1. This Policy regards all personal data of yours that we have obtained – whether from you directly or indirectly from any entity – for the planning and organization of your GEI program and related GEI services. These data will be processed and handled by us in accordance with our policies, with the European Union’s General Data Protection Regulation (“GDPR”), and with the principles of fairness, lawfulness, transparency, purpose limitation, accuracy, storage limitation, integrity and confidentiality, and accountability, as well as the utmost protection of your privacy. Sensitive data processing will only take place in relation to data regarding your health condition (such as diseases, allergies or food intolerances) or judicial data of relevance to your participation in the GEI program.
2. All data shall be processed exclusively for GEI institutional purposes, connected or related to the activities carried out by GEI, such as the planning and organization of your GEI program, the accomplishment of bureaucratic practices for your entry in your program destination, and the performance of the contractual obligations of GEI in connection with your program stay. In particular, the data supplied or collected may be processed for the following purposes:
a. To fulfill the obligations established by any applicable law;
b. To execute the contractual obligations with reference to your enrolment with the GEI program (such as, but not limited to, program content and logistics bookings, program attendance certification, or participant health and safety protection); and
c. To take the necessary actions in the case of an accident or aggression.
Sensitive data regarding your health conditions and food habits will only be processed for the purpose of protecting your safety or of fulfilling the obligations established by any applicable law. Sensitive data regarding judicial measures which may have been provided to GEI by public bodies will be processed only for purposes relating to a health or safety emergency and complying with any applicable mandatory provision of any applicable law.
3. Submittal and processing of personal data is necessary in order to achieve the purposes above specified. Any refusal will make it impossible to carry out the necessary activities and the correct administrative and didactic management of your program necessary to accomplish the contractual obligations of GEI in connection with your program stay, as well as the obligations imposed by law.
4. Data – including sensitive data – will be collected and processed automatically and/or manually, and by adopting the respective minimum safety measures.
5. The data will be handled only by the persons who are in charge of and responsible for the related program activities and services.
6. Your data may be communicated, in compliance with the rules above indicated, to public or private subjects to whom they may be necessary in order to carry out the planning and organization of your GEI program, and to fulfill obligations set forth by applicable laws. Sensitive data may be communicated to public bodies and authorities (such as public hospitals, public safety authorities, police offices, courts, magistrates and the like) and to private subjects (such as private hospitals and clinics, security supervisors, insurance companies and the like) only for purposes relating to health and safety emergency and for the purposes of fulfilling obligations set forth by applicable laws.
7. You will be able to exercise any and all rights foreseen, among others, by the GDPR, electronically available at http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf. This includes, among others, the following rights:
a. You have the right to obtain confirmation of the existence or not of personal data, even if not yet recorded, and their communication in intelligible form.
b. You have the right to obtain indication a) of the origin of the personal data, b) of the ends and methods of their processing, c) of the logics applied in the event of processing being carried out with the aid of electronic equipment, d) of the identification data of your data manager at GEI, and e) of the organizations and categories of organizations to whom personal data can be communicated or who are likely to get to know them at the program destination(s).
c. You have the right to obtain a) the update, the rectification or, if you have the interest to, the integration of the data, b) the cancellation, transformation in anonymous form or blockage of any data processed unlawfully, including those whose storage is not necessary in relation to the aims for which the data were collected or later processed, and c) a statement that the operations indicated in a) and b), including their content, have been made known to those to whom the data have been communicated or released, except in the case of this being found to be impossible or requiring the use of means which are clearly disproportionate to the protected right.
d. You have the right to completely or partially oppose a) for legitimate reasons, the processing of personal data even if relevant to the aims of their collection, and b) the processing of personal data for the purpose of sending publicity material, direct sales or for carrying out market research or commercial communications.
8. The Data Controller for your data is GEI. In order to exercise the rights mentioned in 7. above, you can contact us at 426 State Street, #4001 (c/o Mlekoday), Schenectady, NY 12305, USA, or by sending an email to programs@global-engagement.org.
