevant verifications.
  6. Receive your Personal Data in a structured, commonly used, and machine-readable format, and transmit it or, where technically feasible, request its direct transfer to another Data Controller, in cases where processing is carried out by automated means and based on your consent or a contract to which you are a party.
  7. Withdraw consent for the processing of your Personal Data for any of the purposes for which consent was given.

You can exercise your rights by accessing the “Contacts” section of the Website or by sending a letter to ECCO at the address indicated in the “Identity and Contact Details of the Data Controller” section.

Additionally, if you believe that the processing of your Personal Data violates privacy regulations, you can lodge a complaint with the Data Protection Authority in the country where you reside, work, or where the alleged violation occurred. You may also contact the Authority for information on how to exercise your rights under privacy regulations.

The right to object to the processing of your Personal Data

At any time, and for reasons related to your specific situation, you have the right to object to the processing of your Personal Data where it is necessary for pursuing a legitimate interest of the Data Controller or third parties. In such cases, the Data Controller will cease processing your Personal Data unless there are compelling legitimate grounds that override your interests, rights, and freedoms, or if the processing is necessary for the establishment, exercise, or defence of legal claims.

Without prejudice to your right to withdraw consent for newsletter subscription purposes, you also have the right to object to the processing of your Personal Data by accessing the “Contacts” section of the Website.

If you object to the processing of your Personal Data for this purpose, the Data Controller will no longer be able to carry out such processing.

 

PRIVACY NOTICE – COOKIES

Cookies are text strings that function as IT markers sent by a server (in this case, the Site’s server) to a user’s device (typically their Internet browser) when they access a specific webpage of a website. Cookies, which may also be set by websites other than the one the user is visiting (“third-party cookies”), are automatically stored by the user’s browser and retransmitted to the server that generated them each time the user accesses the same Internet page. For example, cookies allow and/or facilitate access to certain Internet pages to improve user navigation (i.e., enabling the storage of visited pages and other specific information, such as frequently visited pages, connection errors, etc.), or enable profiling activities. Therefore, to ensure an easier and more complete use of a website, users should configure their browser to accept these cookies.

Browsers are often set to accept cookies automatically. However, users can modify their default settings to disable or delete cookies (either on a case-by-case basis or permanently), though this may result in suboptimal use of some website areas. It is also possible to verify the methods and types of cookies stored on one’s browser by modifying the cookie settings within the browser.

Characteristics and purposes of cookies

Our Site uses the following categories of cookies, which may belong to BCFN or third parties.

  1. Technical and functional cookies:
  2. a) Technical cookies or “technical cookies”:

These facilitate your navigation on the Site and the use of its features. Among technical cookies, we highlight essential cookies, also known as “strictly necessary” cookies, which enable functions without which the Site cannot be fully utilized, as well as performance cookies, which help improve the Site’s functionalities.

  1. b) Functional cookies or “functionality cookies”:

These allow the Site to remember the choices you make (such as the language or geographical area you are in) and offer them upon subsequent access to provide better and more personalized services (e.g., they can be used to suggest content similar to what you have previously requested).

  1. Profiling Cookies: These are used to send advertisements and services aligned with your expressed preferences.

Specifically, they are used to offer you advertisements and services potentially matching your interests and to create individual profiles based on your tastes, preferences, and consumption choices as observed while browsing the Site or through the comparison of activities performed via your browser. For example, they are used to limit the number of times a specific advertisement is displayed or to deduce the effectiveness of a campaign from the frequency with which the advertisement is viewed.

Description of consent methods for cookie installation

Upon first accessing the Site, you will see a banner with a brief notice containing a link to this extended notice where you can find more information about the cookies installed by the Data Controller and third parties.

In this extended notice, you will find more details about the description and characteristics of different categories of cookies and will have the option to independently decide which cookies to authorize.

Your consent is not required for the use of technical and analytical cookies. However, you can disable them by following the procedure described in the section “how to enable or disable cookies on your browser.”

For the use of profiling cookies, which help send advertisements and services aligned with your tastes, preferences, and consumption choices, your consent is required.

By browsing the Site, you consent to the use of cookies, including profiling cookies. In any case, you can modify your cookie preferences at any time, including denying consent to any cookies (including those installed by third parties) using the table below.

The following table describes the cookies sent to your browser when accessing the Site. The table was last updated on 24 May 2018; any updates will always be published on this page.

Third-party technical cookies:

  • Gigya technical cookies, with storage extended until manually deleted.

Analytical Cookies:

  • Google Analytics

Profiling cookies (marketing):

  • DoubleClick Cookies
  • Google Cookies

Below are links to the privacy policies and consent modules of third parties, independent data controllers, through which you can obtain more information, manage, and disable these cookies.

How to Enable or Disable Cookies on Your Browser:

You can block cookie acceptance via your web browser. However, this may make some Site functions less efficient or prevent access to certain features or pages.

Below are the methods provided by major browsers to block cookie acceptance:

Additional methods to disable analytical and profiling cookies:

In addition to disabling and/or deleting cookies through your browser settings, you can disable and/or delete individual analytical and profiling cookies by accessing the following sites:

  • Google Analytics: Google Analytics cookies, which are part of a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, which are text files stored on the user’s computer to help analyse how users interact with the Site/App. The information generated by the cookies regarding the user’s use of the Site/App will be transmitted to and stored on a Google server. Google will use this information to analyse the user’s interaction with the Site/App, compile reports on Site/App activities, and provide additional services to the operator of the Site/App relating to Site/App and Internet usage. Google will not associate the IP address transmitted by the user’s browser within Google Analytics with any other data held by Google. Users can prevent cookies from being stored by adjusting their browser software settings; however, this may result in a less personalised experience based on their preferences. Users can obtain information about how Google Analytics processes their personal data at the following link: https://support.google.com/analytics/answer/6004245. Additionally, they can prevent Google from collecting data generated by cookies and related to their use of the Site/App (including their IP address) as well as the processing of such data by Google by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en. By using the Site/App, users consent to the processing of their data by Google in the manner and for the purposes set out in Google’s privacy policy related to Google Analytics, available at the following link: https://www.google.com/intl/en/policies/privacy/partners/. To disable these cookies, visit: https://tools.google.com/dlpage/gaoptout?hl=en
  • DoubleClick: Visit https://adssettings.google.com/authenticated to remove cookies provided by the DoubleClick platform.
  • www.youronlinechoices.eu: Managed by the European Interactive Digital Advertising Alliance (EDAA), this website allows EU users to manage and remove cookies from various providers.

More information on cookies is available at www.allaboutcookies.org