Data Subjects: Navigators, service users and newsletter subscribers
“CLUB FAMILY HOTEL SRL”, in its capacity of Data Controller of your personal data, pursuant to and for the purposes of Regulation (EU) 2016/679 hereinafter 'GDPR', hereby informs you that the aforementioned legislation provides for the protection of data subjects with regard to the processing of personal data and that such processing will be based on the principles of correctness, lawfulness, transparency and protection of your privacy and your rights.
In order to fulfil its purposes, relating to the management of the relationship, the Data Controller needs to acquire personal data, such as, for example, name and surname, telephone or mobile phone number, email address, tax code. Your personal data will be processed in accordance with the legal provisions of the aforementioned legislation and the confidentiality obligations therein.
Purpose of processing: Service provision: Your data will be processed in order to respond to any requests you may receive from the forms available on the website, or to requests received by email.
Legal basis: The legal basis for the processing is contractual in the sense that data is processed in response to a request for information that is followed by a reply.
Consequences of non-disclosure: the processing of functional data for the fulfilment of these obligations is necessary for the proper management of the relationship and their provision is mandatory for the implementation of the abovementioned purposes. The Data Controller also makes it known that failure to provide, or incorrect communication of, any of the mandatory information may make it impossible for the Data Controller to guarantee the appropriateness of the processing itself.
Optional purposes: Marketing - newsletter reception service: in particular, your data will be processed, subject to your free consent, for the purpose of receiving newsletters, either by entering your email address in the text box provided for this purpose or by check-ing/unchecking the box indicating "newsletter subscription" on a form.
Legal basis: The legal basis for the processing is the consent of the data subject.
Consequences of refusal for optional purposes: The provision of data is optional for you, with regard to the above-mentioned purposes, and your refusal to provide such data does not affect the continuation of the relationship or the appropriateness of the processing.
Processing methods: Processing is carried out using manual and/or computerised and telematic tools, in such a way as to guarantee the security, integrity and confidentiality of the data in compliance with the physical and logical organisational measures laid down by the provisions in force, so as to minimise the risks of destruction or loss, unauthorised access, modification and unauthorised disclosure in compliance with the procedures set out in Art. 6, 32 of the GDPR.
Target audience: In order to carry out certain activities, or to provide support for the opera-tion and organisation of the activity, some data may be brought to the attention of or communicated to recipients. These subjects are divided in: Third parties: (communication to: natural or legal persons, public authorities, service or oth-er body other than the data subject, data controller, data processor and authorised persons responsible for processing) including:
- Companies operating traditional or com-puterised postal services
- Any other parties to which disclosure of data is necessary to achieve the above-mentioned purposes.
Data processors: (the natural or legal person, public authority, service or other body processing personal data on behalf of the data controller)
- Providers of IT, web, or other services necessary to achieve the purposes necessary for the management of the relationship.
Within the company structure, your data will only be processed by personnel expressly authorised by the Data Controller, with assurance of the adoption of confidentiality agreements and, in particular, by the following categories of employees:
- Administration;
- Other employees whose processing is necessary for the proper execution of the contract;
Diffusion: Your personal data will not be disseminated in any way.
Transfer of data to third countries: The Data Controller uses data processors located in non-EU countries, in particular: __________________ with guaranteed adoption of measures such as Standard Contractual Clauses, in the case of U.S. adherence to the international Privacy Shield agreement, or with the consent of the data subjects.
Retention period: We would like to inform you that, in compliance with the principles of lawfulness, purpose limitation and data minimisation, pursuant to Art. 5 of the GDPR, the retention period of your personal data is established for a period of time not exceeding the fulfilment of the purposes for which they are collected and processed; in case a contract is signed, such retention period may end with the forfeiture or termination of the contract, the same data may be retained, where applicable, for a further period of time for the purpose of handling any litigation, the legal basis for such retention is the legitimate interest of the data controller. The retention period for marketing-related data processing is functional to the purposes pursued by the data controller, and in any case not longer than 3 years from the last contact, or feedback received.
Data Controller: the Data Controller, according to the law is “CLUB FAMILY HOTEL SRL”, with legal headquarters Via Cesare Abba, 90 – 47042 Cesenatico (FC), VAT number/Tax Code: 03848460402 person of its legal repre-sentative pro tempore. By sending an e-mail to the following address info@clubfamilyhotel.com you can request further information on the da-ta provided.
EU Reg. 2016/679: Art. 15, 16, 17, 18, 19, 20, 21, 22 - Rights of the Data Subject
1. The data subject has the right to obtain confirmation of the existence or non-existence of personal data concerning them, even if not yet recorded, and its communication in intelligible form.
2. The data subject has the right to be informed:
- a. on the origin of personal data;
- b. the purposes and methods of processing;
- c. on the logic applied in the event of processing carried out with the aid of electronic instruments;
- d. on the identification details of the Data Controller and Processor, pursuant to Article 5(2);
- e. on the entities or categories of entity to whom or which the personal data may be communicated or who or which may become aware of them in their capacity as designated representative(s) in the territory of the State, data processor(s) or person(s) in charge of the processing.
3. The data subject has the right to obtain:
- a. updating, rectification or, where inter-ested, integration of the data;
- b. cancellation, transformation into anonymous form or blocking of data pro-cessed in breach of the law, including da-ta whose storage is not necessary in rela-tion to the purposes for which the data were collected or subsequently pro-cessed;
- c. certification to the effect that the oper-ations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, un-less this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected;
- d. data portability.
4. The data subject has the right to object, in whole or in part:
- a. for legitimate reasons, to the pro-cessing of personal data concerning them, even if pertinent to the purpose of collection;
- b. the processing of personal data con-cerning them for the purpose of sending advertising or direct sales material or for carrying out market research or com-mercial communication.
Complaint: Data subjects also have the right, where applicable, to lodge a complaint with the Garante as supervisory authority in accordance with the procedures laid down. For any further information, and to assert your rights under the European Regulation, you may contact the data controller at the above-mentioned refer-ences.
Consent
Formula for acquiring the data subject’s consent Your consent to receive the newsletter will be recorded (IP address, email, date and time) by ticking the box below the email entry, or by placing / clicking in the appropriate box, and in conjunction with pressing the "send" / "ok" but-ton. This consent will be stored in order to prove that it has been given, and to allow you to unsubscribe at any time, in addition to all the other rights set out above.
