Privacy Policy pursuant to and for the purposes of art. 13 EU Regulation 2016/679 (GDPR)

 

1.   SUBJECTS OF TREATMENT

 

The Data Controller is T4U Srl with headquarters in Via Cacciatori 21, 92010 Lucca Sicula (AG) - (hereinafter also "the Owner")
RESPONSIBLE FOR DATA PROTECTION (RPD / DPO - DATA PROTECTION OFFICER)
Data Protection Officer (DPO): Marco Casella
Mail: dpo@t4-u.com

 

2.   TYPE OF DATA PROCESSED

We collect your personal information about when you use our App, book your visits, create and manage your account to use the services and offers intended for registered users only ("Dedicated Services"). The data we collect is divided into two categories: (a) data provided to us by the user; (b) data we collect using automated methods.

Personal Data means any information with particular reference to an identifier such as the name, IP device or an online identifier (Tag) able to trace your person.

 

3.   DATA OF MINORS

The use of the App is allowed to those who are at least 16 years old. According to the art. 8 of Regulation (EU) 2016/679 the processing of personal data is lawful if the child is at least 16 years old. The Owner will not be in any way responsible for any false declarations that may be provided by the minor and, in any case, should he ascertain the falsity of the declaration, he will immediately cancel any personal data and any material acquired.

 

4.   PURPOSE OF THE TREATMENT

The personal data provided will be processed in compliance with the conditions of lawfulness pursuant to art. 6 EU Reg. 2016/679 for the following purposes:
A) Management of inherent data processing (art. 6 let. A):
- direct marketing, with prior consent up to your opposition, by means
automated e-mail and push notifications:
- to receive news, promotions, advertising material from T4U also relating to events and initiatives of third party partners of the owner;
- for carrying out market research and compiling statistics;
- to receive commercial and information communications.

The Data Controller uses systems with reports to send news and promotions via e-mail to compare and possibly improve the results of communications.

B) Management of inherent data processing (art. 6 let. F):

It is essential for T4U to cross information deriving from the use of the App in order to provide a service adequate to the user's expectation. With the term expectation we refer to the "reasonable expectations" nurtured by users when they decide to use the service offered by the application and in particular the "Dedicated Services" of the App to registered users only.
The data processing is based on article 6, paragraph 1, letter f), when the user can reasonably expect that a profiling activity will take place by T4U for statistical activity, to improve the offer of products / services in the light of his tastes and activities on the App, such as booking a visit.

 

5.   ADDRESSEES OR CATEGORIES OF RECIPIENTS

The personal data provided may be communicated to recipients who will process the data as data processors and / or as natural persons acting under the authority of the Data Controller and the Data Supervisor, in order to comply with contracts or related purposes. Specifically, the data may be communicated to recipients belonging to the following categories:
- Group company;
- Companies, organizations or consortia that provide processing services or perform activities instrumental to this service;
- external parties that manage / support / assist, even occasionally, the Data Controller in the administration of the information system and telecommunications networks (including the maintenance and / or updating of the App and all that is instrumental to it);
- Competent authorities for the fulfillment of legal obligations and / or provisions of public bodies, upon request;
The subjects belonging to the aforementioned categories act as Data Processing Manager, or operate in total autonomy as separate Data Controllers.

 

6.   INTERNATIONAL TRANSFERS

The personal data provided are not transferred outside the European Union. The same can be transferred outside the European Union only within the limits and conditions set by EU Regulation 2016/679 for the protection of personal data.

 

7.   PRESERVATION OF DATA OR CRITERIA USED FOR THE DEFINITION OF SUCH PERIOD

The processing will be carried out in an automated and partially automated way, with methods and tools aimed at guaranteeing maximum security and confidentiality, by persons specifically appointed for this purpose.
In compliance with the provisions of art. 5 paragraph 1 letter. e) of the EU Regulation 2016/679 the personal data collected will be stored in a form that allows the identification of data subjects for a period of time not exceeding the achievement of the purposes for which the personal data are processed. The criteria adopted by the Data Controller regarding the storage of personal data provided can be requested at this link

 

8.   NATURE OF THE PROVISION AND REFUSAL

The provision of personal data and consent to processing for the purposes referred to in point 4 A) is optional. Failing this, T4U will find it impossible to carry out direct marketing activities in order to keep you updated on the latest promotions of producers, accommodation facilities and all those published on the T4U App.
The provision of data for the purposes referred to in point 4 B) is necessary for the pursuit of the legitimate interest of the Data Controller or to improve the offer of products / services in light of your tastes and preferences. This legitimate interest respects your interests, your rights and your fundamental freedoms regarding the processing of personal data.

9. DATA SUBJECT'S RIGHTS AND DATA ACCESS

 

Whoever is in the European Union has additional rights in relation to the methods of processing their personal data, including the right to:
- request access to their personal data and obtain a copy of the same;
- request the right to the portability of the personal data provided;
- request the rectification of personal data if they are inaccurate or incomplete;
- object, for reasons connected to its particular situation, to the processing of personal data, based on the pursuit of legitimate interests;
- request the deletion of personal data as permitted by applicable law. This aspect concerns, for example, the case in which the data are obsolete or it is no longer necessary or legitimate for us to maintain them or in the case in which the interested party revokes the consent to the treatment, or in the case in which his opposition to the treatment by our party is accepted;
- obtain the limitation of the processing pending our response to the requests of the interested party or the complaints of the interested party regarding (i) the accuracy of the personal data, (ii) our legitimate interests to treat them or (iii) the lawfulness of our treatment activity;
- withdraw consent at any time in the case of voluntary participation in T4U initiatives.
All these rights can be exercised free of charge. However, in compliance with the applicable law, T4U is authorized to charge a reasonable fee or to refuse to comply with a request if it is clearly unfounded or excessive, especially if repeated.
In some circumstances, T4U may refuse to take action or impose limits on the information disclosed if, for example, their disclosure could negatively affect the rights or freedoms of others, jeopardize the fulfillment or enforcement of the law or interfere with ongoing or future legal proceedings.
The interested party also has the right to lodge a complaint regarding the processing of personal data by us at a supervisory authority of the Member State where he habitually resides, where he works or where the alleged violation occurred.
To exercise all your rights of cancellation, rectification, withdrawal of consent to marketing re-contact, you can act independently using the features of the App.
For further requests regarding the exercise of your privacy rights, please contact us at this link

10. MODIFICATION OF THE PRIVACY INFORMATION

 

This Privacy Policy is effective from the date indicated at the beginning of the document. Occasionally, we may modify this Privacy Policy; in this case, we will publish the updated version here and we will modify the "date of the last update" (the starting date) indicated at the beginning of the Information.

Last update date: 18 March 2019