Privacy Policy – Personal Data Processing
Pursuant to Article 13 of EU Regulation 2016/679 (GDPR)
The Fondazione Haydn of Bolzano and Trento, as the Data Controller, informs you—pursuant to Article 13 of EU Regulation 679/2016—about the processing of personal data you provide for the management of the contractual relationship.
Purpose and Legal Basis of Processing
The personal data provided (e.g., phone number, name, profile picture) are processed solely for the purpose of sending communications via the WhatsApp Business broadcast channel, activated upon the user’s request.
These communications may include:
- updates and informational content related to the requested service;
- notifications, alerts, reminders, or organizational content directly linked to the service.
In both cases, the legal basis for processing is Art. 6(1)(b) of EU Regulation 679/2016 (performance of a contract or pre-contractual measures requested by the data subject).
No marketing communications will be sent unless explicitly requested, and no processing beyond what is necessary for the service activation will be carried out.
Processing Methods
Processing is carried out using electronic tools, exclusively through the WhatsApp Business broadcast function, which allows the Data Controller to send one-way messages (subscribed users cannot reply).
No automated decision-making or profiling of the data subject is involved.
Recipients or Categories of Recipients
Data may be processed by:
- authorized personnel of the Data Controller, properly trained;
- technology service providers (e.g., cloud providers, digital services), possibly appointed as Data Processors pursuant to Article 28 GDPR.
Data will not be disclosed.
An up-to-date list of Data Processors is available upon request.
Data Transfer to Third Countries
Using WhatsApp may involve the potential transfer of data to non-EU countries.
Processing is carried out in compliance with Articles 44 and following of the GDPR through standard contractual clauses and, where applicable, adequacy decisions or international agreements and protocols (e.g., EU-U.S. Data Privacy Framework).
WhatsApp LLC (Meta Platforms) may process data on servers located in the United States or other countries.
Data Retention Period
Data will be processed for the duration of the subscription to the broadcast channel and deleted within 12 months of the last meaningful interaction or upon request for unsubscription.
Users may leave the channel at any time directly via the WhatsApp interface.
Nature of Data Provision
Providing data (phone number, subscription to the channel) is optional but necessary to receive content via the broadcast channel.
If data is not provided, communications via this channel cannot be delivered.
Data Controller and Data Protection Officer
Data Controller: Fondazione Haydn of Bolzano and Trento, via Gilm 1/a, 39100 Bolzano, Tel. +39 0471 975031, Email: info@haydn.it
Data Protection Officer: Dr. Federica Ziglio, via Mazzini 14, 38122 Trento, Tel. +39 0461 261768, Email: info@ziglioassociati.it
Rights of the Data Subject
The data subject has the right to:
- access their data (Art. 15 GDPR);
- request rectification (Art. 16) or erasure (Art. 17);
- restrict processing (Art. 18);
- request data portability (Art. 20);
- object to processing in case of violations (Art. 21).
They also have the right to lodge a complaint with the Italian Data Protection Authority: www.garanteprivacy.it
