Milano City Church uses personal data about living individuals for the purpose of general church administration and communication.

Milano City Church recognises the importance of the correct and lawful treatment of personal data. All personal data, whether it is held on paper, on computer or other media, will be subject to the appropriate legal safeguards as specified in the General Data Protection Regulation 2017.

Milano City Church fully endorses and adheres to the eight principles of the GDPR. These principles specify the legal conditions that must be satisfied in relation to obtaining, handling, processing, transportation and storage of personal data. Employees and any others who obtain, handle, process, transport and store personal data for Milano City Church must adhere to these principles.

The Principles

The principles require that personal data shall:

1. Be processed fairly and lawfully and shall not be processed unless certain conditions are met.

2. Be obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with that purpose.

3. Be adequate, relevant and not excessive for those purposes.

4. Be accurate and where necessary, kept up to date.

5. Not be kept for longer than is necessary for that purpose.

6. Be processed in accordance with the data subject’s rights.

7. Be kept secure from unauthorised or unlawful processing and protected against accidental loss, destruction or damage by using the appropriate technical and organisational measures.

8. Not be transferred to a country or territory outside the European Economic Area, unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.

Introduction

Milano City Church (Associazone Amo La Mia Città) – the church – has adopted this Privacy Policy as we recognize and take seriously the right of people to keep their personal information private. This Policy covers the church’s use of personal information that you provide, and that we collect and hold, including the use of the website: www.milanocitychurch.com

By continuing to use this website you are agreeing to comply with the following terms and conditions of use that govern the church’s relationship with you. Should you disagree with any part of the Policy please desist from providing any personal information and/or using the website.

Data Protection

The Policy explains how Milano City Church complies with the General Data Protection Regulation (GDPR) that came into effect on May 25th, 2018.

By providing your personal details/information you are agreeing to allow Milano City Church to contact you by telephone, email, mail, or SMS text in connection with it’s charitable purposes.

1. Maintaining Confidentiality

Milano City Church will treat all your personal information as private and confidential and not disclose any data about you to anyone other than the leadership and ministry overseers of the church in order to facilitate the administration and day-to-day ministry of the church.

All Milano City Church staff and volunteers who have access to Personal Data will be required to agree to sign a Confidentiality Policy and a Data Protection Policy.

There are four exceptional circumstances to the above permitted by law:

1. Where we are legally compelled to do so.

2. Where there is a duty to the public to disclose.

3. Where disclosure is required to protect your interest.

4. Where disclosure is made at your request or with your consent.

2. Use of Personal Information

Milano City Church will use the personal information we collect for the purpose disclosed at the time of collection, or otherwise as set out in this Privacy Policy.

Generally, we use and disclose your personal information as follows:

1. The day-to-day administration of the church; e.g. pastoral care and oversight including calls and visits, preparation of ministry rotas, maintaining financial records of giving for audit and tax purposes. (This is not an exhaustive list)

2. To establish and maintain your involvement in the church and contacting you to keep you informed of church services, activities and events.

3. Statistical analysis; gaining a better understanding of church demographics.

N.B. although collated church data may be passed to a third party, such as number of Dinner Party groups or Dinner Party’s attendance, no personal data will be disclosed.

3. Collection of Information

Data is collected or passed through to Milano City Church in a variety of ways including when you:

• Complete a ‘Connection’ Card at Church events.

• Visit the website;

• Register your details and/or your families, via an embedded form on our website

• Make a donation, by completion of giving cards or by electronic means

• Provide personal details, written or oral, to church staff and volunteers;

• When you communicate with the church by means such as email, letter, and telephone;

• Access social media platforms the church uses such as Facebook, WhatsApp, Instagram and Twitter.

For all of these methods of data collection, the method of collection, storage and sharing will be subject to GDPR regulations.

The church doesn’t hold Debit or Credit card details for donations or registrations made via the Milano City Church website. Card payments made via the website, and other electronic means, are handled by service providers who encrypt card information. Currently (as of August 2021) the church uses PayPal.

4. The Milano City Church Database

Information contained on the database will not be used for any other purposes than set out in this section. The database is accessed through the cloud and therefore, can be accessed through any computer or smart device with internet access.

Milano City Church has selected Planning Center Online (www.planningcenteronline.com) to host the pastoral database of Milano City Church. Planning Center Online are a Data Processor of our data and they have extensive policies, Q&As and support on their website to give information on how they store and control data.

The server for Planning Center Online is based in the US.

1. Access to the database is strictly controlled through the use of name specific passwords, which are selected by the individual.

2. Those authorised to use the database only have access to their specific area of use within the database. This is controlled by specified administrators. These are the only people who can access and set these security parameters. This list is regularly checked and maintained.

3. People who will have secure and authorised access to the database include Milano City Church Trustees, Staff, Administration Team, Team Leaders and Dinner Party Leaders.

4. Each user will only be given access to the appropriate part of the Planning Center Online database.

5. The database will NOT be accessed by any authorised users outside of the EEA, in accordance with the Data Protection Act, unless prior consent has been obtained from the individual whose data is to be viewed.

6. All access and activity on the database is logged and can be viewed by the Database Administration.

7. Subject Access – all individuals who are the subject of personal data held by Milano City Church are entitled to:

• Ask what information the church holds about them and why.

• Ask how to gain access to it.

• Be informed how to keep it up to date.

• Be informed what Milano City Church is doing to comply with its obligations under the General Data Protection Regulation 2017

8. We do not sell or pass any of your personal information to any other organisations and/or individuals without your express consent, with the following exceptions:

By providing us with your details you are giving Milano City Church your express permission to transfer your data to service providers including mailing houses, such as MailChimp, to enable fulfilment of the purpose for collection.

9. Sensitive Personal Information: The Church may collect and store sensitive personal information such as health information, religious information (church attendance) when you and/or your family attend, register for church events and conferences. Your personal information will be kept strictly confidential. It is never sold, given away, or otherwise shared with anyone, unless required, by law.

Please let us know as soon as any of your contact details change so that we can keep our records up to date.

You can request access to the personal information that the church holds about you by contacting the church via milanocitychurch@gmail.com. We will provide you with access to your personal information unless we are legally authorised to refuse your request.

Please bear in mind that the Internet is not a totally secure method of transmitting information. Accordingly, the church cannot accept responsibility for the security of information you send to or receive from us over the Internet or for any unauthorised access or use of that information. We take measures to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage.

COOKIES POLICY

Cookies are small amounts of information that we store on your computer. Unless you have indicated your objection when disclosing your details to us, our system will issue cookies to your computer when you log on to the site.

You may set up your computer to reject cookies although, in that case, you may not be able to use certain features on our site.

SOCIAL MEDIA

The church uses social media such as Facebook and Instagram. Users should verify authenticity of sites before posting or providing personal information on such sites.

Our website may provide social media buttons, permitting sharing our web content directly to a social media platform. Use of such buttons is at your own risk. Unless it is material supplied or officially posted by the church we do not endorse social media website(s) and have no responsibility for the content nor for the cookies they may contain.

POLICY CHANGES

The church may amend this Privacy Policy from time to time to ensure compliance with changes or amendments to the law of Italy and Europe. Any amended version will be available on our website at www.milanocitychurch.com

Milano City Church Details

Name: Milano City Church (Associazione Amo La Mia Città)

Website: www.milanocitychurch.com

Registered Address: Via Giovanni Gherardini 7, 20145, Milano, Italia

Codice Fiscale: 97871510158