Privacy policy
Information on the processing of personal data
Genial S.r.l., based in Martinsicuro (TE), via Roma 318, Tax Code and VAT No. 00980800676 (the “Controller”), as data controller, informs you pursuant to art. 13 of EU Regulation 2016/679 (the “GDPR”) and of Italian Legislative Decree 196/2003, as amended by Legislative Decree 101/2018 (the “Privacy Code”), that your data will be processed in the manner and for the purposes set out below:
1. Subject of the processing
The Controller processes the personal and identifying data (for example first name, surname, address, telephone, e-mail) that you provide when subscribing to the newsletter, sending information requests or using the services of the camping-italy.net site.
2. Purposes of the processing
Your personal data are processed:
A) without your express consent (art. 6 lett. b, c, f GDPR), as these are “ordinary” data, for the following service purposes:
1) to respond to requests for information and quotes and to provide the services of the camping-italy.net site;
2) to fulfil the pre-contractual, contractual and tax obligations arising from your existing relationships;
3) to comply with obligations laid down by law, regulation or EU legislation;
4) to exercise the Controller's rights (for example in the case of legitimate interest or for legal defence).
B) only with your specific and separate consent (art. 7 GDPR), for the following marketing purposes: to send you (by e-mail or possibly post, telephone contacts, SMS) commercial communications, advertising material and offers or promotions on the products and services offered by the Controller, as well as communications to measure satisfaction levels.
3. Legitimate interest of the Controller
The legitimate interest in processing the data arises from the need to carry out direct marketing activities to promote the Controller's goods and services. This tool is used towards existing customers and is also legitimised on the basis of Recital 47 of the GDPR.
4. Processing methods
The processing of personal data is carried out by means of the operations indicated in art. 4 no. 2 GDPR: collection, recording, organisation, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, erasure and destruction of the data. Data are processed both on paper and electronically and/or in automated form. Processing for marketing purposes is legitimised by the Controller's legitimate interest and by the explicit consent given, including through subscription to the newsletter on the camping-italy.net site. All processing takes place in compliance with arts. 6 and 32 of the GDPR, with the adoption of adequate security measures.
5. Data retention period
The processed data, subject to legal obligations (for example the retention of tax and accounting documents, set at 10 years), are kept until the data subject expressly requests their deletion and are in any case periodically reviewed, including by automated procedures, to ensure they remain up to date and genuinely relevant to the purposes of the processing. Once the purpose for which they were collected no longer applies, the data are deleted, unless the data subject expressly requests otherwise.
6. Access to the data
The personal data may be made accessible, for the purposes referred to in art. 2, to employees and collaborators of the Controller in their capacity as persons authorised to process data and/or system administrators, and to any third-party companies or other parties (for example credit institutions, professional firms, consultants, IT service providers) that carry out outsourced activities on behalf of the Controller, as external data processors.
7. Communication of the data
Without the need for express consent (art. 6 lett. b, c, f GDPR), the Controller may communicate your data to supervisory bodies, judicial authorities, credit institutions and those parties to whom communication is required by law. Such parties will process the data as independent controllers. The personal data provided will not be disseminated.
8. Transfer of data outside the EU
Personal data are stored on servers located at the Controller's premises or on cloud servers, in any case within the European Union. Should it become necessary, the Controller may also move the servers outside the EU: in that case the transfer will take place in accordance with applicable legal provisions, following the conclusion of the standard contractual clauses provided by the European Commission.
9. Nature of the provision of data
Providing the data for the purposes referred to in art. 2.A is mandatory: without them it will not be possible to provide you with the related services. Providing the data for the purposes referred to in art. 2.B is instead optional: you may therefore decide not to provide any data or to refuse consent to process data already provided; in that case you will not receive newsletters, commercial communications and advertising material, but you will continue to be entitled to the services referred to in art. 2.A.
10. Rights of the data subject
As a data subject you have the rights set out in arts. 15-22 GDPR, namely to:
1) obtain confirmation as to whether or not personal data concerning you exist and have them communicated in intelligible form;
2) obtain information on the origin of the data, the purposes and methods of the processing, the logic applied in the case of processing carried out with electronic tools, the identifying details of the controller and of the parties to whom the data may be communicated;
3) obtain the updating, rectification or integration of the data, as well as the erasure, transformation into anonymous form or blocking of data processed in breach of the law;
4) object, in whole or in part, on legitimate grounds to the processing and to processing for the purpose of sending advertising material or direct selling or market research;
5) the rights of rectification, erasure (right to be forgotten), restriction of processing, data portability and objection, as well as the right to lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).
11. How to exercise your rights
You may exercise your rights at any time by sending:
— a registered letter with return receipt to Genial S.r.l., via Roma 318, 64014 Martinsicuro (TE);
— an e-mail to info@genial.it or a certified e-mail (PEC) to info@pec.genial.it.
12. Controller, processor and authorised persons
The data controller is Genial S.r.l., with its registered office as indicated above. The updated list of processors and persons authorised to process the data is kept at the Controller's premises.