This policy statement is provided in pursuance of Section 13 of Legislative Decree 196/2003 (Code for the Protection of Personal Data).
The newsletter is only sent to users upon explicit request, which must be made by filling in the form provided at the foot of our website’s pages and by authorising Itinera Servizi Turistici Soc. Coop. to process your personal data.
In pursuance of Section 130, par. 2, of Legislative Decree 196/2003, and of the regulations of the Italian Data Protection Authority as regards personal data protection in matter of promotional communication – according to which the use of personal data for marketing purposes is forbidden if data subjects have not previously given their consent to it (referring in particular to the Regulations of May 23, 2003; November 26, 2006; July 14, 2005; July 14, 2007; and lastly the Italian Data Protection Authority’s Guidelines against undesired commercial offers dated July 23, 2013) – we, as designated Data controllers, inform our users that our newsletter will be sent only upon prior free and explicit consent of recipients, with the exception of the cases mentioned in Paragraph 4 of section 130, which are reported below.
In case of consent, the processing of personal data will be carried out for informative and promotional purposes, in order to provide information about new products or services.
In pursuance of Paragraph 4 of Section 130 of Legislative Decree 196/2003, the data subject’s consent will not be necessary (unless the data subject has explicitly refused to give such consent from the very start, or on the occasion of subsequent communications) if the same subject has already purchased other products or services from us.
Precisely, “where a data controller uses, for direct marketing of his/her own products or services, electronic contact details for electronic mail supplied by a data subject in the context of the sale of a product or service, said data controller may fail to request the data subject’s consent, on condition that the services are similar to those that have been the subject of the sale and the data subject, after being adequately informed, does not object to said use either initially or in connection with subsequent communications”(Paragraph 4, Section 130 of Legislative Decree 196/2003)
1. DATA CONTROLLER As pursuant to Section 28 of the Code, the owner of the website www.piemonteitinera.net and Data controller is Itinera Servizi Turistici Soc. Coop. Via Rio Misureto, 8 12051 Alba (Cn) Italy.
2. PROCESSING ARRANGEMENTS Data is processed by our staff, who have been formally designed as pursuant to the Code and who have been trained at confidentiality and safety in matters of personal data. Data will be stored both in the databases located at our premises and in databases belonging to hosting companies located in Italy and/or in the European Union.
3. PURPOSE OF DATA PROCESSING Data voluntarily provided by users will be directly processed for the following purposes: Sending informative material; Performing promotional activities through the sending of informative or commercial material, such as invitations to fairs, events and displays, catalogues, training courses, and product sales, through traditional means (telephone, traditional mail) and/or automated means (such as faxes, e-mails, text messages, and so on); Performing analyses of statistical reports to better evaluate the progress of e-mail marketing campaigns; Performing statistics in anonymous and aggregate form.
4. PERSONAL DATA VOLUNTARILY PROVIDED BY THE USER The user’s explicit and voluntary provision of data is necessary if said user wants to access the Newsletter service. It therefore entails the provision of the user’s e-mail address and other personal data necessary for sending notices about news, products, and promotional services. Consent for such purposes is free and optional. Failing to provide such consent will entail the impossibility to receive the Newsletter and any other notice.
5. PROCESSING ARRANGEMENTS The processing of the users’ personal data may entail its collection, but also its registration, preservation, modification, communication, and deletion. The processing operations will be carried out mainly through electronic means and exclusively by technical staff in charge of said processing. Personal data will be processed through means suitable to guarantee its safety and confidentiality as pursuant to the Code. In particular, again as pursuant to the Code, every possible technical, electronic, organizational, logical and procedural safety measure will be adopted to guarantee the minimum level of protection of personal data as per the current regulations.
6. COMMUNICATION OF DATA Personal data acquired for the indicated purposes may be transmitted to third parties – within their specific province – we have recourse to, such as: Subjects who provide services for the managing of data processing systems; Subjects who provide or develop softwares and applications for the Organization.
7. LENGTH OF DATA PROCESSING Personal data provided by the users who have agreed to receive promotional notices will be processed only for the time necessary to achieve the marketing purposes for which it has been collected, as further explained below.
8. DATA SUBJECTS’ RIGHTS Data subjects are entitled at any time to obtain confirmation of the existence of personal data concerning them and to be informed of their contents and source, verify their accuracy, or else request that such data be supplemented, updated or rectified (Section 7 of Legislative Decree no. 196/2003).
In pursuance of the aforementioned Section, the data subject has the right to request the erasure, the anonymisation or blocking of any data that has been processed in breach of the law, and also to object – on legitimate grounds – to their processing. As pursuant to the Guidelines on Marketing and against Spam dated July 4, 2013, and published on the Gazzetta Ufficiale dated July 26, 2013, the Data subject has the right to send specific notice to the Data controller with the purpose of exercising that right also partly, e.g. by objecting only to marketing communications via automated means (under Section 7(4)b) of the Code).
The user has the right to express his/her refusal to receive further newsletters and promotional e-mails by directly using the specific section to be found in the footer of the message (the so-called Opt-out). However, if the user wants to stop receiving e-mails and promotional notices he/she may e-mail such request to firstname.lastname@example.org.