PRIVACY POLICY - Podere Le Fonti

INFORMATION PURSUANT TO ART. 13 OF EU REGULATION 679/2016
1. Introduction

For PODERE LE FONTI S.R.L.S. Your privacy and the security of your personal data are particularly important, which is why we collect and process them with the utmost care and attention, while at the same time adopting specific and adequate technical and organizational measures to guarantee full security of the processing.

We therefore inform you, pursuant to art. 13 of the European Regulation 2016/679 (“GDPR” or “Regulation”) and of the Privacy Code (“Privacy Code”), as amended by Legislative Decree 101/2018 (jointly, the “Regulation”), that the processing of your personal data takes place according to methods suitable to guarantee security and confidentiality and is carried out using paper, IT and telematic media, as detailed in this information.

2. Data controller

The processing of your personal data is carried out by PODERE LE FONTI S.R.L.S. (hereinafter also just “PODERE LE FONTI S.R.L.S.” or “Data Controller”), with registered office in Località Torri, 2a – 53036 – Poggibonsi (Siena) – Italy, as Data Controller pursuant to and for the purposes of the Regulation.

For any questions or requests related to the processing of your personal data, you can contact the Company at any time by sending a request to the following references:

Data controller

Business name: PODERE LE FONTI S.R.L.S.

Registered office address: Località Torri, 2a – 53036 – Poggibonsi (Siena) – Italy

Telephone contact details: +39 366 1516365

Email contact details: info@poderelefonti.com

3. Type of Data Processed, Purpose and Legal Basis of the processing

The personal data that the Company processes are those that you provide to us while browsing or using the online services offered by the Company through the website www.poderelefonti.com

The Company may therefore collect data about you such as personal data such as name and surname, e-mail, telephone, your requests and navigation data.

No particular data are processed pursuant to art. 9 GDPR or data relating to criminal convictions and crimes pursuant to art. 10 GDPR.

Your personal data, once collected, are processed for the following purposes:

Detect your experience of using our websites, the services we offer, as well as ensuring the correct functioning of our web pages and their contents. The processing carried out for these purposes is based on a legitimate interest of the Data Controller, and does not require specific consent from the interested party.
Fulfill obligations established by laws, regulations and European legislation. The processing carried out for these purposes is necessary for the fulfillment of legal obligations and to make the requested service available, and does not require specific consent from the interested party.

Subscription to our Newsletter service. The processing carried out for these purposes is carried out with the specific and free consent provided by the user. Carry out direct promotional activities, including by periodically sending newsletters and other promotional tools to the e-mail address that you spontaneously provided to us when registering on the Site. The processing carried out for this purpose is carried out with the specific consent provided by the user, except for commercial communications relating to products and/or services similar to those already purchased and/or subscribed to by the user for which the processing is based on a legitimate interest of the Owner. Your personal data are processed exclusively by Company personnel specifically authorized and designated pursuant to art. 4 paragraph 10 of the Regulation and art. 2-quaterdecies of the Privacy Code which has been adequately formed in relation to regulatory obligations regarding privacy and which processes data following precise indications from the Data Controller.

4. Managers pursuant to art. 28 and Recipients of the data

Your personal data will also be transmitted to third parties we use. These subjects have been selected by us and offer an adequate guarantee of compliance with the rules regarding the processing of personal data and in the event that they process data in the name and on behalf of PODERE LE FONTI S.R.L.S. have been appointed Data Processors pursuant to art. 28 of the Regulation and are required to carry out their activities according to the specific instructions given by the Company and under its control.

These third parties may belong to the following categories: financial operators; internet providers; companies specializing in IT services, consultancy firms, cloud service providers. Furthermore, your data may be communicated to third-party companies operating in the publishing sector and to companies operating in the following sectors with which PODERE LE FONTI S.R.L.S. could conclude partnership agreements linked to the digital marketing activity for hotels carried out. A specific and updated list of these subjects is available at the Data Controller’s headquarters, and can be consulted upon request by the interested party.

For administrative purposes, we inform you that your data may be communicated by the Data Controller to other companies in the Group.

It is understood that your personal data will not be communicated to third parties so that they can use them for their own promotional purposes and will not be disclosed in any way.

Your data may also be transmitted to Public Bodies for legal compliance or to the Police Forces and the Judicial and Administrative Authorities, in compliance with the law, for the investigation and prosecution of crimes, prevention and protection from threats. to public safety, as well as to allow the Company to exercise or protect its own or third party rights before the competent authorities, as well as for other reasons related to the protection of the rights and freedoms of others.

5. Mandatory or optional nature of providing data

Without prejudice to the freedom in the provision of personal data by the interested party, please note that:

the communication of data for purposes A) and B) referred to in paragraph 4 is mandatory. Failure to communicate the data will make it impossible for the Company to establish any relationship with you and allow you to use the site;

the communication of data for purposes C) and D) referred to in paragraph 3 is optional. Failure to communicate the data will make it impossible to subscribe to the newsletter service and benefit from the promotional services offered by the Company.
6. Transfer of data outside the EU

Some of the third parties to whom the data is transferred may be based in states outside the European Union, also by virtue of the use of cloud services implemented by the Company. This transfer is carried out to states that offer an adequate level of data protection, as established by specific decisions of the European Commission.

The transfer of your personal data to third parties resident or located in states that do not belong to the European Union and which do not ensure adequate levels of protection will be carried out only with your consent or following the conclusion of specific agreements between the Company and said subjects, containing safeguard clauses and appropriate guarantees for the protection of your personal data, so-called “standard contractual clauses”, also approved by the European Commission, or if the transfer is necessary for the conclusion and execution of a contract between you and the Company or for the management of your requests.

7. Data Retention

We inform you that your data will be stored for a limited period of time, which varies depending on the type of processing activity and its specific purposes, as indicated below:

data collected in the context of the use of services offered by the Company: these data are kept for the entire duration of the service until the termination of the same or the cancellation of the subscription to the service by the User or the related revocation of consent; data collected for sending informative material via newsletter or for carrying out promotional activities (purpose C) and D) referred to in paragraph 3): until the user requests interruption of the activity and in any case within 2 years from the last interaction of any kind of the interested party with the Company. At the end of these periods, your data will be definitively deleted or, in any case, irreversibly anonymized by the Company.

8. Your rights

We inform you that you have the right to exercise the following rights in relation to the personal data covered by this information, as provided for and guaranteed by the Regulation:

Right of access and rectification (articles 15 and 16 of the Regulation): you have the right to access your personal data and to request that they be corrected, modified or integrated. If you wish, we will provide you with a copy of the data we hold about you. Right to erasure of data (Article 17 of the Regulation): in the cases provided for by current legislation you can request the erasure of your personal data. Once your request has been received and analysed, we will cease processing and delete your personal data, if found legitimate. Right to limit processing (Article 18 of the Regulation): you have the right to request the limitation of the processing of your personal data in the event of unlawful processing or contestation of the accuracy of the personal data by the interested party.
Right to data portability (Article 20 of the Regulation): you have the right to request to obtain your personal data from the Data Controller in order to transmit them to another Data Controller, in the cases provided for in the referred to article. Right to object (Article 21 of the Regulation): you have the right to object at any time to the processing of your personal data carried out on the basis of our legitimate interest, explaining the reasons justifying your request; before accepting it, the Company will have to evaluate the reasons for your request. Right to lodge a complaint (Article 77 of the Regulation): you have the right to lodge a complaint before the competent Guarantor Authority for the protection of personal data if you believe that a violation of your rights has occurred, or is underway, in relation to the processing of personal data. Your personal data. At any time you can exercise your rights with reference to the specific processing of your personal data by the Company.

Without prejudice to what has been expressed so far, we remind you that the above rights can also be exercised by anyone who has an interest of their own, or who acts for your protection, as your agent, or for family reasons worthy of protection, pursuant to art. 2-terdecies of Legislative Decree 101/2018.

These rights can be exercised by email to info@poderelefonti.com or by ordinary mail to the address: PODERE LE FONTI S.R.L.S., Località Torri, 2a – 53036 – Poggibonsi (Siena) – Italy

Further information regarding the rights of the interested party can be obtained by asking the Owner for a complete extract of the articles mentioned above.

9. Security measures

The Company adopts adequate security measures aimed at safeguarding the confidentiality, integrity, completeness and availability of the personal data of the interested party. Technical, logistical and organizational measures are developed which aim to prevent damage, even accidental losses, alterations, improper and unauthorized use of the data processed.

Furthermore, the Data Controllers cannot be held responsible for untruthful information sent directly by the user (example: correctness of the e-mail address or postal address), as well as information concerning him or her which has been provided by a third party, even fraudulently.

10. Changes to this information

The constant evolution of our services may lead to changes in the characteristics of the processing of your personal data described above. This privacy policy may undergo changes and additions over time, as necessary due to new regulatory interventions regarding the protection of personal data, or the evolution/modification of our services.

We therefore invite you to periodically check the contents of our information: where possible, we will try to promptly inform you of the changes made and their consequences.

11. Last update date

Siena, 25/11/2023