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Privacy Notice pursuant to Art. 13 of EU Regulation 2016/679 (GDPR)

Pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation, hereinafter "GDPR"), and in compliance with Legislative Decree 30 June 2003, no. 196, as amended by Legislative Decree 10 August 2018, no. 101, we inform you that the personal data provided will be processed in compliance with the confidentiality obligations provided for by the aforementioned legislation to which the project is bound.

1. Data Controller

The Data Controller is the project, located at Via Roma 123, 00100 Rome, email: privacy@saluteora.it.

2. Purpose of Processing

The personal data you provide is necessary for:

  • Provision of requested healthcare services
  • Management of bookings and appointments
  • Compliance with legal and fiscal obligations
  • Communications related to subscribed services
  • Improvement of services offered
  • With prior consent, sending newsletters and promotional communications

3. Legal Basis for Processing

The processing of your personal data is based on consent (Art. 6 par. 1 lett. a GDPR), performance of a contract (Art. 6 par. 1 lett. b GDPR) and compliance with legal obligations (Art. 6 par. 1 lett. c GDPR).

4. Categories of Data Processed

The data processed includes:

  • Personal details (name, surname, date of birth, tax identification number)
  • Contact information (address, email, phone)
  • Health data (medical history, diagnoses, treatments)
  • Administrative and fiscal data

5. Processing Methods and Retention

Processing will be carried out in automated and/or manual form, in compliance with the provisions of art. 32 of the GDPR regarding security. Data will be retained for the time necessary to provide the requested services and for legal compliance, and in any case not beyond 10 years from the termination of the relationship for service purposes, and not beyond 2 years from collection for marketing purposes, unless consent is withdrawn.

6. Data Subject Rights

At any time, you may exercise, pursuant to articles 15 to 22 of the GDPR, the right to:

  • Access to personal data
  • Rectification or erasure of the same
  • Restriction of processing
  • Data portability
  • Object to processing
  • Withdraw consent

To exercise these rights, you can contact the Data Controller at the email address: privacy@saluteora.it

Last updated: April 30, 2025

INFORMATION NOTICE ON THE PROCESSING OF PERSONAL DATA OF PATIENTS

PARTICIPATING IN THE PROJECT "Promotion of oral health for pregnant women in conditions of socio-economic vulnerability"

pursuant to Article 13, EU Regulation 2016/679 (GDPR)

Dear Madam,

You have agreed to participate in the project "Promotion of oral health for pregnant women in conditions of socio-economic vulnerability."

Therefore, as required by EU Regulation 679/2016 (hereinafter "GDPR"), this document explains which of your personal data will be collected, who will see it, how it will be managed, so that you have all the necessary information regarding the processing of your personal data. Please note that the processing of your personal data is essential for your participation in the project.

DATA CONTROLLER AND DATA PROTECTION OFFICER

a) The Data Controller is

the Istituto Nazionale per la promozione della salute delle popolazioni Migranti e per il contrasto delle malattie della Povertà ("INMP"), with headquarters in Rome (00153), Via di S. Gallicano n. 25/a, represented by the Director General and legal representative pro tempore, contactable at: segdirgen@inmp.it

b) The Data Protection Officer

is domiciled for the role at the same offices and can be contacted at: rpd@inmp.it

WHAT PERSONAL DATA WILL BE COLLECTED?

For the purposes indicated below, only essential personal identification data, data related to pregnancy, and information concerning your economic situation, such as the ISEE (Equivalent Economic Situation Indicator), will be processed to verify eligibility for the project.

FOR WHAT PURPOSE AND HOW WILL YOUR PERSONAL DATA BE USED?

For the purposes indicated below, essential identification data, pregnancy-related data, and economic information such as the ISEE will be processed to verify eligibility for the project. These data will initially be collected by Fondazione ANDI E.T.S. for healthcare purposes.

These data will be anonymized and aggregated, except for the data required for the justification of disbursed funds.

Legal basis

The data will be used by INMP for the following purposes:

  • a) Reporting: for this purpose, socio-economic and pregnancy-related data of pregnant women will be communicated by Fondazione ANDI E.T.S. to INMP in a personal form, in order to justify the financial expenditure incurred.
  • b) Statistical analysis.
  • c) Assessment of access to healthcare services by vulnerable populations.

Data processing for purposes b) and c) will be carried out in aggregated, non-identifiable form.

The legal basis for all purposes is Article 9, paragraph 2, letter i) of the GDPR, as well as Article 2-septies of Legislative Decree 196/2003, since processing is necessary for reasons of public interest in the area of public health. Processing will be carried out in compliance with the required technical and organizational measures.

DURATION OF DATA PROCESSING

INMP processes personal data in the ways, times, and limits strictly necessary to achieve the stated purposes, i.e., no later than the publication of the study in scientific journals.

However, data will be processed for a maximum of 10 years from the project's closure, in order to allow possible inspections or checks by the competent authorities.

ENTITIES TO WHOM THE DATA MAY BE COMMUNICATED OR TRANSMITTED

The data will be processed by INMP personnel authorized and involved in the project, subject to confidentiality obligations.

Your personal data will be securely stored and will be available exclusively to the persons indicated.

Please note that all persons authorized to process your personal data are bound by confidentiality obligations.

The data will not be subject to automated decision-making, including profiling.

DISCLOSURE OF PERSONAL DATA

Personal data will not be disseminated.

The results of the project may be shared publicly (conferences, scientific publications) in anonymous and aggregated form, not attributable to individual participants.

TRANSFER OF DATA OUTSIDE THE EUROPEAN UNION

Personal data will not be transferred outside the European Union.

DATA SUBJECT RIGHTS

At any time, the data subject may exercise the following rights:

  • Right of access: to obtain confirmation from the Data Controller as to whether personal data concerning them are being processed and, if so, to access their data -- and receive a copy -- along with related information; however, during the study, access to data may be restricted to protect the integrity of the study.
  • Right to rectification: to obtain without undue delay the correction of inaccurate personal data and the completion of incomplete data, also by providing a supplementary statement.
  • Right to erasure: to obtain the deletion of personal data without undue delay if one of the following applies: the data are no longer necessary for the purposes collected; the data subject objects to processing and there is no overriding legitimate ground to continue; the data have been processed unlawfully; or erasure is required to comply with a legal obligation.
  • Right to restriction of processing: to obtain restriction where one of the following applies: the accuracy of the data is contested (for the period necessary for verification); processing is unlawful and the data subject opposes erasure, requesting restriction instead; the data are no longer needed by the Controller but are required for legal claims; the data subject has objected pending verification of overriding legitimate grounds.
  • Right to data portability: to receive personal data provided to the Controller in a structured, commonly used, machine-readable format and to transmit such data to another Controller, where processing is based on consent or contract and carried out by automated means.
  • Right to object: to object to processing carried out in the public interest, in the exercise of official authority, or based on the Controller's or third party's legitimate interest, as well as to object to processing for direct marketing purposes, including profiling linked to such marketing.

HOW CAN I EXERCISE MY RIGHTS?

You may exercise your rights by sending an email to INMP (segdirgen@inmp.it) which will reply as soon as possible and, in any case, within 30 days of your request.

If you have questions about the collection and use of your information, you may also ask the study physician.

COMPLAINT

If you wish to lodge a complaint regarding the way your personal data are processed by the Controller or concerning the handling of a complaint, you have the right to submit a complaint directly to the Data Protection Authority, according to the procedures indicated on the website www.garanteprivacy.it.