General Data Protection Regulation (GDPR – EU Reg. 2016/679)

Sources and categories of personal data

The personal data held by the undersigned organisation are collected directly from the data subjects.

Navigation data

The computer systems and software procedures used to operate the website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected in order to be associated with identified interested parties, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users connecting to the site, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and IT environment. This data is used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct operation, and is deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes to the detriment of the site.

Profiling data

No profiling data are directly acquired concerning the habits or consumption choices of the person concerned. However, it is possible that through links or by incorporating third-party elements, such informationmay be acquired by autonomous or separate parties. See in this respect the section on third-party cookies .

Cookies

Like others, this website saves cookies on the browser used by the user concerned to transmit information of a personal nature and to enhance the user experience. In fact, cookies are small text strings that the sites visited by the user send to his/her terminal (usually to the browser), where they are stored, sometimes even with wide temporal persistence, to be then re-transmitted to the same sites on the next visit.

As explained below, you can choose whether and which cookies to accept, bearing in mind that refusing their use may affect your ability to carry out certain transactions on the site or the accuracy and appropriateness of certain customisable content offered or the ability to recognise you from one visit to the next. If no choice is made in this respect, the default settings will apply and all cookies will be activated: however, at any time, you will be able to communicate or change your decisions in this respect.

Technical cookies

In particular, we use so-called session cookies, which are not stored permanently on the user’s computer and disappear when the browser is closed, and whose use is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to enable the safe and efficient exploration of the site and avoid the use of other techniques potentially prejudicial to the privacy of users’ browsing and do not allow the acquisition of personal identification data. Then we use analytics cookies that help us understand how visitors interact with the site’s contents, gathering information (geographical and web origin, technology used, language, entry pages, visited pages, exit pages, dwell times, etc.) and generating website usage statistics without personally identifying individual visitors. All of these are to be considered technical cookies for which, since it is not necessary to give consent, the opt-out mechanism applies. Technical cookies are not disclosed to third parties as they are necessary or useful for the operation of the site; they are therefore processed only by persons qualified as data processors, data controllers or system administrators

Third part Cookies

Lastly, the site incorporates cookies and other elements (tags, pixels, etc.) of third parties (autonomous and for which the Owner has no responsibility) that also carry out profiling activities and for which please refer to their respective sites.

Data provided voluntarily by the user

The optional, explicit and voluntary sending of e-mails to the addresses indicated on the site entails the subsequent acquisition of the sender’s address, which is necessary to reply to requests, as well as any other personal data included in the e-mail. The explicit and voluntary sending of the forms that can be filled in on the site containing the data of the person concerned also entails processing for the purpose of fulfilling pre-contractual obligations or carrying out the services provided with the sending of the forms. Such information in the forms may concern personal data, contact details, telephone numbers, email addresses of the interested parties and of identified and identifiable third parties having cause with the user of the site. However, specific summary information will be progressively reported or displayed on the pages of the site set up for particular services on request

Purpose and legal basis of processing

Personal data are processed (ref. Art. 6(b) of the GDPR):

to allow navigation on the site and possibly to perform the service or performance requested as part of the normal activity carried out by this organisation

Furthermore, all personal data may be processed:

1. for purposes related to obligations laid down by law, as well as by provisions issued by authorities empowered to do so by law (ref. articles. 6(c) and 9(b,g,h) of the GDPR);
2. for the establishment, exercise or defence of a judicial or extrajudicial right (legitimate interest) of the undersigned organisation (ref. art. 6(f) and 9(f) of the GDPR);
3. for direct marketing purposes according to the legitimate interest of the Controller in particular; for cookies , advertising ids used to show advertisements and announcements; for e-mail addresses to send the newsletter ; for navigation and usage logs to protect the site and the service from cyber-attacks; in these cases, the data subject may always refuse consent so that the Data Controller will refrain from processing (ref. artt. 6(f) of the GDPR);
4. for purposes functional to the activity for which the data subject has the right to give consent or not, such as, for example, subscribing to the newsletter in order to receive information and promotional and sales messages on products and services, satisfaction surveys, communication of data to third parties for receiving information and promotional and marketing communications (GDPR art. 6(a))
5. with the consent of the data subject, in the case of sensitive data (ref. Art. 9(a) of the GDPR)
6. with the consent of the data subject, for profiling the data subject (ref. Art. 6(a) of the GDPR)

Consequences of refusal to provide data

The provision of data collected from the data subject is optional but indispensable for the purpose of processing them for the purposes set out in points a) and b). In the event that the interested parties do not communicate their indispensable data and do not allow the processing, it will not be possible to proceed with the fulfilment and implementation of the proposed services and to follow up on the contractual obligations undertaken, with consequent prejudice to the correct fulfilment of regulatory obligations, such as accounting, tax and administrative obligations, etc.

Apart from what is specified for navigation data, the user is free to provide personal data for cookies and specific requests via forms e.g. on products and/or services. Failure to provide them may result in the impossibility of obtaining what has been requested. For all non-essential data, including sensitive data, their provision is optional. In the absence of consent or incomplete or erroneous provision of certain data, including sensitive data, the fulfilment of the required fulfilments could be so incomplete as to cause prejudice or in terms of sanctions or loss of benefits, both because of the impossibility of guaranteeing the congruity of the processing itself with the obligations for which it is carried out, and because of the possible mismatch between the results of the processing itself and the obligations imposed by the laws to which it is addressed, the undersigned organisation being understood to be exempt from any and all responsibility for any sanctions or afflictive measures.

Modalities of data processing

Processing related to the site’s web services is carried out by automated tools for the time strictly necessary to achieve the purposes for which it was collected; it takes place at the server in Italy or the EU and is handled only by technical personnel in charge of processing, or by those responsible for maintenance and administration operations. Specific security measures are observed to prevent loss of data, illicit or incorrect use and unauthorised access and loss of confidentiality.

The facility is equipped with anti-intrusion, firewall, log and disaster recovery devices. Specific data encryption and segregation mechanisms and user authentication and authorisation are used.

Processing of data means its collection, recording, organisation, storage, processing, modification, deletion and destruction, or the combination of two or more of these operations. In relation to the aforementioned purposes, the processing of personal data is carried out by means of manual, computerised and telematic tools, with logics strictly related to the purposes themselves and, in any case, in such a way as to guarantee security and confidentiality personal data will therefore be processed in compliance with the methods indicated in Art. 5 Reg.to EU 2016/679, which provides, inter alia, that the data shall be processed lawfully and fairly, collected and recorded for specified, explicit and legitimate purposes, accurate, and if necessary updated, relevant, complete and not excessive in relation to the purposes of processing, respecting the fundamental rights and freedoms and the dignity of the person concerned with particular reference to confidentiality and personal identity, by means of protection and security measures. The undersigned organisation has put in place and will further refine the security system for data access and storage.

No automated decision-making (e.g. profiling) is carried out.

Transfers outside the EU

Processing will mainly take place in Italy and the EU, but may also take place in non-EU and non-EEA countries if deemed functional to the efficient performance of the purposes pursued in compliance with the guarantees in favour of the data subjects. In particular, the processing takes place in the EU, the UK, the USA, Singapore and Australia, where the site’s servers are located, insofar as it is deemed functional to the efficient performance of the purposes pursued in compliance with the guarantees in favour of the data subjects. Finally, processing that takes place in non-EU and non-EEA countries when, at the request of the interested party, connections to the site come from these countries, is outside the responsibility of the Data Controller.

Storageperiod

Personal data will be stored, in general, as long as the purpose of the processing lasts according to the category of data processed.

The data (only those that are indispensable) are communicated to data processors and persons in charge of processing, both internal to the organisation of the writer, as well as external, who carry out specific tasks and operations ( site administration , analysis of navigation data, traffic data, profiling, management of emails and forms sent voluntarily by the user, processing of e-commerce requests and orders, etc..); in the cases and to the persons envisaged by law.

Categories of recipients

The data will not be disclosed unless otherwise provided by law or after anonymisation. With the exception of what has been specified for cookies and third-party elements, without the general prior consent of the person concerned for communications to third parties, it will only be possible to carry out services that do not provide for such communications. If necessary, specific and punctual consents will be requested and the subjects receiving the data will use them as autonomous data controllers.

In certain cases (not covered by the ordinary management of this site) the Authority may request news and information, for the purpose of monitoring the processing of personal data. In such cases, a reply is mandatory under penalty of administrative sanction.

Rights of the data subject

You may at any time exercise your rights (access, rectification, cancellation, restriction, portability, opposition, no automated decision-making processes ) when provided against the data controller, pursuant to Art. 15 to 22 of the GDPR; lodge a complaint with the Garante; where the processing is based on consent, withdraw that consent, taking into account that the withdrawal of consent does not affect the lawfulness of the processing based on consent before revocation.

Disabling cookies

Almost all browsers offer the possibility to manage and disable cookies, in order to respect users’ preferences. In some browsers it is possible to set rules to manage cookies on a site-by-site basis, an option that offers more precise control over user privacy; another function available on some browsers is the incognito mode, so that all cookies created in this mode are deleted after closing.

For cookie management in the relevant browser, please refer to the help documentation drawn up by the browser manufacturer.

Addresses and contacts

The data controller is Rosa Apartment.

Via Montegrappa 21, 90128 Palermo (PA) – Italy.

Contact details are: info@rosaapartment.it

The full list of data controllers is available on request.