Below is a trace of privacy information in Italian, compliant with Regulation (EU) 2016/679 (GDPR) and suitable for the use of the Brevo plugin (formerly Sendinblue) for managing the newsletter. Naturally, before final publication, it is advisable to submit the text to verification by your legal department or the Data Protection Officer (RPD/DPO), if appointed.

INFORMATION ON THE PROCESSING OF PERSONAL DATA
(pursuant to art. 13 of Regulation (EU) 2016/679)

This information is provided for the website https://villaromanavarignano.cultura.gov.it (hereinafter also “Site”), managed by the National Museums of Genoa – Regional Directorate of National Museums of Liguria (hereinafter “Data Controller” or “DRMN Liguria”).

1. TITOLARE DEL TRATTAMENTO
   The Data Controller is the National Museums of Genoa – Regional Directorate of National Museums Liguria, with headquarters in Via Balbi 10, 16126 Genoa, Italy.
   For any requests for clarification or to exercise the rights provided for by Regulation (EU) 2016/679, you can write to:
   • E-mail: drm-lig@cultura.gov.it
   • PEC:drm-lig@pec.cultura.gov.it
   • Postal address: Musei Nazionali di Genova – Direzione regionale Musei Nazionali Liguria , Via Balbi 10, 16126 Genova (GE)

2. TYPE OF DATA PROCESSED
   a) Navigation data
   During normal operation, the computer systems and software procedures used to operate this Site acquire certain personal data, the transmission of which is implicit in the use of Internet communication protocols (e.g. IP addresses, domain names of the computers used by users, URI/URL of the resources requested, time of the request, method used to submit the request to the server, size of the file obtained in response, numeric code indicating the status of the response and other parameters relating to the user’s operating system and computer environment).
   This information is not collected in order to be associated with identified interested parties; however, by its very nature it could allow users to be identified, through processing and association with data held by third parties. It is used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning. They may also be used to ascertain responsibility in the event of any computer crimes to the detriment of the Site.

   Translated with DeepL.com (free version)

   b) Data provided voluntarily by the user

   The voluntary sending of emails to the addresses indicated on this Site and/or the completion of any contact forms entail the subsequent acquisition of the sender’s address and other personal data included in the communication, necessary to respond to requests.

   In particular, the Site collects personal data (such as name and email) from users who voluntarily subscribe to the newsletter, managed through the Brevo plugin (formerly Sendinblue).

3. PURPOSE AND LEGAL BASIS OF THE PROCESSING
   a) Provision of services and management of requests
   Personal data are processed to manage user requests (for example, requests for information or subscription to the newsletter). The legal basis for such processing is the execution of pre-contractual or contractual measures adopted at the request of the interested party (art. 6, par. 1, lett. b) of the GDPR).

   b) Sending informative and promotional communications (newsletter)
   The email address provided by the user may be used to send newsletters containing information on events, initiatives and cultural activities related to the National Museums of Genoa – Regional Directorate of National Museums of Liguria and, in particular, to the Villa Romana del Varignano. The processing takes place exclusively with the consent of the interested party (art. 6, par. 1, letter a) of the GDPR). The user may revoke the consent at any time, without prejudice to the lawfulness of the processing carried out prior to the revocation.

   c) Statistics and traffic analysis
   Browsing data are processed in aggregate form for statistical purposes and technical monitoring of the correct functioning of the Site. The legal basis of the processing is the legitimate interest of the Data Controller (art. 6, par. 1, lett. f) of the GDPR).

4. PROCESSING METHODS AND SECURITY MEASURES
   The processing of personal data occurs mainly with electronic tools, in compliance with adequate security measures to guarantee the protection and confidentiality of the data, in accordance with the provisions of art. 32 of the GDPR.
5. DATA RETENTION PERIOD
   • The data collected for sending the newsletter will be retained until the interested party requests cancellation (opt-out) or revokes consent.
   • Browsing data is retained for the duration strictly necessary to achieve the purposes for which it is collected and, in any case, no longer than the terms established by current legislation.
6. COMMUNICATION AND DISSEMINATION OF DATA
   • Personal data may be processed by personnel and collaborators in charge of processing (designated and trained by the Data Controller).
   • They may also be communicated to third-party providers of services strictly connected and functional to the provision of the service (e.g. hosting service, Brevo newsletter plugin, etc.), appointed as Data Processors pursuant to art. 28 of the GDPR, who are bound to comply with the provisions on the protection of personal data.
   • The data is not intended to be disseminated.
   • The data will not be transferred outside the European Economic Area, unless this is necessary for specific technical needs related to the newsletter service, in which case suitable guarantees will be adopted as per articles 44 et seq. of the GDPR.
7. COOKIES
   The Site uses technical cookies and, where necessary, third-party analytical cookies in anonymous/aggregated form. For more information on the types of cookies used and how to manage them, please consult the dedicated Cookie Policy (if available on the Site).
8. RIGHTS OF THE INTERESTED PARTY
   In accordance with the provisions of articles 15-22 of the GDPR, the user has the right to:
   • obtain confirmation of the existence or otherwise of personal data concerning him/her;
   • know the origin, purposes and methods of processing;
   • obtain the updating, rectification or, if there is interest, integration of the data;
   • request the cancellation, transformation into anonymous form or blocking of data processed in violation of the law;
   • object to the processing of data for legitimate reasons;
   • revoke consent at any time (without prejudice to the lawfulness of the processing based on the consent given before the revocation);
   • file a complaint to the Guarantor for the protection of personal data (www.garanteprivacy.it).

     To exercise the rights listed above, you can send a written request to the Data Controller at the addresses indicated in paragraph 1.

9. CHANGES TO THE INFORMATION
   This information may be subject to updates. Any substantial changes will be communicated with adequate evidence on the Site or by email to registered users, where necessary.

   Last update date: 08 02 202