Privacy

Policy on personal data processing based on REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 (GDPR)

Introduction
The following Terms and Conditions of Sale regulate the sale on this website “https://www.villagabrisa.it” (Website). The seller is G.I.R.L. SRL, with registered office in Viale Pasitea 221 Positano (SA) 84017 IT, Chamber of Commerce of Salerno, VAT number 04200310656, share capital of 110.000,00 € fully paid (Company)

Purchasing through the Website
The Company shall acquire and process your personal data to process your request to purchase through the Website.

Marketing
If you provide your explicit consent, the Company shall process your personal data to send you promotional communications and/or newsletter regarding services offered for sale by the Company or by third parties.

Soft Spamming
The Company is entitled to sale its services using the email that you communicated during your first purchase on the Website, if this service is similar of the first sale (soft spamming). You may at any time notify the Company of your refusal to receive this type of communication.

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Pursuant to the GDPR, the Seller shall process the personal data provided by you as indicated in this privacy policy.
Article 1. Purpose of the processing. Legal basis. Mandatory or optional nature of data provision and consequences of any refusal.
The Company shall process the personal data provided by you for the following purposes: a. for administrative/accounting purposes. The legal basis for the processing is Company’s commitment to be compliance with a legal obligation or to take steps at the request of the data subject prior to entering into a contract, as the case may be;
b. in the case of the execution of an online purchase order, to allow the conclusion of the purchase contract and the proper execution of transactions related to the same (and, where necessary, to fulfill tax obligations). The legal basis for the processing is Company’s commitment to be compliance with a legal obligation or to perform a contract to which the data subject is party;
c. limited to the email address provided by you when purchasing services offered on the Website, to enable the direct sale of similar services (soft spamming), without requiring your express and prior consent and provided that you do not exercise your right to object. The legal basis for the processing is the Company's legitimate interest to perform these activities. This legitimate interest is equal to the user's interest to riceve "soft-spam" comunication; d. if you provide your explicit consent, for the Company to send you newsletter and for market research purposes also aimed at evaluating the level of customer satisfaction and to send you promotional communications in relation to the services of the Company and / or third-parties, by email (marketing purposes); The legal basis for the processing is your consent; e. to respond to your requests through the customer care service. The provision of data is purely optional. However, as the said processing is necessary in order to respond to your request, your refusal to provide the relevant data will prevent you from obtaining answer from the customer care of the Company. The legal basis for the processing is the Company's legitimate interest to perform these activities. This legitimate interest is equal to the user's interest to use the customer care service of the Website;
f. in order to answer to your requests by email, by telephone. The provision of data is purely optional. However, as the said processing is necessary in order to respond to your request, your refusal to provide the relevant data will prevent you from obtaining answer from the customer care of the Company. The legal basis for the processing is the Company's legitimate interest to perform these activities. This legitimate interest is equal to the user's interest to receive answer by the Company.
The provision of data for the purposes set out in at Point b) is purely optional. However, as the said processing is necessary in order to enable you to register with the Website and to provide the online purchasing your refusal to provide the relevant data will prevent you from registering with the Website andfrom completing an online purchase.
Consent to marketing purposes is purely optional. Failure to consent will have the following consequences.
Failure to consent to the processing of personal data for marketing purposes will prevent you to receive promotional communication and newsletter regarding services of the Company and/or third-parties and will prevent the Company to carry out market research purposes aimed at evaluating the level of customer satisfaction.
It is understood that the Company may use your personal data to comply with legal obligations and to perform the purchase contract.
You may revoke your consent using the relevant link indicated in any promotional email sent by the Company.

Social Network
You may register and/or access to the Website using Facebook e Google. You give consent to the relevant social network to share with the Company your personal data necessary to register and/or access to the Website.

Payment Card Data
In order to make a payment through one of the payment cards offered on the Website, you shall enter the data of the payment card directly on a page that will communicate through secure encryption protocol with the payment service provider (which will act as an independent data controller). These data will not pass through the server of the Company which, therefore, will not process such data in any way. In execution of the legal obligations provided for by Directive 2015/2366/ (EU) on payment services in the internal market (PSD2), You are informed that, with reference to purchases made on the Web Site by credit card, data necessary for the conclusion of the purchase process may include the phone number communicated by You, or a different personal data necessary to complete the purchase process. In order to allow you to complete the purchase, the payment institution in charge of managing the transaction will send you an authentication code, which must be reported by You during the purchase process to meet the authentication criteria provided by PSD2 (Strong Customer Authentication). The processing of your personal data for these purposes has as its legal basis the fulfillment of legal obligations and does not require your consent.

To provide the above-indicated data is necessary to make purchases on the Website.

PayPal
You may make purchases using PayPal. In this event, you will be directed to a page outside the Website, where you must indicate the personal data requested by PayPal to complete the purchase process (PayPal will act as a data controller). These data will not pass through the server of the Company which, therefore, will not process such data in any way. To provide the above-indicated data is necessary to make purchases on the Website.

Special Categories of Personal Data. Judicial Data.
The Company does not process special categories of personal data nor judicial data.

Article 2. Methods of Processing Personal Data
The processing of your personal data will be carried out by electronic or automated means, in the manner and with the appropriate tools to ensure the security and confidentiality in accordance with the GDPR.
The information and methods of processing will be relevant and not excessive in relation to the type of services provided. Data will be managed and protected in environments where access is under constant control.

Article 3. Data Disclosure
For the purposes described in this privacy policy, the personal data provided by you may be disclosed or communicated to the following parties:
• to all those parties (including Public Authorities) that have access to the data by virtue of regulatory or administrative measures
• to parties who process online payment transactions
• to companies, consultants or professionals in charge of the installation, maintenance, updating and the management of the Company's hardware and software or which the Company uses for the provision of its services
• to the Data Protection Office (DPO)
• to the companies that send the newsletters and/or other informative communications transmitted on behalf of the Company
• to the employees and/or collaborators of the Company
• to the company in charge of the customer care service
• companies managing online payment transactions
• to all those public and/or private parties, natural and/or legal persons (legal, administrative and tax consultancy firms), where the communication is necessary or of practical use for the correct fulfilment of contractual obligations undertaken in relation to the services provided through the Website, and of legal obligations.
Your data may be disclosed only in anonymous and aggregated form for statistical or research purposes.

Article 4. Data Controller; Data Protection Officer

You can contact the Company, as Data Controller, at the following addresses: G.I.R.L. SRL Viale Pasitea 221 Positano (SA) 84017 IT
By fax, writing to: +39089811607
By telephone, calling: +39 089 811 498
By email, writing to: info@villagabrisa.it

By selecting the contact form on the Website.
You can contact the Data Proteciont Office at the following addresses:
You may address requests relating to the processing of your personal data to both the Data Controller and the Data Protection Officer.

Article 5. Data Storage
Personal data will be stored according to the following logics: (i) for marketing purposes, until consent is revoked. For inactive users, personal data will be deleted after one year from the sending of the last email that may be viewed; (ii) for the purpose of executing the sales contract, for 10 years from the date of receipt of the purchase order; (iii) for purposes of defense in court, until the judgment is final; (iv) for purposes of compliance with the legislation, for the time necessary for this purpose; (v) for the purpose of performing any service requested through the Site, for the time necessary to execute the request. Article 6. Rights of the Data Subject
Purstuant to GDPR (Article 13), you have the right to:
• request access to and rectification or erasure of personal data or restriction of processing or object to their processing, in addition to the right to data portability
• withdraw consent at any time without prejudice to the lawfulness of processing based on consent given prior to the withdrawal
• lodge a complaint before a supervisory authority (for instance, the Italian Data Protection Authority).
The above-mentioned rights may be exercised by making a request to or to the Data Protection Officer at the contacts indicated above.

Article 7. Amedments
The Company reserves the right to change this privacy policy at any time, giving suitable notice to users and ensuring in any case an adequate and similar protection of personal data. In order to view any changes, you are invited to regularly consult this privacy notice.
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