Agrolinker's Forum - Privacy Policy (EU Regulation, No. 679 of 2016)

DISCLOSURE PURSUANT TO EU Regulation No. 679 of 2016 (and Legislative Decree No. 296 of 30/6/2003 and further national laws - eg the Cookie Law - in the parties that do not conflict with the EU regulation):

  1. Foreword: Some definitions
  2. Agrolinker website forum privacy notice: Owner and place of processing
  3. Processing data
  4. Basis of data processing
  5. Prohibition of registration for persons under the age of 16: details
  6. Data processing: Purpose and mode
  7. Data is not passed on to third parties
  8. Data is not transmitted overseas
  9. Data retention time
  10. Subjects, or categories of subjects, to whom personal data can be communicated or who can learn about it
  11. Security measures implemented in data retention
  12. General information about cookies
  13. Link to the cookie information page
  14. Exercise the right to remove data
  15. Note: information updates
  16. List of Agrolinker site privacy information

(1) Introduction: Some definitions

(a) Definition of personal data:

Personal data are those that make it possible to identify an individual or those who describe it so that it can be identified, possibly with the support of other data.
For example: the email, the IP and the data provided through some kinds of cookies are personal data, they allow the identification of the individual (or allow the information made available by them), with or without the support of others data available on the Internet.

(b) Definition of data controller:

The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of processing personal data.

(c) Definition of data controller:

The natural or legal person, public authority, service or other body that processes personal data on behalf of the 'holder'.

The activities carried out by this site are shown below to guarantee the privacy of the users of the forum and the principle of accountability, on which the European Union Regulation no. ° 679 of 2016.


(2) Owner and place of processing

The data controller is the director responsible for Agrolinker, Luca Federico Fianchini, who can be contacted through the addresses indicated in the section Editor of the site; the place of processing is at the site location; he is also an administrator of the forum.
It was not instead named a Data Protection Officer (RPD), because this figure was deemed not mandatory according to the parameters established by the GDPR (Union Regulation European No. 679 of 2016); please find below the FAQ of the Privacy Guarantor regarding the Private Data Protection Officer (RPD).

(3) Data subject to processing

The processing of data necessary to ensure the operation of this service has always been reduced to the minimum necessary and is limited to the request to indicate a e-mail address working and to choose a fantasy-user-name .
Such data are necessary for the provision of the service of interaction with other subscribers and with the same site, which takes place through the forum, but it is not necessary that they include personal identifiers and it is required that at least the name- user (= user-name, or nickname) does not contain personal data, such as name, surname, professional qualifications, etc., since they remain in time within the messages posted in the forum (even after the cancellation of registration ). Otherwise the permanence of personal identifiers in the forum posts would contrast with the principle of the temporality of data processing and could also create problems when a hypothetical request based on the right to be forgotten , would result in deleting forum posts, breaking up the related discussions.
- In this sense the Agrolinker forum regulation has advised for years the use of anonymous username as an anonymisation tool for the published data and therefore the user names that were not anonymous at the entry into force of the European Union Regulation No. 679 of 2016 (this standard is also provided for by the recent legislation, to reduce the amount of processing to the necessary data only) and therefore is now mandatory to use names "Fantasy" user .
- The objective to be achieved is the 'minimization of data processing' , recommended by the current legislation on privacy and therefore the administrator of the forum reserves the right to anonymize the user-names, not meeting the required requirements, in order to balance the protection of privacy with the manageability of the forum.
In this case, the new username will be communicated via e-mail to the relative members, who will still be able to modify them through the appropriate interface, provided they remain anonymous.
- Unlike user-names, e-mail addresses, only personal data currently processed by the forum, are not visible in the published discussions in the Agrolinker forum and messages to them addressed can be sent only by registered users, through a special form. Furthermore, each member can block this action through his own user interface. Therefore no one except the data controller can know the email addresses of the subscribers, who are either not communicated to collaborators or transferred to third parties.
Each subscriber through his user interface can publish additional information that is not necessary for the forum to work, therefore the Agrolinker website invites forum users to limit the personal data of their own and others, whose inclusion the author accepts however to take responsibility for it; the Data Controller is therefore free from any liability to third parties.

(4) Basis of data processing:

The processing of data in the forum is generally based on consent, as a specific consent is required for the processing of data provided at the time of registration. For some forms of treatment, which concern both the members of the forum and the visitors and who are not subject to the request for explicit authorization (e.g. use of session cookies and technical and log archives), the treatment is based respectively on the legitimate interest of the owner and on legal obligations (regarding the conservation of some logs).

(5) Prohibition of registration for persons under the age of 16: details

Registration to this forum is forbidden to persons under the age of 16, as the privacy policy stipulates that, in this case, consent to the processing of data must be granted by the parents , which, however, in the case of a website is not easily verifiable.
Anyone who signs up for this forum declares that he / she is over 16 years of age and that he / she fully understands the regulation and the privacy policy .
This consent is expressed , together with the other subject of this information and the forum rules, selecting the acceptance option, located at the bottom of the page of the forum registration form .

(6) Data processing: Purpose and modality

The personal data requested from the user are processed, also by means of computer tools, by the data controller, guaranteeing security and confidentiality. The treatment will be exclusively for the purposes strictly connected to the registration and use of the forum service and the related newsletter service. The newsletter service is essential to provide updates about the forum and the site and therefore the registration to the forum implies the acceptance of the sending of the related newsletter newsletter and vice versa. The e-mail box should therefore remain up-to-date, as the non-receipt of the newsletter is an indicator of the need to remove an entry that has become inactive.

As soon as registration is made in the forum, the new user receives a letter confirming the registration, which is automatically generated by the system, which has been specially set up to verify the existence of a confirmation by the interested party. Following the confirmation of registration, obtained by pressing a link placed in the email, sent to the email address indicated, is therefore confirmed acceptance of the forum rules and privacy policy. The data stored in the forum therefore derive all from explicit authorization to the processing, then also confirmed; in case of failure to confirm the pre-registration are cancelled.

The forum used, whose name is PHPBB, is structured in such a way that it is possible, for the administrator of the forum, to set options based on permissions, more or less extended, both for users who for themselves; therefore the application of the privacy policy is also based on the ability of the administrator of the forum to be able to make a very precise setting even limiting their possible actions in the areas allowed by law.

The information system of the PHPBB forum, currently used by the Agrolinker site, also allows access to the profile of each user to be able to test the operation, to delete, suspend, or even to modify the options for custom choice; but this last intervention is never performed because it is not useful to define specific settings for each user, intervening in a different way on personal interfaces, since it would determine complexity, uncertainty, instability and therefore insecurity of the whole system, which is preferable to be set uniformly and therefore the same for each user.
Consequently, as no specific treatment of the email data of each user is carried out, the settings are always managed in an aggregated manner, to achieve the same objectives that are the same for all users.

(7) Data are not transferred to third parties

- Therefore all the data above are not processed, nor transferred to third parties, either directly or indirectly collected on the site by third parties, as no services provided by third parties have been activated.

(8) Data are not transmitted abroad

- User data is not transmitted abroad; in addition, the website hosting service was purchased from an Italian company, whose servers are physically in Italy; Neither Agrolinker uses 'Cloud' services.

(9) Data retention time

Personal data is retained as long as it remains registered on the forum, which is removed, except in exceptional cases, only at the request of the member and the data is not deleted as long as the forum remains active.

(10) Subjects, or categories of subjects, to whom personal data can be communicated or who can learn about them:


(11) Security measures in data processing: minimize the risk of destruction, loss or unauthorized access to data:

(12) General information on cookies

- Cookies are often considered as a source of personal data, when they have specific characteristics and are viewed negatively by many internet users, although they are used by the management programs of many blogs to perform basic activities of their operation. > The Privacy Guarantor, through the diagram below, then clarifies what are the cookies that really threaten privacy (link to the site of the Privacy Guarantor) and the duties of the system administrators.
- The PHPBB software (currently version 3.2.2; 24/5/2018) used by the Agrolinker forum uses session cookies and analytical cookies of the first part. The role of session cookies is to facilitate the writing in the use of the forum, avoiding him, where he chooses, to log in more than once.
In fact, normally, the forum periodically requires a new login to prevent any user profile from being hacked. It is in any case possible, for the subscriber, to activate the 'remember me' option at login, which through a session cookie, allows you to avoid logging in at every access to the forum. The subscriber can also delete all cookies , by acting on the basket icon , located below each page of the forum.
In addition, the forum uses first-party analytical cookies , which are intended to report error logs, administrator and moderator logs and finally user registration logs.
- The error logs are used to identify errors that occur on the site, in order to improve the service and handle any complaints related to malfunctions.
- The logs of the directors and moderators must be filed according to the provision concerning the ADS (system administrators) of 27 November 2008 (published on the G.U. n.300 of 24 December 2008). These logs are used to verify that data management by the system administrator and moderators has always been correct.
- User registration logs are required to be able to demonstrate the signing of the registration consent.
The collection of such data can be considered based on legal obligations and on the legitimate interest of the owner to verify the causes of system errors to provide protection, in order to offer a service that meets the user's expectations, also guaranteeing security conditions. in data management.
These comprehensive logs are accessible only to the system administrator, who is required to keep them for a variable period of time depending on the different obligations; they are automatically archived in the forum, waiting to be deleted.
In this forum, however, absolutely no use is made of advertising tracer cookies, neither their own, nor third parties.

(13) Link to the cookie information page

(14) Exercise of the right to remove data

The data as indicated above can be removed directly from the member with the exception of the registration to the forum, which must be done by the administrator of the forum.

The privacy policy guarantees to anyone who can request, to a given subject that processes data (data controller), if there are personal data that concern them and in the affirmative can ask the modification, integration and cancellation, in the face of the duty of those who hold the data to work to meet any update request.
This type of rule is normally aimed at those who collect data from unsuspecting people.
In this specific case, the member of a discussion forum, although he can act directly on the data published by him, deleting or even increasing it, can also, as 'holder of the right' on your data, make a -> request ('login request') to get the update, or cancellation.
In fact, anyone who subscribes to a forum must still have the possibility to obtain the cancellation of their data, even in the hypothesis that, for example, lose login credentials. Your request must be processed within 15 days and in case of no reply, the right holder can lodge an appeal, or an alert to the Privacy Guarantor.
In the request, as conceived in general by the current legislation, the holder of the right can request to know if his data exist, for what reason they have been collected, which is the modality of the treatment. The right holder can also revoke a previous authorization to the processing, can request to know the name of the data controller and of the controller (if appointed); can finally request data modification, integration and deletion.

(15) Note: updates of the 'informative

This information was published on 24 May 2018,
it could be integrated, compatibly with the limits offered by the current legislation, on the occasion of possible variations may result in significant changes in the programs, or their extensions (and their characteristics), or changes to the set operating options. In this case users can be updated regarding any consequent significant changes in data processing.

List of information on the Agrolinker website: