PRIVACY POLICY Information on the processing of personal data EX ARTT. 13-14 REG.TO EU 2016/679 SUBJECTS OF INTEREST: WEB USERS CONTACTS SECTION Le Querce exclusive c. Hoiuse in its capacity as Data Controller of your personal data, pursuant to and for the purposes of EU Reg.to 2016/679 hereinafter ‘GDPR’, hereby informs you that the aforementioned legislation provides for the protection of data subjects with respect to the processing of personal data and that such processing will be based on principles of correctness, lawfulness, transparency and protection of your privacy and your rights. Your personal data will be processed in accordance with the legislative provisions of the aforementioned legislation and the confidentiality obligations provided for therein. TYPES OF DATA COLLECTED Among the Personal Data collected by this Application, independently or through third parties, there are: Tracking Tool; email; Usage Data. Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data are collected. Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this Application. Unless otherwise specified, all Data requested by this Application is mandatory. If the User refuses to communicate this Data, it may be impossible for this Application to provide the Service. In cases where this Application indicates some Data as optional, Users are free not to communicate such Data, without this having any consequences on the availability of the Service or on its operation. Users who have doubts about which Data are mandatory, are encouraged to contact the Owner. Any use of Cookies - or other tracking tools - by this Application or by the owners of third-party services used by this Application, unless otherwise specified, is intended to provide the Service requested by the User, in addition to the other purposes described in this document and in the Cookie Policy, if available. The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application and guarantees that he/she has the right to communicate or disseminate them, freeing the Owner from any liability towards third parties. METHODS AND PLACE OF PROCESSING OF COLLECTED DATA Methods of processing The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data. Processing is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Owner, in some cases, other parties involved in the organization of this Application (administrative, commercial, marketing, legal, system administration personnel) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) may have access to the Data, also appointed, if necessary, as Data Processors by the Owner. The updated list of Data Processors may always be requested from the Data Controller. Legal basis for processing The Data Controller processes Personal Data relating to the User if one of the following conditions applies: the User has given consent for one or more specific purposes; Note: in some jurisdictions the Data Controller may be allowed to process Personal Data without the User's consent or any other of the legal bases specified below, until the User objects (“opt-out”) to such processing. However, this does not apply if the processing of Personal Data is regulated by European data protection law; processing is necessary for the performance of a contract with the User and/or for the execution of pre-contractual measures; processing is necessary for compliance with a legal obligation to which the Data Controller is subject; processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller; processing is necessary for the pursuit of the legitimate interest of the Data Controller or of third parties. It is always possible to ask the Owner to clarify the specific legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract. Place The Data is processed at the operational headquarters of the Owner and in any other place where the parties involved in the treatment are located. For further information, contact the Owner.
The User's Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of processing, the User can refer to the section relating to the details on the processing of Personal Data. The User has the right to obtain information regarding the legal basis of the transfer of Data outside the European Union or to an international organization governed by public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures adopted by the Owner to protect the Data. The User can verify whether one of the transfers described above is taking place by checking the section of this document relating to the details on the processing of Personal Data or inquire with the Owner by contacting him at the contact details provided at the beginning. Retention period The Data is processed and stored for the time required by the purposes for which it was collected. Therefore: Personal Data collected for purposes related to the performance of a contract between the Owner and the User will be retained until such contract has been fully performed. Personal Data collected for purposes related to the legitimate interest of the Owner will be retained until such interest is fulfilled. The User may obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner. When the processing is based on the User's consent, the Owner may retain Personal Data for a longer period until such consent is revoked. Furthermore, the Owner may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority. At the end of the retention period, Personal Data will be deleted. Therefore, upon expiration of such term, the right of access, cancellation, rectification and the right to portability of Data can no longer be exercised. PURPOSE OF THE PROCESSING OF COLLECTED DATA The User's Data is collected to allow the Owner to provide its Service, comply with legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of Users or third parties), identify any malicious or fraudulent activity, as well as for the following purposes: Tag Management, Contact Management and sending messages, Statistics and Displaying content from external platforms. To obtain detailed information on the purposes of the processing and on the Personal Data processed for each purpose, the User may refer to the section "Details on the processing of Personal Data". Contact Management and sending messages This type of service allows you to manage a database of email contacts, telephone contacts or contacts of any other type, used to communicate with the User. These services may also allow you to collect data relating to the date and time the messages are viewed by the User, as well as the User's interaction with them, such as information on clicks on links inserted in messages. Tag Management This type of service is functional to the centralized management of the tags or scripts used on this Application. The use of these services involves the flow of User Data through them and, if necessary, their retention. -Google Tag Manager (Google Ireland Limited) Google Tag Manager is a tag management service provided by Google Ireland Limited. Personal Data processed: Tracking Tool. Place of processing: Ireland – Privacy Policy. Statistics The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behavior. -Google Analytics with anonymized IP (Google Ireland Limited) Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google. Google may use the Personal Data to contextualize and personalize the ads of its own advertising network. This integration of Google Analytics makes your IP address anonymous. Anonymization works by shortening the IP address of Users within the borders of the member states of the European Union or in other countries adhering to the Agreement on the European Economic Area. Only in exceptional cases will the IP address be sent to Google's servers and shortened within the United States. Personal Data processed: Usage Data; Tracking Tool. Place of processing: Ireland – Privacy Policy – Opt Out. Displaying content from platforms and
FURTHER INFORMATION ON THE PROCESSING Defense in court The User's Personal Data may be used by the Owner in court or in the preparatory stages of its possible establishment for the defense against abuse in the use of this Application or related Services by the User. The User declares to be aware that the Owner may be required to reveal the Data by order of public authorities. Specific information Upon request of the User, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data. System logs and maintenance For needs related to operation and maintenance, this Application and any third-party services used by it may collect system logs, which are files that record the interactions and may also contain Personal Data, such as the User's IP address. Information not contained in this policy Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details. Response to “Do Not Track” requests This Application does not support “Do Not Track” requests. To find out whether any third-party services it uses support them, the User is invited to consult their respective privacy policies. Changes to this privacy policy The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to Users on this page and, if possible, on this Application and, if technically and legally feasible, by sending a notification to Users through any contact information available to it. Please therefore consult this page frequently, referring to the date of the last modification indicated at the bottom. If the changes affect processing based on consent, the Data Controller will collect the User’s consent again, if necessary. DEFINITIONS AND LEGAL REFERENCES Personal Data (or Data) Personal data means any information that, directly or indirectly, also in connection with any other information — including a personal identification number — allows a natural person to be identified or identifiable. Usage Data This information is collected automatically through this Application (also from third-party applications integrated into this Application), including: the IP addresses or domain names of the computers used by the User who connects to this Application, the URI (Uniform Resource Identifier) addresses, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.), the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example, the time spent on each page) and the details relating to the itinerary followed within the Application, with particular reference to the sequence of pages visited, the parameters relating to the operating system and the IT environment of the User. User The individual who uses this Application who, unless otherwise specified, coincides with the Data Subject. Data Subject The natural person to whom the Personal Data refers. Data Controller (or Controller) The natural person, legal person, public administration or any other body which processes Personal Data on behalf of the Controller, as set out in this privacy policy. Data Controller (or Controller) The natural person, legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data and the tools used, including the security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application. Service The Service provided by this Application as defined in the relevant terms (if any) on this site/application. European Union (or EU) Unless otherwise specified, any reference to the European Union contained in this document shall be deemed to extend to all current member states of the European Union and the European Economic Area. Cookies Cookies are Tracking Tools consisting of small sets of data stored in the User's browser. Tracking Tool Tracking Tool means any technology – e.g. Cookies,
