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INFORMATION MADE UNDER THE ART. 13-14 OF GDPR (GENERAL DATA PROTECTION REGULATION) 2016/679
According to the law indicated, the processing of data is managed in compliance with the principles of correctness, lawfulness, transparency and protection of confidentiality and personal rights.
G4B - Golf for Business Srl with registered office in Viale della Grande Muraglia 205 -00144 Roma, C.F. and P.I.
IT 06963890964 (hereinafter, "Owner"), as data controller, informs you pursuant to art. 13 Legislative Decree 30.6.2003 n. 196 (hereinafter, "Privacy Code") and art. 13 EU Regulation n. 2016/679 (hereinafter "GDPR") that your data will be processed in the following manner and for the following purposes:
Subject of processing
The Owner processes personal, identifying data (by way of example but not limited to: name, surname, company name, address, telephone number, e-mail address, fiscal code and VAT number - later, "personal data" or "data") communicated by you on the occasion of the conclusion of contracts for the services of the Data Controller, participation in opinion polls and approval, the completion of the registration form via the website www.golferhotels.it to events organized by the Data Controller, the online request of estimates, information or support requests or registration to the newsletter service.
Purpose of processing Your personal data is processed:
A) without your express consent (art. 24 letter a), b), c) Privacy Code and art. 6 lett. b), c), e) GDPR), for the following Service Purposes:
- conclude the contracts for the owner's services;
- allow you to use any Services requested by you;
- participate through the Website in initiatives organized by the Data Controller (for example, events);
- processing a contact request;
- fulfill the pre-contractual, contractual and fiscal obligations deriving from existing relationships with you;
- to fulfill the obligations provided for by the law, by a regulation, by EU legislation or by an order of the Authority (such as in the field of anti-money laundering);
- exercise the rights of the Owner, for example the right to defend in court;
B) Only with your specific and distinct consent (Articles 23 and 130 of the Privacy Code and Article 7 of the GDPR), for the following Marketing Purposes:
- send you newsletters, commercial communications and / or advertising material about products or services offered by the Data Controller via e-mail, post and / or text messages and / or telephone contacts, and detection of the degree of satisfaction with the quality of the services;
- to send commercial and / or promotional communications to third parties via e-mail, post and / or text message and / or telephone contacts (for example, business partners, insurance companies, other companies connected to G4B - Golf for Business Srl.
The legal basis that legitimates the processing is the execution of a contract of which the interested party is a party or the execution of pre-contractual measures adopted at the request of the same. In the cases expressly indicated the legal basis is the consent freely provided by the interested party.
We inform you that if you are already a customer of ours, we will be able to send you commercial communications relating to the services and products of the Data Controller similar to those that you have already received, unless you disagree (Article 130 c. 4 of the Privacy Code).
The processing of your personal data is carried out by means of the operations indicated in the art. 4 Privacy Code and art. 4 n. 2) GDPR and more precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data is subject to both paper and electronic and / or automated processing.
The data collected will be processed by electronic or automated, computerized and telematic means, or by manual processing with logic strictly related to the purposes for which the personal data was collected and, in any case, in order to guarantee the security of the same in each case. .
Data retention time
The Data Controller will process personal data for the time necessary to fulfill the aforementioned purposes and in any case for no more than 10 years from the termination of the relationship for the Service Purposes and for no more than 10 years from the collection of data for Marketing Purposes.
The Owner has taken the necessary security measures to protect your data against the risk of loss, abuse or alteration. In particular: it has adopted the measures referred to in Articles 32-34 Privacy Code and art. 32 GDPR; uses protected data transmission protocols known as HTTPS; and software that comply with ISO / IEC 27000 Standards. Data will be processed using appropriate security measures to minimize the risk of unauthorized access to data by third parties, their destruction and / or deterioration, and to guarantee its confidentiality, pursuant to art. 32 of the GDPR.
Access to data
Your data may be made accessible for the purposes referred to in art. 2.A) and 2.B):
- to employees and collaborators of the Data Controller or companies connected to G4B - Golf for Business Srl in Italy and abroad, in their capacity as appointees and / or internal processors and / or system administrators;
- to third party companies or other subjects (for information and non-exhaustive purposes, hotels, airlines, car rentals, travel service providers, credit institutions, insurance companies for the provision of insurance services, website provider, cloud provider, provider e-payment service, suppliers, hardware and software support technicians, shippers and carriers, professional offices, consultants, etc.) who carry out outsourced activities on behalf of the Data Controller, in their capacity as data processors.
Without the need for express consent (pursuant to art. 24 letter a), b), d) Privacy Code and art. 6 lett. b) and c) GDPR), the Data Controller may communicate your data for the purposes referred to in art. 2.A) to Supervisory Bodies, judicial Authorities, insurance companies for the provision of insurance services, as well as to those subjects to whom the communication is obligatory by law for the fulfillment of the said purposes. These subjects will treat the data in their capacity as independent data controllers. For all the purposes indicated in this statement, your data of a common nature may also be communicated abroad, within and outside the European Union, in compliance with the rights and guarantees provided for by current legislation, subject to verification that the Country in question guarantees an "adequate" level of protection. Your information will not be disseminated.
Data transfer Personal data is stored on servers located in Italy, within the European Union. In any case, it is understood that the owner, if necessary, will have the right to move the servers even outside the EU. In this case, the Data Controller ensures from now on that the extra-EU data will be transferred in compliance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses envisaged by the European Commission.
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Nature of data provision and consequences of refusal to respond
The provision of data for the purposes referred to in art. 2.A) is mandatory. In their absence, we cannot guarantee the services of the art. 2.A) that is the impossibility to carry out the intermediation activity and precludes G4B - Golf for Business Srl directly and / or through its own brands to fulfill the contractual obligations as foreseen by the respective commercial and travel contract.
The provision of data for the purposes referred to in art. 2.B) is instead optional. He may therefore decide not to give any data or subsequently deny the possibility of processing data already supplied: in this case, he will not be able to receive newsletters, commercial communications and advertising material relating to the Services offered by the Data Controller. However, he will continue to be entitled to the Services referred to in Article 2.A).
G4B - Golf for Business Srl does not adopt any automated decision-making process, including profiling, as per article 22, paragraphs 1 and 4, of EU Regulation no. 679/2016.
Rights of the interested party
As an interested party, you have the rights set forth in art. 7 Privacy Code and art. 15 GDPR and precisely the rights of:
obtain confirmation of the existence or not of personal data concerning you, even if not yet recorded, and their communication in intelligible form;
obtain the indication: a) of the origin of the personal data; b) the purposes and methods of processing; c) the logic applied in the case of processing carried out with the aid of electronic instruments; d) of the identification data concerning the data controller, data processors and the representative designated pursuant to art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the State, managers or appointees;
obtain: a) updating, rectification or, when interested, integration of data; b) the deletion, transformation into anonymous form or blocking of data processed in violation of the law, including data which does not need to be kept for the purposes for which the data was collected or subsequently processed; c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the event that such fulfillment occurs it proves impossible or involves a manifestly disproportionate use of resources with respect to the protected right;
object, in whole or in part: a) for legitimate reasons to the processing of personal data concerning you, even if pertinent to the purpose of collection; b) to the processing of personal data concerning you for the purpose of sending advertising materials or direct sales or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by e-mail and / or through traditional marketing methods by phone and / or mail. Please note that the interested party's right of objection, set out in the previous point b), for direct marketing purposes by automated means, extends to the traditional ones and that the possibility for the interested party to exercise the right of opposition also remains valid only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or none of the two types of communication.
Where applicable, it also has the rights set forth in Articles 16-21 GDPR (Right of rectification, right to be forgotten, right to limitation of treatment, right to data portability, right to object), as well as the right to complain to the Guarantor Authority.
Mode of exercise of rights
You can exercise your rights at any time by sending:
- a registered letter a.r. to G4B - Golf for Business Srl Via della Grande Muraglia 205 - 00144 Rome
- an e-mail to the address email@example.com
If article 6, paragraph 1, letter a) GDPR applies, as regards the direct offer of services to minors, the processing of personal data of the minor is lawful if the minor is at least 16 years old. If the minor is under the age of 16, such treatment is lawful only if and to the extent that such consent is given or authorized by the holder of parental responsibility.
Owner, manager and appointees
The data controller is G4B - Golf for Business Srl Via della Grande Muraglia 205 - 00144 Roma
The updated list of data processors and data processors is kept at the registered office of the Data Controller.
Changes to this Statement
This information may be subject to change. We therefore recommend that you regularly check this Information and refer to the latest version.