This is a courtesy translation of the Italian privacy notice. In case of any discrepancy, the Italian version prevails.

Website Privacy Notice

The “Olimpo 2 APS” Association, a registered third-sector organisation (ETS), with registered office in Via Provinciale 27, 83020 Forino (AV), Italy, tax code 94074400659, as Data Controller (hereinafter the “Association”), informs you, pursuant to art. 13 of Italian Legislative Decree 196/2003 (hereinafter the “Privacy Code”) and art. 13 of EU Regulation 2016/679 (hereinafter the “GDPR”), that it will process the data of users (hereinafter “User” and/or “Users”) collected through the website www.olimpo2.it (hereinafter also the “Site”) in the manner and for the purposes set out below.

I. Types of data processed by the Association through the Site

The Association processes the following types of personal data (hereinafter “data”) provided by Users when they browse the Site, in particular:

  1. Data obtained while a User browses the Site. The computer systems, cookie technology and software procedures used to run the Association’s website acquire, in the course of their normal operation, certain data whose transmission is implicit in the use of the Internet. This information is not collected in order to be associated with identified data subjects, but by its very nature it could, through processing and association with data held by third parties, allow Users to be identified. This category includes, for example, the IP addresses or domain names of the computers used by Users connecting to the Site, the pages visited by Users within it, the domain names and addresses of the websites from which the User reached the Site (referral), the URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the web server, the size of the file obtained in response, the numerical code indicating the status of the server’s response, and other parameters relating to the User’s browser (e.g. Internet Explorer, Firefox), operating system (e.g. Macintosh, Windows) and computing environment.
    These data are collected by means of first-party technical cookies and third-party analytics cookies. For more information on browsing data, Users are invited to read the Cookie Policy available on the Site.
  2. Personal data provided by Users. All pages and contents of the Site can be accessed by the User (“unregistered User”) without having to be identified. Accessing and browsing the Site therefore does not require any registration and, at present, there are no so-called “reserved areas”.
  3. Data provided to subscribe to the newsletter. If the User subscribes to the newsletter through the relevant form, the Association processes their first name, last name and email address, as well as data on their interactions with the communications received (for example, opening the messages and clicking on links), collected by means of tracking pixels as described in section VIII-bis.

II. Purposes of processing

1. The data provided by the User will be processed, without the User’s prior consent pursuant to art. 24(b) of the Privacy Code and art. 6(b) GDPR, for the following Service purposes:

  • to manage and carry out statistical surveys on the use of the Site;
  • to carry out the maintenance and technical support needed to ensure that the Site and its related services work properly;
  • to improve the quality and structure of the Site and to create new services, functions and/or features;
  • to allow the User to find the Association’s premises;
  • to process any contact request sent by the User through the relevant form or by email, e.g. to obtain information about the Association or to send a report to the Internal Supervisory Body;
  • to allow the Association to exercise its rights in court and to counter unlawful conduct;
  • to comply with legal or regulatory obligations.

2. With the consent given by the User when subscribing (art. 6(1)(a) GDPR and art. 130 of the Privacy Code), the data will also be processed to send the newsletter and promotional communications about the Association’s activities and events and, on the basis of the same consent (art. 122 of the Privacy Code), to measure interactions with those communications statistically by means of tracking pixels (section VIII-bis). Apart from these cases, the data provided by the User will not be processed for commercial purposes.

III. Nature of the provision of data

Providing data is mandatory for the Service purposes referred to in point 1 of the previous paragraph. However, refusing to provide such data may make it impossible to provide the services (e.g. to send a communication to the Internal Supervisory Body).

Providing data for the newsletter is optional: not providing them only means that the User will not receive the communications.

IV. Processing methods

Users’ data are processed by means of the operations set out in art. 4 of the Privacy Code and art. 4(2) GDPR, in particular: collection, recording, organisation, storage, consultation, processing, modification, selection, extraction, comparison, access, use, interconnection, blocking, communication, erasure and destruction of data.

Users’ data are processed with and without automated tools, only for the time strictly necessary to achieve the purposes for which they were collected and, in any case, for no longer than 10 years from their collection for the Service purposes referred to in point 1, with particular reference to reports sent to the Internal Supervisory Body.

Newsletter data are kept until consent is withdrawn or the User unsubscribes; data collected by means of tracking pixels are kept until consent is withdrawn and in any case for no longer than 24 months from collection.

V. Access to data

For the purposes set out above only, the data may be made accessible to:

  • members of the Association, in their capacity as persons in charge of processing and/or internal processors and/or system administrators;
  • third-party companies or other entities (for example, associations or professional firms providing assistance and consultancy services to the Association, with particular but not exclusive reference to the management of the information system used by the Association) that carry out outsourced activities, in their capacity as external processors;
  • the email delivery platform Mailchimp (The Rocket Science Group LLC, an Intuit company), appointed as data processor for the management of the newsletter.

VI. Communication of data

Without the User’s express consent (pursuant to art. 24(a), (b), (d) of the Privacy Code and art. 6(b) and (c) GDPR), the Association may communicate the User’s data to supervisory bodies, judicial authorities and all other entities to which communication is required by law. Users’ data will not be disseminated.

VII. Transfer of data

Personal data provided by the registered User will not be communicated to third parties for the purpose of sending commercial communications by any means.

Data will be managed and stored on servers located within the European Union, belonging to the Association and/or to third-party companies appointed as Data Processors. Data will not be transferred outside the European Union, with the exception of newsletter data, which are managed through Mailchimp on servers located in the United States: this transfer is based on the European Commission’s adequacy decision on the EU-U.S. Data Privacy Framework, to which the provider adheres, and on the standard contractual clauses. It is nevertheless understood that the Association may, if necessary, move its servers to Italy and/or the European Union and/or non-EU countries. In that case, the Association guarantees that any transfer of data outside the EU will take place in accordance with the applicable law, by means of agreements ensuring an adequate level of protection and/or by adopting the standard contractual clauses of the European Commission.

VIII. Third-party websites

Please note that, should the Site contain links to third-party websites, the Association cannot exercise any control over the content of those websites and has no access to the personal data of their visitors.

The owners of those websites therefore remain the sole data controllers responsible for the processing of their users’ personal data, and the Association has no involvement in that activity nor any liability for any damage or cost arising from its failure or incorrect performance.

The Site may also contain links to other websites owned by the Association.

We therefore recommend that you read the privacy policies and terms of use of those websites carefully before providing your personal data or consenting to its processing.

VIII-bis. Newsletter and tracking pixels in emails

In accordance with measure no. 284 of 17 April 2026 of the Italian Data Protection Authority (Garante per la protezione dei dati personali), “Guidelines on the use of tracking pixels in email communications”, the Association informs Users that newsletter emails may contain tracking pixels.

Tracking pixels are small invisible images, hosted on a remote server, that are downloaded when the message is opened with image display enabled. They make it possible to detect that the email has been opened, the date and time, the IP address and the type of email program or device used; the links in the emails also make it possible to detect clicks. They do not give access to the content of the mailbox or to the files stored on the User’s device.

The Association uses this information only in statistical form and to improve its communications; it does not pass it on to third parties.

The legal basis is the consent given by the User to receive the newsletter. The User may at any time:

  • withdraw consent to tracking pixels only, while continuing to receive the newsletter without tracking tools, by writing to info@olimpo2.it;
  • unsubscribe from the newsletter using the link at the bottom of every email;
  • prevent pixels from working by disabling the automatic download of images in their email program.

Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.

IX. Users’ rights

The User may exercise the rights set out in art. 7 of the Privacy Code and art. 15 GDPR.

In particular, the User has the right at any time to obtain from the Association confirmation as to whether or not personal data concerning them exist, and to have them communicated in an intelligible form.

The User also has the right to be informed of: a) the source of the personal data; b) the purposes and methods of processing; c) the logic applied in the case of processing carried out with automated tools; d) the identity of the controller, the processors and the designated representative; e) the persons or categories of persons to whom the personal data may be communicated or who may learn of them as designated representative in the territory of the State, processors or persons in charge of processing.

The User also has the right to obtain: a) the updating, rectification or, where they have an interest, integration of the data; b) the erasure, anonymisation or blocking of data processed unlawfully, including data that need not be kept for the purposes for which they were collected or subsequently processed; c) certification that the operations under a) and b) have been notified, including as regards their content, to those to whom the data were communicated or disseminated, unless this proves impossible or involves a manifestly disproportionate effort compared with the right protected.

The User has the right to object, in whole or in part: a) on legitimate grounds, to the processing of personal data concerning them, even if relevant to the purpose of collection; b) to the processing of personal data concerning them for the purpose of sending advertising material or direct selling, or for market research or commercial communication (for example newsletter services).

Where applicable, the User also has the rights set out in arts. 16–21 GDPR (right to rectification, right to be forgotten, right to restriction of processing, right to portability of contractual and raw browsing data, right to object), as well as the right to lodge a complaint with the Italian Data Protection Authority (Garante).

X. How to exercise your rights

To exercise the rights set out in the previous article, the User may contact the Association at any time:

  • by email at info@olimpo2.it, also to withdraw consent to the newsletter or to tracking pixels only;
  • by registered letter to “Olimpo 2 APS”, Via Provinciale 27, 83020 Forino (AV), Italy, for the attention of the President of the Association.

XI. Data Controller and Data Processor

The Data Controller is the “Olimpo 2 APS” Association, with registered office in Via Provinciale 27, 83020 Forino (AV), Italy.

The internal Privacy Officer is the President of the Association, Mr Roberto Ortu.

The list of external data processors may be requested, also by email and with a reasoned request, at info@olimpo2.it.

The complete and up-to-date list of processors and persons in charge of processing is kept at the Association’s registered office and may be requested, also by email and with a reasoned request, at info@olimpo2.it.

XII. Updates to this notice

This notice will be updated periodically; any update will be published on the Site.

XIII. Date of last update

This notice was last updated on 30 October 2026.