Please read this Privacy Policy (hereinafter, "
Privacy Policy"), which is intended for users of the website
mics.mitralacademy.it (hereinafter, the "
Website"), prepared in accordance with Article 13 of the General Data Protection Regulation No. 2016/679 (hereinafter, also "
GDPR"), in which we provide you with all the details regarding the processing of your personal data (hereinafter, also "
Data") and its use.
Please note that this Privacy Policy is only applicable to Data processing carried out on the Website and not to processing performed on different or additional websites, even if they are accessible through links present within the Website itself.
TABLE OF CONTENTS
1. Data Controller and contact details
The Data Controller is Gruppo Villa Maria S.p.A. (hereinafter, the "
Controller", "
GVM" or "
Company"), with registered office in Lugo (RA), Corso Garibaldi, n. 11.
Email: gvm-careandresearch@legalmail.it.
Phone: 0545/909711.
2. Contact details of the Data Protection Officer (DPO)
It will be possible to contact the Data Protection Officer (DPO) by addressing: Gruppo Villa Maria S.p.A., p.zza F. Trisi, n. 16 – 48022, Lugo (RA).
PEC: gvm-dpo@legalmail.it.
Phone: 0545/909711.
3. Types of Data processed
3.1 Navigation Data
We collect the following Data through the services used by the user.
Technical Data
This category of Data includes IP addresses or domain names of the computers used by users who connect to the Website, the URI (
Uniform Resource Identifier) addresses of the requested resources, 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 server's response (successful, error, etc.) and other parameters relating to the user's operating system and computer environment. This Data is used only for statistical information (and is therefore anonymous), to check the correct functioning of the Website, and is deleted immediately after processing. The Data could be used to ascertain liability in the event of hypothetical cybercrimes against the Website. Except for this eventuality, web contact Data does not persist for more than 7 days.
Cookies
The Website collects Data using cookies or similar technologies. For further information, we invite you to visit the Website's "
Cookie Policy".
3.2 Data voluntarily provided by the user
Filling out the form dedicated to the request for information involves the acquisition, by GVM, of the user's personal data such as name, surname, telephone number and sender's addresses necessary to respond to the requests, as well as any other personal data included in the communication. Users of the site are invited, in their requests for services and/or their questions, not to send the names or other personal data of third parties that are not strictly necessary; the use of fictitious names appears much more appropriate for this purpose. Through the voluntary registration process, GVM collects personal data such as: name, surname, email address, telephone, address, postcode, province, country.
3.3 Third-party data
If you decide to provide us with third-party Data, please ensure that these subjects have been previously and adequately informed about the methods and purposes of processing indicated here. In relation to this hypothesis, you act as an autonomous data controller, assuming all legal obligations and responsibilities.
3.4 Data of minors under 16 years of age
We remind you that if you are under 16 you cannot provide us with any personal data, and, in any case, we do not assume any responsibility for any false statements you provide. Should we become aware of the existence of untruthful declarations, we will proceed with the immediate cancellation of any personal data acquired.
4. Services offered by the Website
Below, an illustration of the services offered by the Website is provided. For each of the services offered, the following are indicated: the purposes of Data processing, the legal bases on which the processing is based and the retention times of the processed Data.
4.1 Contact Us section
Inside the Website there is the "Contact Us" section. The latter allows the visitor to submit their requests for information to the Company. For the purpose of providing this service, the user is necessarily required to provide the following personal data: name, surname, province, e-mail address and telephone number. If the interested party wishes to request information by telephone, the personal data requested by the operator will be processed exclusively for the purpose indicated below. Purpose of the processing: to provide feedback to the information requests advanced by the user through the "Contact Us" section of the Website or by telephone. Legal basis of the processing: art. 6, paragraph 1, letter b) of the GDPR, "performance of a contract to which the data subject is a party or the execution of pre-contractual measures adopted at the request of the same". Retention times: personal data will be kept for a period not exceeding 24 months from the moment they are provided.
5. Additional purposes of processing
As part of the processing of personal data carried out through the Website, the Controller pursues the following further specific purposes:
5.1 Compliance with legal obligations
The Controller, where necessary, processes the personal data of the interested parties, collected through the Website, in order to guarantee compliance with the legal obligations, regulations and community rules to which it is subject. Legal basis of the processing: art. 6, paragraph 1, letter c) of the GDPR, "the processing is necessary to comply with a legal obligation to which the data controller is subject". Retention times: personal data will be kept for the period strictly necessary to allow the Controller to fulfill the legal obligations to which the same is subject.
5.2 Establishment, exercise and defense of rights in court
The Controller, where necessary, processes the personal data of the interested parties, collected through the Website, in order to establish, exercise or defend its rights in court or whenever the judicial authorities exercise their jurisdictional functions. Legal basis of the processing: art. 6, paragraph 1, letter f) of the GDPR, "the processing is necessary for the pursuit of the legitimate interest of the data controller". Retention times: personal data will be kept for the period strictly limited to the duration of the dispute, until the terms for taking legal action have expired.
5.3 Direct marketing activities
Your personal data, subject to your free and specific consent, will be processed to update you on GVM's promotional, commercial and advertising initiatives, on events, initiatives or partnerships, in compliance with the provisions of the provision of the Italian Data Protection Authority "Guidelines on promotional activities and contrast to spam – 4 July 2013 [2542348]". We inform you that these activities may be carried out, as required by the current regulations, by means of paper mail, telephone contacts via operator (so-called "traditional methods"), e-mail, sending of text messages, push notifications and use of social networks (so-called "automated methods"). Furthermore, we will process your Data to carry out analysis and reporting activities connected to the promotional communication systems, such as, for example, the detection of the number of opened e-mails, the clicks made on the links present within the communication, the type of device used to read the communication and the relative operating system. In the absence of your specific consent for this purpose, we will not be able to process your personal data for direct marketing purposes and therefore we will not be able to inform you of the new products and/or promotions in progress. Legal basis of the processing: art. 6, paragraph 1, letter a) of the GDPR, "the interested party has expressed consent to the processing of their personal data for one or more specific purposes". Retention times: personal data will be kept until the user withdraws consent. In any case, GVM reserves the right to keep the visitor's personal data for the period of time provided for and permitted by Italian law to protect its own interests.
5.4 Profiling
Subject to your free, optional and specific consent, we will process your personal data for profiling purposes. In particular, by monitoring the bookings you have made, as well as the products and services you have purchased through the Website, we will more accurately evaluate your behavior and analyze your preferences, interests and consumption habits.
We inform you that this treatment is not subject to any automated decision.
Legal basis of the processing: art. 6, paragraph 1, letter a) of the GDPR, "
the interested party has expressed consent to the processing of their personal data for one or more specific purposes".
Retention times: personal data will be kept until the user withdraws consent. In any case, GVM reserves the right to keep the visitor's personal data for the period of time provided for and permitted by Italian law to protect its own interests.
6. Recipients and transfer of personal data
Your Data may be shared with:
- Persons authorized by the Controller to process personal data who have received adequate operational instructions, have committed to confidentiality or are subject to an adequate legal obligation of confidentiality;
- subjects delegated and/or appointed by the Controller to carry out activities strictly related to the pursuit of the purposes indicated above (including technical maintenance interventions on the systems), rightly appointed Data Processors;
- persons, companies or professional firms that provide assistance and consultancy to the Controller, rightly appointed Data Processors;
- 4subjects, entities or authorities to whom the communication of your personal data is mandatory by virtue of legal provisions or orders from competent authorities.
The management and storage of the Data takes place on the Controller's servers and/or on servers of third-party companies appointed as Data Processors. These servers are located at the Controller's premises (in Italy) and in any case within the European Union.
Personal data are not transferred outside the European Union. In any case, it is understood that, where necessary, the Controller may also transfer personal data to non-EU countries, guaranteeing from now on that the transfer will take place in compliance with the applicable legal provisions and therefore by stipulating, if and when necessary, specific agreements that guarantee an adequate level of personal data protection, or in any case by adopting the standard contractual clauses provided by the European Commission for the transfer of personal data outside the EU.
7. Withdrawal of consent and exercise of Data Subjects' rights
7.1 Withdrawal of consent
To withdraw the consent given for marketing and/or profiling purposes, you can contact the Controller at any time by writing to
gvm-careandresearch@legalmail.it. We remind you, in any case, that the withdrawal of the consent given does not affect the lawfulness of the processing based on the consent before the withdrawal.
7.2 Exercise of rights
Consistent with the provisions of the GDPR, you have the right to ask the Controller, at any time, for access to your personal data, their rectification or cancellation or to oppose their processing. The law also allows you to exercise the right to request the limitation of processing in the cases provided for by art. 18 of the GDPR, as well as to obtain the Data concerning you in a structured, commonly used and machine-readable format, in the cases provided for by art. 20 of the GDPR.
Requests can be sent to the e-mail address:
gvm-careandresearch@legalmail.it.
Finally, we remind you that you always have the right to lodge a complaint with the competent supervisory authority (Garante per la Protezione dei Dati Personali - Italian Data Protection Authority), pursuant to art. 77 of the GDPR, if you believe that the processing of your personal data is contrary to the regulations in force.
8. Privacy Policy updates
This Privacy Policy can be updated and/or modified also in order to incorporate and/or comply with national, community, international regulations or to adapt to technological innovations. The updates and/or changes that will be made to the Privacy Policy will be reported on this web page and made constantly visible so that interested parties can be fully informed about the use that is made of their personal data provided through the Internet site.