Information on the processing of personal data.
(Articles 13 and 14 EUROPEAN REGULATION N. 679/2016)
the undersigned Michel Bruni, a freelance agricultural technician (Collegio Agrotecnici e Agrotecnici Laureati di Pistoia, registration number 379) and environmental hiking guide (GAE), with registered office at the residence in via di Sant'Agostino n.20, CAP 51100, Pistoia (PT), CF: BRNMHL77R31G713N, VAT number 01849900475, as Data Controller informs you, pursuant to articles 13 and 14 of European Regulation n. 679/2016 (hereinafter EU Regulation), that your data will be processed as indicated below:
1. Object of the Processing
The Data Controller informs you that the personal, identifying data (for example, name, surname, company name, address, telephone, e-mail, bank and/or payment details, etc.), hereinafter called personal data or simply data, relating to you, acquired also verbally directly or through third parties in the past, as well as those that will be collected in the future, may be processed in full compliance with the EU Regulation. The Data Controller carries out the processing in a lawful manner specifically for the performance of a contract to which you are a party or for the performance of pre-contractual measures (e.g. preparation of an offer, etc.) requested by you (art. no. 6 of the EU Regulation).
Data processing means any operation or set of operations concerning the collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, destruction of the data itself.
2. Legal basis and Purpose of processing
Legal basis:EU Regulation no. 679/2016
A)without your express consent (art. 6 letter b), c), e) of the EU Regulation), for the following Purposes:
- fulfill the pre-contractual, contractual and tax obligations arising from existing relationships with you;
- fulfill the obligations established by law, by a regulation, by community legislation or by an order of the Authority (such as for example in the matter of anti-money laundering);
- exercise the rights of the Data Controller, for example the right of defense in court;
- for the maintenance of general accounting;
- for management purposes (invoicing, possible document management, etc.);
- for credit management;
- for statistical and quality control analysis;
- for insurance management;
- for technical assistance.
In particular, your data will be processed for purposes related to the implementation of the following obligations, relating to legislative or contractual obligations:
- Technical and Functional Access to the Site, no data is kept after the Browser is closed;
- Advanced navigation purposes or personalized content management;
- Statistical and navigation and user analysis purposes.
B)Only with your specific and separate consent (art. 7 of the EU Regulation), for the following commercial and/or marketing and/or profiling purposes:
- sending via e-mail, post and/or text message and/or telephone contacts of newsletters, commercial communications and/or advertising material on products or services offered by the Data Controller and/or measuring the degree of satisfaction with the quality of what has been carried out at your request;
- sending via e-mail, post and/or text message and/or telephone contacts of commercial and/or promotional communications of third parties (for example, business partners).
3. Processing methods
The processing of your personal data is carried out by means of the operations indicated in art. 4 n. 2) of the EU Regulation and specifically: collection, recording, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, cancellation or destruction, blocking. Your personal data are subjected to both paper and electronic and/or automated processing (in any case suitable to guarantee the security and confidentiality of the data).
If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
4. Data retention periods and other information
The Data Controller will process the personal data for the time necessary to fulfill the purposes mentioned above and in any case for no longer than the legal terms from the termination of the relationship for the Purposes of the existing relationship. With reference to personal data subject to Processing for Marketing Purposes or Processing for profiling purposes, the same will be retained in compliance with the principle of proportionality and in any case until the purposes of the processing have been pursued or until the specific consent is revoked by the interested party. Specifically, the Data Controller will process the data for no longer than 2 years from the collection of data for Marketing Purposes and one year for data collected for Profiling Purposes. The personal data provided by you will be processed lawfully, fairly and transparently protecting your privacy and your rights. It is expected that a periodic check will be carried out annually on the data processed and on the possibility of being able to delete them if no longer necessary for the intended purposes.
5. Access to data
Your data may be made accessible for the purposes referred to in the previous points 2.A) and 2.B):
- to members, employees and collaborators of the Data Controller in Italy and abroad, in their capacity as persons in charge and/or internal data processors and/or system administrators;
- to third-party companies or other entities that carry out outsourced activities on behalf of the Data Controller, in their capacity as external data controllers (for example: associated firms, lawyers, data processing companies, certifying bodies, accounting/tax consultants and in general to all bodies responsible for checks and controls regarding the correct fulfillment of the purposes indicated above, credit institutions, professional firms, consultants, insurance companies for the provision of insurance services, financial offices, Municipal Authorities and/or Municipal Offices, consultants and service companies and for safety in the workplace, who may in turn communicate the data, or grant access to them within their own adhering members, users and related assignees for specific market research. The data collected and processed may also be communicated, in Italy and abroad, to subcontractors, suppliers, for the management of information systems, transporters, freight forwarders and customs agents).
For brevity, the detailed list of these figures is available at our office and is at your disposal.
6. Communication of data
Without the need for express consent (art. 6 letter b) and c) of the EU Regulation), the Data Controller may communicate your data for the purposes referred to in the previous point 2.A) to supervisory bodies, judicial authorities, insurance companies for the provision of insurance services, as well as to those subjects to whom communication is mandatory by law for the fulfillment of the purposes indicated above. These subjects will process the data in their capacity as independent data controllers.
During and after browsing, your data may be communicated to third parties, in particular to:
- Google: Advertising service, Advertising target, Analytics/Measurement, Content personalization, Optimization;
- Google AdWords: Advertising Service, Advertising Targeting, Analytics/Measurement, Content Personalization, Optimization;
- Google Analytics: Advertising Targeting, Analytics/Measurement, Optimization.
Your data will not be disclosed.
7. Data transfer
Personal data is stored on devices located at the Data Controller's headquarters or at providers, within the European Union. In any case, it is understood that the Data Controller, if necessary, will have the right to move the data to non-EU countries. In this case, the Data Controller hereby ensures that the transfer of data outside the EU will take place in compliance with the applicable legal provisions, subject to the stipulation of the contractual clauses and standard checks provided for by the European Commission. Both with regard to the data present on its devices and for any data present at providers, the Data Controller has implemented adequate technical and organizational measures to guarantee an adequate level of security, in full compliance with the provisions of art. 32 of the EU Regulation. Browsing: your browsing data may also be transferred, limited to the purposes indicated above, to the following countries: - EU countries, - United States. Cookie management: in the event that you have doubts or concerns regarding the use of cookies, you can always intervene to prevent their setting and reading, for example by changing the privacy settings within your browser in order to block certain types. Since each browser, and often different versions of the same browser, also differ significantly from each other, if you prefer to act independently through the preferences of your browser, you can find detailed information on the necessary procedure in the guide of your browser.
8. Nature of the provision of data and consequences of refusal to respond
The provision of data for the purposes referred to in the previous point 2.A) is mandatory. In their absence, we will not be able to guarantee you the Services indicated in 2.A). The provision of data for the purposes referred to in the previous point 2.B) is optional. You can therefore decide not to provide any data or to subsequently deny the possibility of processing data already provided: in this case, you will not be able to receive newsletters, commercial communications and advertising material and/or anything else relating to the Services offered by the Data Controller. However, you will continue to be entitled to the Services referred to in point 2.A).
9. Rights of the interested party
In your capacity as interested party, you have the rights referred to in art. 15 of the EU Regulation reported below and specifically:
1. has the right to obtain from the Data Controller confirmation as to whether or not personal data concerning him or her are being processed and, where that is the case, to obtain access to the personal data and the following information:
a) the purposes of the processing;
b) the categories of personal data in question;
c) the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular recipients in third countries or international organizations;
d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
e) the existence of the right of the data subject to request from the Data Controller rectification or erasure of personal data or restriction of processing of personal data concerning him or her or to object to such processing;
f) the right to lodge a complaint with a supervisory authority (the Guarantor for the protection of personal data);
g) where the personal data are not collected from the data subject, any available information as to their source;
h) the existence of automated decision-making, including profiling, referred to in Article 22, paragraphs 1 and 4 of the EU Regulation and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
2. Where your personal data are transferred to a third country or to an international organization, you shall have the right to be informed of the existence of appropriate safeguards pursuant to Article 46 of the EU Regulation relating to the transfer.
3. The Controller will provide you with a copy of your personal data undergoing processing if you request it. If you request further copies, the Controller may charge you a reasonable fee based on administrative costs. If you submit the request by electronic means, and unless you indicate otherwise, the information will be provided to you in a commonly used electronic format.
4. The right to obtain a copy referred to in paragraph 3 must not infringe the rights and freedoms of others.
Furthermore, where applicable, you may enjoy the rights referred to in Articles 16 to 22 of the EU Regulation and specifically you have:
- the right to rectification of personal data;
- the right to be forgotten (right to erasure);
- the right to restriction of processing;
- the right to data portability;
- the right to object;
- the right to lodge a complaint with the Supervisory Authority.
You also have the right to revoke any consent already given at any time without prejudice to the lawfulness of the processing based on the consent given before the revocation.10. Methods of exercising rights
You may exercise your rights at any time by sending:
- a registered letter with return receipt to the undersigned (see the address indicated on the letterhead);
- an e-mail to the address tuscanyhiking@gmail.com
11. Minors
What is offered by the Data Controller and the subject of the relationship with you does not include the intentional acquisition of personal information relating to minors. In the event that information on minors is inadvertently recorded, the Data Controller will delete it promptly, upon request of the interested party.
12. Personal data not obtained from the interested party
It may happen that the undersigned is not the Data Controller to whom you have given your personal data, but is a joint data controller or external data processor and therefore your data has reached the undersigned at a later stage due to a contract that regulates the parties. In this case, it is specified that the undersigned will do everything possible to ensure that you have been informed and have given consent to the processing. You can ask the undersigned at any time for the origin of the acquisition of your data.
13. Owner and Persons in Charge
Below we provide you with some information that is necessary to bring to your attention, not only to comply with legal obligations, but also because transparency and fairness towards our customers is a fundamental part of our business. Data Controller. The Data Controller of your personal data is Michel Bruni on behalf of the legal representative, responsible to you for the legitimate and correct use of your personal data and who you can contact for any information or request at the following addresses: telephone +39 3333244749, e-mail: tuscanyhiking@gmail.com Persons in Charge. The updated list of persons in charge of processing is kept at the headquarters of the Data Controller.
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A demographic profiling of users can also be carried out, extracting statistically relevant data including age group, gender, categories of interest.
More information on data processing by Google Inc. can be found at the following address http://www.google.com/analytics/learn/privacy.html To disable Google Analytics for display advertising or to customize the types of ads displayed, you can access the address https://www.google.it/settings/ads To completely disable the collection of statistical data by Google Analytics you can install the browser add-on, which can be downloaded for free from the address https://tools.google.com/dlpage/gaoptout/
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Privacy information, treatment of personal data