Updated to EU Reg. 2016/679
(European Regulation on the Protection of Personal Data)


1) Introduction

Gaycs takes your privacy seriously and is committed to respecting it. This privacy policy describes the personal data processing activities carried out by Gaycs through the website and the related commitments undertaken by the Association. Gaycs may process your personal data when you visit the Site and use the services and features on the Site. In the sections of the Site where the user’s personal data is collected, a specific information notice is normally published pursuant to art. 13 /15 of EU Reg. 2016/679.

If provided for by EU Reg. 2016/679 will be required the consent of the user before proceeding to the processing of your personal data. If you provide personal information to third parties, you must ensure that your disclosure to Gaycs and subsequent processing for the purposes specified in the applicable privacy policy complies with EU Reg. 2016/679 and applicable law.


2) Identification of the data controller

Adriano Bartolucci Proietti, Via Orvinio 2 00199 Rome;


3) Type of data processed

Visiting and browsing the Site generally does not involve the collection and processing of your personal data except for browsing data and cookies as specified below. In addition to the so-called “navigation data” (see below), may be processed personal data voluntarily provided by the user when he interacts with the functionality of the Site or requests to use the services offered on the Site. Subject to the Privacy Code, Gaycs may also collect your personal data from third parties in the course of its business.


4) Cookies and navigation data

The Site uses “cookies”. By using the Site, you consent to the use of cookies in accordance with this Privacy Policy. Cookies are small files stored on your computer’s hard drive. There are two cookie macro-categories: technical cookies and profiling cookies.

Technical cookies are necessary for the proper functioning of a website and to enable your navigation; without them you may not be able to view the pages correctly or use certain services.

Profiling cookies have the task of creating user profiles in order to send advertising messages in line with the preferences expressed by the same during navigation.

Cookies can also be classified as:

  • “session” cookies, which are deleted immediately when the browser is closed;
  • “persistent” cookies, which remain within the browser for a certain period of time. They are used, for example, to recognize the device that connects to a site and make authentication easier for the user;
  • “own” cookies, generated and managed directly by the operator of the website on which the user is browsing; “
  • “third party” cookies, generated and managed by parties other than the operator of the website on which the user is browsing.


5) Cookies used on the site

The Site uses the following types of cookies:

  • own, session and persistent cookies, necessary to allow navigation on the Site, for internal security and system administration purposes;
  • third party cookies, session and persistent, necessary to allow the user to use multimedia elements on the Site, such as images and videos;
  • third party cookies, persistent, used by the Site to send statistical information to the Google Analytics system, through which Gayc can perform statistical analysis of access / visits to the Site. The cookies used are for statistical purposes only and collect information in aggregate form. Through a pair of cookies, one persistent and the other session (expiring when the browser is closed), Google Analytics also saves a register with the times of the start of your visit to the Site and of your exit from it. You can prevent Google from collecting data via cookies and then processing the data by downloading and installing the browser plug-in from the following address:
  • persistent third-party cookies used by the Site to include in its pages the buttons of certain social networks (Facebook, Twitter and Google+). By selecting one of these buttons, the user can publish on his/her personal page of the relevant social-network the contents of the web page of the Website he/she is visiting

The following table shows a detail of the cookies on the Site


Indicate the name of the site Indicate whether you Indicate the purpose of Indicate  the  privacy
or a third party the presence of cookies policy of reference Your system administration Point 1 Point 2
Google Analytics Third party analysis Point 3
Facebook Third party Social Sharing Point 4


The Site may contain links to other sites (so-called third party sites). Gaycs does not access or control cookies, web beacons or other user tracking technologies that may be used by third party sites that you may access from the Site; Gaycs does not control the content or materials posted to or obtained through third party sites, or how your personal information is processed, and expressly disclaims any and all liability in connection therewith. The user is required to check the privacy policy of third party sites that he accesses through the Site and to inform himself about the conditions applicable to the processing of his personal data. This Privacy Policy applies only to the Site as defined above.


6) How to disable cookies in browsers

In this section you will find links to how to deactivate cookies for the following borwsers: Chrome, MozillaFirefox, Internet Explorer, Safari, Opera – data available on Google


7) Storage of personal data

Personal data is stored and processed through information systems owned by Gaycs and operated by Gaycs or third party technical service providers; for more details please refer to the section entitled “Scope of Access of Personal Data” below. The data are processed exclusively by specifically authorised personnel, including personnel responsible for carrying out extraordinary maintenance operations.


8) Purposes and methods of data processing

Gaycs may process your personal data for the following purposes: use by users of services and features on the Site, management of requests and notifications by its users, sending newsletters, management of applications received through the Site, management of subscriptions to training courses and events promoted by the Association etc. .

Furthermore, with the additional and specific optional consent of the user, Gaycs may process personal data for marketing purposes, i. e. to send the user promotional material and/or commercial communications relating to the services of the Association, at the addresses indicated, either through traditional methods and/or means of contact (such as paper mail, telephone calls with an operator, etc. ) or automated (such as, communications via the Internet, fax, e-mail, SMS, applications for mobile devices such as smartphones and tablets – so-called apps -, social network accounts – e. g. via Facebook or Twitter -, telephone calls with an automatic operator, etc. ).

Personal data are processed both in paper and electronic form and entered into the information system in full compliance with EU Reg. 2016/679, including security and confidentiality profiles and inspired by the principles of fairness and lawfulness of treatment. In accordance with the EU Reg 2016/679 the data are stored and conserved until the interested party indicates his intention to have his data deleted with a written request to be sent to the email to


9) Security and quality of personal data

Gaycs is committed to protecting the security of your personal data and complies with the security provisions of applicable law in order to prevent loss of data, unlawful or unlawful use of data and unauthorized access to them, with particular reference to the Technical Regulations on minimum security measures. In addition, the information systems and computer programs used by Gaycs are configured to minimize the use of personal data and identification,such data are processed only for the achievement of specific purposes from time to time pursued. Gaycs uses a variety of advanced security technologies and procedures to help protect your personal information; for example, your personal information is stored on secure servers located in secure, controlled access locations. You may help Gaycs update and maintain your personal information by notifying us of any changes to your address, job title, contact information, etc. by sending an email to


10) Scope of communication and access to data

The user’s personal data may be communicated to:

  • all subjects whose right to access these data is recognized by regulatory measures;
  • to our collaborators, employees, as part of their duties;
  • to all those natural and/or legal persons, public and/or private when the communication is necessary or functional to the carrying out of our activity and in the ways and for the purposes illustrated above;
  • to EGLSF


11) Nature of conferment of personal data

The provision of some personal data by the user is required to allow the Association to handle communications, requests received from the user or to contact the user to respond to his request. This type of data is marked with an asterisk [*] and in this case the provision is mandatory to allow the Association to respond to the request that, in default, can not be processed. On the contrary, the collection of other data not marked with an asterisk is optional: failure to do so will not have any consequences for the user.

The provision of personal data by the user for marketing purposes, as specified in the section “Purposes and methods of treatment” is optional and refusal to provide them will not have any effect. The consent given for marketing purposes is extended to the sending of communications through methods and / or means of contact both automated and traditional, as above exemplified.


12) Rights of the interested party

  1. 1) Art. 15 (Right of access) , 16 (Right of rectification) of EU Reg. 2016/679

The interested party has the right to obtain from the owner of the treatment confirmation that or not is in progress a processing of personal data concerning him and in that case, to obtain access to personal data and the following information:

  • the purposes of the processing;
  • the categories of personal data concerned;
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular if they are recipients in third countries or international organisations;
  • the envisaged period of retention of the personal data or, if that is not possible, the criteria used to determine that period;
  • the existence of the right to require the data controller to correct or erase personal data or to limit the processing of personal data relating to him or her or to object to their processing;
  • the right to lodge a complaint with a supervisory authority;
  • the existence of an automated decision-making process, including profiling and, at least in such cases, meaningful information on the logic used, as well as the importance and the expected consequences of such processing for the data subject.

The right of access and the right of rectification can be exercised by writing an email to


  1. 2) Right as per art. 17 of EU Reg. 2016/679 – right to cancel (“right to be forgotten”)

The interested party has the right to obtain from the data controller the cancellation of personal data concerning him without undue delay and the data controller has the obligation to delete without undue delay personal data, if there is one of the following reasons:

  • personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • the data subject withdraws the consent on which the processing is based in accordance with point (a) of Article 6(1) or point (a) of Article 9(2) and if there is no other legal basis for the processing;
  • the data subject objects to the processing referred to in Article 21(1) and there is no overriding legitimate reason for the processing, or objects to the processing referred to in Article 21(2);
  • the personal data have been processed unlawfully;
  • personal data must be erased in order to comply with a legal obligation under Union law or the law of the Member State to which the data controller is subject;
  • the personal data have been collected in relation to the offer of information society services as referred to in Article 8(1) of Regulation (EU) No 2016/679

The person concerned can have recourse to the cancellation of his data, and then easily exercise his right to oblivion, by writing an email to


  1. 3) Right under Art. 18 Right to limitation of processing

The interested party has the right to obtain from the holder of the treatment the limitation of the treatment when one of the following cases occurs:

  1. the data subject disputes the accuracy of the personal data, for the period necessary for the data controller to verify the accuracy of such personal data;
  2. the processing is unlawful and the data subject objects to the erasure of personal data and requests instead that the use of such data be restricted;
  3. although the data controller no longer needs them for the purposes of the processing, the personal data are necessary for the data subject to ascertain, exercise or defend a right in court;
  4. the data subject has opposed the processing pursuant to Article 21, paragraph 1, of EU Reg. 2016/679 pending verification of whether the legitimate reasons of the data controller prevail over those of the data subject.


  1. 4) Right as per Art. 20 Right to data portability

The data subject has the right to receive in a structured format, in common use and readable by automatic means, personal data concerning him provided to a data controller and has the right to transmit such data to another data controller without hindrance of any kind.