PRIVACY POLICY 

As part of the membership agreement, the club will collect some of your personal data. Personal data is any information that makes a member identifiable (directly or indirectly) as an individual, for example, name and contact information. Any personal data that we collect or that you choose to give us will only be used to maintain and improve the relations between you and IWCT.

When you apply for membership, we ask you to provide the following personal data:
● Name and Surname
● Email
● Contact phone number
● City
● Your country of origin (statistical reporting)
● Age group (statistical reporting).

Optionally, you may give us information on the following:
● Your photo
● Nationality (statistical reporting)
● Length of club membership
● Social media links
● A short “About Me” paragraph
● Your feedback on specific issues related to the Club’s activities and organization.

As a member of the IWCT we may collect:
● Photos and / or videos of you recorded during IWCT events. Images of family members (partners, children, etc.) will only be collected after you have given specific consent for us to do so.
● Financial information (e.g., bank account, credit card, etc.) is only collected when you make a payment (i.e., for the membership fee, participation in club activities, or donations).

The IWCT will never ask you to provide sensitive personal data, such as political, religious or philosophical beliefs; health, sexual orientation or racial/ethnic origin; genetic data; biometric data; social assistance/aid measures or criminal or administrative proceedings and penalties, etc.

As a member of the IWCT, we may collect photos and / or videos of you recorded during club events for use in our communications (newsletter, print materials, social media) and on our website. Images of family members (partners, children, etc.) will only be collected and used after you have given specific consent for us to do so. If you would not like your photo / video to be used or if you would like a specific photo removed, please contact Kelsey at techsupport@iwct.it

The IWCT is a non-profit organisation with a mission to provide its members with opportunities to meet for social, cultural and sporting purposes and to take part in community service in and around Torino.

Therefore, we will use your data to:
● Process your membership application including payment of the membership fee;
● Provide you with access to the members-only area of the club’s website;
● Communicate with you about your membership and your IWCT online account;
● Provide you with news and updates about the activities of the club through our newsletter, social media, and website;
● Promote the club’s activity and mission towards members, partners, the local community and other stakeholders;
● Respond to your questions, comments, support needs, complaints, and suggestions;
● Seek your views or comments on the activities the club provides;
● Process event bookings that you have made, including payment;
● Notify you of any changes to bookings or events;
● Send you communications which you have requested;
● Create a membership directory which will ONLY be visible to other members on the password-protected website.

We collect your data when you:
● Register to become a member;
● Sign up for club activities;
● Participate in physical or online events;
● Voluntarily give consent to be photographed at or during club activities for use in club communications;
● Voluntarily complete a survey or provide feedback on any of our messaging services (WhatsApp, etc.) or via email;
● Use our website and voluntarily give consent to its cookies.

The use of your personal data relies on the following lawful basis:
● Consent: you give informed consent for the use of your personal data for the purposes outlined above.
● Contractual requirement: club membership constitutes a contract between a member and the club with rights and responsibilities for each side. The club needs to process some personal data to establish and fulfil that contractual relationship.

This means you directly provide the club with the data we collect and you give us your informed consent to do so, i.e., you understand the way in which your given data will be processed. Informed consent means we will provide you with the information you need to understand the personal data required and the data processing associated with:
● Becoming a member of the club;
● Participating in club activity groups and events;
● Providing us with your personal data.

When you give us your consent to collect and process your personal data, you agree that you have been provided with and understand this information. You give your consent when you sign the membership agreement and through the annual renewal of your membership.

NB: We do not collect personal data that members share in group chats or through personal social media profiles. Therefore, the IWCT cannot be held responsible for possible security risks or misuse of any of these data. Likewise, the club cannot be held responsible for outdated information. Members are responsible for updating their data on their personal profile page.

We collect your data mainly through the IWCT website or other digital forms. Only when this is not possible, do we collect data via paper documents (printed membership form only on specific occasions, sign-in sheets at club events, etc.). We scan printed documents in order to store and secure them in digital form.

You can cancel your IWCT membership at any time, by writing to membership@iwct.it.
You can opt-out from the newsletter mailing list by clicking the “unsubscribe” or “update your preferences” links at the bottom of every newsletter email.
You can update your IWCT account preferences directly on your personal profile page.

The club would like to make sure you are fully aware of all your data protection rights. Every member is entitled to the following:

● The right to be informed – You have the right to access information about your personal data processing.

● The right to access – You have the right to request copies of your personal data and information about data processing.

● The right to rectification – You have the right to request that the club corrects any information you believe is inaccurate, and completes information you believe is incomplete.

● The right to removal / deletion of data (‘Right to be forgotten’)– You have the right to request that the club removes and deletes your personal data, unless the request would require a disproportionate effort or is impossible to comply with.

● The right to restricted processing – you have the right to limit the way that the Club uses your data, under specific circumstances which are when:
○ The accuracy of data is contested.
○ You don’t want the data to be erased.
○ The club no longer needs the data but you would like your data to be preserved;
○ The club is working on a request to erase your data.

● The right to object to processing – You have the right to object to the club’s processing of your personal data when:
○ The data might be used for direct marketing purposes;
○ You withdraw your consent for processing of your data.

● The right to data portability – You have the right to request that our club transfer the data that we have collected to another organization, or directly to you in an automated (no paper), structured, commonly used and machine-readable format.

● Rights in relation to automated decision making and profiling – You have the right not to be subject to automated decision making if it is producing a legal effect that significantly affects you. Please be aware that our club does NOT process personal data with automated decision-making and profiling.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: privacy@iwct.it
Or write to us: Strada Comunale Di Reaglie 22, 10132, Torino.

The IWCT is committed to respecting the GDPR – General Data Protection Regulation.
Based on your rights as a data subject, the club takes and maintains security measures to protect your data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Specifically, we have implemented the following measures:

1. Processing of your data:
Your data are processed only by members that have an active or institutional role in club activities and organization (mainly by the Board and activity group leaders). Data access and process is secured through password-protected systems. Your data are not subject to transfer, nor are they subject to any completely automatic decision-making processes, profiling included.

2. Storage and deletion of your personal data
Our club will keep your necessary personal data, i.e. name and contact information for as long as you are a member. Once your membership has expired, we will delete your data from our electronic record within one year. However, a member’s email shall be archived in the newsletter distribution system (Mailchimp).

● Offline storage
All club members’ personal data are stored offline on IWCT-owned hardware (laptop & external drive) and only specific board members have access to this data, i.e., President, Membership Chair, Web Chair, and Treasurer. The Membership Chair will check the current offline database each year and will delete data of previous members after a retention period of one year. 
You can ask for your data to be deleted at any time. However, we may not be able to continue your membership benefits or allow event registration without it. To request deletion of your data from the offline membership database, send a written request by email to the Membership Chair (membership@iwct.it).

● Online storage
All data provided or accessed through our website is stored on a secure server. Our servers are located in Europe and all data is transmitted via Secure Socket Layer (SSL) technology.
Only the data that each member has consented to sharing will be included in the digital membership directory in the members-only area of our website. Each member can update, change or delete her data from the membership directory, which is only accessible to current club members who have an active account with the IWCT.

3. Your account on the IWCT website
When you become a member, we will provide you with an account that will give you access to the members-only area of the website. You are responsible for keeping your password updated and secure. You need to change your password immediately if you suspect that your account may have been compromised. We recommend you update your password every 90 days.

4. Sharing of your personal data with other members
As members, you can participate in club events, activity groups and groups affiliated with the IWCT. You may choose to share contact information such as your mobile number with the activity leader of a group, in order to be included in group messaging services (i.e., WhatsApp).
However, please be aware that the club cannot be held responsible for personal data shared voluntarily by you on these occasions. Members are fully responsible for their personal data voluntarily shared.

The IWCT never sells your personal information to any third party for any purpose. However, it may be necessary to share your information with some third-party suppliers who provide services necessary to serve our membership. These suppliers (“processors”) may process your personal data on our behalf. They only process and protect your personal information under strict contractual conditions.

Only the necessary personal information is shared with external third parties for specified purposes. We aim to take reasonable steps to ensure recipients shall only process the disclosed personal information in accordance with those purposes.

Relevant Third Party Suppliers (and their respective privacy policies):

• Aruba (privacy policy), our website host and email service provider
• Stripe (privacy policy), a payment processor
• PayPal (privacy policy), a payment processor
• Satispay (privacy policy), a payment processor
• Mailchimp (privacy policy), our email newsletter service provider
• SurveyMonkey (privacy policy), occasional survey service provider
• Google (privacy policy), occasional survey service provider
• Zoom (privacy policy), video conferencing service provider
• WhatsApp (privacy policy), group messaging service provider

When you visit our website, we ask you to accept cookies. Cookies are text files placed on your computer to collect standard visitor behaviour information. When you visit our website, information about what you do is recorded and stored in a simple text file. The next time you visit our website that information is retrieved to make using the website easier for you and to help us diagnose faults or security issues. For further information, visit allaboutcookies.org.

There are a number of different types of cookies and our website uses:

• Necessary or Technical cookies: These cookies are required and allow the proper operation of certain sections of the site.
• Functional cookies: Our club uses these cookies so that we recognize you on our website and remember your previously selected preferences.
• Analytical cookies: Our club uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. We sometimes share limited aspects of this data with our sponsors for statistical purposes only, and never your personal details.

Our club uses cookies in a range of ways to improve your experience on our website, including:

• Keeping you signed in and remembering your preferences;
• Understanding how you use our website to improve our services.

You can set your browser not to accept cookies and this website (allaboutcookies.org) tells you how to do this. However, some of our website features may not function as a result. You can also manage your cookie preferences directly on our website.

Our club keeps its privacy policy under regular review and places any updates on this web page. When necessary (e.g., before starting any new data processing), we inform you through specific communication such as our newsletter.

This privacy policy was last updated on 27 June 2024.

NB: Our website contains links to other websites. Our privacy policy applies only to ours. If you click on a link to another website, you should read their privacy policy.

If you have any questions about our club’s privacy policy, please do not hesitate to contact us.

Email us at: privacy@iwct.it

Or write to us at: Strada Comunale Di Reaglie 22, 10132, Torino.

How to contact the appropriate authority: 

Should you wish to report a complaint or if you feel that our club has not addressed your concern in a satisfactory manner, you may contact the relevant national authority in Italy: https://www.garanteprivacy.it/home_en.