Privacy&GDPR

MyInVitroCloud Privacy Policy

PRIVACY NOTICE PURSUANT TO ARTICLES 13 AND 14 OF REGULATION (EU) 2016/679 (“GDPR”)

Project: “Collaboration platform “MyInVitroCloud””

1. Data Controller

The Data Controller is the University of Pavia, represented by the Rector, with registered office at Corso Strada Nuova 65, 27100 Pavia, Italy (Certified Email/PEC: amministrazione-centrale@certunipv.it).

The Data Protection Officer (DPO) can be contacted at: privacy@unipv.it.

The Scientific Coordinator of the Project is Prof. Giulia Scalet.

The hosting infrastructure of the platform is provided by Aruba S.p.A., appointed as Data Processor pursuant to Article 28 GDPR.

The University has entrusted PLAY YOUR GAME with the development and, where required, the technical maintenance of the dedicated website. Should the provider, in the performance of maintenance or support activities, have access to personal data processed through the platform, it shall act as Data Processor pursuant to Article 28 of Regulation (EU) 2016/679 (GDPR), under a specific data processing agreement concluded with the University.

2. Purpose and Legal Basis of the Processing

The personal data provided by the user are processed for the purpose of enabling user registration and account management, granting access to the restricted areas of the “MyInVitroCloud” platform, managing collaborative activities among researchers, and ensuring the security of the IT systems used within the framework of the project.

The processing is carried out by the University of Pavia in the performance of its institutional tasks relating to research and the promotion of scientific collaboration, pursuant to Article 6(1)(e) of Regulation (EU) 2016/679 (GDPR) and Article 2-ter of Italian Legislative Decree No. 196/2003, as amended.

Pursuant to Article 13(3) and Article 14(4) of Regulation (EU) 2016/679 (GDPR), where the Data Controller intends to further process personal data for a purpose other than that for which the personal data were collected, the Data Controller shall, prior to that further processing, provide the data subject with information on that other purpose and with any relevant further information.

3. Categories of Data Processed

The categories of data processed relate to registered users and research materials uploaded to the platform, and may include:

  • Identification data: first name, last name, affiliated institution;
  • Contact details: institutional e-mail address;
  • Professional/academic information: academic qualifications, position, affiliation, and research experience;
  • Access logs and records of operations performed on the system;
  • Research materials (e.g., documents, images, datasets, technical specifications, textual information, analyses, and draft publications) uploaded by the user and/or made available with the user’s authorization;
  • Technical browsing data and technical cookies.

The user is responsible for ensuring the lawfulness of the content uploaded to the platform, verifying whether such content contains information subject to confidentiality obligations, and ensuring that it complies with the applicable legislation on personal data protection and intellectual property rights.

The user shall indemnify and hold harmless the Data Controller and the website administrators from and against any claims, liabilities, or damages arising from any infringement of copyright and/or intellectual property rights.

4. Methods of Processing and Security Measures

Data are processed in accordance with the principles of lawfulness, fairness, transparency, data minimization, and integrity set out in Article 5 of the GDPR, using both paper-based and electronic means.

Data sharing is carried out through:

  • the protected collaboration platform “MyInVitroCloud” (www.myinvitrocloud.com), managed by the University of Pavia, Department of Civil Engineering and Architecture, and hosted on a hosting platform implementing technical and organizational security measures appropriate pursuant to Article 32 of the GDPR, with restricted access based on user authentication and authorization profiles.

Registered users may access only the information and content for which they have been authorized according to the access profiles defined within the platform.

Where materials containing personal data are uploaded (subject to the conditions set out in Section 7), access is restricted to the individuals authorized within the relevant project or working group.

Authorized personnel (platform users) are bound by confidentiality obligations.

Appropriate technical and organizational measures have been implemented, in accordance with Article 32 of the GDPR and AgID Circular No. 2/2017, to prevent unauthorized access, loss, disclosure, or unlawful processing of personal data, including:

  • encryption of data at rest and in transit;
  • access management based on individual user credentials;
  • trained and authorized personnel;
  • regular data backups;
  • system logging and audit trails.

5. Provision of Personal Data and Consequences of Refusal

The provision of personal data is voluntary; however, it is necessary in order to access the “MyInVitroCloud” collaboration platform (www.myinvitrocloud.com).

6. Data Retention

The retention period for personal data is determined in accordance with the principle of storage limitation and is proportionate to the purposes for which the data were collected. In particular:

  • Registration and access data:
    • Account-related data: retained for the entire duration of the user’s registration on the platform and, thereafter, for the period necessary to manage any requests, disputes, or legal and regulatory obligations;
    • Access logs and security-related data: retained only for the period strictly necessary to ensure the security of the platform and, in any event, for no longer than six months, unless a longer retention period is required for the investigation of unlawful activities or to comply with legal obligations;
  • Research materials uploaded by users: retained for the duration of the relevant research project or of the “MyInVitroCloud” collaboration platform, and then anonymized, or until the authors expressly request their deletion.

Requests of this nature must be submitted exclusively by e-mail to: support.myinvitrocloud@unipv.it

Data processed for security purposes will be deleted or anonymized as soon as they are no longer necessary for the purposes for which they were collected and, in any event, no later than six months after collection, unless a longer retention period is required by law.

7. Categories of Recipients to Whom Data May Be Disclosed or Who May Process Such Data in Their Capacity as Data Processors or Authorized Persons – Recipients of Data

The personal data of users may be accessed and processed, in compliance with the applicable data protection legislation, by public authorities where required by law, as well as by employees and collaborators of the competent offices of the entities involved, who have been duly authorized and appropriately instructed by the Data Controller, or by the providers of the platforms used to deliver the services.

External service providers are contractually bound to process personal data in accordance with the applicable European data protection legislation, including the implementation of technical and organizational measures appropriate to the nature of the processing activities.

IT service providers are appointed as Data Processors pursuant to Article 28 of the GDPR, following verification that they provide sufficient guarantees for compliance with the applicable data protection requirements.

All data are stored in data centers located within the European Union. No transfers of personal data outside the European Union are envisaged.

The platform is intended for the sharing of scientific and technical documentation. The upload of datasets or materials containing personal data is not permitted, unless expressly authorized and carried out in compliance with the applicable data protection legislation.

Research materials uploaded by users are accessible exclusively to individuals authorized within the platform and in accordance with the access profiles defined for the relevant projects or working groups.

The personal data collected for the registration and management of platform users will not be disclosed to the public. Such data may be communicated only to persons authorized to process personal data and to service providers acting on behalf of the University in compliance with the applicable legislation.

PLAY YOUR GAME has been authorized to access the content of the website’s informational pages.

The University has entrusted PLAY YOUR GAME with the development and, where required, the technical maintenance of the website. Should the provider, in the performance of maintenance or support activities, have access to personal data processed through the platform, it shall act as Data Processor pursuant to Article 28 of Regulation (EU) 2016/679 (GDPR), under a specific data processing agreement concluded with the University.

8. Cookies

The platform uses technical cookies only, which are strictly necessary for its operation and user authentication.

The platform does not use:

  • profiling cookies;
  • non-essential third-party cookies;
  • tracking technologies for marketing or advertising purposes.

Technical cookies (or equivalent technologies) are essential for the proper functioning of the website and are necessary to:

  • manage the user’s browsing session;
  • enable authentication and access to the platform and protected repositories;
  • ensure the security of the website and prevent unauthorized access;
  • maintain the user’s technical preferences (e.g., language, login status, and basic functionality).

These technical cookies do not collect users’ personal data for profiling purposes.

Further information is available in the dedicated Cookie Policy published on www.myinvitrocloud.com.

9. Rights of Data Subjects

Pursuant to the GDPR, data subjects may exercise the following rights:

  • Right of access to their personal data (Article 15);
  • Right to rectification of inaccurate or incomplete personal data (Article 16);
  • Right to erasure (“right to be forgotten”), where applicable (Article 17);
  • Right to restriction of processing (Article 18);
  • Right to object to the processing of personal data (Article 21);
  • Right to data portability (Article 20).

Requests to exercise these rights should be submitted by e-mail to: support.myinvitrocloud@unipv.it

Data subjects also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) (www.garanteprivacy.it).

10. Updates to this Privacy Notice

This Privacy Notice may be updated from time to time.

Any amendments will be communicated through the official channels of the institutions involved and published on www.myinvitrocloud.com.

Confidentiality Clause

By accessing the “MyInVitroCloud” collaboration platform, users may view and share non-public information and materials.

Users undertake to:

  • keep all information and materials viewed or uploaded through the platform strictly confidential;
  • not disclose or communicate such information or materials to unauthorized persons;
  • use such information and materials exclusively for purposes related to the project;
  • promptly report any security breaches, unauthorized access, or misuse of the platform;
  • upload only materials for which they hold the necessary rights or have obtained the appropriate authorization;
  • indemnify and hold harmless the University and the website administrators from any liability arising from infringements of copyright or other intellectual property rights.

Intellectual Property and Copyright

Materials uploaded to the platform shall remain the property of their respective authors and/or affiliated institutions.

Users are granted a limited, non-exclusive, non-transferable licence to use such materials solely within the “MyInVitroCloud” collaboration platform.

Any external reuse, publication, distribution, or disclosure of the materials requires the prior written authorization of the author who created them or of the relevant affiliated institution.

Users warrant that they upload only materials for which they hold the necessary rights or have obtained the appropriate authorization.

1. Ownership of Content

All content uploaded and/or shared through the platform (including, but not limited to, documents, images, datasets, technical specifications, textual information, analyses, and draft publications) shall remain the property of the author who created it or of the relevant affiliated institution.

The upload and/or sharing of such content shall not result in the transfer of ownership or the granting of any implied licence to the associated economic copyright or other intellectual property rights.

2. Internal Licence to Use the Materials

The upload or sharing of materials grants authorized users of the project a limited, non-exclusive, non-transferable internal licence to use such materials solely for the following purposes:

  • viewing;
  • consultation;
  • analysis;
  • operational use within the scope of the project activities.

Any other use is prohibited unless the prior written authorization of the author has been obtained.

3. Restrictions on Use and User Responsibilities

The following activities are prohibited:

  • any reuse of the materials for purposes other than those set out in Section 2;
  • the distribution, disclosure, or communication of the materials to third parties;
  • the modification or adaptation of the materials for unauthorized purposes;
  • the upload of content for which the user does not hold the necessary rights or authorization.

Users are responsible for ensuring the lawfulness of the content they upload, verifying whether such content contains information subject to specific confidentiality obligations, and ensuring that it complies with the applicable legislation on the protection of personal data and intellectual property rights.

Users shall indemnify and hold harmless the Data Controller and the website administrators from and against any claims, liabilities, or damages arising from any infringement of copyright and/or other intellectual property rights.

Users who upload content to the platform warrant that the collection, use, and any sharing of the data contained in the uploaded materials are carried out in compliance with the applicable legislation and under the sole responsibility of the user uploading such content.

4. Publications and Dissemination

Any use of the materials for:

  • scientific publications;
  • presentations;
  • dissemination or public communication;
  • inclusion in other research projects;

requires the prior written authorization of the author or of the institution holding the relevant rights.

The original authors must be properly acknowledged, and substantial intellectual contributions shall be recognized in accordance with accepted academic practices, including, where appropriate, co-authorship.

5. Optional Licensing

Upon agreement between the Parties, materials may be made available under specific licences (e.g., Creative Commons CC BY-NC).

In the absence of any specific indication, the standard provisions of applicable copyright law shall apply.

6. Termination of the Single Project or of the “MyInVitroCloud” Collaboration Platform

Upon the conclusion of the project or the termination of the “MyInVitroCloud” collaboration platform:

  • authors may export or withdraw their own materials;
  • the Data Controller may delete or archive the materials in accordance with its internal data retention and archiving policies;
  • any further use of the materials shall require the explicit written agreement of the Parties.