PRIVACY POLICY ARCO CARDS

What is this document?

We at ARCO are committed to safeguarding the privacy of our members. We want you to know how we collect, use, share and store data concerning you and which choices are available to you when you request to become our member.

In this privacy notice, we describe the way in which ARCO (Associazione Ricreativa Circoli Omosessuali), in its capacity as Data Controller, collects, uses, shares and stores your personal data, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the General Data Protection Regulation), during the use of your membership card or during the use of our smartphone application named ONE PASS.

If you interact with us online, you may find an Online Privacy Notice for our website www.arco.lgbt
, which describes how we collect, use, share and store your personal data in this context. The information collected under this privacy notice will be used together with the information collected online about you. Therefore, we invite you to also review the Online Privacy Notice.

ARCO reserves the right to amend this Privacy Notice. Depending on the nature of the changes, members will be informed of such changes through communications via our website www.arco.lgbt
and any other IT channels of the Association.

Source of personal data

This privacy notice describes how we (and our Service Providers) collect, use, share and store your personal data. The personal data we collect may vary depending on the service you request or use.

We collect personal data relating to you in the following ways:

• from the membership application form or other documents you provide to us;
• from the request or use of products, goods or services you make (for example, when you use your Membership Card to make transactions with our affiliates or within the smartphone application named ONE PASS);
• from you, through the way you communicate with us and use your Membership Card (for example, email addresses, physical addresses, telephone numbers provided/displayed during calls to member support);
• from any market research, surveys, etc. in which you participate or access, or from any marketing offers for which you have given consent to receive.

Purpose of processing

We use your personal data: (i) where necessary for the performance of a contract or compliance with a legal obligation; (ii) for our legitimate interests, such as exercising and protecting our legal rights, preventing fraud and/or improving our services; or (iii) where we have obtained your consent, for marketing purposes, including profiling.

More specifically, we use your personal data for the following purposes:

to provide products and services, including but not limited to:

• processing your membership application, which involves making decisions regarding approval of your request and the subsequent issuance of the ARCO Membership Card;
• administering and managing your Membership Card, such as checking its validity when accessing our affiliates;
• communicating with you via email, SMS or other methods you have authorised regarding your Membership Card, to update you on new features and new benefits relating to our ONE PASS app, and for communications related to products or services you have requested;
• providing and managing any additional benefits and membership programs associated with the products or services requested;
• responding to your questions and requests.

2. to advertise and offer products and services of ARCO and our Business Partners, including but not limited to:

• presenting content tailored to your expressed preferences;
• helping us understand whether you are interested in new products or services;
• communicating to you, with your prior consent, offers (by mail, email, phone, SMS, online or through other electronic communication tools such as our ONE PASS app) regarding products and services that may interest you or that are similar to the ARCO products and services you currently use.

3. to improve our products and services and conduct research and analysis, including but not limited to:

• understanding your needs, preferences and behaviours;
• accurately analysing whether our advertisements, promotions, and offers are effective;
• performing tests to ensure the security and updating of our systems, processing data, administering our website, supporting and developing the technological infrastructure system;
• allowing you to express your opinion on general topics or matters related to association life or LGBT issues, as well as for evaluating our products and services;
• processing data analysis, statistical research and reports on an aggregated basis.

4. to manage fraud, operational and security risks (using automated and/or manual processes), including but not limited to:

• detecting and preventing fraud or criminal activity;
• safeguarding the security of your personal data.

5. to comply with applicable laws and regulations, exercise and protect our legal rights, assist in dispute resolution, process and manage your membership request (or customise your offers) using automated and/or manual processes.

Data disclosure

We do not disclose your personal data to anyone, except as described below. We may disclose your data only with your consent or as required or permitted by applicable laws, for example:

• to regulatory authorities and courts, in order to comply with rulings, regulatory or legal requirements, and requests from such authorities;
• to our Service Providers, who perform services on our behalf;
• to any third party you authorise.

Marketing choices

You may choose how you prefer to receive – or not receive – marketing communications, including direct marketing via regular mail, email, SMS or phone, at the time of your membership request. If you no longer wish to receive marketing communications from ARCO and Business Partners, you will soon be able to access the protected area of the website arco.lgbt and update your privacy preferences. If you prefer, you may contact ARCO at info@arco.lgbt
to update/learn about your preferences. If you choose not to receive marketing communications from our Association, your choice will be respected.

You should be aware that, if you choose not to receive such promotional communications, certain offers relating to products or services you have selected may not reach you.

Furthermore, we will continue to contact you regarding the management of your Membership Card, the fulfilment of your requests, or the management of promotions or programs you have consciously chosen to participate in.

Data retention

We will retain your data—excluding your personal details, membership data and membership history—only for the time necessary to provide the requested products and services, unless we are required to retain them for longer periods due to laws, regulations, or if necessary for resolving disputes or legal investigations. If your membership has an irregular status after cancellation, such information may be retained by our Association for longer periods and taken into consideration if you request to join ARCO again in the future.

When your data is no longer required for legal or regulatory needs, or for managing your membership and providing the products and services you requested, our Association will take reasonable measures to securely destroy such data or render it permanently unidentifiable. For more information on how we retain personal data, you can contact ARCO at info@arco.lgbt

International data transfer

We may transfer your data outside Italy or the EU, for example to the United States and the United Kingdom (where our main operational data centers are located), as well as process transactions and provide our products and services.

Regardless of where we process your data, we will take appropriate measures to ensure an adequate level of protection even in countries outside Italy or the EU, including the United Kingdom and the United States.

Security

We use organisational, administrative, technical and physical security measures to safeguard your data and ensure it is processed in a timely, accurate and complete manner. We require our Service Providers to safeguard your data and to use it only for the purposes specified and as set out in this privacy notice.

Access to data

We encourage you to regularly verify that your data in our possession is accurate and up to date. If you believe it is incorrect or incomplete, you may request that such data be corrected, updated, or removed from our Association’s records. Additionally, you will soon be able to update your personal information by accessing the protected area of our website. If you wish, you can exercise your rights by contacting ARCO’s Membership Office at Via della Salute 8/2/a, 40132 BOLOGNA or at info@arco.lgbt

Member rights

You have the right to access, update, delete, modify or correct your personal data. In particular, you have the right to:

• withdraw consent for the use of your personal data at any time, where processing is based on your consent. However, failure to provide or withdrawal of personal data collected in the membership application form, or other personal data that may be requested during the membership relationship, may result in the Association being unable to establish and/or continue, in whole or in part, the relationship or to process your membership request;
• limit and/or object to the use of your data;
• request a manual review of certain automated data processing activities that affect your rights;
• request a copy of your personal data held by our Association;
• withdraw your consent to receive marketing communications from ARCO.

If you wish to exercise your rights, you can contact ARCO’s Membership Office, Via della Salute 8/2/a, 40132 Bologna, or write to info@arco.lgbt attaching a valid government-issued ID for proper identification.

Questions or complaints

If you have questions regarding this privacy notice or how your data is handled, you may contact the Data Protection Officer of our Association at:

ARCO, Via della Salute 8/2/a, 40132 Bologna, or by email at info@arco.lgbt

If you wish to file a complaint, you may contact ARCO’s Complaints Office at Via della Salute 8/2/a, 40132 Bologna, or write to arco.lgbt@pec.it

You also have the right to contact directly the Italian Data Protection Authority (Garante per la protezione dei dati personali), Piazza Venezia 11, 00187 ROME, Telephone switchboard: (+39) 06.696771, Email: protocollo@gpdp.it
, Certified email: protocollo@pec.gpdp.it

Glossary

ARCO (we, our Association) – ARCO Associazione Ricreativa Circoli Omosessuali, Data Controller.

ONE PASS – Smartphone application for digital management of the ARCO card and display of clubs and partners participating in the “ONE PASS” recreational network.

Personal data – data relating to an identified or identifiable natural person, such as name, address, telephone number and email address, and other information specific to that person, such as demographic data and transaction information.

Service Providers – any provider, third party and/or company that provides services or performs operations on behalf of our Association, such as printing, mailing and other communication services (email, direct mail, etc.), marketing, data processing and outsourced technology, support, management of advertising campaigns.

Business Partners – third parties with whom we operate and have contractual relationships as external data processors, or as independent controllers, distributors, providers of insurance and travel services, and parties that accept ARCO-branded membership cards for discounts and/or promotions on goods/services purchased by the member (e.g., affiliated businesses).

Last updated 06/05/2023

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