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Privacy policy

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This policy is provided pursuant to art. 13 of Legislative Decree no. 196 of 30.06.2003 (the "Personal Data Protection Code") and art. 13 of EU Regulation no. 2016/679 (the "European General Data Protection Regulation").

The company ACQUE ALBULE S.p.A, Tax Code/Reg. No.: 00435290580, VAT No.: 00891651002, in the person of TERRANOVA BARTOLOMEO, in its capacity as Data Controller (hereinafter, the "Controller"), informs you pursuant to art. 13 of Legislative Decree no. 196 of 30.06.2003 (hereinafter, the "Privacy Code") and art. 13 of EU Regulation no. 2016/679 (hereinafter, the "GDPR") that your data will be processed in the manner and for the purposes set out below:

1. Subject of the processing

The Controller takes care of the protection of your personal data and complies with the applicable personal data protection legislation (the Privacy Code and GDPR 2016/679). Your personal data are processed confidentially and transferred to third parties only as provided for in this Policy or with your consent. We process the personal data you provide to us while using the website and/or after registering on the website.

In particular, we process: personal, identifying and sensitive data (in particular, first name, surname, tax code, VAT number, e-mail, telephone number — hereinafter, "personal data" or simply "data") provided directly by you, upon registration on the site and/or when requesting to use individual services; data not provided directly by you — and in any case acquired within the limits of art. 14, paragraph 5, GDPR — whose transmission is connected to the use of Internet communication protocols (by way of example only, page accesses, amount of data transferred, status messages on completed accesses, session ID numbers, IP addresses, URL addresses, etc.). Such data make it possible to reconstruct the path of your visits to the site.

2. Purposes of the processing

Your personal data are processed:

A) Service Purposes

Without your express consent (art. 24, letters a), b), c), Privacy Code and art. 6, letters b), e), GDPR), for the following Service Purposes:

  • to process a contract request or a pre-contractual request;
  • to carry out pre-contractual measures adopted at your request;
  • to compile internal statistics;
  • to fulfil tax obligations arising from existing relationships;
  • to fulfil obligations laid down by law, by regulation, by EU legislation or by an order of the Authority;
  • to safeguard the vital interests of the data subject or of another natural person;
  • to perform tasks carried out in the public interest or connected to the exercise of official authority vested in the data controller;
  • to prevent or detect fraudulent activity or abuse harmful to the website;
  • to pursue a legitimate interest of the Data Controller or of third parties, within the limits and under the conditions of art. 6, letter f), GDPR;
  • to exercise the rights of the Controller (by way of example only, the right of defence in legal proceedings).

B) Marketing Purposes

Only with your specific and unequivocal consent (arts. 23 and 130, Privacy Code and art. 7, GDPR), for the following Marketing Purposes: to send by e-mail newsletters, commercial communications and/or advertising material on products and/or services offered by the Controller, other than and/or dissimilar to those already purchased.

3. Nature of the provision of personal data

The provision of your data for the purposes described in point 2, letter A), nos. i and ii) is necessary in nature. Without such provision we cannot guarantee your registration on the Site, nor the possibility of processing your requests.

The provision of Data for the purposes described in point 2, letter B), is instead optional in nature. You may therefore decide not to provide any data or to revoke our ability to process data previously provided. In that case, you will no longer receive our newsletters, while you will continue to receive our services and will retain the right to remain registered on the site.

4. Methods of processing

The processing of your personal data is carried out by means of the operations indicated in art. 4 of the Privacy Code and art. 4, no. 2), GDPR, namely: collection, recording, organisation, storage, consultation, elaboration, modification, selection, extraction, comparison, use, interconnection, blocking, communication, erasure and destruction of data. The processing of your Data will be based on the principles of fairness, lawfulness and transparency and may also be carried out through automated means suitable for storing, managing and transmitting them, and will take place using tools suitable, as far as reasonable and in line with the state of the art, to guarantee security and confidentiality through the use of appropriate procedures that avoid the risk of loss, unauthorised access, unlawful use and dissemination.

5. Data retention period

The Controller will process the personal data for the time necessary to fulfil the purposes set out above and for no longer than 2 years from the collection of the data for Marketing Purposes. Once this retention period has elapsed, the data will be destroyed or anonymised.

6. Access to the data

The personal data processed by the Controller will not be disseminated, that is, they will not be disclosed to unspecified parties, in any possible form, including making them available or allowing their simple consultation. They may, however, be communicated to workers employed by the Controller and to certain external parties who collaborate with them. In particular, your data may be made accessible to:

  • employees and collaborators of the Controller, consultants authorised to manage the site and provide the related services (by way of example: customer services, IT department, etc.), in their capacity as internal Data Processors and/or Persons in charge of processing personal data and/or System Administrators;
  • third-party companies or other parties (by way of example only: credit institutions, professional firms, consultants, insurance companies, etc.) that carry out outsourced activities on behalf of the Controller, in their capacity as external Data Processors and/or Persons in charge of processing personal data.

Your data may also be communicated, within the limits strictly necessary, to parties entitled to access them by virtue of legal provisions, regulations or EU legislation.

7. Communication of the data

Without your express consent (pursuant to art. 24 letters a), b), d), Privacy Code and art. 6 letters b), c), GDPR), the Controller may communicate your data, for the purposes indicated, to Supervisory Bodies, Judicial Authorities and all other parties to whom communication is required by law for the fulfilment of the aforesaid purposes.

8. Data transfer

The management and storage of personal data will take place on servers of the Controller and/or of duly appointed third-party companies designated as Data Processors, located within the European Union, or in accordance with the provisions of arts. 45 et seq., GDPR. The servers are currently located in the European Union. The data will not be transferred outside the European Union. It remains understood in any case that, should it become necessary to relocate the servers, within Italy and/or the European Union and/or non-EU countries, such relocation will always take place in compliance with arts. 45 et seq., GDPR. In that case, the Controller hereby assures that any transfer of data outside the EU will take place in accordance with the applicable legal provisions, entering into, where necessary, agreements guaranteeing an adequate level of protection and/or adopting the standard contractual clauses provided for by the European Commission.

9. Browsing data

The computer systems and software procedures used to operate the site may acquire, in the course of their normal activity, certain personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified data subjects, but which by its very nature could, through processing and association with data held by third parties, make it possible to identify users (i.e. parameters relating to the user's operating system and computing environment). Such data are used by the Controller solely for the purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning, and are deleted immediately after processing. Such data may also be used to ascertain liability in the event of hypothetical computer crimes against the Site.

10. Cookies

When you use our site, cookies are stored on your computer. Cookies are small text files that are saved on your computer and provide us with certain information. They are widely used in order to make websites work, or work more efficiently, to improve the user experience, as well as to provide certain information to the owners of the site. Our site uses cookies that remain on your computer for varying lengths of time. Some expire at the end of each session and some remain longer so that when you return to our Site, you can benefit from a better user experience. Web browsers allow you to exercise a certain degree of control over cookies through the browser settings. Most browsers allow you to block cookies or to block cookies from specific sites. Browsers can also help you delete cookies when you close the browser. However, you should bear in mind that this may mean that any opt-outs or preferences you have set on the site will be lost. Please consult the technical information for your browser for instructions. If you choose to disable the setting of cookies or refuse to accept a cookie, some parts of the service may not function correctly or may be significantly slower.

11. Rights of the data subject

In your capacity as data subject, you have the rights set out in art. 7 of the Privacy Code and art. 15 GDPR, namely the rights to:

  • obtain confirmation of the existence or otherwise of personal data concerning you, even if not yet recorded, and their communication in intelligible form;
  • obtain an indication of: a) the origin of the personal data; b) the purposes and methods of the processing; c) the logic applied in the case of processing carried out with the aid of electronic instruments; d) the identification details of the controller, of the processors and of the representative designated pursuant to art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR; e) the parties or categories of parties to whom the personal data may be communicated or who may become aware of them in their capacity as designated representative within the territory of the State, as processors or as persons in charge of the processing;
  • obtain: a) the updating, rectification or, where you have an interest therein, the integration of the data; b) the erasure, anonymisation or blocking of data processed in breach of the law, including data whose retention is not necessary in relation to the purposes for which the data were collected or subsequently processed; c) certification that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except where such fulfilment proves impossible or involves the use of means manifestly disproportionate to the right protected;
  • object, in whole or in part: a) on legitimate grounds, to the processing of personal data concerning you, even where pertinent to the purpose of the collection; b) to the processing of personal data concerning you for the purposes of sending advertising material or direct sales, or for carrying out market research or commercial communications, through the use of automated calling systems without the intervention of an operator, by e-mail and/or through traditional marketing methods by telephone and/or paper mail.

Please note that the data subject's right to object, set out in point b) above, for direct marketing purposes through automated means extends to traditional means, and that in any case the data subject retains the possibility of exercising the right to object even only in part. The data subject may therefore decide to receive only communications through traditional means, or only automated communications, or neither type of communication.

Where applicable, you also have the rights set out in arts. 16 – 21, GDPR (right of rectification, right to be forgotten, right to restriction of processing, right to data portability, right to object), as well as the right to lodge a complaint with the Italian Data Protection Authority (Garante).

12. How to exercise your rights

You have the right to ask the Controller for access to the Data concerning you, for their rectification or erasure, for the integration of incomplete Data, and for the restriction of processing; to receive the data in a structured, commonly used and machine-readable format; to revoke, at any time, any consent given regarding the processing of your sensitive data and to object, in whole or in part, to the use of the Data; to lodge a complaint with the Authority, as well as to exercise the other rights granted to you by the applicable legislation.

You may exercise your rights at any time by sending: a certified e-mail (PEC) to acquealbulespa@lamiapec.it

13. Minors

Where the person providing the data is under 16 years of age, such processing is lawful only if and to the extent that such consent is given or authorised by the holder of parental responsibility for whom the identifying data are acquired.

14. Controller, processor and persons in charge

The company ACQUE ALBULE S.p.A, Tax Code/Reg. No.: 00435290580, VAT No.: 00891651002, in the person of TERRANOVA BARTOLOMEO, in its capacity as Data Controller. The updated list of data processors and persons in charge of the processing is kept at the registered office of the Data Controller.

15. DPO – Data Protection Officer

Claudio Cesaroni – CSRCLD86A21A662Q – dpo@claudiocesaroni.it

16. Changes to this Policy

This Policy may be subject to changes. You are therefore advised to check this Policy regularly and to refer to the most up-to-date version.

Tivoli Terme, 02/05/2019