PRIVACY POLICY

PRIVACY INFORMATION AND COOKIES PURSUANT TO ART. 13 OF EU REGULATION N. 2016/679
This information is provided pursuant to and by effect of art. 13 of EU Regulation no. 2016/679 of 27 April 2016 (hereinafter also “GDPR”) concerning the protection of natural persons with regard to the processing of personal data. Specifically, Spazio Srl, as Data Controller, wishes to inform you that, in implementation of the obligations deriving from the GDPR, it is required to provide some information regarding the methods and purposes of the processing of personal data, of which it may come into possession at following the consultation and use of the website by the user.
1. DATA CONTROLLER
The Data Controller for all personal data collected and processed and used in relation to the management of the website is the company Spazio Srl, owner of the site “https://milanoi.spazionikoromito.com”, with registered office legal in Contrada Santa Liberata snc – 67031 Castel di Sangro (AQ). Website: https://milano.spazionikoromito.com E-mail: privacy@spazionikoromito.com
2. DATA PROCESSED AND PURPOSE OF THE TREATMENT
2.1 TYPE OF DATA PROCESSED:
a) Personal data In the optional, explicit and voluntary use of the site, the following will be acquired: a.1) Personal data: any information which, directly or indirectly, also in connection with any other information, including a personal identification number, identifies or an identifiable natural person; date of birth, country and language in which you wish to receive the newsletter; a.2) Particular data: food intolerances or food preferences for religious reasons, if voluntarily indicated by the User in the reservations. All content entered voluntarily by the user will be visible by the Data Controller and his appointees. The personal data of the interested party, collected and registered to access the site, will be treated in a strictly confidential form by the Data Controller and by the subjects appointed by the same, and may be used only for statistical purposes in the form aggregated or in any case in such a way as to make them anonymous.b) Navigation data The computer systems and software procedures used to operate the site acquire, during their normal operation, some personal data whose transmission is implicit in the use of communication protocols of the Internet. This category of data includes the IP addresses or domain names of the computers used by users who connect to the site, the addresses in URI ( Uniform Resource Identifier ) notation of the requested resources, the time of the request, the method used when submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user’s computer environment .
These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the site and the Data Controller only at the request of the supervisory bodies in charge.
2.2 PURPOSE OF THE TREATMENT.
Your personal data is processed: A) Even without your express consent (art. 24 letter a), b), c) Privacy Code and art. 6 lett. b), e) GDPR), for the following Service Purposes: allow the use of the information request service, fulfill the obligations established by law, by a regulation, by community legislation or by an order of the Authority (such as, by way of example and not limited to: tax purposes, anti-money laundering purposes L. 231/07 and subsequent amendments );
exercise the rights of the Data Controller, for example the right to defense in court;B) Only with your specific and distinct consent (Articles 23 and 130 of the Privacy Code and Article 7 of the GDPR), for the following Marketing Purposes: to send you newsletters ,
communications commercial and/or advertising material on products or services offered by the Data Controller and detection of the degree of satisfaction with the quality of the services; send you marketing sms containing commercial communications and offers on products or services offered by the Data Controller and detection of the degree of satisfaction with the quality of the services; identification, also through electronic processing of consumer behavior and habits in order to improve the services and products offered, satisfy specific needs and direct commercial offers of interest. It should be noted that the personal data processed for direct marketing purposes are: name , surname, e-mail, telephone number. In the event that the interested party has given his consent when subscribing to the newsletter, or to SMS marketing, or expresses it subsequently and until the revocation of the same, personal data may be processed by the Data Controller also for direct marketing purposes , or for sending e-mails of an informative, advertising and/or promotional nature, the sending of text messages also of an informative, advertising and/or promotional nature and, more generally, for sending commercial communications . This treatment will be carried out through automated contact methods, and in particular through e-mail and text messages (where consent has been given).
2.3 The possibility remains for the Data Controller to process the aforementioned data in aggregate form, in compliance with the measures prescribed by the EU Regulation and by the Guidelines of the Privacy Guarantor and by virtue of the specific exemption from the consent provided by the same Authority, for electronic analysis and processing (for example, the classification of the entire class of users into homogeneous categories for levels of services, consumption, expenditure, etc.) aimed at periodically monitoring the development and economic trend of Spazio Srl’s activities, for the purpose of improving services and optimization of online services.
LEGAL BASIS OF THE TREATMENT
3.1 The legal basis for the processing of the personal data indicated above is: – as for point 2.1 letter a.1), Types of data processed, the need to perform the services requested by the User, and compliance with the obligations of law relating to billing; – as regards point 2.1 letter b), Types of data processed, the need to allow navigation on the site; – as regards point 2.2. letter A), Purpose of the processing, compliance with legal obligations and the need to perform the services provided by the Data Controller. Therefore, the provision of data is mandatory and any failure to provide it could result in the non-execution or suspension, even interruption, of the provision of the services offered; – as for point 2.2 letter B), Purposes of the Processing, the interest of the Data Controller; – as for point 2.2 letter B), Purposes of the processing, the consent expressed by the Customer for the direct marketing purposes indicated above. The Customer may revoke his consent at any time, either by connecting to the form to revoke the consent at the bottom of the newsletter, or by writing to privacy@spazionikoromito.com.
3.2 With the exception of technical cookies strictly necessary for normal navigation, the provision of data is left to the will of the user who decides to navigate and use the website after having read the brief information contained in the appropriate banner and to take advantage of the services that involve the installation of cookies. The interested party can therefore avoid the installation of cookies by keeping the banner (therefore refraining from closing it by clicking on the “ok” button), as well as through the specific functions available on their browser. We also remind you that the majority of internet browsers are initially set to accept cookies automatically. This means that you have the possibility, at any time, to set your browser to accept all cookies, only some, or to refuse them, disabling their use by the sites. Furthermore, you can normally set your browser preferences in such a way as to be notified each time a cookie is stored on your computer.
3.3 Finally, at the end of each browsing session, you can delete the collected cookies from the hard disk of your device. If you want to delete the cookies installed in the cookie folder of your browser, remember that each browser has different procedures for managing settings.
By selecting the links below, you can obtain specific instructions for some of the main browsers.Google ChromeMozilla FirefoxApple SafariMicrosoft Internet ExplorerMicrosoft EdgeBraveOperaYou can also visit the site, in English, www.aboutcookies.org or www.youronlinechoices.com for further information on how to manage/ delete cookies based on the type of browser used. To delete cookies from the Internet browser of your smartphone/tablet, refer to the device’s user manual. 3.4 Please note that if cookies are disabled, the site may not function properly.
PROCESSING METHODS
4.1 Personal data is processed with automated and non-automated tools, for the purposes for which it was collected. Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access. 4.2 The data collected may be used on behalf of the Data Controller, by the administrators in charge of carrying out processing and correct execution services of site activities. The treatments connected to the web services of this site can also take place at the web service provider. It should be noted that personal data will be kept and controlled, also in relation to the knowledge acquired on the basis of technical progress, the nature of the data and the specific characteristics of the treatment, through the adoption of suitable and preventive security measures, both physical and that of a logical type, in order to minimize the risk of destruction or loss of the data itself; of unauthorized access; of treatment that is not permitted or does not comply with the purposes of the collection. In addition to the Owner, therefore, in some cases, other subjects involved in the organization of this Website (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Managers can always be requested from the Data Controller. 4.3 The Data is processed at the Data Controller’s operating offices and in any other place where the parties involved in the processing are located. For more information, contact the Owner. The User’s Personal Data may be transferred to a country other than the one in which the User is located. The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to a international organization of public international law or constituted by two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data. The data will be kept on a physical server located in the Italian territory. The treatment will be carried out by the Data Controller and by the persons in charge expressly authorized by the Data Controller.
5. DURATION OF DATA CONSERVATION
5.1 The processing of your personal data is carried out by means of the operations indicated in art. 4 Privacy Code and art. 4 no. 2) GDPR.5.2 The data necessary for the provision of the service will be kept by the Owner for the time necessary to provide the requested services or until the service itself is exhausted by the Owner.5.3 The Owner may keep the user’s personal information even after the provision of the services provided if this storage is reasonably necessary to comply with legal obligations, meet regulatory requirements, resolve disputes between users, prevent fraud and abuse or apply this privacy statement.
5.4 The navigation data will be kept for the technical time necessary to carry out the functions for which they were collected and in any case for a maximum period of 6 months.
5.5 The Data Controller will therefore process personal data for the time necessary to fulfill the aforementioned purposes and in any case for no more than 10 years from the termination of the relationship for the Service Purposes and for no more than 2 years from the collection of data for the of Marketing and in reference to the newsletter service (as per the Provision of the Guarantor of 24 February 2005), without prejudice to the possibility of the interested party to cancel their data at any time, with the notice that, in any case, upon the relative expiry, such data will be automatically deleted or made anonymous in a permanent and non-reversible way.
COOKIES
6.1 In order to make its services as efficient and easy to use as possible, this site uses cookies. Therefore, when you visit the Site, a minimum amount of information is entered into the User’s device, such as small text files called “cookies”, which are saved in the User’s Web browser directory. There are different types of cookies, but basically the main purpose of a cookie is to make the site work more effectively and to enable certain features. 6.2 Cookies are used to improve the overall navigation of the User. In particular:They allow you to navigate efficiently from one page to another on the website.They memorize the username and preferences entered.They allow you to avoid entering the same information (such as username and password) several times during the visit.They measure the use of the services by Users, to optimize the browsing experience and the services themselves. They present targeted advertising information according to the interests and behavior shown by the User while browsing. There are various types of cookies. Below are the types of cookies that can be used on the site with a description of the purpose linked to their use. 6.3 Our site uses the following types of cookies: Technical cookies Cookies of this type are necessary for the correct functioning of some areas of the site. Cookies in this category include both persistent cookies and session cookies. In the absence of these cookies, the site or some portions of it may not function properly. Therefore, they are always used, regardless of user preferences. Cookies in this category are always sent from our domain. Analytical cookies Cookies of this type are used to collect information on the use of the site. The Owner uses this information for statistical analyses, to improve the site and simplify its use, as well as to monitor its correct functioning. This type of cookie collects anonymous information about user activity on the site and how they arrived at the site and the pages visited. Cookies in this category are sent from the site itself or from third-party domains. Third-party cookies These cookies will only be installed if the site owner enables the related functions made available by the platform. In particular:Google Analytics: Google Analytics is a web analytics service provided by Google Google Inc. (1600 Amphitheater Parkway , Mountain View , CA 94043, USA), for purposes of history, visit count, navigation statistics. The information and privacy notes relating to the functioning and consent to the use of Google cookies are available at the following links:
Information on “How Google uses data when using the sites or applications of our partners”: http:/ /www.google.it/policies/privacy/partners/Information on Google Analytics cookies: How to refuse Google Analitycs cookies : you need to download and install the browser plug-in available at the following link: https://tools.google. com/dlpage/gaoptout?hl=it
Information and general notes on Google services: http://www.google.it/analytics/learn/privacy.html This cookie is activated only with the express consent of the interested party. Cookies to integrate products and third-party software functions parts (such as software for generating maps and other software that offer additional services). These cookies are sent from third-party domains and from partner sites that offer their functionality between the pages of the site. The site https://milano.spazionikoromito.com uses the following external services:maps.google.com (“Google Maps ”)Google MapsGoogle Maps is a service that allows you to view maps and driving directions provided by Google, Inc. (“Google”). For more information see Google, privacy and terms.
DATA COMMUNICATION – RECIPIENTS AND RECIPIENT CATEGORIES
7.1 The personal data provided will not be disseminated or disclosed to unspecified subjects. 7.2 The data may instead be communicated to clearly defined subjects only by the Data Controller for the purposes indicated, in particular: a) Data processors and appointees (the list of the former may only be made available to directly interested parties who explicitly request it); b) Legal, tax and corporate consultants, for the best management of tax profiles and billing, who will in any case remain independent data controllers, unless they are expressly appointed as external data processors. 7.3 Without the need for express consent (pursuant to art. 24 letter a), b), d) of the Privacy Code and art. 6 lett. b) and c) GDPR), the Data Controller may communicate your data for the purposes referred to in art. 2. A) to supervisory bodies, judicial authorities, as well as to all those subjects to whom the communication is mandatory by law for the accomplishment of the aforementioned purposes. These subjects will process the data in their capacity as independent data controllers. 7.4 Your personal data may also be communicated for the same purposes to other companies of the Niko Romito Group of which Spazio Srl is a part (parent, subsidiary or associated companies also indirectly), as well as to third party suppliers of IT or archiving services. 7.5 The list of companies to which your data may be communicated for the same purposes and the list of subjects appointed as external data processors is available at the following references, it may be requested from Spazio Srl at the address privacy@spazionikormito.com. 7.6 Your data will not be disclosed. Your data will not be transferred either to Member States of the European Union or to third countries not belonging to the European Union.
NATURE OF THE PROVISION OF DATA AND CONSEQUENCES OF THE REFUSAL TO ANSWER
8.1 The provision of data for the purposes referred to in art. 2.2 A) is mandatory. In their absence, we will not be able to guarantee you the Services of the art. 2.A).
8.2 The provision of data for the purposes referred to in art. 2.2 B) is instead optional. You can therefore decide not to provide any data or to subsequently deny the possibility of processing data already provided: in this case, you will not be able to receive newsletters, commercial communications and advertising material relating to the Services offered by the Data Controller. However, you will continue to be entitled to the Services referred to in art. 2.2A).
RIGHTS OF THE INTERESTED PARTY
9.1 In your capacity as an interested party, and art. 13 GDPR and precisely the rights: – of access, rectification, cancellation, limitation and opposition to the processing of data; – to obtain without impediments from the data controller the data in a structured format of common use and readable by an automatic device to transmit them to a other data controller;
– to revoke the consent to the treatment, without prejudice to the lawfulness of the treatment based on the consent acquired before the revocation.
9.2 In this regard, we inform you that the deadline for responding to the interested party is, for all rights, one month from receipt of the request, which can be extended up to three months in particularly complex cases. 9.3 The aforementioned rights can be exercised by written communication to be sent by e-mail to the address: spaziosrl@casellapec.com or registered letter with return receipt to the address: Spazio Srl, Contrada Santa Liberata snc, Castel di Sangro (AQ) – 67031.
10. COMPLAINT TO THE AUTHORITY ‘ GUARANTOR
10.1 The interested party has the right to lodge a complaint with the Data Processing Authority. 10.2 The complaint is the tool that allows the interested party to contact the Guarantor to complain about a violation of the regulations on the protection of personal data pursuant to of the art. 77 of the GDPR and to request a verification from the Authority.10.3 The complaint can be lodged by the interested party with the Supervisory Authority of the place where he resides, or in the place where he works or in the place where the alleged violation has occurred.10.4 The interested party also has the right to bring a judicial appeal before the ordinary Court if he believes that the rights he enjoys have been violated following a treatment. This privacy policy may require an update from time to time, e.g. due to the implementation of new technologies or for the processing of data for purposes other than those indicated. The Owner therefore reserves the right to modify or supplement this privacy information at any time. In this case, it will be the Owner’s responsibility to publish the changes and inform the interested party (the interested party by means of a communication on this website).