Transfer

Dear User,
in compliance with the obligations under the European Privacy Regulation UE/2016/679 (GDPR) and legislative decree 196/2003 as amended by legislative decree 101/2018, we hereby inform you that the company Euro Gestioni Spa, acting as controller, will process any personal data regarding you that have been or will be submitted to us – by either you or other subjects – by compiling forms and utilising online services.
The processing of the data, either willingly submitted by you or collected in other ways, will be carried out in observance of the privacy laws currently in force; in line with the principles of fairness, lawfulness and transparency and carried out in observance of relevance, completeness and non-exceedance.
Hence, as provided for in the article 13) of the European Privacy Regulation UE/2016/679 (GDPR), we hereby inform you that:
1) Upon browsing the website, the following information may be collected and processed for the sole purposes of safety and improvement of the services offered:

- Access page to the site (through query parameters in the URL)
- Source page redirecting visitors
- Date and time of access
- Quantity of transferred data
- State of access (translated page, page not found, etc.)
- Operative system and browser utilised
- Registration details, statistics about visited pages, traffic data and advertising data (see “Cookies Policy”).

If you were to decide to proceed with a reservation in our receptive facilities through the online booking service, you will be requested the following personal data, which are mandatory in order to complete the registration and booking processes (said data will be disclosed to the selected facility upon reservation, which will act as autonomous controller):
- E-mail address - Permanent address or legal address
- Name and surname - Telephone number

The above-mentioned data will be processed for the following purposes:
a) For the regular implementation of the institutional activities and/or those required by the business objective.
b) For particular needs pertaining to the drafting of contracts and fulfilment of tasks (management of reservations) and their execution, to all subsequent modifications or variations and for any obligation required for their finalisation;
c) For operative, organisational, management, fiscal, financial, insurance or accounting needs pertaining the contractual and/or pre-contractual relationship in force, such as for example: sending a request for feedback on the service/transaction made; sending the information which are needed to utilise the requested service, etc.
d) To fulfil any duty under laws, regulations or Community legislation.
e) For the registration, management and conservation of any log and potential access to the company’s Website, the Company’s Informative System and corporate headquarters;
f) For the safety and improvement of the service offered through the website

If you were to decide, after staying in our receptive facilities, to keep in contact with us by either subscribing to our newsletter or receiving our promotional material, you will be asked the following personal data, which are required in order to complete the subscription process:
- E-mail address - Permanent address or legal address
- Name and surname - Telephone number
Such data will be processed for the following purposes:
g) For the communication of updates and periodical information regarding our activity, offers and advertising via newsletter;
h) For direct marketing activities such as: sending of flyers, catalogues and commercial and/or technical documents via regular mail and/or telephone call with an operator.

2) The data processing, which will be carried out both manually, partially automated or fully automated, may consist in the following operations: collection, recording, organization and conservation, consultation and utilisation, elaboration, modification, selection, extraction, comparison, submission and communication. The processing will be carried out both utilising paper support and with the help of electronic, IT and computerised instruments which aim at guaranteeing the safety and confidentiality of the aforementioned data, in compliance with art. 32) of the European Privacy Regulation UE/216/679 (GDPR).
During the processing operation, however, we ensure that all possible technical, IT, organisational, logistic and procedural resources aimed at data safety are used. The aforementioned methods of data processing only guarantee access to the data to the subjects specified at paragraphs 4) and 5).

3) Data submission and processing is:
- Mandatory and does not require your consent for the fulfilment of objectives relating to those obligations under laws, regulations or Community legislation. Paragraphs c) d)
- indispensable and does not require your consent for all those personal data which are essential for a correct instalment, management and continuation of the commercial and/or contractual relationship. Paragraphs a) b) c)
- indispensable and does not require your consent for the pursuit of legitimate business interests. Paragraph f)
- facultative and requires your explicit consent by filling out the “Privacy Consent” form which will be handed to you upon check-in for all your peculiar “sensitive” data. Paragraph c)
- facultative and requires your explicit consent by filling in the boxes for marketing activities. Paragraphs g) h)

4) The subjects or categories of subjects that can be made aware of the data or to whom the personal data may be submitted are the following:
- In charge of the processing: administrative area and direction, business office, marketing office;
- External processors: consultants and consulting companies, professionals, banks and/or insurance companies;
- System administrators.
The personal data may also be disseminated, but only in aggregate and anonymous form and for statistic purposes.

5) The personal data can also be submitted to Public authorities, Law enforcement or other Public or Private Subjects, with the exclusive purpose of complying with the laws, regulations or community legislation.

6) The management and conservation of the personal data makes use of servers located inside the European Union (Italy), belonging to the controller and to third parties, aptly nominated as processors. The processed data can also be processed and submitted, for the purposes specified in paragraph 1) and with the modes specified in paragraph 2), also to those subjects referred to in paragraph 4) located in countries which may or may not be part of the European Union based on the adequacy decisions of the European Commission or on the adequate measures for the safeguard of privacy in use.

7) The data will be collected and recorded for the sole purposes described above, and will only be conserved for the time needed for the completion of the activities under the contractual obligations, which will not in any case be more than 10 years from their collection for administrative and accounting reasons. For marketing purposes, the data will be conserved for a period not exceeding 24 months. In every newsletter or communication, a link is present which allows for removal from the mailing list. Nonetheless, at the end of said term, the controller – if he means to extend the processing of the aforementioned data for an additional 24 months – can send a specific verification notice, containing a link which allows for delisting.

8) Under any circumstances and at any given moment, you can request from the Legal Representative a copy of your personal data, information regarding the location where your data are being processed and an up-to-date list with the identification details of all the processors and the system administrators authorised for processing your data.

9) You can freely revoke the given consent at any moment, without any burden or prejudice concerning the legitimacy of the data processing carried out up to that point, and exercise the following rights of the person concerned towards the controller, under the European Privacy Regulation UE/2016/679: Access, Correction, Cancellation, Limitation, Complaint to the Data Protection Authority.
The request can be submitted by writing an e-mail to privacy@etgroup.info

10) Identity and contact details of the controller
Euro Gestioni Spa
Legal address in Corso del Sole nr. 102
30028 Bibione (VE)
E-mail: europa@etgroup.info
Tel: +39 0431 430144

11) Identity and contact details of the DPO
Massimiliano Glerean
E-mail: dpo@etgroup.info

Date and Place:01.01.2019, Bibione