Last updated: 01/12/2025

PRIVACY POLICY
OF THE SHINZENBI SAFEGUARDING CENTER

1. Introduction

This document ("Policy") governs the manner in which the Shinzenbi Safeguarding Center (hereinafter, "Center") collects, uses, retains, and protects the personal data of data subjects ("Users"), in compliance with applicable data protection regulations, including the General Data Protection Regulation (EU Regulation 2016/679, "GDPR").

The use of our services implies acceptance of the terms of this Policy. We invite Users to read it carefully and contact us for any clarification.

 

2. Data Controller

The Data Controller is the Association A.C.S.D. SHIN ZEN BI (Tax Code 91141730159)

The Data Controller guarantees compliance with personal data protection legislation and undertakes to process data lawfully, fairly, and transparently.

 

3. Types of data collected

The Center may process the following categories of personal data:

3.1. Common data provided directly by the User:

Reporting Form:

  • Reporter: Name and Surname, Date and Place of Birth, Role, Address, Phone, Email.  
  • Data of the Person Involved: The situation you wish to report, What do you think is the risk level of the episode?, Name and Surname, Age, Role, Gender, Nationality, Disability, Have Parents Been Informed?, How Do They Intend to Proceed?, Medical Intervention, Did Law Enforcement Intervene?,
  • Person Responsible for the Abuse: Name and Surname, Place of the event, Date, Time, Repeated actions, Additional Details, Additional details of the event.
  • Witnesses: Witness Name, Details of the event reported by the witness;

Contact Form:

  • Gym of Origin;
  • Name and Surname;
  • email address, phone number;
  • reason for contact, content of the request;

3.2. Sensitive data (special categories of data):

The Center may process sensitive data (for example, data relating to health, ethnic origin, religious or political opinions) exclusively within the limits provided for by applicable legislation and subject to the explicit consent of the User, where required.

3.3. Automatically collected data:

    IP address, location data, device type, operating system, and browser information;
    Information on the use of the website or applications managed by the Center (through cookies and similar technologies, where applicable).

 

4. Purposes of processing

The personal data of Users will be processed exclusively for the following purposes:

4.1. Management and resolution of safeguarding-related issues: Receipt, analysis, and processing of reports and support requests.
4.2. Institutional communications: Sending updates, service communications, or information related to the Center's activities.
4.3. Regulatory compliance: Fulfillment of legal or regulatory obligations, including requests from competent authorities.
4.4. Improvement of services: Analysis and monitoring of service use to optimize the quality of the User experience.

The processing of personal data will be carried out based on the following conditions of lawfulness: consent, performance of a contract, fulfillment of legal obligations, or pursuit of the legitimate interest of the Data Controller.
 

5. Retention of personal data

Personal data will be kept for the time strictly necessary to fulfill the purposes for which they were collected, in compliance with the principles of storage limitation and data minimization.

At the end of the retention period, the data will be deleted, anonymized, or made unusable, unless otherwise required by legal or regulatory obligations.
 

6. Methods of processing and data security

The processing of personal data will be carried out using paper, electronic, and/or telematic tools, adopting adequate technical and organizational measures to ensure the security, integrity, and confidentiality of the data.

In particular, the Center adopts measures aimed at:

  • Preventing unauthorized access or data loss;
  • Ensuring protection against alteration, misuse, or unauthorized disclosure;
  • Limiting access to data to authorized subjects only.

 

7. Communication and transfer of data

Users' personal data may be communicated to:

  • President of the Shinzenbi ASD, the ASD board of directors, and the Safeguarding Collaborator, exclusively for purposes strictly related to the service offered;
  • Competent authorities, in compliance with legal obligations or for the protection of the Center's rights and interests;
  • Technical and IT service providers acting as Data Processors.

Data will not be transferred to third countries outside the European Economic Area (EEA) without adequate protection guarantees, in compliance with applicable legislation.
 

8. Data Subject Rights

The User, as the data subject, has the right to:

  • Access their personal data processed by the Center;
  • Request the rectification of inaccurate data or the integration of incomplete data;
  • Request the erasure of their personal data, unless processing is necessary for legal obligations;
  • Restrict data processing in the presence of certain conditions;
  • Object to processing for legitimate reasons, where applicable;
  • Request the portability of their data in a structured, commonly used, and machine-readable format.

Requests related to the exercise of rights can be sent to the Data Controller using the contact details indicated in **section 2.**

 

9. Cookies and tracking technologies

The potential use of cookies or tracking technologies on the Safeguarding Center will be governed by a specific Cookie Policy, available separately.
 

10. Changes to the Privacy Policy

The Center reserves the right to modify this Policy at any time, subject to communication to Users, where required by law. The changes will be effective from the date of publication on the website or direct communication to Users.
 

11. Complaints

In case of violation of the User's rights, a complaint can be submitted to the competent supervisory authority. In Italy, the authority is the Garante per la Protezione dei Dati Personali (www.garanteprivacy.it).