Privacy and Personal Data Protection Policy of AA-MARINET

AA-MARINET is (…), whose mission is (…).

AA-MARINET deals with personal data on a daily basis and it is committed to the policies and obligations imposed by the new European legislation on data protection, namely Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data), hereinafter referred to as GDPR.
AA-MARINET is strongly committed to the protection of personal data for which it is responsible and intends to implement effective technical and administrative measures for the compliance with the principles of data protection, taking into account the nature, scope, context, and purposes of data processing, as well as the risks of failure in the protection of the rights and freedoms of the individuals.
Therefore, this personal data protection policy shall be approved with the purpose of reinforcing its commitment and compliance with the rules of privacy and protection of personal data. This policy shall apply to all operations carried out by AA-MARINET.

Personal data
Personal data means any information relating to an identified or identifiable natural person, both directly and indirectly.

Entity responsible for data processing
The entity responsible for data collection and processing is AA-MARINET which, in its context, shall determine what type of data to be collected, the purposes and means of the processing, and the storage periods.

Type of personal data collected
Within the scope of its activity, AA-MARINET shall collect and process personal data necessary for the pursuit of its mission and responsibilities, in accordance with the Legal Framework of Higher Education Institutions (Law no. 62/2007, of 10 September) and its Statutes (approved by Legislative Decree 50/2008, DR. no. 185, 2nd Series, of 24 September).

Collection of personal data
AA-MARINET shall collect personal data on-site, in writing or through computer systems. Collected personal data shall be processed by both non-automated (e.g., manual files) and automated means, in compliance with the personal data protection law, and stored in specific databases created for that purpose. Under no circumstances shall collected data be used for any other purpose other than that for which consent has been given by the data subject or when required by law.

Lawfulness of personal data processing
In AA-MARINET, the processing of personal data shall depend on the legitimate and lawful conditions for that processing, as well as the compliance with the principle of proportionality.
Specifically, personal data shall be processed at AA-MARINET only if:
– it is necessary for the purposes of the legitimate interests and if the data subject has given consent to the processing;
– it is necessary for the performance of a contract or for compliance with a legal obligation to which the controller is subject;
– it is necessary in order to protect the vital interests of the data subject or of another natural person;
– is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
– it is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject;
– it is necessary for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, under the terms foreseen in the GDPR.

Purposes of personal data processing
AA-MARINET respects the right to privacy and does not collect personal information other than personal data that is provided voluntarily through the completion of a form, or other legitimate means for the effect. By providing personal data to AA-MARINET, the user acknowledges and consents that such information be processed in accordance with the privacy policy and processing of personal data, being reassured that this information shall only be used for the purposes determined at the time of collection.
When personal data processing by AA-MARINET is based on the data subject’s consent, information shall be provided about the specific and legitimate purposes of data collection.
When personal data is processed for purposes other than those for which they were initially collected, AA-MARINET shall request explicit consent for that further processing, with the exception of cases in which data processing is lawful without consent, in accordance with the legislation in force.
Personal data processed by the AA-MARINET can be legitimately passed on to a third party whenever there is compliance with the purposes directly associated with the legitimate functions of the data owner or the responsible for data processing.

Collected data shall be used by AA-MARINET in accordance with the purposes determined at the time of collection or for the compliance of legal obligations.
Collected data shall be processed in a confidential manner and can be accessed by a restricted number of workers/collaborators of the AA-MARINET in order to carry out their professional duties, within the limits applicable.

Personal data storage period
The storage period varies according to the purpose of the processing.
AA-MARINET shall store personal data for as long as it is required for any liability arising from legal relations, contract processing, or the application of pre-contractual measures. If there are no specific legal requirements, data shall be stored only for the necessary period to fulfil the purposes for which data were collected, or for a time period authorized by the Control Authority, after which data shall be deleted.
At AA-MARINET, personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, while ensuring appropriate safeguards, in accordance with the legislation in force, for the rights and freedoms of the data subject. Those safeguards shall ensure that technical and organizational measures are in place in particular in order to ensure respect for the principle of data minimization.

Rights of data subjects
In accordance with the legal framework on Personal Data Protection, AA-MARINET shall ensure that data subjects have the right to access, update, rectify or erasure their personal data, within the limits of the legislation in force, upon a written request addressed to the data protection officer.
The data subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
Furthermore, the data subject has the right to be notified in case of a personal data breach, in accordance with the GDPR.
The data subject’s right of access should be limited when it adversely affects the rights and freedoms of others.

Personal data protection
AA-MARINET shall implement technical and organizational measures to secure personal data stored in the system against unauthorized access, use, alteration or destruction.
Personal data shall be stored for a period of time limited to what is necessary for the purposes for which they are collected and processed, in compliance with the legislation in force.

Processing of technical/anonymous information
The website of AA-MARINET collects anonymous information about its visitors which is made available by its browsers and web servers, such as browser type, language preference, originating website, pages visited, length of visit, date and time of each visit, search terms, among others. AA-MARINET shall not intentionally collect personally identifiable information. This information helps to understand how our users use the website to improve the quality and usefulness of the services provided.
Notwithstanding the anonymous information collected and processed on our Web Analytics platform, technical information may be collected about your visit(s) by the technological infrastructure that supports the system. AA-MARINET shall not share this information with third parties, without prejudice to the legal requirements imposed by the legislation in force (that is, this information may be shared with the competent public authorities, in compliance with the European legislation).

Use of cookies
When you use the website of AA-MARINET, cookies (small text files) are stored on your end device which allow us to, for example, understand whether or not you agree to the use of cookies or are logged in, among others.
Personal data shall not be collected through functional and analytical cookies and be transferred securely. Third-party cookies are not managed by our system so they may have their own cookies and privacy policy, outside the scope of this policy. Under no circumstances will our system send any personal data intentionally to external services.
Cookies can be blocked and/or disabled by the user. Please check your browser settings for more information.

Changes to this Policy
AA-MARINET reserves the right, at any time, to make adjustments or updates to this Privacy Policy and those changes shall be published.

Questions and suggestions
To learn more about how the AA-MARINET processes your personal data or to clarify any information, please submit a complaint or comment regarding our privacy and personal data protection policy to:


Data Protecion Officer

Date of approval: