The purpose of this privacy policy provides all the information on the processing of personal data carried out by Villa La Ripa S.r.l, when the User subscribes to the newsletter (as indicated below).
- INTRODUCTION – WHO WE ARE?
Villa La Ripa S.r.l., with registered office in Arezzo - Località Antria, 38 – 52100, Italy, VAT No. and Fiscal Code No. 02299020517 and registration number in the Italian trade Register of Arezzo under number REA 176325 (hereinafter, “Data Controller”), owner of the internet website https://www.villalaripa.it/en/ (hereinafter, the “Website”), in its capacity as data controller in relation to personal data pertaining to the users (hereinafter, the “Users”) hereby provides the privacy policy pursuant to art. 13 of the Regulation EU 2016/679 of the Council of 27 April 2016 (hereinafter, “Regulation” or “Applicable Law”).
- HOW TO CONTACT US?
The Data Controller takes the utmost account of its Users’ right to privacy and protection of personal data.
For any information related to this privacy policy, Users may contact the Data Controller at any time, using the following methods:
- registered letter with return receipt (to the following address Arezzo - Località Antria, 38 – 52100, Italy);
- By sending an e-mail to info@villalaripa.it.
The Data Controller has not identified a data protection officer (DPO), as it is not subject to the obligation of designation provided for by art. 37 of the Regulation.
- WHAT DO WE DO? - PROCESSING PURPOSES
By browsing the Website, the User may communicate to the Data Controller his/her willingness to receive, for marketing purposes, commercial communications containing promotional material through which the Data Controller proposes the purchase of products and/or services offered by the Data Controller and/or third-party companies.
In connection with the activities that may be carried out through the Website, the Data Controller collects personal data relating to Users.
This Website and the services eventually offered through the Website are reserved to subjects over the age of 18 years old. Hereby, the Data Controller does not collect personal data pertaining to subjects under the age of 18 years old. At request of the Users, the Data Controller will promptly delete all the personal data, involuntary collected, pertaining to subjects under the age of 18 years old.
Particularly, the personal data of the Users will be lawfully processed for the following purposes:
- marketing (sending of advertising material, direct sales, commercial communication and newsletters): Users’ personal data (name, surname, email address) are collected and processed by the Data Controller for marketing purposes (sending of advertising material, direct sales and commercial communication), i.e. so that the Data Controller can contact the User by e-mail to propose to the User the purchase of products and/or services offered by the Data Controller itself and/or by third party companies, to present offers, promotions and commercial opportunities. The User data collected by the Data Controller for this purpose include name, surname, e-mail address;
- legal obligations, i.e., to comply with obligations imposed by law, an authority, a regulation or European legislation.
The provision of personal data for the above processing purposes is optional but necessary, since failure to provide such data will make it impossible for the User to receive promotional e-mails from the Data Controller. An asterisk will show the Users the data compulsory in order to carry out the purposes of this paragraph 3.
The User may easily oppose further sending of promotional communications by clicking on the appropriate link in each e-mail. Once the request has been made, the Data Controller will send the User an e-mail message to confirm that what the User has requested has been carried out.
The Data Controller informs that, following the exercise of the right to object to the sending of promotional communications by e-mail, it is possible that, for technical and operational reasons (i.e., the formation of contact lists already completed shortly before the receipt by the Data Controller of the request for objection) the User will continue to receive some further promotional messages. If you continue to receive promotional messages after 24 hours of exercising your right to object, please report the problem to the Data Controller using the contact details set out in paragraph 7 below.
- LEGAL BASIS FOR PROCESSING
Marketing (as described in par. 3, lett. a)): the legal basis consists in art. 6, paragraph 1, lett. a) of the Regulation, namely, the provision by the data subject of consent to the processing of his/her personal data for one or more specific purposes. For this reason, the Data Controller asks the User to provide a specific free and optional consent, in order to pursue such processing purpose.
Legal obligations (as described in the previous paragraph 3, letter b)): the legal basis consists of art. 6, paragraph 1, lett. c) of the Regulation, as the processing is necessary for compliance with a legal obligation to which the Data Controller is subject.
- PROCESSING METHODS AND DATA RETENTION PERIOD
The Data Controller will process the personal data of Users using manual and IT tools, with logic strictly related to the purposes themselves and, in any case, in order to guarantee the security and confidentiality of the data.
As regards the purpose described in paragraph 3, letter a) above, Users’ personal data will be stored for the time strictly necessary to fulfil the purposes described therein and, in any case, until Users withdraw their consent.
As regards the purpose described in paragraph 3, letter b) above, the personal data of the Users will be kept for the time strictly necessary to fulfil such purpose, or in any case as long as necessary to protect the interests of both the Users and the Data Controller in civil proceedings.
In any case, this is without prejudice to possible retention periods provided for by laws or regulations.
- TRANSMISSION AND DISSEMINATION OF DATA
The User’s personal data may be transferred outside the European Union, and, in this case, the Data Controller will ensure that the transfer takes place in accordance with the Applicable Law and, in particular, in accordance with Articles 45 (Transfer on the basis of an adequacy decision) and 46 (Transfer subject to adequate guarantees) of the Regulation.
The personal data of the Users may be disclosed to the employees and/or collaborators of the Data Controller in charge of managing the Website, the newsletter’s service and the Users’ requests. These subjects, who have been instructed to do so by the Data Controller pursuant to Article 29 of the Regulation, will process the User’s data exclusively for the purposes indicated in this policy and in compliance with the provisions of the Applicable Regulations.
The personal data of the Users may also be disclosed to third parties who may process personal data on behalf of the Data Controller as “Data Processors” pursuant to Article 28 of the Regulations, such as, for example, IT and logistic service providers functional to the operation of the Data Controller’s Website, suppliers of outsourcing or cloud computing services, professionals and consultants.
Users have the right to obtain a list of any data processors appointed by the Data Controller, making a request to the Data Controller in the manner indicated in paragraph 7 below.
- RIGHTS OF THE DATA SUBJECTS
Users may exercise their rights granted by the Applicable Regulations by contacting the Data Controller as follows:
- By sending a registered letter with acknowledgment of receipt to the registered office of the Company (Località Antria, 38 – 52100, Arezzo, Italy);
- By sending an e-mail to info@villalaripa.it.
The Data Controller has not identified a data protection officer (DPO), as it is not subject to the obligation of designation provided for by art. 37 of the Regulation.
Pursuant to Applicable Regulations, the Data Controller informs that Users have the right to obtain indication (i) of the origin of personal data; (ii) the purposes and methods of the processing; (iii) the logic applied in the event of processing carried out with the aid of electronic instruments; (iv) of the identification details of the data controller and processors; (v) the subjects or categories of subjects to whom the personal data may be communicated or who may come to aware of them as processors or agents.
Furthermore, Users have the right to obtain:
a) Access, updating, rectification, or, when interested, integration of data;
b) The cancellation, transformation into anonymous form or the restriction of data processed in breach of the law, including data that does not need to be stored in relation to the purposes for which the data was collected or subsequently processed;
c) Certification to the effect that notification has been supplied of operations as per letters a) and b), as regards their content, to those to whom the data was communicated or disseminated, except for the case where notification proves impossible or requires the use of means clearly disproportionate to the right being protected.
Moreover, the Users have:
a) The right to withdraw consent at any time, if the processing is based on their consent;
b) (if applicable) The right to data portability (the right to receive all personal data concerning them in a structured format, commonly used and readable by automatic device);
c) The right to oppose to:
i) in whole or part, for legitimate reasons, the processing of personal data relating to you for legitimate reasons even pertinent to the purpose of collection;
ii) in whole or part, the handling of personal data for the purpose of sending advertising or sales materials or for the carrying out of market research or for commercial communication purposes;
iii) if personal data is processed for direct marketing purposes, at any time, to the processing of data for this purpose, including profiling in so far as it is related to such direct marketing.
d) If it is deemed that the processing concerning their personal data violates the Regulation, the right to lodge a complaint with a Supervisory authority (in the Member State in which they usually reside, in the one in which they work or in the one in which the alleged violation has occurred). The Italian Supervisory Authority is the “Garante per la protezione dei dati personali”, with registered offices in Piazza Venezia No. 11, 00187 – Rome (http://www.garanteprivacy.it/).
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The Data Controller is not responsible for updating all links viewed in this privacy policy, therefore, whenever a link does not work and/or is not updated, the Users acknowledge and accept that they must always refer to the document and/or section of the websites referred to by this link.