OUR POLICY

By using this Website, you agree to the Polo Center of Sustainability’s Website Privacy Policy (WPP) set out below. The WPP applies only to our handling of your personal information via the Polo Center of Sustainability’s website.

YOUR PERSONAL INFORMATION

The Polo Center of Sustainability recognizes the importance of protecting the privacy of personal information collected about visitors to this website. Personal information held by the Polo Center of Sustainability may include: (1) your name, date of birth, and current and previous addresses; (2) telephone number, mobile telephone number, email address, occupation, health status, and other details provided by you. You can choose not to supply us with any part of this information although this may limit the level of service we can provide.

HOW YOUR PERSONAL INFORMATION IS USED AND SECURITY OF YOUR PERSONAL INFORMATION

The Polo Center of Sustainability will only use your personal information submitted on the website for the purpose for which it was submitted. This may include: (1) to verify your identity; (2) to contact you regarding your participation or collaboration with research either as a client or on behalf of our clients; (3) to contact you about working at or with the Polo Center of Sustainability; (4) to contact you in response to any inquiry you make; and (4) to send you information regarding any of the above. The Polo Center of Sustainability strives to ensure the security, integrity and privacy of personal information submitted to this website, and periodically reviews and updates its security measures attributable to the haste transition of existing and emerging technologies. It should be noted, no data transmission over the Internet can be guaranteed to be completely secure. Although the Polo Center of Sustainability strives to protect your personal information, it cannot ensure or warrant the security of any information you may transmit to the Polo Center of Sustainability. Once the Polo Center of Sustainability receives your transmission, however, it makes every effort to ensure its security on the Polo Center of Sustainability’s systems.

COLLECTION OF PERSONAL INFORMATION AND WEB COOKIES

When visiting the Polo Center of Sustainability’s website, the website server makes a record of the visit and logs the following information for statistical and administrative purposes: (1) the user’s server address; (2) the date and time of the visit to the website (3); and duration of the visit. A cookie is a piece of information that an Internet web site sends to your browser when you access information at that site. Cookies are either stored in memory (session cookies) or placed on your hard disk (persistent cookies). The Polo Center of Sustainability website does not use persistent cookies. Upon closing your browser the session cookie set by this web site is destroyed and no personal information is maintained which might identify you should you visit our website at a later date.

INFORMATION

The Privacy Program constitutes the Polo Center of Sustainability’s privacy policy. It outlines how the Polo Center of Sustainability protects your privacy rights and upholds its obligations when handling your personal information. The Polo Center of Sustainability respects and upholds your rights under the Rules and Regulations for Italian and European Union Governments. Specifically, under the European Commission Data Protection, under the General Data Protection Regulation, the Data Protection Law Enforcement Directive and other rules concerning the protection of personal data, found at [https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en]. The Polo Center of Sustainability lets you know what personal information of yours we hold, what we do with it, who we will disclose it to and how you can access the personal information we hold about you. You can also find out here how to change inaccurate personal information and how to opt out of receiving communications from us. The Polo Center of Sustainability collects both personal and sensitive information as part of its regular scientific and social scientific research activities. As part of our research we are likely to collect your personal information. Given the nature of the social sciences, work conducted by the Polo Center of Sustainability, it is not always practicable for interview subjects to remain anonymous or to use pseudonyms. Depending on the nature of the research we conduct, we may also collect sensitive information from you. This may include an individual, but is not limited to: (1) racial or ethnic origin; (2) political opinions, membership of a political association; (3) religious beliefs or affiliations; (4) philosophical beliefs; (5) membership of a professional or trade association, membership of a trade union; (6) sexual orientation or practices; (7) criminal record; and (8) health information about an individual, genetic information (i.e., not otherwise health information). Sensitive information will only be collected with your prior consent and only if it is directly related to, or reasonably necessary for the research we conduct.

COLLECTION AND USE

The Polo Center of Sustainability will generally collect your personal information directly from you in the course of you participating in our research. However, we may also from time to time collect personal information about you from third parties, such as when a client provides us with a list of sample data to use in conducting our research. If this is the case, we will inform you that we have received your personal information as soon as is practicable and the circumstances of the collection. At this time you will be provided with an opportunity to decline participation and opt-out of any research process. If you elect to do so, we will delete any of your personal information in our possession, as soon as is reasonably practicable. We may also collect personal information from public phone directories, commercial or consumer listings, data organizations, and respondent recruitment agencies. We will only use and disclose your personal and research information for the purpose of conducting our research. We will not use or disclose your personal information for the purpose of advertising, promotions or direct marketing activities. If you have participated in our research, we will only re-contact you if you were informed of this prior to collecting your personal information or if we have valid reasons to believe a genuine research concern warrants such re-contact.

DISCLOSURE

We will not disclose any personally identifiable research information we collect from you unless we have your express prior consent and will only report the information you provide in an aggregate form that will not personally identify you. We will not disclose any personal information or personally identifiable research information to a third party for a purpose other than conducting our research unless we have your express prior consent or are required to do so by a judicial authority or court/tribunal order. In the course of conducting our research, we may rely on third party service providers to host or store the data we collect. We take all reasonable steps to ensure that third party service providers comply with our privacy standards.

THE IMPORTANCE OF PRIVACY

The Polo Center of Sustainability considers that the privacy of your information is of the utmost importance. Below there are several of our privacy resources and additional links to privacy information we and our cliental utilize for regularity and consistency. The WPP is central to any web user who accesses our website. The WPP is available by clicking on the Privacy link at the bottom of any of our webpages on our website. The Polo Center of Sustainability’s privacy program extends to include a number of matters that comply with the completed European Commission’s Community Research and Development Information Service project, “Privacy and emerging fields of science and technology: Towards a common framework for privacy and ethical assessment (PRESCIENT)”. The PRESCIENT website can be found at [https://cordis.europa.eu/project/id/244779/reporting]. As privacy is a multifaceted concept, a moving target and a salient topic in technology policy making, PRESCIENT provides an early identification of privacy and ethical issues arising from emerging technologies and their relevance for European Commission policy. PRESCIENT contributed to the quality of research in the field of ethics, by distinguishing between privacy and data protection and analyzing the ethical, legal, and socioeconomic conceptualizations of each.

COMPLAINT

If you have any questions about the privacy guidelines we have set out or believe that we have at any time failed to keep one of our commitments to you to handle your personal information in the manner we have stated within the privacy sections of of website, then we ask that you contact us immediately via email, placing in the subject heading "PRIVACY COMPLAINT" and directing it to: privacy@polocenter.org. We will respond and advise whether we agree with your complaint or not. If we do not agree, we will provide reasons. If we do agree, we will advise what, if any, action we consider is appropriate to take in response. This policy is effective from the date of publication 01 January 2022 and will be reviewed periodically.

FURTHER INFORMATION

The Polo Center of Sustainability reviews its WPP periodically and reserves the right, at its discretion, to modify or remove portions of this policy at any time. This page should be reviewed periodically so that you are updated on any changes. Under the WPP, “personal information” has the same meaning as under the EU Directive 95/46/EC. If you require further information about the WPP, Privacy Program, or Privacy Resources, or to ask for access to your information, or if you have a complaint concerning your information or wish to have your information corrected, please contact us at: privacy@polocenter.org.