Privacy Policy

Privacy policy on the processing of personal data. Effective as of 20th may 2024

INTRODUCTION

This information takes into account the provisions of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) and of the Privacy Code (Legislative Decree 30 June 2003 n. 196). The document has also been drafted in accordance with the Guidelines of the Privacy Guarantor (especially the Guidelines for combating spam issued by the Privacy Guarantor on July 4, 2013).

Data Controller: FERDINANDO CAROTENUTO, VIA PASSANTI FLOCCO, 3 - TERZIGNO (NA) 80040 ITALY - info@rocacharter.com - P.IVA 10512631218

Site to which this privacy policy refers:https://rocacharter.com (Sito).

The Data Controller has not appointed a DPO. Therefore, you may send any inquiries directly to the Data Controller.

GENERAL INFORMATION

This document describes how the Data Controller processes your personal data.

The following describes the main processing of your personal data. In particular, we explain the legal basis of the processing, whether the provision of personal data is compulsory and the consequences of not providing personal data. To better describe your rights, if necessary, we have specified if and when a certain processing of personal data is not carried out.On the Site you have the possibility to enter personal data of third parties. In this case you guarantee to have obtained the consent of these subjects to the insertion of these personal data. Therefore, you agree to indemnify and hold harmless the Data Controller from any liability.

Site registration

The Site does not offer the possibility of registration. Therefore, the Data Controller does not process your personal data for this purpose.

Purchases on the Site

It is not possible to make purchases on the Site. Therefore, your personal data will not be processed for this purpose.The Data Controller may send emails to remind the user to complete a purchase. The legal basis for this processing is the legitimate interest of the Data Controller in sending this type of communication. Through the "follow on shop" option, the Data Controller may process your personal data to send updates via email and/or telephone (depending on the options available on the Website) regarding order status, shipments, and/or supplies. The legal basis for this processing is the Data Controller's legitimate interest in sending this type of communication. This interest is equivalent to your interest in receiving this type of updates. Providing personal data for this purpose is optional. However, if personal data is not provided, it will not be possible for the Data Controller to send this type of communication.

Answering your requests

Your data will be processed to respond to your requests for information. The conferment is optional, but your refusal will make it impossible for the Data Controller to answer your questions. The legal basis for the processing is the legitimate interest of the Data Controller in fulfilling your requests. This legitimate interest is equivalent to the user's interest in receiving a response to communications sent to the Data Controller.

Marketing

Subject to your consent, the Data Controller may process the personal data provided by you in order to send you advertising material and/or newsletters relating to its own products or those of third parties. The legal basis of this treatment is your consent. The provision of personal data for this purpose is purely optional. Failure to consent to the processing of data for marketing purposes will make it impossible for you to receive advertising material relating to products/services of the Data Controller and/or third parties, as well as making it impossible for the Data Controller to carry out market surveys, also aimed at assessing the degree of user satisfaction, and to send you newsletters. These communications will be sent to your e-mail and/or telephone number (in this last case also through SMS and/or WhatsApp).

Profiling

Subject to your consent, the Data Controller may process your personal data for profiling purposes, i.e. for the analysis of your consumption choices by revealing the type and frequency of purchases made by you, in order to send you advertising material and/or newsletters relating to its own products or third parties, of your specific interest. The legal basis of this treatment is your consent. The provision of data for this purpose is purely optional. Failure to consent to the processing of your personal data for profiling purposes will make it impossible for the Data Controller to elaborate your commercial profile, through the detection of your choices and buying habits and to send you advertising material about products of the Data Controller and/or third parties, of your specific interest. These communications will be sent to your e-mail and/or telephone number (in this last case also through SMS and/or WhatsApp).

Data transfer

The Data Controller does not transfer your personal data to third parties.

Geolocalization

The Site does not implement tools to geolocate the user's IP address.

Curriculum Vitae

It is not possible to send CVs via the Website. Your data will therefore not be processed for these purposes.

Booking Service

The information and data requested when booking an appointment and/or service will be used to enable you to make the booking with the Data Controller as explained on the Site. The legal basis of the processing is the Data Controller's need to execute pre-contractual measures taken at the request of the data subject. The provision of data is optional. However, your refusal to provide the data will make it impossible to book an appointment and/or service on the Site.

Communication of personal data

As part of its ordinary business, the Data Controller may communicate your personal data to certain categories of subjects. In article 2 you can find the list of subjects to which the Data Controller communicates your personal data. In order to facilitate the protection of your rights, Article 2 may specify in certain cases when your data is not communicated to third parties.

The "communication" of personal data to third parties is different from the "transfer" (governed by the preceding point). In fact, in the communication the third party to whom the data is transmitted can use it only for the specific purposes described in the relationship with the Data Controller. In the transfer, instead, the third party becomes the autonomous Data Controller. Moreover, to transfer your personal data to third parties is always required your consent.

Without prejudice to the foregoing, it is understood that the Data Controller may still use your personal data in order to correctly fulfill the obligations provided for by the laws in force.

PRIVACY POLICY

Art. 1 Method of processing

1.1 The processing of your personal data will be mainly carried out with the help of electronic or automated means, according to the methods and with the tools suitable to ensure their security and confidentiality.

1.2 The information acquired and the methods of treatment will be relevant and not excessive in relation to the type of services rendered. Your data will also be managed and protected in secure computer environments appropriate to the circumstances.

1.3 Through the Site are not processed "special data". Particular data are those that can reveal racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organizations of a religious, philosophical, political or trade union, health and sex life.

1.4 No judicial data is processed through the Site.

Art. 2 Communication of personal data

The Data Controller may communicate your personal data to certain categories of subjects. The Data Controller wishes to inform users that, in the context of using the YouTube service (managed and owned by Google LLC), some personal data may be collected and shared. This data collection is essential to provide and enhance the user experience on our Site and to enable viewing of video content integrated through the YouTube API. In detail, when a user views a video content through the YouTube API on our Site, the following information may be collected: IP Address: Used to connect the user's device to YouTube for video transmission. Behavioral Data: Includes information on how the user interacts with videos, such as which videos are viewed and for how long. Location Information: Used to provide relevant content based on the user's geographical location. These data are automatically collected by the system and, in some cases, may be stored to improve user experience and for internal analytical purposes at YouTube. It is specified that our Site uses YouTube's API services and, by viewing content through these APIs, the user accepts YouTube's Terms of Service available at https://www.youtube.com/t/terms. For further details on data management by Google LLC, users are invited to consult Google LLC's privacy policy at http://www.google.com/policies/privacy and YouTube's at https://www.youtube.com/intl/ALL_it/howyoutubeworks/our-commitments/protecting-user-data/. Details on the use of User API Data User API Data: When a user interacts with YouTube videos embedded in our Site, data such as viewing preferences, video viewing history, and interactions with video content (likes, comments, shares) may be collected. These data are made available through the YouTube API and help to understand how users interact with video content. Access to data via the Client API: Our Site may use specific API calls to request and receive data from YouTube. This may occur when a user views a video, with the system automatically recording relevant information. Data Collection: Data are automatically collected by the YouTube system when users interact with YouTube videos on our Site. This process is essential to provide a smooth and personalized user experience. Data Storage: The collected data are securely stored in YouTube's systems for a period that does not exceed the necessity of use. YouTube adopts all necessary security measures to protect these data from unauthorized access or illicit uses. Use of Data: YouTube uses these data for various purposes, including: Internal Analysis: To better understand user interactions with video content and improve the quality of YouTube services. Content Personalization: To offer users a more personalized experience, based on their preferences and interaction history. User Experience Improvement: To identify and resolve any technical issues and optimize the usability of video content. The subjects to whom the Data Controller reserves the right to communicate your data are indicated below:

The Data Controller may communicate your personal data to all those subjects (including Public Authorities) who have access to personal data by virtue of regulatory or administrative measures. Your personal data may also be disclosed to all those public and / or private individuals and / or legal entities (legal, administrative and tax, judicial offices, Chambers of Commerce, Chambers and Offices of Labor, etc..), if the communication is necessary or functional to the proper fulfillment of obligations under the law. The Data Controller does not make use of employees and/or collaborators in any capacity. Therefore, your personal data will not be communicated to this category of subjects. In its ordinary activity of managing the Site, the Data Controller makes use of companies, consultants or professionals in charge of the installation, maintenance, updating and, in general, the management of the hardware and software of the Data Controller or which the latter uses for the provision of its services. Therefore, only with reference to these purposes, your data may also be processed by these subjects. The Data Controller does not use CRM platforms (companies that carry out the activity of sending automated communications to users. Therefore, your personal data are not communicated to these companies. The Data Controller does not use external companies to provide customer care services. Therefore, your personal data will not be processed for this purpose. Buyers' personal data are not communicated to couriers or forwarding agents.

The Data Controller reserves the right to modify the above list in accordance with its ordinary operations. Therefore, you are invited to regularly access this information to check to which subjects the Data Controller communicates your personal data.

Art. 3 Personal data retention

3.1 This article describes how long the Data Controller reserves the right to retain your personal data.

User data will be kept only for the time necessary to ensure the proper provision of the services offered through the Site. For the purpose of executing the sales contract, the data will be kept for 10 years from the date of receipt of the purchase order. This is to allow the Data Controller to exercise its right of defence and to prove the Seller has performed its duties. As provided for in Article 2220 of the Civil Code, invoices, as well as all accounting records in general, are kept for a minimum period of ten years from the date of registration, so that they can be presented in the event of an audit. If you have activated the option to be updated on orders, shipments, and/or supplies, your personal data will be stored for this purpose exclusively for the time necessary to perform this service. For marketing purposes, unless consent is revoked before, data will be stored for 24 months from the time of submission. After consent revocation or the end of the 24-month period, personal data will be deleted and no longer used for marketing purposes. For marketing purposes, "profiling," unless consent is revoked before, data will be stored for 12 months from the time of submission. After consent revocation or the end of the 12-month period, personal data will be deleted and no longer used for this purpose. For the purpose of use, publication and reproduction of photographs and/or videos depicting you, the data are kept for the time necessary to carry out the informative and promotional purposes related to the activity of the Data Controller.

3.2 Without prejudice to the provisions of Article 3.1, the Data Controller may retain your personal data for the time required by specific regulations, as amended from time to time.

Art. 4 Transfer of personal data

4.1 The Data Controller is located in a country that has an adequate level of security from a regulatory standpoint. If the transfer of your personal data takes place to a non-EU country and for which the European Commission has expressed a judgment of adequacy, the transfer is deemed safe from a regulatory standpoint in any case. This article 4.1 indicates from time to time the countries where your personal data may possibly be transferred and where the European Commission has expressed a judgment of adequacy.

You are therefore invited to access this article regularly to check whether the transfer of your personal data takes place in a country with these characteristics.

4.2 Without prejudice to what is stated in article 4.1, your data may also be transferred to countries outside the EU for which the European Commission has not issued an adequacy opinion. You are therefore invited to regularly review this article 4.2 to find out to which of these countries your data may be transferred.

4.3 In this article, the Data Controller indicates the countries in which it may specifically direct its activities. This circumstance may imply the application of the legislation of the reference country, together with that which governs the relationship with the user as indicated in the Preamble.

The Site processes personal data of individuals located in Australia. This notice has been prepared taking into account the provisions of Australian national and federal legislation. In particular, reference is made to the Federal Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs). The Site also handles personal data of Brazilian users. Brazilian users are informed that this privacy policy complies with the provisions of the Brazilian Law on Personal Data Protection (LGPD), which came into force on September 18, 2020. Therefore, all the above-mentioned regulations apply. The Site also handles personal data of Canadian users. Therefore, Canadian users are advised that this privacy policy also complies with the Personal Information Protection and Electronic Documents Act. The California Consumer Privacy Act (CCPA) is a California law that was passed in June 2018. The Data Controller processes personal data of California users under this law. The user is informed that the personal data processed are those communicated on the Site to allow the execution of the contract. The user may exercise their rights under the CCPA by contacting the Data Controller at the contact details published in the foreword. The Virginia Consumer Data Protection Act (CDPA) is a law in Virginia that was passed in March 2021. The Data Controller processes the personal data of Virginia users in accordance with this law. Users are informed that the personal data processed are those communicated on the Site to allow the execution of the contract. The user can exercise the rights provided by the CDPA by contacting the Data Controller at the contact details published above. The Nevada Privacy Law (Senate Bill 220) is a piece of legislation in Nevada, enacted in 2019, aimed at protecting the privacy of user data. The Data Controller manages the personal data of users in Nevada in line with this legislation. Users are notified that the personal data being handled are those provided through the Site to facilitate the contract’s fulfillment. Users can avail themselves of the rights guaranteed by the Nevada Privacy Law by reaching out to the Data Controller using the contact information provided earlier. The New Zealand Privacy Act of 2020, which underwent significant amendments in December 2020, governs the protection of users' personal data. In accordance with this legislation, the Data Controller diligently handles the personal data of New Zealand users that are collected through the Site to ensure the proper execution of the contract. Users are hereby informed that they can exercise the rights set forth by the New Zealand Privacy Act by contacting the Data Controller at the contact details initially provided. The Personal Information Protection Law (PIPL) is a Chinese regulation that came into effect on November 1, 2021, and governs the protection of users' personal data. In compliance with this law, the Data Controller is committed to the responsible and secure management of the personal data of Chinese users that are collected through the Site, in order to ensure the appropriate fulfillment of the contract. Users are informed that they can exercise the rights granted by the Personal Information Protection Law by contacting the Data Controller using the contact details provided earlier. The Personal Data Protection Act (PDPA) is a Singaporean regulation that governs the protection of users' personal data. In compliance with the PDPA, the Data Controller commits to responsibly managing the personal data of Singaporean users collected through the Site, to ensure proper fulfillment of the contract. Users are informed that they can exercise the rights stipulated by the PDPA by contacting the Data Controller using the contact details provided earlier. Please be informed that for users residing in the State of Connecticut, the Data Controller closely adheres to the Connecticut Consumer Data Privacy Act (CTDPA), which took effect on July 1, 2023, in processing personal data collected through the Site. This law was established to safeguard consumer data privacy. Users residing in Connecticut can exercise the rights guaranteed by the CTDPA by contacting the Data Controller using the contact details provided.

Art. 5. Your rights

The Data Controller informs you that you have the right:

to request from the Data Controller access to your personal data and the rectification or erasure of the same or the restriction of the processing thereof or to object to the processing thereof, in addition to the right to data portability revoke consent at any time without affecting the lawfulness of the processing based on the consent given before revocation to lodge a complaint with a supervisory authority (e.g. the Italian Data Protection Authority).

The rights referred to above may be exercised by making a request without formalities to the contacts indicated in the Introduction.

Art. 6. Amendments

The Data Controller reserves the right to make changes to this policy at any time, giving appropriate publicity to users of the Site 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 policy. In case of substantial changes to this privacy policy, the Data Controller may give notice of such changes also by email.

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