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PCS Privacy Program
This Privacy Program constitutes the Polo Centre of Sustainability’s privacy policy. It outlines how the Polo Centre of Sustainability protects your privacy rights and upholds its obligations when handling your personal information. The Polo Centre of Sustainability respects and upholds your rights under the Rules and Regulations for Italian and European Union Governments. Specifically, under the European Commission, Justice, Building a European Area of Justice, Data Protection, found at [ec.europa.eu/justice/data-protection]. The Polo Centre of Sustainability lets you know what personal information of yours we hold, what we do with it, who we will disclose it to and how you can access the personal information we hold about you. You can also find out here how to change inaccurate personal information and how to opt out of receiving communications from us.

Information
The Polo Centre of Sustainability collects both personal and sensitive information as part of its regular scientific and social scientific research activities. As part of our research we are likely to collect your personal information. Given the nature of the social sciences, work conducted by the Polo Centre of Sustainability, it is not always practicable for interview subjects to remain anonymous or to use pseudonyms. Depending on the nature of the research we conduct, we may also collect sensitive information from you. This may include an individual, but is not limited to: (1) racial or ethnic origin; (2) political opinions, membership of a political association; (3) religious beliefs or affiliations; (4) philosophical beliefs; (5) membership of a professional or trade association, membership of a trade union; (6) sexual orientation or practices; (7) criminal record; and (8) health information about an individual, genetic information (that is not otherwise health information). Sensitive information will only be collected with your prior consent and only if it is directly related to, or reasonably necessary for the research we conduct.

Collection and Use
The Polo Centre of Sustainability will generally collect your personal information directly from you in the course of you participating in our research. However, we may also from time to time collect personal information about you from third parties, such as when a client provides us with a list of sample data to use in conducting our research. If this is the case, we will inform you that we have received your personal information as soon as is practicable and the circumstances of the collection. At this time you will be provided with an opportunity to decline participation and opt-out of any research process. If you elect to do so, we will delete any of your personal information in our possession, as soon as is reasonably practicable. We may also collect personal information from public phone directories, commercial or consumer listings, data organisations and respondent recruitment agencies. We will only use and disclose your personal and research information for the purpose of conducting our research. We will not use or disclose your personal information for the purpose of advertising, promotions or direct marketing activities. If you have participated in our research, we will only re-contact you if you were informed of this prior to collecting your personal information or if we have valid reasons to believe a genuine research concern warrants such re-contact.

Disclosure
We will not disclose any personally identifiable research information we collect from you unless we have your express prior consent and will only report the information you provide in an aggregate form that will not personally identify you. We will not disclose any personal information or personally identifiable research information to a third party for a purpose other than conducting our research unless we have your express prior consent or are required to do so by a judicial authority or court/tribunal order. In the course of conducting our research, we may rely on third party service providers to host or store the data we collect. We take all reasonable steps to ensure that third party service providers comply with our privacy standards. To further examine our Centre's standpoint on privacy, look at our Privacy Resources section concerning European privacy and complaints.