Privacy Policy

1. Data Controller

The Data Controller for the processing of personal data is WECANCHANGEIT S.R.L.S., manager of the CIO Club Italia® trademark, with registered office at Via Toledo 156 — 80134 Naples (NA), Italy, VAT no. 09503671217, in the person of its Legal Representative Pasquale Testa.

Contact: p.testa@cioclubitalia.it

2. Data collected and purposes

The website collects the following personal data:

• Browsing data — IP address, browser type, pages visited. Collected automatically for technical and security purposes.
• Registration data — first name, last name, professional email, role, password (encrypted). Provided voluntarily by the user to access membership services.
• Contact data — email provided via form or direct communications, to respond to requests.

The purposes of processing are:

• Management of membership registration and relationships (legal basis: performance of a contract)
• Sending institutional communications and newsletters (legal basis: consent)
• Compliance with legal and tax obligations (legal basis: legal obligation)

3. Data retention

Browsing data is retained for the time strictly necessary to provide the service. Members' data is retained for the duration of the membership relationship and for the following 10 years, in compliance with the tax and accounting obligations required by Italian law.

4. Disclosure and dissemination

Personal data is not disclosed to third parties for commercial purposes. It may be disclosed to:

• Technical suppliers providing services on behalf of the association (hosting, event platforms), acting as Data Processors under Art. 28 GDPR
• Public authorities, in cases provided for by law

5. Rights of the data subject

Under Articles 15-22 of EU Regulation 2016/679 (GDPR), the data subject has the right to:

• Access their personal data (Art. 15)
• Rectify inaccurate data (Art. 16)
• Obtain erasure of data ("right to be forgotten", Art. 17)
• Restrict processing (Art. 18)
• Data portability (Art. 20)
• Object to processing (Art. 21)
• Withdraw consent at any time (Art. 7)

To exercise your rights, write to p.testa@cioclubitalia.it. You may also lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) at www.garanteprivacy.it.

6. Transfer of data outside the EU

Data may be processed by suppliers with servers located in the European Union or in third countries that guarantee an adequate level of protection under the GDPR (e.g. Standard Contractual Clauses). The hosting provider is Vercel Inc. (USA), which adheres to GDPR-compliant transfer mechanisms.

7. Changes to this policy

The Data Controller reserves the right to modify this Privacy Policy at any time. Changes will be published on this page with an updated date at the bottom.