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Privacy Policy

Briefing note provided pursuant to Chapter III of EU Regulation 2016/679

Dear Sir/Madam
We wish to inform you that Chapter III of EU Regulation 2016/679 on the protection of individuals with regard to personal data processing and the free movement of data provides for the protection of individuals. Under the law, data processing must adhere to principles of accuracy, lawfulness and transparency and the protection of your privacy and rights. Accordingly, Italian Luxury Asset di Cappella Sandra (hereafter the “Company”) as the Data Controller, is required to provide you with some information regarding the processing of your personal data.

 Article 13 (1) – EU Regulation 2016/679 

A1) The Data Controller 
The Data Controller is Italian Luxury Asset  di Cappella Sandra Via C. Battisti, 29  62012 Civitanova Marche (Mc)  Contact details Tel 349 2321 597 Email info@italianluxuryasset.com 

B1) Personal Data processed 
Personal details (Full Name), Contact Details (Landline, Mobile or Email),

C1) Why the Company processes the data 
1) The Company processes personal data exclusively for the following purposes:
• Sending informative material regarding the activity of the Company, advertising / promotional material and offers related to Real Estates (sale/purchase or lease) listed by the Company (direct marketing).
The provision of data is compulsory and you will therefore be required to provide precise and explicit consent to be provided directly on the form by ticking the box.
Without your consent, the Company shall not send you the communications and shall not process your data.

C1.1) Legal basis of the Company’s data processing 
The processing of data is carried out by the Company based on your consent to the processing.

D1) Categories of subjects to whom the data may be communicated 
In relation to the purposes indicated in section C1), the Company communicates your personal data to the following public bodies (non-economic):
• Police forces, armed forces and other public bodies, in fulfilment of obligations provided under laws, regulations or European Community legislation; Financial administration.
• Companies that carry out the technical transmission of emails or SMS messages upon request of the Company.

E1) Transfer of data to third countries 
Your data will not be transferred abroad or sent or disseminated to foreign bodies, associations or companies. The data are held on servers owned by the Company or third-party servers always located in the Italian Republic, used for this specific purpose and suitably protected. 

Article 13 (2) – EU Regulation 2016/679 

A2) Data retention period 

Personal data will be retained for as long as you will be subscribed to the Company’s website and will be cancelled upon your request. Note that hard and soft copy accounting data must be retained for at least 10 years and that the only data that can be deleted, at the request of the data subject, are contact data once all outstanding accounts are settled and any obligations of law are fulfilled. 
In all cases, when the data is deleted, data subjects will receive a confirmation email or SMS. 

B2) Rights of the data subject 
The data subject may ask the Data controller for
• access to their personal data
• correction or
• deletion of the data
The data subject may also ask for the processing to be restricted or may object to it. 

C2) Right to withdraw consent 
The data subject has the right to withdraw their consent to the processing in respect of direct marketing. Cancellation will be carried out within 10 days from reception of your request.

D2) Right to file a complaint with a supervisory authority 
The data subject has the right to file a complaint with a Supervisory Authority, currently Garante per la Privacy whose website – http://www.garanteprivacy.it/ – explains how to make a complaint. 

E2) Obligatory or optional provision of data and consequences of non-provision 
With reference to the processing purposes listed above:
1) The provision of data is compulsory as the non-provision will not allow the Company to send you any communication.

F2) Automated decision-making process 
No profiling activity is planned. 

Updated on 13/01/2019