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This page describes how our website manages the personal data of users who visit it. This notice is provided pursuant to Article 13 of Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR) to those who interact with the web services of Associazione Vecchio Borgo ETS (hereinafter referred to as the "Controller"), accessible at www.colleveroni.it.

This notice applies solely to the Controller's website and not to any other websites that may be accessed via links contained herein.

1. Data Controller

Residence Colle Veroni
C.da Veroni nr. 13B, 64023 Mosciano S. Angelo (TE) — Italy
VAT No.: 01713720678
Email: info@colleveroni.it

2. Place of Processing

The processing operations connected to the web services of this site take place at the Controller's registered office and are carried out only by duly authorised technical staff, or by personnel occasionally entrusted with maintenance operations. Where necessary, data connected to certain services may be processed by companies responsible for the technical maintenance of the site, appointed as Data Processors pursuant to Article 28 of the GDPR. An up-to-date list of such Processors is available at the Controller's registered office.

3. Types of Data Processed

a. Navigation data

The computer systems and software procedures used to operate this website collect, during their normal operation, certain personal data whose transmission is implicit in the use of internet communication protocols. This includes: IP addresses, domain names of users' computers, URI addresses of requested resources, time of the request, method used to submit the request to the server, size of the file received in response, the server's response status code, and other parameters relating to the user's operating system and computing environment.

These data are used solely to obtain anonymous statistical information on website usage and to verify its correct functioning. They are deleted immediately after processing and do not persist for more than seven days, except where retention is necessary to ascertain responsibility for cybercrime offences.

b. Data voluntarily provided by the user

The optional, explicit and voluntary sending of emails to the addresses listed on this site entails the acquisition of the sender's address — necessary to respond to requests — as well as any other personal data included in the message (e.g. name, surname, telephone number). Specific summary notices will be progressively displayed on pages set up for particular on-request services (e.g. contact forms).

c. Data provided by minors

No personal data should be submitted to this website by minors without the prior consent of their parents or guardians. The Controller is committed to not knowingly retaining or using any personal data collected from minors for any purpose, including disclosure to third parties, except as necessary to provide services requested by parents or guardians.

d. Cookies

For the policy regarding the use of cookies on this website, please consult our Cookie Policy.

4. Purposes of Processing and Legal Basis

a. Provision of requested services and contractual obligations

Purpose: Secure browsing and registration on this website in order to access its content; acquisition and management of product and/or service requests and related administrative, accounting and tax obligations (e.g. order fulfilment, invoicing, after-sales support).

Legal basis: Performance of a contract to which the data subject is party or pre-contractual measures taken at the data subject's request (Art. 6(1)(b) GDPR) and compliance with a legal obligation (Art. 6(1)(c) GDPR).

b. Direct marketing activities (subject to prior consent only)

Purpose: Sending commercial/promotional/informational communications regarding the Controller's products and services, by post, telephone, SMS, fax, email, and newsletter.

Legal basis: Freely given consent of the data subject (Art. 6(1)(a) GDPR). Consent may be withdrawn at any time.

c. Defence of a right in legal proceedings

Purpose: Establishing, exercising or defending a right in legal proceedings or whenever judicial authorities exercise their functions.

Legal basis: Legitimate interest of the Controller (Art. 6(1)(f) GDPR).

5. Nature of Data Provision

The provision of data for purpose 4.a) is mandatory, as it is necessary to provide the requested services and comply with legal obligations. Any refusal to provide such data will make it impossible for the Controller to deliver the requested products or services.

The provision of data for purpose 4.b) (direct marketing) is optional. Failure to provide such data will have no bearing on the ability to use the services described under purpose 4.a). Consent to marketing may be withdrawn at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Communication and Disclosure of Data

Personal data will not be disclosed to the general public. Specific consent will be required for any such disclosure. Data may be communicated to the following categories of third parties, in order to fulfil the purposes set out above:

The above entities act as Data Processors or operate independently as separate Data Controllers.

7. Processing Methods and Retention Period

Data processing will be carried out in automated electronic and/or manual form, using methods and tools designed to ensure maximum security and confidentiality, by duly authorised personnel in accordance with Articles 29 and 32 of the GDPR. Specific security measures are in place to prevent data loss, unlawful or incorrect use, and unauthorised access.

Personal data will be retained only for as long as strictly necessary for the purposes for which they were collected. In particular:

Upon expiry of the retention period, personal data will be permanently deleted or irreversibly anonymised, unless further retention is required to comply with legal obligations or to establish, exercise or defend a right in legal proceedings.

8. Rights of the Data Subject

As a data subject, you have the right to exercise the following rights under the GDPR:

Right of access — Art. 15 GDPR

To obtain confirmation as to whether or not personal data concerning you is being processed and, if so, to access such data and the information relating to the processing.

Right to rectification — Art. 16 GDPR

To obtain without undue delay the rectification of inaccurate personal data concerning you and the completion of incomplete personal data.

Right to erasure ("right to be forgotten") — Art. 17 GDPR

To obtain without undue delay the erasure of personal data concerning you, where the GDPR conditions apply (e.g. the data is no longer necessary for the purposes for which it was collected).

Right to restriction of processing — Art. 18 GDPR

To obtain restriction of processing where one of the GDPR conditions applies (e.g. you contest the accuracy of the data).

Right to data portability — Art. 20 GDPR

To receive personal data concerning you in a structured, commonly used and machine-readable format, and to transmit it to another controller where technically feasible.

Right to object — Art. 21 GDPR

To object at any time to the processing of personal data concerning you, including objection to direct marketing.

Right to withdraw consent — Art. 7(3) GDPR

To withdraw consent at any time, without affecting the lawfulness of processing based on consent prior to its withdrawal.

Right to lodge a complaint — Art. 77 GDPR

To lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) if you believe that the processing of your data infringes the GDPR.

How to exercise your rights To exercise your rights or for any request for information, clarification or complaints regarding the processing of personal data, please contact the Controller:

By email: info@colleveroni.it

By post: Residence Colle Veroni — C.da Veroni nr. 13B, 64023 Mosciano S. Angelo (TE) — Italy

If you no longer wish to be contacted for direct marketing purposes (purpose 4.b), use of your personal data for that purpose will cease immediately. Please provide your email address, name, postal address and/or telephone number to allow us to process your request correctly.