privacy policy

Policy  on personal data protection of the Gen  4 Centre website, according to Regulation (EU) 2016/679 (GDPR)




1.1  personal data protection and social responsibility  

The Gen4 Center recognizes the importance of the law regarding the handling of personal data of its adherents and of those who are in contact with  it, being aware that the law regarding the handling of personal data is a fundamental human right.

In this perspective, together  with a determined adherence to high standards of Social Responsibility, the Gen4 Center intends to set forth in a transparent manner the aims and methods with which the processing of personal data is carried out, also showing its willingness to collaborate with its adherents and with the Users of the Gen4 Center website, as identified below, to put in place, where requested, the operations useful or necessary to update, correct or delete personal data that may be processed by the Gen4 Center, in compliance with current legislation and the specific needs of the interested parties.

Therefore, the following information is provided, to be understood  as provided pursuant to the General Data Protection Regulation (EU) 2016/679.

1.2  gen 4 center website          

It should be specified in advance that, in this statement, any reference to the website of the Gen4 Center is a reference  to the following site:, with the warning that every other site referred to by text or to which one or multiple links are presented in  hypertext or in other forms do not belong to the Gen4 Center, unless otherwise indicated, and therefore cannot be traced back to tools used in handling personal data owned by the Gen4 Center.


The  controller of personal data processing is P.A.F.O.M, with registered office in Rocca di Papa (Rome-Italy), Via Frascati, 306.

The Data Protection Officer (DPO) is the lawyer. Sergio Barbaro who can be contacted  at the following address: Personal Data Protection Officer, via Frascati n. 306, Rocca di Papa (Rome-Italy), email:


3.1.  information and contacts

The Gen 4 Center of P.A.M.O.M. , through its Internet site, pursues informative purposes in relation to the performance of its activity. The aforementioned information (concerning also the description of the services offered) is accompanied by the indication of the contact details of the Gen 4 Center Secretariat, so that it can be reached by those who are  in touch with or want to be in touch with the aforementioned body (including Adherents, potential Adherents, Suppliers, Employees, etc.) with technological or traditional tools.

The contact details and information on the Gen4 Center website are made available to potential adherents and adherents  so that they can know, evaluate and possibly join the Gen4 Center or be in regular contact, in order to reach a more efficient performance of services, with an increase in the level of customer satisfaction.

The contact details and information on the website are also made available to internal and external suppliers or collaborators, in order to improve the network of relationships and the efficiency of contacts.

3.2.   data known to the interested party

Through the indication of the addresses made available to the Adherents and / or Users, including the e-mail address, the Gen4 Center can learn about the personal data sent to it by them. 

3.3. data not supported by the expressed consent of the interested party

If the personal data provided contain sensitive and / or judicial data, the interested party will be asked for a specific written consent to the processing, if the consent  is not provided the data will be deleted and / or destroyed by the Gen4 Center.

The Gen4 Center may process the personal data of  interested parties, even without a clearly expressed consent, for the hypotheses envisaged by  current legislation, which will be verified in relation to the specific case, such as, for example, in the event that the processing is necessary to fulfill legal obligations, regulations or legislation, or is necessary to perform obligations arising from a contract to which the interested party is party to or to fulfill specific requests that the interested party makes in the pre-contractual phase. The Gen4 Center also reserves the right to cancel data relating to third parties for which the necessary written consent has not been given, if requested.


3.4. purposes excluded

In any case, unless otherwise clearly  expressed by the data subject’s consent, the personal data collected directly by the Gen4 Center and for which the Gen4 Center is the data controller is not used for marketing purposes, to define profiles or personality of the interested party, for sending advertising material or direct sales, nor for carrying out market research or commercial communication.




4.1. tools and supports for data processing

Data processing is carried out with IT and telematic systems and with electronic instruments.

The processing is carried out partly on special servers owned by P.A.F.O.M. In the latter case, the Gen4 Center, under a specific contract, has the exclusive legal availability of the server or servers used, without any communication of data to the service provider company, which remains in any case contractually with the Gen4 Center to adopt appropriate and updated security and protection measures, both physical and logical, on the servers used by the Gen4 Center.

The data processing is also carried out with computer and electronic systems present at the headquarters of the Gen4 Center or, in any case, with IT tools owned by the same or, where necessary, by persons in charge of data processing, in compliance with the security measures required by current legislation and, in any case, those given by the data processing controller.

Data may also be processed using non-electronic tools, including the use of paper.

4.2. data processing  operations

The processing operations may consist of one or more operations concerning the collection of data, their registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction, even regardless of their registration in a database.

4.3. communication of data

The personal data collected by the Gen4 Center or of which the Gen4 Center should become aware in the performance of its activities may be communicated to (or may be the object of knowledge by) subjects in charge of and / or responsible for processing, in relation to the specifications competences and functions, in order to satisfy the aforementioned purposes or to implement regulatory and / or contractual obligations.

Normally the data are not communicated to or made known to other data controllers, unless this should be necessary in compliance with regulatory or contractual provisions or to fulfill specific obligations. In this case the aforementioned data may, in particular, be brought to the knowledge of the following subjects or of the following categories of subjects, to the extent that this is necessary for the fulfillment of legal and / or contractual obligations in compliance with current legislation.

4.4.  data dissemination 

In any case, personal data will not be disseminated, unless expressly requested by the interested party, possibly also in carrying out  specific contractual provisions with the interested party. In such cases the scope of data dissemination remains contained within the limits of the request of the interested party or of the contractual agreements made.

However, it is possible that the navigation data of the site will be disclosed only, but in this case the data will be disseminated in an aggregate and anonymous form, in order to make statistical surveys about  consultation of the Gen 4 Center website or part of it.

4.5.  navigation data

Consulting the Gen4 Center website may involve an automatic processing of the User’s navigation data for the sole purpose of making the consultation technically possible, as well as checking and ensuring its correct functioning in relation to the hardware and software tools used. Although the processing of the aforementioned data is not carried out to identify who is browsing the website specified above, there is nevertheless the possibility that the identity of the User  may be traced, if such data are associated with other data given to the Gen 4 Centre or to third parties. 

Among the navigation data the following can be processed: IP numbers of the instruments used by the User; access numbers; pages viewed; access and connection times; navigation browser; operating system used by the User; URL visited before accessing the Gen 4 Centre website; numeric code indicating the status of the response given by the server (success, error, etc.) and other parameters relating to the operating system and the User’s computer environment.

These data will not be used except for the purposes specified above, including that of any monitoring in anonymous form for statistical purposes.

If the aforementioned information should be used for statistical purposes, the data relating to the User are treated in aggregate and anonymous form, so as to preserve a high level of protection of the interested parties.

The navigation data could be used, where necessary, to ascertain responsibility in the event of hypothetical computer crimes against the site.


This website uses different types of “cookies” (small text files saved on the user’s device). The use of session cookies (which are not stored permanently on the user’s computer) is strictly limited to allow a safe and efficient exploration of the site.

Session cookies do not allow the acquisition of  user personal identification data. Extensive information on the cookies used on this website is given below.


On the Gen 4 Center website there is also a special reserved area, accessed by entering an identification code and a password. This allows the Gen 4 Center and those in charge of data processing to carry out the necessary operations to provide and manage services and to manage and maintain the entire IT and telematic system.

Access to the reserved area is also allowed to  adherents who have previously obtained specific personal authentication credentials, in order to access the services requested from  the Gen 4 Center and provided by the latter.

By accessing the reserved area, specific consents will be requested and  the appropriate information given. The system will be able to collect and process information relating to the times and methods of access and the operations performed. In this case, the processing  is aimed exclusively at managing the service offered and maintaining the system’s security levels. 


Except for the data provided voluntarily by the user for specific services, for which specific information will be made, the navigation  information will be kept for a maximum of fourteen months after collection; except in the case of their use to ascertain responsibility in the event of computer crimes damaging the site. In this case the information will be kept available to the Authority for the time necessary to guarantee P.A.F.O.M. the exercise of their defense rights.


Providing personal data of an interested party is optional, except in cases where, in the case of a form, the field relating to the insertion of data is marked with an asterisk. In such cases, the provision of data is to be considered mandatory.

The automatic processing of navigation data, data relating to access and permanence in the reserved area and contractual data is also mandatory.


EU Regulation 2016/679 (GDPR) recognizes  a series of rights for users including, by way of example, the right:

(a) to access their Personal Data

(b) to ask for their correction

(c) updating and cancellation, if incomplete, incorrect or collected in violation of the law

(d) to ask that the processing  be limited to a part of the information concerning them

(e) to transmit to them or to third parties indicated by them the information concerning them (so-called “data portability”)

(f) to oppose their processing  for legitimate reasons

(g) to withdraw their consent at any time by means of a written request addressed without formalities to the Gen Center to the  contacts indicated.

Finally, please note that in the event of  violations during the processing of personal data, the interested party has the right to lodge a complaint with the Guarantor Authority for the protection of personal data (


To facilitate the interested party in the exercise of their rights and in interacting with the Gen 4 Center for the operations indicated above, the following contact details are provided in case of need:

e-mail address: | 

For any further request in relation to their data processing , the user can contact P.A.F.O.M. without particular formalities. email address:; 00040 Rocca di Papa (RM), Via Frascati, 306.