DATA PROTECTION GUIDANCE NOTE
AS PER THE E.U. GENERAL DATA PROTECTION REGULATION (G.D.P.R.) 2016/679
1. INTRODUCTORY STATEMENT
1.1. Exclusive Italy (hereinafter referred to as ‘E.I.’), owned by Mrs. Laura Frappa, seriously takes into account the privacy of the online users who visit its website, www.exclusiveitalyweddings.com (the ‘Website’), and constantly works to guarantee the respect thereof.
1.2. The present document (the ‘Guidance Note’) has been written according to the obligations imposed by the EU G.D.P.R. 679/2016 to allow you to understand how your personal data are treated every time you, any visitor or user (the ‘Person concerned’) surfs the Website and possibly uses its services e functions (the ‘Services’).
1.3. The present Guidance Note concerns only the E.I. Website and no other sites that may be potentially visited through other links; for those sites you will need to consult their own data protection policy/note.
1.4. Therefore, we kindly suggest you read the present Guidance Note attentively before you submit any of your personal details, fill in any form or use any functions of this Website. In any case, you can specifically find this Note on those Website pages where special services are described and which your personal data are requested for.
2. DATA CONTROLLER AND CONTACTS
2.1. The Data Controller is Exclusive Italy, owned by Mrs. Laura Frappa, in the person of its pro tempore legal representative, with its registered office in Via Roma 96, 33033 Codroipo (Udine), Italy; VAT No. 02358380307, F.C. FRPLRA74P70Z614E, Tel. No. +39.0432.913513, Fax No. +39.0432.913809, e-mail email@example.com
3. TYPE OF DATA
3.1. The Website offers informative and interactive contents. While surfing the Website, i.e. when you make use of its services, the Company itself acquires and uses your personal data, which means ‘any pieces of information regarding an identified or identifiable natural person’.
3.2. Said personal data may be an online identity or, on the basis of how you choose to use the Services, also your identity or contact details or even any pieces of information which you will freely decide to submit (e.g. when you fill in a form, send a request or other).
a) INTERNET USAGE DATA
E.I. does not usually process the Internet usage data in a direct way. Nevertheless, the IT systems and the procedures which the Website functioning is based on normally acquire some personal data, whose transfer is implicit in the use of Internet communication protocols. They are pieces of information which are not collected by E.I. in order to be associated with identified interested people; instead, because of their nature, they may allow the Company to identify the users by means of their elaboration and association with data processed by third parties (e.g. in case of cybercrimes upon request of the Judicial Authority and of its access to third parties’ data bases).
This data category includes IP addresses or the domain names for the computers used by those who connect to the Website, the URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the dimension of the file obtained as a reply, the numeric code indicating the status of the reply given by the server (‘sent successfully’, ‘delivery failure’, etc.) and other parameters related to the operating system and to the user ‘s IT environment. These data may be used for the sole purpose of obtaining anonymous statistical information regarding the use of the Website, of verifying its correct functioning and also of finding anomalies and/or abuses. The above said data are kept by the provider in conformity with and within the limits set forth by the law, save for those data which are used to determine liability in case of hypothetical cybercrimes to the detriment of the site or third parties.
c) VOLUNTARILY SUBMITTED DATA
You can freely choose to utilize the specific Services on our Website. In that case, before proceeding with the activation or use of a particular Service or the forwarding of a specific request, you will personally submit your data after having read the present Guidance Note and, when necessary, after having given the required consent so as to be able to obtain what you are interested in (information and/or follow-up contact, quotations, etc.). In particular you will be asked to give – as an example – pieces of information like the first name and the last name, the email address, the residence address, etc. The personal data requested for the single Services may differ depending on the form used each time, nevertheless the information to fill them with will always be clear.
4. SPECIAL CATEGORIES OF PERSONAL DATA AND THIRD PARTIES’ DATA
4.1 With the aim of meeting your needs at best, E.I. may learn of some personal data of yours which belong to the special categories of personal data (‘special data’), namely those revealing your racial or ethnic origin, your political opinions, your religious or philosophical beliefs or if you are a member of the trade unions as well as your genetical data, your biometric data needed to univocally identify your identity as a natural person, your health or sexual life or sexual orientation. For instance, this may happen when you choose to submit data which are related to the type of ceremony you desire, to your religious orientation, etc.
4.2 Some Website sections allow you to freely inform us of your requests, namely after having electively chosen to complete specific optional fields or to submit more details about what you are interested in. We also kindly ask you to take into consideration that the special data that you voluntarily decide to share with us may be processed only upon your explicit consent, in compliance with the relevant law in force. On the basis of the service offered, E.I. regards as necessary to ask for your explicit consent to processing your special data so as to be able to reply to your requests adequately.
4.3 However, if you submit or otherwise process third parties’ personal data while using the Website, you guarantee as of now that such particular hypothesis is based on the consent of said third party or on another adequate legal authorization which legitimates the processing of the information in question as per the relevant law in force. As a consequence, you are fully responsible thereof and release E.I. from any third party’s claim.
5 DATA PROCESSING METHODS
5.1 Your personal data are processed manually on paper, electronically and by means of IT, telematic and/or automated devices by following principles which are strictly connected to the purposes described herein and in compliance with the regulations in force.
5.2 Your personal data are protected by proper technical and organizational measures so as to ensure their safety and confidentiality. E.I. has implemented specific safety measures to avoid losing or destroying personal data, to avoid their unauthorized modification or disclosure and also to avoid accidentally or illegally accessing the personal data which have been submitted, stored or, in any case, processed.
6. DATA PROCESSING PURPOSES AND LEGAL BASIS
6.1 E.I. processes the personal data which you submit through the Website only to carry out all those activities that are strictly necessary to meet your requests and all other activities functionally related to its work or to the protection of its rights. For instance, the submitted data may be used to manage your notes, to send you the information you are in need of, to prepare a quotation and, in any case, to share with you all the pieces of information you might be interested in. If necessary, your data may be used for administrative, accounting and insurance purposes, for the fulfillment of legal obligations and the exercise of its rights in court. For said purposes your consent is not required. As a matter of fact, the above-mentioned uses are considered licit, as they are needed to fulfil a contract which you are part of or to carry out precontractual measures that have been adopted upon your request, to allow E.I. to adhere to a legal obligation it is subject to or, finally, to guarantee the safeguard of its own rights. As better explained in the specific dedicated paragraph, the processing of possible special data will be carried out by virtue of your explicit consent and also, those data may be used, when strictly indispensable, to safeguard E.I.’s rights. Moreover, on the basis of the services offered, it is regarded as fundamental to ask for your explicit consent to processing your special data. Failure to do so E.I. may not be able to carry out the services requested.
7. CONFERMENT OF DATA AND CONSEQUENCES OF A POSSIBLE REFUSAL
7.1 Except for the Internet usage data, which are collected automatically by the system, the conferment of data depends on your free will.
7.2 Failure to confer ‘obligatory’ data on specific forms will prevent E.I from supplying you with the Service you need, and whose performance requires the processing of those same data.
7.3 Also, on the basis of the services offered, E.I. regards as necessary to ask for your explicit consent to processing your special data. Failure to do so E.I. may not be able to carry out the services requested.
8. KNOWABLE DATA AND THEIR DISCLOSURE
8.1 Your personal data are processed by subjects who have been specifically authorized or designated by E.I. and who work in its premises (employees and collaborators, however named), where they have to perform the tasks and the duties assigned to each one of them.
8.2 Your personal data may also be processed by other external subjects working on behalf of E.I. by virtue of specific contractual bonds or by subjects who have been properly authorized or appointed to be the data controllers. By way of example, if necessary, your personal data may be processed by: suppliers of IT, telematic and technological services, including hosting services and maintenance; companies offering the maintenance, the update and the creation of websites and related services; control and/or certification bodies or other related bodies; auditors; supervisory bodies. The updated list of the subjects in charge is available at our seat and may be consulted upon request.
8.3 Even so, your personal data may always be transmitted to third parties, public and private, to fulfil legal obligations, to adhere to public authorities’ orders or to enforce a right in court or any other fora.
8.4 The personal data which have been submitted are not ceded and are not subject to distribution.
9. DATA TRANSFERS ABROAD
9.1 E.I. mainly uses its data inside its seats or, in any case, within the E.U. borders and/or the European economic area.
9.2 Also, on the basis of the IT applications used, E.I. may transfer your personal data, where necessary, to third countries. Anyway, we ensure that the processing and transfer of your personal data are carried out in compliance with the conditions imposed by the G.D.P.R. (art. 44 ff), i.e. the adequacy decisions of the Commission, the standard contractual clauses or other guarantees which are considered adequate.
10. DURATION OF THE PROCESSING
10.1 Your personal data are processed and kept for a period of time which is set according to strict necessity requirements in virtue of the various purposes we pursue and, nevertheless, in compliance with the present regulations in the field of personal data protection and conservation of the account books, and respecting the rights of E.I. (prescription period as per Civil Code).
10.2 As far as the duration of the cookie conservation is concerned, we kindly ask you to read the relevant Cookie Note by clicking on the link at the bottom of each Website page or by clicking here.
10.3 Further pieces of information regarding the period of conservation of personal data and the criteria adopted to determine said period of time may be obtained by contacting E.I. at: firstname.lastname@example.org
11. RIGHTS OF THE INDIVIDUAL
11.1 Pursuant to the G.D.P.R. you may exercise your rights at any time, if applicable:
– You may receive the confirmation that your personal data are or are not being processed and, if so, you may gain access to them and to any other piece of information foreseen in art. 15 of the G.D.P.R., and possibly obtain a copy of them unless it infringes on someone else’s rights or freedom;
– You may obtain the correction of wrong personal data without unjustified delay. Considering the purposes of the data processing, you have the right to ask for and obtain the integration of incomplete personal data with missing ones by also submitting an integrative statement;
– You may obtain the cancellation of your personal data without unjustified delay;
– You may obtain the limitation of the data processing, if one of the hypotheses foreseen in art. 18 of the G.D.P.R. comes true;
– You may obtain the data portability, namely receive the personal data you have submitted to E.I. in a common structured format and readable on an automated device;
– You may not be subject to a decision based solely on an automated data processing system which may cause legal effects related to or affecting significantly your persona. This right does not apply to the cases regulated by art. 22, par. 2 of the G.D.P.R.; – You may file a complaint to the competent supervisory authority.
11.2 You may revoke your consent at any time without impairing the lawfulness of the data processing based on your consent, which was given before the revocation;
11.3 You may oppose the processing of your personal data at any time as per art. 21 of the G.D.P.R. In case you decide to exercise your right of objection, E.I. will refrain from processing your personal data any further, unless legitimate reasons, prevailing over your interests, rights and freedom, exist and force the company to proceed with the data processing or with the verification, the enforcement or protection of a right in court;
11.4 To enforce the abovesaid rights, you may contact E.I. at any time. To manage you requests more correctly, we kindly ask you to send us a letter by registered post or send us an email at: email@example.com
12. MODIFICATIONS AND UPDATES
12.1 We remind you that the present Note is subject to modifications and updates, which are reported on the Website. The version now in use is the one published on the Site. We advise you to verify the Note periodically in order to be adequately informed and to be sure that you agree with and accept possible modifications.
□ I hereby acknowledge that I have read and understood the Guidance Note written by the Data Controller as per the EU G.D.P.R. 679/2016, and I explicitly agree with the processing of the special data which I have possibly submitted (such as my religious belief, the type of ceremony I have chosen, etc.) Due to the nature of the service offered, it will not be possible to meet any request without said consent.