Purposes of personal data processing

Your personal data have been freely given by you [the «data subject»] and acquired by us due to the activities performed by the undersigned EMN These personal data will be lawfully and fairly processed with the following purposes:

inclusion of users’ data in the electronic system;
administrative and accounting management of personal data.

The processed data can be common data, identifying data, or sensitive data. The processed data are up to date, relevant, and complete; they do not exceed the aforementioned purposes for which they are collected and subsequently processed.


Procedures of personal data processing
Data will be processed adopting the following procedures, in a manner that ensures appropriate security and confidentiality. Collection of data from the data subjects: these data are collected and registered for specific, explicit and legitimate purposes; they are used in other processing operations in full conformance with the aforementioned purposes; data are processed by electronic and automated means.


Legal basis of the data processing
The legal basis of the processing of your personal data is the Article 6 of the GDPR. You, as data subject, agree with the processing of your personal data for the aforementioned purposes. This is necessary for the execution of the agreement in which you are an involved part.


Legitimate interests of the data controller
Legitimate interests of the data controller are a consequence of the necessary fulfillment of and compliance with the agreement obligations undersigned by the parts. In compliance with the Article No. 6 of the GDPR, the lawfulness of the data processing is based on the explicit consent provided in writing by the data subject.


Mandatory or discretionary nature of data disclosure and consequences of a possible refusal to provide information
Your data disclosure is necessary, in order for the data controller to provide the services required. In case of refusal, it will be impossible to complete the registration process and the data controller will be unable to fulfill the obligations of the agreement.


Disclosure to third parties
Your personal data will be processed by the data controller, by the data processors appointed by the data controller and by the strictly authorized data processing staff. Your personal data can be disclosed to companies (if there are any) that share the authority of controlling data. Moreover, due to potential inspections or verifications, your data can be disclosed (if requested) to all the inspecting institutions in charge of the monitoring and verification of compliance with the applicable laws. Your personal data can also be disclosed to professional companies or firms that perform activities of assistance, consultancy, or collaboration for the data controller in relation to accounting, administrative, fiscal, legal, tax-related, and financial matters. Your personal data can also be disclosed to the public administrative authorities for the fulfillment of their institutional functions in compliance with the applicable laws and regulations. Your personal data can also be disclosed to third parties providing services: this disclosure is mandatory for the fulfillment of the services described in the agreement.

Your personal data are not subject to dissemination.


Duration of data storage
As required by the applicable laws and regulations, your personal data will be stored for 10 (ten) years from the end of the agreement for the offer of services/goods.


Automated decision-making processing
There is no automated decision-making processing.


Intentions of the personal data controller
The personal data controller will not transfer your personal data to third countries or international organizations.


Data controller and processor
The data controller is EMN
The data processor is Pieter Sonneveld, MD, PhD


Contacts of the data controller

In your capacity as data subject, you have the rights as set out in the Article No. 15 of the GDPR. More precisely, you have the rights:

to obtain confirmation of the existence of personal data concerning you, even if they have not been registered yet; to receive these data in an intelligible from.


to receive the following information:

a) regarding the source of personal data;
b) regarding purposes and procedures of the data processing;
c) regarding the logics applied to the possible use of electronic devices;
d) regarding the identity of the data controller, of the data processors, and of the designated representative in compliance with the Article No. 5, Paragraph 2 of the Personal Data Protection Code and with the Article 3, Paragraph 1 of the GDPR;
e) regarding the subjects or the categories of subjects to whom personal data can be disclosed or who can access personal data as designated representatives of controllers or processors in the European Union’s territory.


to obtain:

a) the update, the rectification or (if you deem it necessary) the supplementation of data;
b) the deletion, the anonymization, or the blockade of data processed in infringement of the applicable laws, including those data whose storage is not required in relation to the purposes for which they were collected or subsequently processed;
c) the confirmation that the operations described here above at the letters (a) and (b) have been reported, also in relation to their contents, to the persons to whom the data had been disclosed, except where that fulfillment is found to be impossible or involves the use of means patently disproportionate to the protected right.


to object, in whole or in part:

a) for legitimate reasons, to the processing of personal data relating to you, even if pertinent to the purpose of their collection;
b) to the processing of personal data relating to you and entailing the conveyance of promotional material, the direct sale of products, the conduct of market researches, or the transmission of commercial information done using automated-call methods by e-mail or using traditional marketing methods by phone call and/or printed mail. The right of objection of the data subject, as it is described at the letter (b) and regarding direct marketing methods done using automated methods, is extended to traditional methods. In any case, the possibility remains for the data subject to exercise the right of objection even partially. Therefore, the data subject can decide to receive communications using only traditional methods or only automated communications or none of the two types of communication.

Where applicable, the data subject keeps also the rights as set out in the Articles 16-21 of the GDPR (right to rectification, right to be forgotten, right to restriction of processing, right to data portability, right to object), as well as the right to complain to the competent supervisory authority.