Privacy policy
Introduction
Round Table International and Round Table Italia Association, referred to herein individually or collectively as ‘RTI’, respect your privacy and undertake to protect it in the manner set out in this policy (hereinafter ‘Policy’). The protection of the data entrusted to us is of the utmost importance to RTI.
This Policy describes the types of data that may be collected by us or provided by users when they visit the website www.roundtable.it (hereafter ‘Site’), join our clubs, use our services or participate in our programmes. In addition, our rules as well as the manner, purpose and scope of disclosure and dissemination of such data are described.
Please note: Additional rules apply to individuals whose data is collected if they reside in the European Union or the European Economic Area. (See Appendix A: EU Privacy Policy).
This Policy applies to personal data collected by us:
Through the Site.
In interactions between you and our advertising and applications on third party web pages (or through services provided by third parties), when those pages contain links to this Policy.
Through RTI boards, districts and partner organisations when you become a member.
When registering for or participating in events organised by us.
In other types of interaction with RTI; for example, when contacting us for enquiries.
This Policy may be amended from time to time (see Amendments to this Policy). We therefore recommend that you read the Policy periodically for the most up-to-date version. In case of interpretation or other doubts, the English language version shall prevail.
Type of data collected and how it is collected
Different types of personal data are collected, including:
Data that could personally identify you, such as your first and last name, postal address, e-mail address or personal telephone number;
Data concerning the user's internet connection, the devices used to access the Site and other information concerning the use of the Site.
Data is collected by:
Users of our Site
Round Table Italia members
RTI donors
People who attend RTI events
People who participate in RTI programmes
This data is collected:
When the user provides them to us directly.
Automatically while browsing the Site. (Automatically collected data may include usage details, IP addresses, data collected via cookies and other tracking systems).
By third parties engaged by us to provide services; such as event organisers, travel service providers (used by RTI), payment processing services, email marketing services and software providers; also note that these service providers may change, or new service providers may be added without notice.
From clubs, districts, including multiple district organisations, and our global network partners.
From publicly available resources.
User-provided data
We collect data provided by you through the Site, or in your dealings with RTI, or our offline network. This data includes the following:
Data provided when requesting information from RTI, or when becoming a member of an RTI club, including data provided when registering on the Site.
Personal data provided when registering for certain services available on our Site.
Personal data required to post content on our Site.
Personal information that may be required for you to enter a competition or promotion sponsored by us.
Personal data provided to report technical problems with the Site.
Records and copies of correspondence (including emails, social media posts and other electronic messages) exchanged with users who contact us.
Responses to polls and other surveys.
Registration to attend or follow RTI events
Personal data provided at the time of donation
Personal data provided when applying, e.g. for scholarships, grants or fellowships
Biographical or other data provided to us, RTI boards
Details of transactions and order fulfilment made through the Site and financial or payment data may be required to place purchase orders through the Site.
Data on searches made by the user on the Site.
Personal data collected by other features developed in the future that may involve the collection of such data.
The user may provide personal data to be published on the Site (hereinafter referred to as ‘Posted’) or transmitted to other users or third parties (hereinafter referred to collectively as ‘User Content’). In these cases the user assumes the risk of the Posting and transmission to third parties. Although RTI restricts access to certain pages and you can set certain privacy preferences in your profile, the absolute security of your data following access based on your credentials cannot be guaranteed. RTI also cannot control the actions of other users of the Site with whom you choose to share your content.
Usage details, IP addresses, cookies and other technologies
During your visit to or interaction with the Site, certain data relating to your equipment, browser and usage habits may be automatically collected, including:
Details relating to the visit: for example, traffic and location data, standard server information (logs), other communication data, and information about the resources viewed and used by you during your visit to the Site.
Data relating to your computer and internet connection, including your IP address, operating system and browser type.
Data collected after accessing RTI is anonymous and aggregated into statistical data that allows us to improve the Site and provide a more valuable and personalised service, enabling us to:
Formulate estimates of the size of our audience; statistics relating to browsers, content popularity and usage habits;
Speed up user searches;
Recognise the user on subsequent visits to the Site.
Cookies (broweser cookies) are used for automatic data collection.
Cookies are small files placed on the user's hard drive). You can change your browser settings to refuse cookies; however, if you do so, access to some pages of the Site may be denied. Our system automatically issues cookies unless you have set your browser preferences to disable them.
When you have gained access to your account at RTI we automatically collect usage data that relates directly to your account. In such cases, this data will be used for purposes of making improvements to the Site and your browsing experience and will be processed in accordance with this policy.
Use of cookies and other tracking technologies for third party advertising
Some advertisements on the pages of the Site and RTI's offerings are served by third party advertisers, ad networks and ad servers. In addition, some of the applications accessible from or on our Site may belong to third parties. These parties may use cookies and/or other tracking technologies to collect data about our users. RTI has no control over these third party technologies and their possible use. If you have any questions or queries in this regard, please contact the advertising manager directly. For information on how to block the receipt of contextualised advertisements from these providers, please see below the section User choices about our use and disclosure of personal data.
How we use collected data
The information we collect about you, or that you provide to us, including any personal information, is used to:
Present the Site and its content to you;
Provide, upon your request, information, products or services;
Carrying out the purposes of our core business activities:
Compliance with RTI's obligations to tablers and other individuals
Financial processing
Supporting RTI, including fundraising initiatives
Facilitation of planning for Congress and special events
Communication of the organisation's key messages through publications and other RTI materials
Support of RTI's programmes and membership
Compliance with all legal obligations
Carry out the activities for which you have provided us with your information;
Allow us to fulfil our obligations and exercise our rights under contracts entered into between you and us, including billing and collection of payments;
Notify you of any changes to the Site or products or services offered through the Site;
Allow you to use the interactive features of the Site;
Store data about your preferences and offer you contextualised content based on your personal preferences;
All other purposes of which you are informed when you provide your personal data.
All other purposes for which you provide us with your consent.
Your data may also be used to offer you goods and services, either ours or those of third parties, in which you may be interested. RTI confirms its commitment not to sell or disclose the data of its members without the prior consent of the Board. If you wish to prevent your data from being used in the ways described above, you may do so by contacting us. For more information see User Choices regarding our use and disclosure of personal data.
Disclosure of personal data
RTI may share with third parties, without restriction, data about its users in aggregate form and other data that does not directly identify you.
We may also share personal data collected or obtained directly from you as described in this Policy:
With service providers and other external parties engaged to support us in our activities, who have contractually agreed not to disclose the data collected and to use it only for the purposes for which we have disclosed it to them.
With third parties (with your prior consent), so that they can send you promotional messages regarding their products or services. These parties have undertaken to protect the confidentiality of the personal data to which they will have access and to use them only for the agreed purposes. For more information see your choices about our use and disclosure of personal information.
To enable us to carry out the activities for which you have provided us with your data.
For any other purpose of which you will be informed when you are asked to provide such data.
With the user's consent.
The personal data collected may also be disclosed:
To respond to court orders, judicial or legal proceedings and other legal measures imposed by competent authorities.
If we believe that such disclosure is necessary to protect the rights, property or safety of RTI, RTI partners, RTI boards and other RTI entities. This includes exchanging data with other companies and organisations for the purpose of protecting against fraud and reducing credit risk.
Your choices about how we use and disclose personal data
RTI has put in place the following mechanisms to give you the ability to exercise control over your data:
Tracking and advertising technologies. You can set your browser to reject all cookies, accept only some cookies, or ask to be notified each time a cookie is set. If you choose to disable these technologies or refuse cookies, some pages on this Site may not be accessible or may not function properly. In addition, you will not be able to access RTI's offerings.
Disclosure of personal data for third party advertising. If you do not want your personal information to be shared with third parties not affiliated with RTI for promotional purposes, you may in some cases express this preference by going to your profile pages on the Site and setting your privacy preferences by checking or unchecking the relevant options. Alternatively, you may submit your request by sending an email to info@roundtable.it.
Promotional Offers. If you do not want your contact information to be used by RTI for the promotion of RTI or third party products or services, you may in some cases express this preference by going to your profile pages on the Site and setting your privacy preferences by checking or unchecking the relevant options. Alternatively, you may forward your request by sending an email to info@roundtable.it. If you have already received a promotional email, you may reply to the sender asking to be removed from the distribution lists.
Personal data and privacy of RTI foundation donors
RTI will not sell, exchange or share an RTI Foundation donor's personal data, including name, phone number, email or mailing address, with any non-tablers or send communications to donors on behalf of other independent organisations. This regulation applies to all data received by RTI, whether online or offline, as well as any other communication in digital, written or oral format. RTI occasionally uses external providers to manage and process donors' personal data who are bound by strict confidentiality agreements.
Access to personal data and changes
You can check and change your data by the following methods:
By sending an email to info@roundtable.it to request access to your data or to correct or delete data you had previously provided to us.
Requests for changes may be rejected if it is believed that they are in violation of the law or may be incorrect. Your content, even if removed by the owner, may still be viewable in the cache or archive pages or may have been copied or archived by other users of the Site. However, for residents of the EU/EEA, this does not affect your mandatory rights under EU privacy legislation (see Appendix A: EU Privacy Policy).
Minors under 16 years of age
RTI does not knowingly collect information from minors or children under the age of 16. We do not knowingly collect data from persons under the age of 16 without the written consent of their parents or legal guardians. They are asked not to use our Site to provide information, register, make purchases, use features that allow the public to post comments or provide personal information including name, address, telephone number, e-mail address, aliases or user names. If we become aware that we have collected personal data relating to a child under the age of 16, in the absence of demonstrable parental consent we will delete it. Anyone who believes that we have collected data from a child under the age of 16 should contact us at info@roundtable.it.
Data protection
RTI has taken appropriate measures to protect your information from loss, unauthorised access, use, alteration and disclosure. When developing new systems or improving existing systems and processes, RTI implements adequate data protection during all data processing operations.All data provided to us by users is stored on secure servers protected by firewalls and we use Secure Sockets Layer (SSL) to ensure that the transmission of sensitive data for payments and contributions is encrypted and adequately protected. We provide our employees with training on the importance of data security and focus specifically on practices related to protection against unauthorised disclosure of personal data. We have a documented plan for responding to incidents that violate RTI's security or privacy policies, and this plan is reviewed and updated regularly.
Data security also depends on the user. The password given by us to you (or chosen by you) to enable you to access certain sections of our Site must be kept confidential by you. Passwords registered with the Site are encrypted to protect you from unauthorised access to your personal data. You are asked not to disclose your password to anyone. Similarly, caution should be exercised before releasing information in the sections of our Site that are open to the public, as they could be seen by anyone.
Unfortunately, the transmission of data via the Internet is not always completely secure. Although we do our best to protect your personal data, we cannot guarantee the absolute security of personal data transmitted to our Site. You must therefore bear the risk of the transmission of your personal data. RTI accepts no liability for any circumvention of the data protection settings and other security measures in place on our Site.
Changes to this Policy
RTI may change, add, amend or remove sections of this Policy at any time. Such changes will take effect immediately upon their posting on this page. The date of the last revision of the Policy can be found at the bottom of the page. You are responsible for periodically reviewing this Policy to inform yourself of any updates. By continuing to visit our Site, join our clubs, use our services, or participate in our programs you give your implied consent to the changes to the Policy.
Contact Information
If you have any questions about RTI's privacy practices, please send an email to info@roundtable.it
Last modified: 15 December 2018
Appendix A: Privacy policy for EU residents
The following additional information applies to residents of the European Union (EU) or European Economic Area (EEA) whose personal data we collect.
Introduction
In the case of EU or EEA residents whose data (‘personal data’) RTI collects, with certainty, this is done in compliance with all applicable data protection and privacy laws. This includes, but is not limited to, the EU General Data Protection Regulation (2016/679) (‘GDPR’) and the national laws of the EU member states that deal with or regulate the collection, processing and privacy of personal data (collectively ‘EU Data Protection Rules’).
This EU Resident Privacy Policy (‘EU Resident Privacy Policy’), which should be read in conjunction with RTI's Privacy Policy, provides additional information, as required by the EU Data Protection Rules, about how we treat or process personal data that we collect and with whom we may share it.
This privacy policy provides information about your statutory rights under the EU Data Protection Rules and how to exercise them.
How we collect personal data
Due to the global nature of our organisation and its network of clubs, RTI may hold and process data collected from clubs, districts and partner organisations around the world, including within the EU/EEA.
This means, among other things, that personal data of members or individual contacts of this network residing in the EU/EEA may be transferred from the EU/EEA to RTI headquarters in the United States.
The US Privacy Rule is currently not considered to provide the same level of legal protection for personal data as the EU Data Protection Rules. However, in order to safeguard personal data received from the EU/EEA, we allow such data transfers to the US or other third countries only on the basis of approved contracts or other appropriate mechanisms legally authorised under the EU Data Protection Rules.
This is to ensure that personal data received and processed by RTI (insofar as it relates to EU/EEA residents) is properly safeguarded at levels of legal protection similar to those it would enjoy under the EU Data Protection Rules.
Direct Marketing
If RTI sends direct marketing communications to EU/EEA residents about services or events that may be of interest to them, this will be done in accordance with the EU Data Protection Rules; in particular, any contact by us with individuals for the purpose of direct marketing via MS, email, fax, social media and/or any other electronic communication channel will only take place with the consent of the individual concerned or in connection with similar services previously purchased (or directly requested for the purpose of purchase) from RTI by the individual concerned.
Data subjects are also free to object or withdraw their consent to receive direct marketing from us at any time by contacting us at the email address set out below.
Basis of lawfulness for data collection and processing
Personal data is processed by us for the purposes set out above in accordance with one or more of the following lawfulness grounds recognised by the EU Data Protection Rules
(a) when you have freely given your specific, informed and unambiguous consent to the processing of your personal data by RTI for specific purposes;
(b) when RTI has agreed to provide services to the data subject in order to organise and perform what is contractually due and/or exercise its rights;
(c) when it is necessary for us to process and use personal data in connection with our legitimate interests as a global organisation and in order to manage and operate our organisation effectively and consistently in each territory. At all times, we shall endeavour to pursue such legitimate interests in a manner that does not unduly infringe the freedoms and legally recognised rights of data subjects, and in particular their right to privacy; and/or
(d) when it is necessary for us to comply with legal obligations or in order to certify, exercise or protect our rights in court.
Please also note that some of the personal data we receive and process may include so-called ‘sensitive’ or ‘specially processed’ data, such as data relating to ethnic origin or political, philosophical or religious beliefs. This type of data is not part of the data normally collected by RTI or its clubs, but in the event that we need to process this type of sensitive or specially processed data, we will only do so in specific situations where:
(a) the data has been provided to us with explicit consent for such use
(b) there is a legal obligation for us to process such data in accordance with the EU Data Protection Rules
(c) it is necessary to protect vital interests of the data subject (or of others), such as in cases of medical emergencies; or
(d) the data subject has clearly chosen to make such information public; or
(e) when it is necessary in connection with legal proceedings to which we are or may be subject.
Disclosure of personal information to third parties
We may disclose personal information to certain third party organisations that process data solely in accordance with our instructions (referred to as ‘data processors’) such as companies and/or organisations that support our business and operations (e.g. web or database hosting providers, IT support, payment service providers, agencies used by us to conduct fraud audits or mail handling service providers), as well as to professionals used by us, such as lawyers, insurance agents, auditors or accountants. We only use data processors who can assure us that they have put in place adequate safeguards to protect the personal data they process on our behalf.
We may also disclose personal data to third parties who independently make their own decisions about how to process personal data and for what purpose(s) (referred to as ‘data controllers’). The third party data controllers defined above may process personal data according to their own procedures and data subjects are encouraged to check the relevant privacy policies of such companies or organisations in order to understand how they may use their personal data.
Except as described above, we will treat personal data as confidential and will not routinely disclose it to third parties without informing the data subjects. Exceptions include legal proceedings and cases where there is a legal obligation for us to do so without informing the data subject (such as police investigations). In all cases, it is our aim to ensure that personal data is used by the third parties we work with for lawful purposes and in accordance with the principles of the EU Data Protection Rules.
Length of personal data retention
RTI retains personally identifiable data for as long as is necessary in the specific circumstances; for example, as long as the person is a member of a club or as long as he or she is in a relationship with our network; for a reasonable period for sending promotional material where there is regular contact with the data subject; or for as long as is necessary for the exercise of or legal defence against contractual claims or as dictated by applicable law.
RTI has adopted a data retention policy for EU residents (which can be made available on request) which specifies the different periods for which we may retain personal data in compliance with the duties imposed on us by the EU Data Protection Rules. The criteria we use to determine the relevant retention and deletion periods are based on the purposes for which we hold such data and the reasonable expectations of those whose personal data we collect in such circumstances, taking into account the various legal requirements and guidance issued by the relevant EU authorities.
In accordance with the aforementioned data retention regulations, personal data that we no longer need will be deleted or converted into an anonymous form such that the identity of the data subjects cannot be traced from it.
Your rights to your personal data
In accordance with their rights under the EU Data Protection Rules, data subjects have the right to submit requests for access, whereby they may be asked to provide information about the personal data we hold about them, the use we make of that personal data and to whom it may be disclosed, and certain other information.
Generally, we will have one month to respond to a request for access. However, we reserve the right to verify the identity of the requester and, in particularly complex cases, to take an additional two months to respond. We may also charge a fee for the administrative time taken to process manifestly unreasonable or excessive requests. We may also request additional information to locate the specific information that is the subject of the request, and certain legal exemptions under the EU Data Protection Rules may apply when responding to access requests.
Under the EU Data Protection Rules, EU/EEA residents also have the following rights, which are exercisable upon written request
(a) that their inaccurate or incomplete personal data held by us be corrected by us;
(b) to have their personal data erased by us without undue delay where there is no longer any need for us to hold or process such personal data;
(c) to object (where applicable) to automated processing by us in relation to your personal data, such as where we conduct automated credit scoring
(d) to object to the use of their personal data for direct marketing purposes;
(e) to object to and/or restrict the use of their personal data for purposes other than those set out above, except for compelling legitimate reasons; or
(f) that your personal data be transferred by us to third parties where such personal data has been collected with your consent or is used for the performance of contracts entered into with you and is processed by automated means.
Please note that, in order to be able to provide you with a full response, requests may be forwarded to third-party data processors involved in the processing of personal data on our behalf.
If you wish to exercise any of the above rights, please contact us at the address below.
If a request has been made, and our response is deemed unsatisfactory, or if you believe that your personal data is being unlawfully processed by us, you may appeal to The Information Commission Office, UK. Please refer to the attached document.
Contact
If you have any questions or concerns about RTI's privacy practices, or if you believe that RTI has not acted in accordance with this Notice, please contact us at info@roundtable.it