Disclaimer web portal MBC (Mobility Behaviour Change)

art. 13-14 del Reg.to UE 2016/679

This disclaimer is a general obligation that must be filled before or at the latest when starting the direct collection of personal data. In the case of personal data not collected directly from the interested party, the disclosure must be provided within a reasonable time or at the time of communication (not registration) of the data (to third parties or to the interested party). Pursuant to the General Data Protection Regulation (GDPR – Reg. (EU) 2016/679), the undersigned organization, data controller, informs of the following:


The personal data held by the undersigned organization are collected directly from the interested parties. This site does not collect sensitive data revealing racial or ethnic origin, philosophical or other religious beliefs, political opinions, trade union membership, associations or organizations of a religious, philosophical, political nature, data concerning health or data concerning a natural person’s sex life or sexual orientation. 

Navigation Data

The IT systems and software procedures used to operate the website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified interested parties, but which by its nature could, through processing and association with data held by third parties, allows users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connects to the site, the addresses in the Uniform Resource Identifier (URI) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters related to the operating system and the user’s IT environment. These data are only used to obtain anonymous statistical information on the use of the site and to check its correct functioning and are deleted immediately after processing. The data could be used to assess responsibility in case of hypothetical computer crimes against the site.

Profiling Data

No profiling data is directly acquired regarding the consumer habits or choices of the interested party. However, it is possible that through links or by incorporating elements of third parties, such information may be acquired by independent or separate subjects. In this regard, see the section on third-party cookies.


Like others, this website saves cookies on the browser used by the user concerned for the transmission of personal information and to enhance the experience. In fact, cookies are small text strings that the sites visited by the user send to his terminal (usually the browser), where they are stored, sometimes even with characteristics of wide temporal persistence, to be then re-transmitted to the same sites at the subsequent visit.As explained below, it is possible to choose whether and which cookies to accept, bearing in mind that refusing their use may affect the ability to perform some transactions on the site or the accuracy and adequacy of some customizable content proposed or the ability to recognize the user from a visit to the next. If no choice is made in this regard, the default settings will be applied and all cookies will be activated: however, at any time, it is possible to communicate or modify the decisions in this regard.

Technical Cookies

In particular, so-called session cookies are used, which are not stored permanently on the user’s computer and disappear when the browser is closed and whose use is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to allow safe and efficient exploration of the site and which avoid the use of other IT techniques that are potentially prejudicial to the confidentiality of users’ browsing and do not allow the acquisition of personal identification data of the user. Then analytics cookies are used that help to understand how visitors interact with the contents of the site, collecting information (geographic and web origin, technology used, language, entry pages, visited, exit, residence times, etc.) and generating website usage statistics without personal identification of individual visitors. All of these are to be considered technical cookies for which, since it is not necessary to give consent, the opt-out mechanism is in force. Technical cookies are not disclosed to third parties as they are necessary or useful for the functioning of the site; therefore, they are processed only by persons qualified as appointees, data processors or system administrators.

Third party cookies

Finally, the website incorporates cookies and other elements (tag, pixel, ecc.) from third parties (autonomous and on which the Data Controller has no responsibility) who also carry out profiling activities and for which reference is made to the respective sites: • https://policies.google.com/technologies/cookies

Data provided voluntarily by the user

The optional, explicit and voluntary sending of e-mails to the addresses indicated on the site entails the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data included in the e-mail.Even the explicit and voluntary sending of the forms that can be filled out on the site containing the e-mail address involves processing to follow up on pre-contractual obligations or the execution of the services provided for by sending the forms.In particular, in the “Become a Front Runner” section by filling out the registration form and sending the membership request, the registration to the MBC Mobility Behavior Change platform is confirmed, as part of the SaMBA Alpine Space Project, accepting the Terms and Conditions of use.The MBC platform, co-financed by the European Union via Interreg Alpine Space, within the SaMBA Alpine Space Project (European Regional Development Fund), is a transnational community of the EU, of citizens, businesses and public administrations that promotes the change of people’s mobility habits towards sustainable forms. 

Reserved area

The information (e.g. texts, videos, images and information suitable for revealing tastes, preferences, lifestyle or consumption habits) and personal data (only those necessary) that the user uploads in the reserved area may be published on the site according to the methods and conditions indicated in the Terms and Conditions of use.The information is protected by authentication systems and is accessible only to authorized users, or to the direct interested parties and / or the intermediaries involved.This information is not subject to dissemination operations, except in the cases provided by the SaMBA project as indicated in the Terms and Conditions of use.


Personal data are used (ref. articles 6 co. 1 letter b of the GDPR):to allow navigation on the web portal andpossibly to perform the service or provision requested as part of the normal activity carried out by the undersigned organization;joining the MBC Mobility Behavior Change platform and participation in the SaMBA project.Furthermore, all personal data can be processed: for purposes related to obligations established by law, as well as by provisions issued by authorities legitimated by the law (ref. article 6 co. 1 lett. c) and 9 co. 2 lett. b), g), h) of the GDPR);for the assessment, exercise or defence of a right in judicial and extrajudicial (legitimate interest) of the undersigned organization (ref. article. 6 co. 1 lett. f) e 9 co. 2 lett. f) of the GDPR); for purposes according to the legitimate interest of the Data Controller, in particular for navigation and use logs to protect the site and the service from cyber-attacks (ref. article 6 co. 1 lett. f) of the GDPR); 


The provision of data collected from the interested party is optional but essential for the purposes in letters a) and b). In the event that the interested parties do not communicate their essential data and do not allow the processing, it will not be possible to proceed with the completion and implementation of the proposed services and to follow up on any contractual obligations undertaken, with consequent prejudice for the correct fulfilment of regulatory obligations. Apart from what is specified for navigation data, the user is free to provide personal data for cookies and specific requests through forms e.g. on products and / or services. Failure to provide them may make it impossible to obtain what is requested. For all non-essential data, the provision is optional. In the absence of consent, incomplete or incorrect provision of certain data, the required formalities could be so incomplete as to cause prejudice either in terms of sanctions or loss of benefits, or due to the impossibility of guaranteeing the adequacy of the treatment itself to the obligations for which it is carried out, and for the possible mismatch of the results of the treatment itself with the obligations imposed by the law to which it is addressed, intending to exempt the undersigned organization from any and all responsibility for any penalties or afflictive measures. 


The treatments connected to the web services of the site are treated with automated tools for the time strictly necessary to achieve the purposes for which they were collected; take place at the server in Italy or the EU and are only handled by technical personnel in charge of processing, or by any persons in charge of maintenance and administration operations. Specific security measures are observed to prevent the loss of data, illicit or incorrect use and unauthorized access and the loss of confidentiality. The structure is equipped with anti-intrusion devices, firewalls, logs and disaster recovery. Specific encryption and data segregation mechanisms and user authentication and authorization mechanisms are used.Data processing means their collection, registration, organization, storage, processing, modification, cancellation and destruction or the combination of two or more of these operations. In relation to the aforementioned purposes, the processing of personal data takes place using manual, IT and telematics tools, with logic strictly related to the purposes themselves and, in any case, in order to guarantee security and confidentiality, personal data will therefore be processed in compliance with the methods indicated. in art. 5 EU Regulation 2016/679, which provides, among other things, that the data are processed lawfully and fairly, collected and recorded for specific, explicit and legitimate, exact, and if necessary updated, relevant purposes, complete and not excessive in relation to the purposes of the processing, in compliance with fundamental rights and freedoms, as well as the dignity of the interested party with particular reference to confidentiality and personal identity, through protection and security measures. The undersigned organization has prepared and will further improve the data access and storage security system.An automated decision-making process (e.g. profiling) is not carried out.


The processing takes place in non-EU and non-EEA countries, when the connections to the site come from these countries (at the request of the interested party who is there).


Personal data will be kept, in general, as long as the purposes of the processing persist according to the category of data processed.


The data (only the indispensable ones) are communicatedto persons in charge of the processing, both internal to the organization of the writer and external, who carry out specific tasks and operations (site administration, analysis of navigation data, traffic, management of e-mails and forms sent voluntarily by ‘user, etc.);in the cases and to the subjects provided for by law.The data will not be disseminated unless otherwise provided by law or after anonymization. Except as specified for cookies and third-party elements, without the prior general consent of the interested party for communications to third parties, it will be possible to carry out only services that do not provide for such communications. In case of need, specific and timely consents will be requested and the subjects who will receive the data will use them as autonomous owners.In some cases (not subject to the ordinary management of this site) the Authority may request news and information, for the purpose of controlling the processing of personal data. In these cases, the reply is mandatory under penalty of an administrative sanction.


At any time you can: exercise your rights (access, rectification, cancellation, limitation, portability, opposition, absence of automated decision-making processes) when provided for in relation to the data controller, pursuant to art. from 15 to 22 of the GDPR (link to the standard); propose a complaint to the Guarantor (www.garanteprivacy.it); if the treatment is based on consent, revoke this consent given, taking into account that the revocation of the consent does not affect the lawfulness of the treatment based on the consent before the revocation.
Disabling cookies
Almost all browsers offer the possibility to manage and not enable cookies, in order to respect user preferences. In some browsers it is possible to set rules to manage cookies site by site, an option that offers more precise control over the user’s privacy; another function available on some browsers is the incognito mode, so that all cookies created in this mode are deleted after closing.Consult the following instructions for managing cookies in the relevant browsers:Chrome Firefox Internet Explorer Microsoft Edge Safari


The data controller is the Fondazione LINKS, with registered offices in via Pier Carlo Boggio 61, 10138 Torino, e-mail address: info@linksfoundation.com, phone number: 011/2276150.