Data subject: customers.
Gattinoni Travel Network S.r.l. in its capacity of Data Controller with regard to the processing of your personal data pursuant to (EU) Reg. 2016/679 (hereinafter the 'GDPR'), hereby informs you that the said regulation protects data subjects with regard to the processing of their personal data and that the said processing will take place in a fair, lawful, transparent manner which protects your privacy and your rights.
Your personal data will be processed in accordance with the terms of the above legal provisions and the confidentiality obligations contained therein.
Purposes and legal basis of processing: specifically, your data will be processed for the following purposes, relating to the fulfilment of legal obligations:
- Current legal requirements;
- legal compliance with regard to taxation and accounting;
- Managing of controversy.
Your data will also be processed for the following purposes relative to the performance of measures connected to contractual or preliminary obligations:
- Activities schedule;
- After sales support;
- Artistic and cultural activities;
- Booking and ticketing services;
- Clients management;
- Historical filing system of customer invoices;
- Marketing and Advertising;
- Quality Management;
- Report management during sales operations;
- Sale of Nitto ATP Final tickets through a special portal with a joint controllers agreement with FIT (Italian Tennis Federation);
- Tourist and leisure activities;
- Vendita servizi aggiuntivi su richiesta per tamponi Covid19.
For the purposes of the aforesaid processing, the Data Controller may obtain knowledge of special categories of data, as follows: General special categories of personal data, health conditions, racial or ethnic origins. Personal data in these special categories are processed in compliance with art. 9 of the GDPR.
For the purposes of the aforesaid processing, the Data Controller may obtain knowledge of personal data relating to criminal convictions or offences pursuant to art. 10 of the GDPR and in particular: General personal data relating to criminal convictions and offences, information concerning judicial measures..
Further to your consent, your personal data may be used for the following purposes:
- Profiling for marketing purposes in order to create a customer profile through the collected data aimed at personalizing commercial offers. Consent can be revoked at any time pursuant to Article 7 paragraph 3 of the GDPR;
- Sending periodic newsletters with marketing, information and regulatory updating contents.;
- Transfer of personal data to third parties (Gattinoni & Co.) for marketing purposes.
Your contribution of data is optional with regard to the abovementioned purpose, and any refusal of consent will not affect the continuation of the relationship or the congruency of the processing.
Processing procedures. Your personal data may be processed by the following ways:
- Using electronic calculators running self-managed softwares or directly engineered;
- using electronic calculators running softwares managed by third parties;
- Creation of profiles concerning clients,suppliers and consumers;
- data collection in public places or places open to the public;
- collecting data by computer or on Internet.;
- Manual personal data processing with paper filing system;
- contract data processing by third parties;
- computer processing.
All data are processed in compliance with the procedures specified in articles 6 and 32 of the GDPR and with the adoption of the appropriate security measures required.
Your data will only be processed by staff specifically authorised by the Data Controller, and specifically by the following categories of staff:
- Admnistration office;
- Business Travel Center;
- Commercial Office;
- DPACK Office;
- GTE Office;
- HR Department;
- IT Department;
- Marketing office;
- Programmers and Analysts;
- Selected Office;
- Travel Agencies.
Disclosure. Your data may be disclosed to external entities for the correct management of the relationship and specifically for the following categories of Recipients, including all the duly designated Data Processors:
- banks and lenders;
- consultant and freelance professionals, also working as firms;
- Freight Forwarders and Logistics Companies;
- pension and welfare institutions;
- Public/private subjects whose data transmission is mandatory or necessary in compliance with regulations or functional to the relationship management;
- I dati saranno comunicati (laddove previsto dal contratto) a società specializzate per l'esecuzione di tamponi covid19, Gattinoni e le Agenzie del suo network non verranno mai a conoscenza degli esiti degli stessi.;
Distribution: Your personal data will not be distributed in any way.
Your personal data may also be transferred, only for the aforesaid purposes, to the following countries:
- EU countries: the transfer is cross-border, therefore intra-EU to servers such as Travel Compositor hosted in Spain or Microsoft 365 servers hosted in European datacenters.
Data Storage Period. In accordance with the principles of lawfulness, limitation of purpose and minimisation of data, pursuant to art. 5 of the GDPR, the data storage period for your personal data is:
- 5 - 10 years pursuant to art. 2948 of the Italian Civil Code which provides for a 5-year prescription for periodic payments; art. 2220 of the Italian Civil Code which provides for the retention of accounting records for 10 years; art. 22 of the Presidential Decree 600 of 29 September 1973.;
- set for a timing not larger than the one which implies its purpose achievement, given the aim to collect data, and collected and processed for the execution and fulfillment of contract purposes;
- In compliance with the terms prescribed by law for the type of activity and in any case until the withdrawal of consent or until the exercise of the right of opposition pursuant to the Provv. general of 05/15/13; art. 21 EU Reg. 2016/679.;
- set for a timing not larger than the supplied services fulfillment;
- Until the duration of the Session. Legitimate interest art. 6 lett. f) and recital 47: the processing is necessary for the pursuit of the legitimate interest of the data controller or of third parties, provided that the interests or fundamental rights and freedoms of the data subject that require the protection of personal data do not prevail, taking into account the reasonable expectations nurtured by the data subject based on his relationship with the data controller. Activities strictly necessary for the operation of the site and the provision of the navigation service on the platform.
Data Controller 1: the Data Controller, as defined by the Law, is Gattinoni Travel Network S.r.l. (VIA STATUTO, 2 , 20121 MILANO (MI); VAT number: 02713750137; contactable at the following addresses: E-mail: email@example.com) in the person of its current legal representative.
Data Controller 2: the Joint Data Controller, as defined by the Law, is the Italian Tennis Federation (Olympic Stadium - Curva Nord - Entrance 44 Scala G, 00135 Rome; VAT number: 01379601006; contacted at the following addresses: E-mail: firstname.lastname@example.org) in the person of its pro tempore legal representative.
The Data Protection Officer (DPO) designated by the Data Controller pursuant to art. 37 of the GDPR is:
- JAERA S.R.L. - Dott. Alessandro Simonassi (Piazza Della Repubblica 32 , 20124 Milano (MI); VAT number: 10557200960; contactable at the following addresses: E-mail: email@example.com).
You are entitled, by application to the Data Processor, to obtain the erasure (right to be forgotten), restriction, updating, rectification and portability of your personal data, to object to their processing, and in general to exercise all your rights under articles 15, 16, 17, 18, 19, 20, 21 and 22 of the GDPR.
You may also examine whenever you like the updated version of the present report by connecting to the following web site https://www.privacylab.it/informativa.php?19637433895&lang=en.
Regulation (EU) 2016/679: Articles 15, 16, 17, 18, 19, 20, 21, 22 - Rights of the Data Subject
1. The data subject has the right to obtain confirmation as to whether or not personal data concerning him or her exist, regardless of their being already recorded, and disclosure of such data in intelligible form, and the right to lodge a complaint with the supervisory authority.
2. The data subject has the right to be informed of:
- the source of the personal data;
- the purposes and methods of processing;
- the logic applied if the data are processed by electronic devices;
- the identification data concerning the Data Controller, the Data Processors and the representative designated as per article 5, comma 2;
- the entities or categories of entity to whom or which the personal data may be disclosed and who or which may get to know said data as designated representative in the State's territory, as data processors or as persons in charge of the processing.
3. The data subject is entitled to obtain:
- the updating, rectification or, where interested therein, integration of the data;
- the erasure, anonymisation or blocking of data that have been unlawfully processed, including data whose retention is not necessary for the purposes for which they were collected or subsequently processed;
- certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were disclosed or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared to the right that is to be protected;
- the portability of the data.
4. The data subject has the right to object, in whole or in part:
- on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
- to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.