Privacy policy

This Policy applies as between you, the User of this Web Site and Europa Donna Breast Cancer Coalition the owner and provider of this Web Site. This Policy applies to our use of any and all Data collected by us in relation to your use of the Web Site and any Services or Systems therein.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:
"Account": means collectively the personal information, Payment Information and credentials used by Users to access Material and / or any communications System on the Web Site;
"Content": means any text, graphics, images, audio, video, software, data compilations and any other form of information capable of being stored in a computer that appears on or forms part of this Web Site;
"Cookie": means a small text file placed on your computer by Europa Donna Breast Cancer Coalition Ltd when you visit certain parts of this Web Site. This allows us to identify recurring visitors and to analyse their browsing habits within the Web Site.
"Data": means collectively all information that you submit to the Web Site. This includes, but is not limited to, Account details and information submitted using any of our Services or Systems;
"Europa Donna Breast Cancer Coalition": means Europa Donna - The European Breast Cancer Coalition, Piazza Gian Lorenzo Bernini, 4, 20133 Milan - Italy;
"Service": means collectively any online facilities, tools, services or information that Europa Donna Breast Cancer Coalition makes available through the Web Site either now or in the future;
"System": means any online communications infrastructure that Europa Donna Breast Cancer Coalition makes available through the Web Site either now or in the future. This includes, but is not limited to, web-based email, message boards, live chat facilities and email links;
"User" / "Users": means any third party that accesses the Web Site and is not employed by Europa Donna Breast Cancer Coalition and acting in the course of their employment; and
"Website": means the website that you are currently using (empowered.europadonna.org) and any sub-domains of this site (e.g. subdomain.yourschool.com) unless expressly excluded by their own terms and conditions.

2. Data Collected

Without limitation, any of the following Data may be collected:
  • 2.1 name;
  • 2.2 date of birth;
  • 2.3 job title & profession;
  • 2.4 contact information such as email addresses and telephone numbers;
  • 2.5 demographic information such as post code, preferences and interests;
  • 2.6 financial information such as credit / debit card numbers;
  • 2.7 IP address (automatically collected);
  • 2.8 web browser type and version (automatically collected);
  • 2.9 operating system (automatically collected);
  • 2.10 a list of URLS starting with a referring site, your activity on this Web Site, and the site you exit to (automatically collected); and
  • 2.11 Cookie information (see Clause 10 below).

3. Our Use of Data

  • 3.1 Any personal Data you submit will be retained by Europa Donna Breast Cancer Coalition for as long as you use the Services and Systems provided on the Web Site. Data that you may submit through any communications System that we may provide may be retained for a longer period of up to one year.
  • 3.2 Unless we are obliged or permitted by law to do so, and subject to Clause 4, your Data will not be disclosed to third parties. This includes our affiliates and / or other companies within our group.
  • 3.3 All personal Data is stored securely in accordance with the principles of the EU General Data Protection Regulation (Regulation (EU) 2016/679 - GDPR). For more details on security, see Clause 9 below.
  • 3.4 Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Web Site. Specifically, Data may be used by us for the following reasons:
  • 3.4.1 internal record keeping;
  • 3.4.2 improvement of our products / services;
  • 3.4.3 transmission by email of promotional materials that may be of interest to you;
  • 3.4.4 contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Web Site.
  • 3.5 Data Processing on Behalf of Europa Donna Coalition
  • 3.5.1 Europa Donna Coalition has engaged Promeditec Innovation S.r.l. as a data processor pursuant to Article 28 of the EU General Data Protection Regulation (GDPR). Promeditec is responsible for the technical configuration, maintenance and management of the e-learning platform on behalf of Europa Donna Coalition.
  • 3.5.2 All data collected via this platform is processed by Promeditec only on documented instructions from Europa Donna Coalition and for the sole purpose of delivering the services requested by users. Promeditec does not determine the purposes or means of processing and does not use the data for its own purposes.
  • 3.6 Newsletter Service and Third-Party Data Processors
  • 3.6.1 Users who opt in to receive our newsletter provide their email address for this specific purpose. The legal basis for this processing is the user's explicit consent (Art. 6.1.a GDPR). Consent may be withdrawn at any time by clicking the unsubscribe link included in every newsletter, or by contacting us at info@europadonna.org.
  • 3.6.2 For the purpose of delivering newsletter communications, personal data (email address) is transferred to Campaign Monitor (Campaign Monitor Pty Ltd), an email marketing platform used by Europa Donna Coalition to create, send and monitor email campaigns. Campaign Monitor acts as a data processor on behalf of Europa Donna Coalition.
  • 3.6.3 Data is transmitted to Campaign Monitor via Zapier (Zapier Inc.), an automation tool that connects the platform's newsletter subscription form to Campaign Monitor. Zapier processes data solely for the purpose of this data transfer and acts as a sub-processor.
  • 3.6.4 Both Campaign Monitor and Zapier are companies based in the United States of America. The transfer of personal data to these services is governed by appropriate safeguards pursuant to Art. 46 GDPR, specifically Standard Contractual Clauses (SCCs) as approved by the European Commission.

4. Third Party Web Sites and Services

Europa Donna Breast Cancer Coalition may, from time to time, employ the services of third parties to support the operation and improvement of this Website and related services. This may include, but is not limited to, providers of technical infrastructure, analytics, communication tools, or marketing support.
Any personal Data shared with such parties will be limited to what is necessary for them to perform the services requested by Europa Donna Breast Cancer Coalition. The use of such Data for any other purpose is strictly prohibited.
All Data processed by these third parties must be handled in accordance with this Privacy Policy and in full compliance with the EU General Data Protection Regulation (Regulation (EU) 2016/679 – GDPR).

5. Changes of Business Ownership and Control

  • 5.1 Europa Donna Breast Cancer Coalition may, from time to time, expand or reduce its business and this may involve the sale of certain divisions or the transfer of control of certain divisions to other parties. Data provided by Users will, where it is relevant to any division so transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Data for the purposes for which it was supplied by you.
  • 5.2 In the event that any Data submitted by Users will be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your Data deleted or withheld from the new owner or controller.

6. Controlling Access to your Data

  • 6.1 Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:
  • 6.1.1 use of Data for direct marketing purposes; and
  • 6.1.2 sharing Data with third parties.

7. Your Right to Withhold Information

  • 7.1 You may access certain areas of the Web Site without providing any Data at all. However, to use all Services and Systems available on the Web Site you may be required to submit Account information or other Data.
  • 7.2 You may restrict your internet browser’s use of Cookies. For more information see Clause 10 below.

8. Accessing your own Data

  • 8.1 You may access your Account at any time to view or amend the Data. You may need to modify or update your Data if your circumstances change. Additional Data as to your marketing preferences may also be stored and you may change this at any time.
  • 8.2 You have the right to request a copy of your personal Data free of charge.

9. Security

Data security is of great importance to Europa Donna Breast Cancer Coalition and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected online.

10. Changes to this Policy

Europa Donna Breast Cancer Coalition reserves the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Web Site and you are deemed to have accepted the terms of the Policy on your first use of the Web Site following the alterations.

11. Contacting Us

If you have any questions regarding this Privacy Policy or wish to exercise your data protection rights, you may contact Europa Donna Coalition as the data controller at info@europadonna.org, or its designated processor Promeditec S.r.l. for technical matters at support@promeditec.com.