The “Eastern Venice Business Network Destination Cycle Tourism of Excellence” signed V.O.D.C.E. based at Corso del Sole 6/1 San Michele al Tagliamento (VE) – managed by the common body “A.B.A. Cooperative Society Services “c.f. 02753950274 on the basis of the network contract pursuant to Law no. 33 of 9 April 2009 Contacts: Telephone: 0431 439566, Email: email@example.com is made up of companies in the tourism-hospitality sector that have established a joint ownership agreement pursuant to art. 26 of EU Reg. 2016/679.
1) CO-OWNERS OF DATA PROCESSING
The “Eastern Venice Business Network Destination Cycle Tourism of Excellence” made up of the joint owners of the processing of your personal data, as a result of the existing contractual agreements, pursuant to and for the purposes of art. 26 of EU Reg. 679/2016, hereinafter “GDPR”, hereby inform you that the aforementioned legislation provides for the protection of your personal data, and that this treatment will be based on principles of correctness, lawfulness, transparency, protection of confidentiality and your rights.
2) ROLES OF RESPONSIBILITY AND PURPOSE OF DATA PROCESSING
on the basis of the contractual agreements in place between the joint data controllers (Article 26 of EU Reg. 679/2016 – essential content of the agreement)
The portal www.veneziaelagunebike.it, allows you to request information, offers and services of a cycle-tourist-receptive nature formulated by all its members, furthermore the aim is to raise awareness of the territory and promote the tourist offer both by sending general and marketing newsletters based on the characteristics and interests of users. The common body “A.B.A. Cooperative Society Services ”coordinates and acts on behalf of the co-controllers of the processing for the purposes indicated above.
3) FOR WHICH PURPOSES AND LEGAL BASES WE PROCESS YOUR DATA:
A) Formulation of offers and estimates based on requests received by filling in the forms on the portal www.veneziaelagunebike.it. The offers will be formulated directly in the name and on behalf of all or some accommodation facilities of interest selected in the search.
– The legal basis of the processing is a pre-contractual obligation in order to respond to the request.
Consequences of failure or incorrect communication of data
The processing of data relating to the collection of information to make a request for a quote is necessary for the correct formulation by the recipient structures of the request. The joint controllers of the processing make it known that any non-communication, or incorrect communication, of one of the contact information, may cause the inability to provide the requested service.
Optional data processing:
B) Direct marketing: with prior consent, information and newsletters are sent on events, initiatives, in the area and in the cycle-tourist accommodation sector which include promotions, newsletters and direct marketing by the “Eastern Venice Destination Cycle Tourism Network of Excellence” and the activities of its complements as independent data controllers.
– Communications will be sent through the contact channels you have indicated, such as email, mobile phone number, sms, whatsapp, traditional mail, telephone calls.
– This marketing activity can be used with prior consent also by joining the additional features and services offered on the portal, by means of a voluntary consent action. – The legal basis of the processing is consent.
C) Profiling: with prior consent, commercial information is sent by the “Eastern Venice Business Network Destination Cycle Tourism of Excellence” for marketing purposes based on the collection of information you indicated in your requests. The communications will be personalized on the basis of your preferences and travel habits, composition of the family unit, age, gender and origin, as well as statistics of the services purchased. Any further commercial communications by the accommodation activities of the network components will be made as independent data controllers. – The legal basis of the processing is consent.
Consequences of the lack of consent for optional purposes
The non-granting of consent for the promotional purposes of direct marketing and / or for the profiling of (purposes B and C) does not affect the processing of data necessary for the provision of the basic service which provides for the receipt of quotes based on your request.
4) HOW WE PROCESS AND PROTECT YOUR PERSONAL DATA:
The data processing is carried out with manual and / or IT and telematic tools, in order to guarantee the security, integrity and confidentiality of the data in compliance with the physical and logical technical and organizational measures, provided for by the provisions in force, in order to reduce to a minimum the risks of destruction or loss, unauthorized access, unauthorized modification and disclosure in compliance with the procedures set out in Articles 5, 32 of the GDPR.
Your data is processed by appropriately trained and trained personnel under the authority of the data controller, as well as through specific confidentiality agreements. The Data Controller is constantly engaged in the use of solutions to ensure the processing of personal data on the basis of new technologies, including by carrying out the “impact assessment” in reference to art. 35 of the GDPR, where necessary. Your personal data will be processed in accordance with the legislative provisions of the aforementioned legislation and the confidentiality obligations set forth therein. Also seen the prov. of the Italian Privacy Guarantor “Guidelines on promotional activities and the fight against spam of – July 4, 2013 (Published in the Official Gazette no. 174 of July 26, 2013).
5) TO WHOM WE COMMUNICATE YOUR DATA – RECIPIENTS
For the performance of certain activities, or to provide support for the operation and organization of the activity, some data may be disclosed or communicated to recipients. These subjects are divided into:
a) Third parties (communication to: natural or legal persons, public authorities, service or other body other than the data subject, the data controller, the data processor and the authorized persons responsible for the processing) including:
– Companies that manage traditional or computerized postal services;
– Legal advisors in the event of any disputes;
– As part of the business network for administrative and accounting purposes to the components of the network for the “legitimate interest” of the data controllers in application of art. 6 paragraph 1 letter f) of the GDPR and recital 48;
– Public bodies where required by law.
b) Data processors (the natural or legal person, public authority, service or other body that processes personal data on behalf of the data controller) including:
– Companies and other subjects, consultants and freelancers who have been given the mandates for the management of mandatory obligations: tax, administrative, accounting, legal consultancy, etc;
– Providers of IT, web, or other services necessary to achieve the purposes necessary for the management of the service;
– Common body of the business network “ABA Servizi Società Cooperativa”.
c) Within the company structure: your data will be processed only by personnel expressly authorized and instructed by the co-controllers of the Data Controller by the following categories of employees: Administration; Secretariat; Technicians; Commercial;
Dissemination: In no case will your personal data be disclosed.
6) HOW LONG WE KEEP YOUR DATA
the conservation of your data will be functional to the purposes of the data controllers for which they were collected, and will be kept until your request for cancellation, which can be made at any time from the communications received. In particular, the data useful for the formulation of estimates will be kept for a further year from the formulation of an estimate. The consent and the related contact details necessary for the receipt of the newsletters and offers referred to in purposes A, will be kept until the same is revoked. The data relating to profiling will be deleted after 1 year of collection.
7) TRANSFER OF DATA TO NON-EU COUNTRIES
The data controller uses web and IT service providers who in turn use cloud platforms located in non-EU countries. Guarantee measures are adopted for the transfer to the recipients, which depending on the case may be: verification of the existence of adequacy decisions for the recipient country by the Commission, signing of standard contractual clauses, verification of the adoption of any additional measures in implementation of the 01/2020 EDPB recommendation, or the signing of the standard contractual clauses for the transfer of personal data to third countries Implementing Decision 2021/914 European Commission. Notwithstanding these guarantees, for data processing (in ref. Dell art. 49 of the GDPR), where applicable, the existence of a contract or pre-contractual measures in favor of the interested party or explicit consent to the transfer is verified.
8) WHAT ARE YOUR RIGHTS
We are obliged to respond to your requests and, specifically, to allow you to exercise your rights as explained below:
a) Access: knowing what data we process, how and why we process them
b) Rectification: correct inaccurate personal data, where applicable
c) Cancellation (right to be forgotten): not applicable in the health sector
d) Limitation of processing: applicable only for some specific situations
e) Receive communication in case of rectification, cancellation, limitation
f) Right to data portability: not applicable for treatments carried out on the basis of a law or regulation and for “derived” data such as assessments regarding the state of health (medical reports and documentation in general)
g) Right to object: the interested party has the right to object to the processing at any time for purposes other than those directly or indirectly connected to hospitalization for the purposes of diagnosis, assistance and health therapy, without prejudice to the existence of legitimate reasons that prevail on the interests, rights and fundamental freedoms of the interested party or for the assessment, exercise or defense of a right in court
h) Right to withdraw consent: applicable only to processing carried out on the basis of the issue of consent, remaining however valid for processing carried out prior to the withdrawal
i) Right to lodge a complaint with a supervisory authority: in the event that the interested party believes that he has not received adequate responses to your requests, he can contact the Privacy Authority of the state in which he resides or works or lodge an appeal before to the judicial authority.
Complaint: The interested parties, having met the conditions, also have the right to lodge a complaint with the Guarantor as the supervisory authority according to the established procedures. For any further information, and to assert the rights recognized to you by the European Regulation, you can contact the data controller at the above references.
10) WHO TO CONTACT AND HOW TO EXERCISE YOUR RIGHTS
The single point of contact for the exercise of your rights is the “Eastern Venice Business Network Destination Cycle Tourism of Excellence” signed V.O.D.C.E. with registered office at Corso del Sole 6/1 San Michele al Tagliamento (VE) – managed by the common body “A.B.A. Cooperative Society Services ”on the basis of the network contract pursuant to Law no. 33 of 9 April 2009. Contacts: Telephone: 0431 439566, Email: firstname.lastname@example.org is made up of companies in the tourism-hospitality sector that have established a joint ownership agreement pursuant to art. 26 of EU Reg. 2016/679.
Rights can also be exercised towards each co-owner of the processing, the list of co-controllers and their respective contact details are available at this link: www.veneziaelagunebike.it/pdf/elenco_retisti.pdf
READING THE INFORMATION ON THE PROCESSING OF PERSONAL DATA
The undersigned interested, having acquired the information provided by the joint data controllers (the list is available at this link) pursuant to articles 13-14 and 26 of the GDPR, confirms that he has read this information on data processing, for the indispensable purposes to the formulation of an offer / quote, indicated in the aforementioned information (purpose A), as necessary to allow the joint owners to correctly manage and treat the data themselves, in order to provide the service, manage and respond to your requests.
FORMULA FOR ACQUISITION OF THE CONSENT OF THE INTERESTED PARTY
As evidence of your explicit and unequivocal consent, we will record the time, date, IP address, your email, your possible consent for direct marketing / receiving newsletters (point B), and / or for profiling (point C), manifested by ticking the appropriate boxes.
3.3.4 Sub-Azione D - 2020-2022 3.3.4 Sub Azione B - 2017-2020
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