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Information on the processing of personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (GDPR). Effective September 1, 2022

FOREWORD

This notice takes into account the provisions of the GDPR and the Privacy Code (Legislative Decree No. 196 of June 30, 2003). The document was also drafted based on the Privacy Guarantor’s Guidelines (especially the Counter Spam Guidelines issued dl Privacy Guarantor on July 4, 2013).

Data Controller: Clio Viaggi S.r.l., based in Inzago, Piazza Maggiore, 22 (20065) p. iva 00959470162, Tel: 02 954 7531, Email: inzago@clioviaggi.com. The Data Protection Officer (DPO) appointed is Maderna Carlo who can be contacted at the following addresses: PEC clioviaggi@pec.it or by registered mail at Clio Viaggi S.r.l. – Piazza Maggiore 22 – 20065 Inzago

Site to which this privacy policy refers: https://www.clioviaggi.com(Site).

The Data Controller has also appointed a DPO (Data Protection Officer) to monitor the Data Controller’s compliance with the GDPR.

GENERAL INFORMATION

This document describes how the Data Controller processes your personal data provided on the Site.

The main processing of your personal data is described below. In particular, the legal basis of the processing, whether the provision is mandatory, and the consequences of not providing personal data are explained. To better describe your rights, if necessary, we have specified if and when a certain processing of personal data is not carried out.

Site Registration

The Site does not offer the option of registration. Therefore, the Data Controller does not process your personal data for this purpose.

Purchases on the Site

Your personal information will be processed to enable you to make purchases on the Site. In the case of placing an online purchase order, to enable the conclusion of the purchase contract and the proper execution of transactions related to it (and, if necessary under industry regulations, to fulfill tax obligations). The legal basis for processing is the obligation of the Data Controller to perform the contract with the data subject or to fulfill legal obligations. Regardless of the above (and thus your consent), the Data Controller may process your data purposes of so-called “soft-spam,” governed by Art. 130 of the Privacy Code. This means that limited to the email you provide in the context of a purchase through the Site, the Data Controller will process the email to enable direct offers from similar products/services, unless you object to such processing in the manner set forth in this policy. The legal basis for processing is the legitimate interest of the Data Controller in sending these types of communications. This legitimate interest can be considered equivalent to the data subject’s interest in receiving “soft-spam” communications. The Data Controller may send emails to remind the user to complete a purchase. The legal basis for this processing is the legitimate interest of the Data Controller in sending this type of communication.

Responding to your requests

Your data will be processed to respond to your inquiries. Providing the information is optional, but your refusal will make it impossible for the Data Controller to answer your questions. The legal basis for the processing is the legitimate interest of the Data Controller in fulfilling the user’s requests. This legitimate interest is equivalent to the user’s interest in receiving responses to communications sent to the Data Controller.

Generic marketing

Subject to your consent, the Data Controller may process the personal data you provide in order to send you advertising material and/or newsletters regarding its own or third-party products. The legal basis for this processing is your consent. The provision of personal data for this purpose is purely optional. Failure to consent to the processing of data for marketing purposes will result in the impossibility for you to receive advertising material related to products/services of the Data Controller and/or third parties as well as the impossibility for the Data Controller to conduct market surveys, including those aimed at assessing the degree of user satisfaction, as well as to send you newsletters. These communications will be sent to the e-mail you have given on the Site.

Profiling

The Data Controller does not perform “profiling” with your personal data. Therefore, it will not send you advertising materials and/or newsletters related to its own or third-party products of your specific interest.

Data transfer

The Data Controller does not transfer your personal data to third parties.

Geolocation

The Site does not implement tools to geolocate the user’s IP address.

Disclosure of personal data

As part of its ordinary business, the Data Controller may disclose your personal data to certain categories of individuals. In Article 2 You can find the list of subjects to whom the Data Controller communicates your personal data. To facilitate the protection of your rights, Article 2 may specify in some cases when your data are not disclosed to third parties.

“Disclosure” of personal data to third parties is different from “transfer” (governed by the point above). In fact, in the communication the third party to whom the data is transmitted can use it only for the specific purposes described in the relationship with the Data Controller. In divestment, on the other hand, the third party becomes the Autonomous Personal Data Controller. In addition, your consent is always required to transfer your personal data to third parties.

Notwithstanding the foregoing, it is understood that the Data Controller may still use your personal data to properly fulfill its obligations under applicable laws.

SPECIFIC PRIVACY POLICY

Art. 1 Method of treatment

1.1 The processing of your personal data will be mainly carried out with the aid of electronic or otherwise automated means, in the manner and with the appropriate tools to ensure their security and confidentiality in accordance with the GDPR.

1.2 The information acquired and the manner of processing will be relevant and not excessive in relation to the type of services rendered. Your data will also be managed and protected in secure computer environments appropriate to the circumstances.

1.3 No “special data” are processed through the Site. Particular data are those that may reveal racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership in parties, trade unions, associations or organizations of a religious, philosophical, political or trade union nature, health status and sex life.

1.4 No judicial data are processed through the Site.

Article 2 Disclosure of personal data

The Data Controller may disclose your personal data to certain categories of individuals. The following are the subjects to whom the Data Controller reserves the right to communicate your data:

  • The Data Controller may disclose your personal data to all those entities (including Public Authorities) that have access to personal data by virtue of regulatory or administrative measures.
  • Your personal data may also be communicated to all those public and/or private entities, individuals and/or legal entities (legal, administrative and tax consulting firms, Judicial Offices, Chambers of Commerce, Chambers and Offices of Labor, etc.), if the communication is necessary or functional for the proper fulfillment of obligations arising from the law.
  • The Data Controller makes use of employees and/or collaborators in any capacity. For the proper functioning of the Site, the Data Controller may disclose your personal data to these employees and/or contractors.
  • In its ordinary business of managing the Site, the Data Controller makes use of companies, consultants or professionals in charge of the installation, maintenance, updating and, in general, the management of the hardware and software of the Data Controller or which the latter uses for the provision of its services. Therefore, only with reference to these purposes, your data may also be processed by these parties.
  • To send its communications, the Data Controller uses external companies contracted to send these types of communications (CRM platforms). Your personal data (especially email) may then be disclosed to these companies.
  • The Data Controller does not use outside companies to provide customer care service.

The Holder reserves the right to change the above list in accordance with its ordinary operations. Therefore, you are encouraged to access this policy regularly to check to which entities the Data Controller discloses your personal data.

Art. 3 Retention of personal data

3.1 This article describes how long the Data Controller reserves the right to keep your personal data.

  • Your personal data will be kept only as long as necessary to ensure the proper provision of the services offered through the Site.
  • For marketing purposes, personal data will be retained until consent is revoked. For inactive users, personal data will be deleted after one year from the sending of any last viewed email.
  • For the purpose of executing the sales contract, data will be kept for 10 years from the date of receipt of the purchase order. This is to enable the Data Controller to exercise its right of defense and to demonstrate that it has properly executed the contract.
  • For customer care purposes, the data will be deleted once the customer care service is completed.
  • As stipulated in Article 2220 of the Civil Code, invoices, as well as all accounting records in general, are kept for a minimum period of ten years from the date of recording so that they can be presented in case of an audit.

 

3.2 Notwithstanding Article 3.1, the Data Controller may retain your personal data for as long as required by specific regulations, as amended from time to time.

Article 4 Transfer of personal data

4.1 The Data Controller is based within the European Union. Therefore, the processing of your data is safe from a regulatory perspective as it is governed by the GDPR. If the transfer of your personal data takes place to a country outside the EU and for which the European Commission has issued an adequacy opinion, the transfer is considered safe from a regulatory point of view in any case. This Article 4.1 indicates from time to time the countries to which your personal data may possibly be transferred and where the European Commission has made an adequacy finding.

  • You are therefore invited to access this article regularly to check whether the transfer of your personal data takes place in a country with these characteristics.

 

4.2 Notwithstanding Article 4.1, your data may also be transferred to countries outside the EU and for which the European Commission has not issued an adequacy finding. You are therefore invited to regularly review this Article 4.2 to ascertain to which, if any, of these countries your data is transferred. To enable the proper functionality of the Site, your personal data may be transferred to the U.S.A. In such cases, the Data Controller will take all appropriate contractual measures to ensure an adequate level of protection of personal data, including, among others, the Standard Contractual Clauses approved by the European Commission on June 4, 2021.

4.3 In this article, the Data Controller indicates the countries where, if any, it specifically directs its activities. This circumstance may imply the application of the relevant country’s legislation, together with that of the GDPR.

  • Upon the user’s request, the Data Controller will apply to the processing of personal data the most favorable legislation, if any, provided by the user’s national legislation.

 

Art. 5. Rights of the data subject

Pursuant to Art. 13 of the Privacy Regulation, the Data Controller informs you that you have the right to:

  • to request from the Data Controller access to your personal data and the rectification or erasure of the data or the restriction of processing concerning you or to object to its processing, as well as the right to data portability
  • Revoke consent at any time without affecting the lawfulness of processing based on consent given before revocation
  • Propose a complaint to a supervisory authority (e.g., the Data Protection Authority).

The above rights may be exercised by request addressed without formalities to the contacts indicated in the Foreword.

Art. 6. Changes and Miscellany

The Data Controller reserves the right to make changes to this policy at any time, giving appropriate publicity to users of the Site and ensuring in all cases adequate and similar protection of personal data. In order to view any changes, you are encouraged to review this policy on a regular basis. In case of substantial changes to this privacy policy, the Data Controller may also give notice by email.

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