Privacy Policy, Legal Notes and social network spaces user policy

Privacy Policy
This Application collects some Personal Data from its Users.

Owner and Data Controller
The titleholder of treatment is the University of Palermo, based in Palermo, Piazza Marina 61 (CAP 90133). The titleholder of treatment notifies that, following consultation of this site, data regarding identified and identifiable persons may be treated.
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies, Usage Data and email address.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics, Displaying content from external platforms, Interaction with external social networks and platforms and Contacting the User.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:

The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.

Google Analytics (Google Inc.): Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. Personal Data collected: Cookies and Usage Data.

Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

YouTube video widget (Google Inc.): YouTube is a video content visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages. Personal Data collected: Cookies and Usage Data.

Google Maps widget (Google Inc.): Google Maps is a maps visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages. Personal Data collected: Cookies and Usage Data.

Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of this Application. The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network. This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

Facebook Like button and social widgets (Facebook, Inc.): The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc. Personal Data collected: Cookies and Usage Data.

Twitter Tweet button and social widgets (Twitter, Inc.): The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc. Personal Data collected: Cookies and Usage Data.

Contacting the User

Contact form/intranet (this Application): By filling in the contact/intranet form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data collected: email address.

The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Additional information about Data collection and processing

Legal action
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Application and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject
The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application
The means by which the Personal Data of the User is collected and processed.

The service provided by this Application as described in the relative terms (if available) and on this site/application.

European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Small sets of data stored in the User’s device.

Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to this Application, if not stated otherwise within this document.

Legal Notes

Copyright notice
All the contents present in including the MIGRANTS logo, are protected according to the current copyright legislation; a non exhaustive list of possible materials are images, texts, audio, video, metadata, scripts, graphics, podcasts, and so on.
Contents are made available and accessible respecting the intellectual property rights of their lawful holders. Contents will be reproduced upon the consent of the rights holders, except those licensed under Creative Commons license. When reproducing the portal contents, it is mandatory to acknowledge the source.
All the enterprises and products referenced in this site are identified by their own brands, which are or can be patented and/or copyrighted by the competent authorities.
Downloadable materials can be copyrighted; the University of Palermo invites users to verify in advance the rights of use of downloadable materials, and shall not be held liable for rights infringement via download.
The use of personal data retrieved in the portal, like telephone numbers, emails, and identification data, is allowed only for institutional research and education activities, and for the needs related to administrative procedures.
The use of published data for marketing and commercial purposes is strictly forbidden without the previous consent of the interested parties. Spamming is also forbidden. Violations will be reported to the competent authorities.

Use of the Website
The web site of the MIGRANTS project supports the institutional purposes of the University of Palermo. All the information related to the services supplied to the users is available and accessible through the portal. Such information is updated promptly, to allow a better fruition by the users. Inaccuracies can be pointed out by sending an email to
The University of Palermo shall not be held liable in any way for whatever damage caused by accessing and/or browsing the portal and possible external sites linked to it, or by using the portal services and interactive tools.

Access to linked external websites
The University of Palermo shall in no way be held directly or indirectly responsible for the contents, services or programmes of external websites connected via links to the or their relative use by users. The University of Palermo has no power or control over the contents, quality or completeness of the information in external websites and therefore all responsibility lies directly with the relative website owners.

The objects, programmes and products (including but not limited to documentation, software etc.) that can be downloaded from the website are protected under the applicable copyright in and industrial property right laws. The University of Palermo therefore invites you to check the conditions of use laid down by the legitimate owners of the download and declines all relative responsibility.
The University of Palermo does not guarantee the safety and compatibility of the programmes and products available via downloads with the systems in use and declines all relative responsibility.

Social network spaces user policy

The terms and the conditions uses social networks as channels for informing and encouraging its users, especially student users, to participate and dialogue. On its official pages the administration’s purpose is institutional in nature and concerns matters of general interest.
The social networks by no means take over the duties of the Student Administration Offices or university front offices, but just about MIGRANTS project. Complete and up-to-date information may be found on the University Portal ( and connected websites.
The University of Palermo uses the social networks to broadcast information on services, projects and initiatives. Contents published can related to institutional business and services, events, projects, results of research, schemes to build up participation, updates on emergency situations.
The University of Palermo may occasionally share in messages and contents from other organizations or people when these are of public interest or utility. While endeavouring to check the accuracy and reliability of such contents, the Administration accepts no responsibility for any wrong or out-of-date information.
As for publicity features surrounding the contents of social network pages, these, be it noted, are outside the Administration’s control and are independently managed by the social networks.

Regulations and Moderation
Terms of service apply to the social networks and must be complied with by all users.
Everyone has the possibility to take an active part in and express their opinions in the University of Palermo’s social spaces, within the limits of the law and without offending others. Users are invited to present their name and surname and abide by certain basic rules:

  • to state their opinion politely and moderately, sticking to verifiable fact as far as possible and respecting other people’s opinions;
  • to avoid insults, vulgar and offensive utterances, threats and all violent attitudes;
  • at all times to respect people’s privacy, and avoid reference to facts or details that have no public import or invade the personal domain of third parties;
  • not to use this area to discuss personal issues, but to confine themselves to topics of public interest;
  • to stick to the point at issue in a discussion and avoid straying from it in an indiscriminate fashion;
  • to abstain from all kinds of publicity, spam or promotion of private interests or illegal activity;
  • not to publish contents infringing copyright, or use registered trademarks without authorisation.

At various stages he University of Palermo will retrospectively moderate its own area, as and when it reasonably can, to limit any contents infringing the user regulations. In the more serious instances – and especially where the common rules outlined above are broken – the Administration reserves the right to cancel contents, ban users from its pages, and report them to the host social network and its moderating filter mechanisms.

Access to linked external websites
The University of Palermo shall in no way be held directly or indirectly responsible for the contents, services or programmes of external websites connected via links to the or their relative use by users. The University of Palermo has no power or control over the contents, quality or completeness of the information in external websites and therefore all responsibility lies directly with the relative website owners.

Getting back to users
As a rule, the social spaces of the MIGRANTS project are reviewed frequently. The University of Palermo undertakes to read all messages and queries and, if required, to give an answer as promptly as possible.
The speed of answering will vary according to the kind of request. If a social network proves the wrong channel on which to meet a request, the editing service will inform the user of the right channel to use and the office to consult.

Please note that users’ personal data is processed in compliance with the applicable policies of the platforms used (Twitter, Facebook, YouTube, etc.). Data shared by users through private messages sent directly to the University of Palermo channels will be processed in compliance with the Italian privacy laws.

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