PRIVACY POLICY – INFORMATION ON THE PROCESSING OF PERSONAL DATA

This information is provided in accordance with Art, 13 of Regulation (EU) 2016/679 (“European General Data Protection Regulation”).

1. Co-processors of the processing
The Data Controllers of any personal data supplied on this Site are: Ricevo S.r.l. with headquarters in Via Roma, 29 in San Vito al Torre (UD) in the person of the Director Alessandro Coslanich, CEM address ricevosrl@legalmail.it
and Ricevo Solutions S.r.l., with registered office in via Scamozzi 6 33057 Palmanova (UD) – UDINE, in the person of the legal representative, telephone 04321772010, e-mail info@ricevosrl.com, PEC ricevosolutions@legalmail.it.
The Joint Data Controllers (hereinafter, “Joint Data Controllers”) inform you pursuant to Art. 13 Reg. (EU) 2016/679 (hereinafter, “GDPR”) that your data will be processed in the following ways and for the following purposes.
The Joint Data Controllers have mutually decided which personal data to collect, the reasons why it is necessary to process personal data and the manner in which the processing activities are carried out. Specifically, the Co-owners share the personal data processing activities resulting from the management of this site. Joint ownership refers to the joint or separate acquisition of personal data through the Site. The rights of the data subjects may be exercised, indiscriminately, against even only one of the Joint Controllers, as indicated in point 11.

2. Purpose of processing
Your personal data are treated confidentially and are transferred to third parties only in accordance with the provisions of this Policy. We process the personal data you provide us during the use of the website palazzotieste.it, owned by Ricevo Solutions S.r.l. In particular, we process:
i. personal, identifying and non-sensitive data (name, surname, email, telephone number – hereinafter, “personal data” or “data”) directly provided by you by filling out the contact form provided to obtain information about the property “Palazzo Tieste” owned by Ricevo S.r.l. and, possibly, expressing consent to receive commercial communications, newsletters on the activities carried out by Ricevo Solutions S.r.l;
ii. data not directly provided by you whose transmission is related to the use of Internet communication protocols (by way of example, access to the page, amount of data transferred, status message when access occurred, session ID numbers, IP addresses, URL addresses, etc.). This data makes it possible to reconstruct the path of your visits to the site.

3. Purpose of processing and legal basis
Your personal data are processed:
A) without your express consent for the following Purposes:

• processing a request for a contract and/or implementing pre-contractual measures taken at your request;
• to fulfil obligations required by law or by an order of the Authority;
• to prevent or detect fraudulent activities or abuses harmful to the website;
• pursue a legitimate interest of the Data Controllers or of third parties; exercise the rights of the Data Controllers (e.g. the right of defence in court);

B) only after your specific and unequivocal consent (Art. 130 Privacy Code and Art. 7 GDPR), for Marketing Purposes and therefore to send via email newsletters, commercial communications and / or advertising material on products and / or services, different and / or dissimilar from those already purchased, offered by the co-owner Ricevo Solutions (e. g. even the activities of building renovation with incentives, carried out by Ricevo Solutions).

LEGAL BASIS FOR PROCESSING
Personal data collected through this site are processed by the co-owners in order to fulfil any requests made by the same user (execution of pre-contractual or contractual measures at the request of the data subject) and to ensure the proper functioning of the site. For marketing purposes, the user is asked to give consent, which constitutes the legal basis of the processing.

4. Nature of the provision of personal data
The provision of your Data for the purposes described in point 2, letter A) is necessary. In the absence of such provision, we cannot guarantee that we will be able to process your requests for information.
On the other hand, the provision of your Data for the purposes described under point 2, letter B) (marketing purposes) is optional. You may therefore decide not to provide any data or withdraw the possibility of processing by us of data previously provided for marketing purposes. In this case, you will no longer receive our newsletters and promotional communications.

5. Modalities of processing
The processing of your personal data is carried out by means of the operations of collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. The processing of your data will be based on the principles of correctness, lawfulness and transparency and may also be carried out by means of automated methods designed to store, manage and transmit them and will take place by means of instruments that are suitable, as far as reasonably possible and in accordance with the state of the art, to guarantee security and confidentiality through the use of appropriate procedures that avoid the risk of loss, unauthorised access, unlawful use and dissemination.

6. Period of data retention
The Data Controllers will process personal data for the time necessary to fulfil the above purposes and therefore for the time necessary to process your request for information and contact. In case of subsequent establishment of a contractual relationship, the data will be kept for up to 10 years after the termination of the relationship. Data collected for marketing purposes will be stored for no longer than 2 years after collection, unless you exercise your right to revoke your consent, whichever is earlier. After this retention period, the data will be destroyed or made anonymous.

7. Access to data
The personal data processed by the Joint Holders will not be disseminated, in any possible form, including making them available or simply consulting them. They may, however, be communicated to the employees working for the Joint Holders and to some external subjects who collaborate with them. In particular, your data may be made accessible to employees and collaborators of the Joint Owners, consultants authorized to manage the site and the provision of related services (for example: customer services, IT department, preparation and / or dispatch of information material and newsletters, etc..), as well as real estate agencies that take care, on behalf of the joint owner Ricevo S.r.l., the presentation of the latter’s sales proposals, in their capacity as authorized to process personal data or, if they are outside the organization, the data processors specifically designated. Where the data processors carry out activities other than those carried out on behalf of Ricevo S.r.l., they will take on the role of autonomous data controllers and, as such, directly bound by the obligations of the GDPR.
Your data may also be communicated, to the extent strictly necessary, to persons entitled to access them under provisions of the law.
The updated list of data processors and persons in charge of the processing is kept by the Data Controllers.

8. Communication of data
Without your express consent, the Controller may communicate your data for the purposes indicated to judicial authorities as well as to all other parties to whom communication is obligatory by law.

9. Transfer of data
The management and storage of personal data will take place on the devices of the co-owners and/or third party companies appointed and duly appointed as Data Processors, located within the European Union. The data will not be transferred outside the European Union. Should it become necessary to transfer the data outside the EU, this will be done in accordance with the applicable legal provisions.

10. Rights of the data subject
As a data subject, you have the rights under Art. 15 GDPR: (a) to request confirmation as to whether or not your personal data exists; (b) to obtain information as to the purposes of the processing, the recipients or categories of recipients to whom the personal data have been or will be disclosed and, where possible, the period of storage; (c) to object to the processing at any time; (d) to object to automated decision-making relating to fixed persons, including profiling (an activity not currently envisaged); e) request from the Data Controller access to and rectification or erasure of personal data or restriction of the processing of personal data concerning him/her or to object to their processing, in addition to the right to data portability; f) withdraw consent at any time without prejudice to the lawfulness of the processing based on consent given before the revocation; g) lodge a complaint with the Italian Data Protection Authority – www. garanteprivacy.it.

11. Changes to this Policy
You can exercise your rights by contacting even one of the holders at the addresses listed above, by sending a racc. A/R or PEC to: Ricevo S.r.l. with registered office in via Roma, 29 in San Vito al Torre (UD) PEC address ricevosrl@legalmail.it or Ricevo Solutions S.r.l. via Scamozzi 6 33057 Palmanova (UD) – UDINE, PEC address ricevosolutions@legalmail.it.

12. Modifiche alla presente Informativa
This Policy is subject to change.We therefore recommend that you check this Policy regularly and refer to the most up-to-date version.

Palmanova, 11th July 2023
The Data Controllers
Ricevo S.r.l. e Ricevo Solutions S.r.l.