Latest Update 2023/03/01

The present document relies on the management Personal Data of the www.proms_initiative.org website users’. This privacy notice is pursuant to art.13 of the EU GDPR 2016/679.

Data Controller 
The Data Controller is the Italian Multiple Sclerosis Foundation – FISM ETS – with registered legal office in Rome (Italy), Via Cavour 181/A, with its national headquarter in Genoa (Italy), Via Operai 40, who can be contacted through the following channels: 

Data Processor
The Data Processor who is responsible for the Data security and management is Liguria Digitale S.p.A., legal office in Genoa (Italy), Via Enrico Melen, 77, who can be contacted through the following channels:

This privacy notice is valid exclusively for www.proms_initiative.org nor for website, which the users may visit via link.

Type of Data

Browsing Data

The IT apparatus that guarantees the correct functioning of the www.proms_initiative.org website during normal operation, acquires Personal Data whose transmission is implicit in the use of Internet communication protocols. This category of Data includes:

  • the IP addresses or name of the users’ computers domains, 
  • the Uniform Resource Identifier (URI), 
  • the time of the request,
  • the method used to submit the request to the server,
  • the size of the file obtained in response,
  • the code indicating the status of the response given by the server (successful, error, etc.).

These Data are used for the sole purpose of checking the correct functioning of the website and will be kept only for the time necessary to outreach the purposes below described, according to art. 5/1c of the GDPR. In any case, the further conservation required by the applicable legislation is reserved.

The Data collected can be used to ascertain responsibility in the event of hypothetical computer crimes against the site. 

Purpose of Processing and Legal Bases

The personal Data are collected and processed according to correctness, lawfulness, minimization of Data and protection of confidentiality principles, exclusively for the purposes below:

  • Analytics
    Collection of Data is exclusively in aggregated and anonymous modality to verify the correct functioning of the website. None of the information is related to the natural person (user) of the website, and does not allow the identification in any way. The explicit consent is not required.
  • Safety

Collection of Data and information in order to guarantee users and website safety (spam filters, firewalls, virus detection) to prevent or unmask fraud or abuse against the website. The Data are automatically recorded and may include personal Data (IP address) which could be used, in compliance with the laws in force, to interrupt damage attempts with respect to the website itself or to cause damage to other users, or in any case harmful activities or constituting a crime. These Data will never be used for the identification or profiling of the User and are periodically deleted. The explicit consent is not required.

  • Other Activities for purpose outreach
    Communicate Data to third parties who perform functions necessary or instrumental to the operation of the service, and to allow third parties to carry out technical, logistical and other activities on our behalf. The suppliers have access only to the personal Data that are necessary to carry out their tasks, and undertake not to use the Data for other purposes, and are required to process the personal Data in accordance with current regulations. 

The legal bases behind the design and outreach of the purpose of processing described above, is to pursue the legitimate interest (art. 6/1f of the GDPR).

The provision of Personal Data for these purposes is optional but failure to provide it would make it impossible to activate the services provided.

Recipients of the Data

The Data collected may be shared with:

  • Subjects/Natural Person authorized by the Data Controller to process personal Data (e.g. employees) ;
  • Third Parties enrolled to collaborate with instrumental services to pursue the above described scope, in some cases acting on behalf of the Data Controller;
  • Google
  • Subjects, bodies or authorities to whom it is mandatory to communicate your personal Data by virtue of provisions of the law or requests of the authorities.

In relation to the described purposes, the processing of Personal Data takes place using manual, IT and telematic tools and, in any case, with methods such as to guarantee the security and confidentiality of the Data, in addition to compliance with the specific obligations of law.

Transfers of Data
Some of the Data collected can be shared with recipients outside EU. The Data Controller guarantees that the treatment of your personal Data with respect to these recipients is compliant with the privacy rules. 

Rights of the Data Subject and Procedure for exercising Rights and Communications (ex art. 15)
Pursuant to art.15 and following of the GDPR, you have the right to ask to the Data Controller to access to your Personal Data at any time, to withdraw the treatment or cancel them. You have the right to request the limitation of treatment in the cases provided by art.18 of the GDPR, as well as to obtain your Data in a structured format, in common use and readable by automatic device, in the cases provided by art.20 of the GDPR.

Please, contact the Data Controller through the following channels: 

In any case, you always have the right to withdraw the permission and to claim it by contacting the GDPR authorities (art.77), if you believe that the processing of your personal Data is not compliant to the legislation in force.

2. COOKIE POLICY

Definitions, properties and rules 
Cookies are small text files sent by the website once you, as user, visit it. Cookies are recorded on your computer or mobile device, and will be then re-transmitted to the same website on the next visits. Thanks to the cookies, the website remembers the user’s actions and preferences (such as, for example, login data, the chosen language, font size, other display settings, etc.), thus not requiring to express or to indicate them when you returns to visit it from one page to another one. Cookies are used to perform authentications, monitoring sessions and to record information while accessing the website (unique identification code to track your browsing preferences for statistical or marketing purposes). While visiting a website, you can receive on your computer, “Third Parties Cookies”, belonging to other web servers or website external to the one you are visiting. Some operative functions cannot be perform without cookies, which are necessary in some cases and are named: “Technical Cookies”. Hence, there are different types of cookies depending on their properties and function. These may rely on your computer for different time span, for example the cookie session expires once closing the website browsing. 

The www.proms_initiative.org website uses technical cookies for service delivery management. In particular, it uses browsing and session cookies that do not interfere with the browsing of the website. 

Your cookies preferences
You can select a feature according to what your computer suggests whenever a cookie is set, or you can decide to disable all cookies (selection wall). You can select these features through your browser settings. Each browser is slightly different; therefore, we invite you to identify the most correct way to modify the functions relating to cookies in the “Help” menu of your browser.

Instructions for cookies’ management
If you have a different type or version of browser, please refer to your browser’s “Help” menu.

Microsoft Edge

  1. Click on the menu “Settings”, and search on the content tab “Cookie and Website authorisations”,
  2. Choose the preferential settings by using the mouse,
  3. For more specific cookies, click on “Show all authorisations”,

Google Chrome

  1. Click on the menu “Settings”, and search on the content tab “Privacy and Safety”
  2. Choose the preferential settings 

Mozilla Firefox 

  1. Click on the menu “Settings”, and search on the content tab “Privacy and Safety”
  2. Choose the preferential settings 

Safari

  1. Click on the menu “Preferences”, and search on the content tab “Privacy” to select cookies settings,
  2. Choose the preferential settings,
  3. For more specific cookies, click on “Details”

Opera

  1. Click on the menu “Tools”, and select ”Preferences”,
  2. In the Cookies section, click on “Manage” and select the preferential option.