This page describe Trullilovely’s site management with reference to the processing of personal data of the users who consult it. This is an information notice that is also provided pursuant to art. 13 of the legislative decree n. 196/2003 – Code regarding the protection of personal data – and the EU REGULATION 2016/679 to those who interact with the web services offered by Art of Taste, accessible electronically and through which the domain can be reached:
that is the home page of the official website of Trullilovely.
The information is provided only for the services provided through the Trullilovely website and not for other websites that may be consulted by the user through links published on the website www.trullilovely.com.
The information follows Recommendation no. 2/2001 that the European authorities for the protection of personal data, gathered in the Group established by art. 29 of directive n. 95/46 / EC, adopted on 17 May 2001 to identify some minimum requirements for the collection of personal data online, and, in particular, the methods, timing and nature of the information that the data controllers must provide to users when they connect to web pages, regardless of the purpose of the connection, and also adapts to the EU REGULATION 2016/679 which in addition to having repealed the directive n. 95/46 / EC has established new standards for data collection and management.
AGE LIMITATIONS ON THE USE OF THE SERVICES OFFERED BY TRULLILOVELY
The services offered by Trullilovely are reserved for individuals who have reached the age of eighteen. Reaching the age of majority by site users is a necessary and fundamental condition to be able to adequately consent to the processing of their personal data and consequently provide the same. In the absence of this requirement, anyone who uses the site and gives consent to the processing of personal data provided without having reached the age of majority is aware of carrying out unlawful conduct with respect to which they declare not to claim any rights or claims for compensation against Trullilovely.
Trullilovely assumes no responsibility for any false statements provided and if it becomes aware of the existence of false statements it will proceed with the immediate cancellation of any personal data acquired subject to taking action against the offender of the unlawful conduct to obtain compensation for any damage caused.
“OWNER” AND “PERSON RESPONSIBLE” for the site
Following consultation of this site, data relating to identified or identifiable persons may be processed.
The “owner” of the processing is Philip Ernest Rowe, C.da San Salvatore 129 – 72017 Ostuni (BR).
The data processor designated pursuant to Article 29 of the Code regarding the protection of personal data, as well as point 8 of art. 4 EU REGULATION 2016/679 is Mr. Philip Ernest Rowe, domiciled in C.da San Salvatore 129 – 72017 Ostuni (BR).
DATA PROCESSING LOCATION
The treatment connected to the web services of this site take place at the aforementioned residence of the owner and are handled personally by the same or by the staff employed by the same.
If necessary, the data connected to the newsletter service can be processed by the staff of the company that takes care of the maintenance of the technological part of the site, at the headquarters of the same company which is given the right to use special service providers for the management of mailing list services.
DATA PROCESSING POLICY
Personal data means any information relating to a natural person, identified or identifiable, even indirectly, by reference to any other information, including a personal identification number.
The processing of personal data means the collection, registration, organization, storage, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, cancellation and destruction or the combination of two or more of these operations in the comparison of the aforementioned personal data.
Trullilovely, beyond the data collected automatically anonymously by simply browsing the site, does not collect any type of data without the express consent and / or without an explicit request from the user / interested party. The data collected through the site by express indication of users are in no way used for profiling and / or analysis of commercial or browsing preferences.
Trullilovely offers the user the possibility to visit the website www.trullilovely.com without any prior registration and / or request for personal data, however, the consultation of the website www.trullilovely.com and the use of the services provided through it implies acceptance by the user of the fact that Trullilovely collects some personal data. Which data is collected by Trullilovely is specified below, as well as the purpose of the collection and use of the data.
In particular, it is possible that for the purpose of using certain services offered through the site – by way of example but not limited to requests for information from users of the site, etc. etc. – Users are required to voluntarily provide personal data through special registration forms such as – by way of example but not limited to – name, surname, e-mail, telephone number, etc.
Personal information will be used to communicate if and when necessary with those who provided it, in order to answer the questions posed, or to send any material and information requested.
It is also possible that the acquisition of data by the user is essential for the purposes of the type of service requested by the same as well as communication with the same, in relation to the services requested, requires adherence to the service of newsletter. In such cases, explicit confirmation will always be requested by the owner of the data, regarding the will to provide them as well as to join the newsletter service and in any case the consent given will always be revocable.
The optional, explicit and voluntary sending of such data through the registration forms or by e-mail to the addresses indicated on this site entails the subsequent acquisition of the sender’s address, necessary to respond to requests and send the outcome of the questionnaires. , as well as any other personal data included in the message or in the request form.
Specific summary information will be progressively reported or displayed on the pages of the site set up for particular services on request.
In any case, Trullilovely, except for the cases expressly contemplated in this statement, cannot transfer any type of data collected to third parties as the collection of the aforementioned information is aimed at providing the best services offered by the site according to the user’s preferences.
TYPE OF DATA PROCESSED
The website offers informative and, sometimes, interactive content. While browsing the site, Trullilovely may, therefore, acquire information about the visitor, in the following ways:
- Navigation data
The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.
This category of data includes: IP addresses, the type of browser used, the operating system, the domain name and the addresses of websites from which access was made, information on the pages visited by users within the site, the access time, the stay on the single page, the analysis of the internal path and other parameters relating to the operating system and the user’s IT environment.
This category of data includes: IP addresses, the type of browser used, the operating system, the domain name and the addresses of websites from which access was made, information on the pages visited by users within of the site, the access time, the stay on the single page, the analysis of the internal path and other parameters relating to the operating system and the user’s IT environment.
- Additional categories of data
This is all personal data provided by the visitor through the site, for example by participating in one of the initiatives launched by Trullilovely alone or in partnership with third parties, by writing to a Trullilovely e-mail address to request information or by calling one of our number to have direct contact with customer service.
Within the categories of data grouped above, it is possible to distinguish the following types of processed data:
- data given freely by the user (private or business)
- Data collected automatically
- Data given volontarily by the user
In the case of private users, who consult the site and use the services offered by it for personal and non-professional purposes, when filling out the various forms, they will be asked to provide some data that are used to use the services provided by Trullilovely.
By way of example, you may be asked to provide:
· Email address in order to be able to receive subsequent contact;
- Name and surname;
- Telephone number.
Third party data
Where personal data of third parties (such as those of family members or friends) are provided, the user must ensure in advance that these subjects have been adequately informed and have consented to its processing in the manner described in this statement.
Data of minors under the age of 18
Children under the age of 18 are prohibited from providing any personal data and registering on the site.
Trullilovely assumes no responsibility for any false statements provided and if we realize the existence of false statements we will proceed with the immediate cancellation of any personal data acquired subject to taking action against the proponent of the illegal conduct to obtain compensation of any damage caused.
2.Data unintentionally provided by the user
The following data are collected through the services used by users:
- technical navigation data: for example IP addresses, type of browser used, operating system, domain name and addresses of websites from which access was made, information on the pages visited by users within the site, hours of access, stay on the single page, internal path analysis, other parameters relating to the operating system, the user’s IT environment and the current (approximate) position of the tool he is using;
- data collected using cookies or similar technologies;
- results of tests carried out through the site.
The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.
This is information that is not collected to be associated with identified data subjects, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified.
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 the Uniform Resource Identifier (URI) notation of the requested resources, the time of the request, the method used to submit 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 and are deleted immediately after processing. The data on web contacts could be used to ascertain responsibility in the event of hypothetical computer crimes against the site: except for this possibility, the data on web contacts are currently recorded in the databases of the site and kept without any type of additional use. than that requested by the user himself.
No use is made of cookies to transmit information of a personal nature, any use of persistent cookies is however subject to acceptance by the user and the user is given the opportunity to delete them. This is without prejudicing the possibility of Trullilovely using systems for tracking anonymous data for the sole purpose of statistical collection such as Google Analytics, Hotjar, etc. In such cases, for the sole statistical purposes mentioned above, only the behaviour put in place by those who surf the site will be taken into consideration without the origin of the aforementioned behaviour being in any way recognizable or traceable.
The use of the so-called session cookies (which are not stored permanently on the user’s computer and disappear when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to allow safe and efficient site exploration.
The so-called session cookies used on this site avoid the use of other IT techniques that are potentially prejudicial to the confidentiality of user navigation and do not allow the acquisition of the user’s personal identification data.
Any use of persistent cookies is solely aimed at improving the browsing experience on the website www.trullilovely.com in order to allow users to keep any settings and / or configurations of the site.
For any further clarification in relation to the types of cookies used by the Trullilovely site, users are invited to consult the specific cookies policy on the site.
It is possible that Trullilovely can access such data for the sole purpose of carrying out backup operations of the same, in any case guaranteeing the anonymity of those who entered them and refraining from carrying out any profiling activity through them.
OPTIONALITY OF PROVIDING DATA
Apart from what is specified for navigation data, the user is free to choose whether to provide the personal data requested by the site with the awareness that failure to provide data may entail limitations on the use of the many services offered by Trullilovely through the website www .trullilovely.com.
For the sake of completeness, it should be remembered that in some cases (not subject to the ordinary management of this site) the Privacy Authority as well as the police, judicial police and the Judicial Authority in general, may request news and information pursuant to article 157 of the Code regarding the protection of personal data, for the purpose of monitoring the processing of personal data. In these cases, the reply is mandatory under penalty of an administrative sanction.
PURPOSE OF THE TREATMENT
It is possible that the information voluntarily provided is used to:
– customize the navigation of the site and allow the sending of information on services and content for which the individual user may have asked for explanations;
– take into account reports / suggestions;
– respond, possibly directly, to requests for clarification;
– fulfill requests for material;
– provide information via e-mail, relating to future events, new services provided and in general on services always at the request of users.
The information collected through the site, and in particular the so-called navigation data better specified in the previous point, may also be used to diagnose problems relating to navigation or to the general use of the services offered, for the purpose of analyzing the behavior of use of the site, for statistical and / or demographic surveys (origin of visitors and their characteristics) in order to improve the Site and offer a more efficient service to users.
Beyond the limited circumstances set out above, Trullilovely does not intend to sell, rent, market or disclose the personal information of visitors to the site to unaffiliated third parties. The disclosure of the information collected, as well as for tax purposes may also be made to service providers who assist Trullilovely in the management and running of the site or our business (see for example mailing list management systems) only for specific permitted purposes and with the consent of the users.
Trullilovely reserves the right in any case to disclose personal information where this is necessary in obedience to laws, regulations, judgments, subpoenas or to enforce the legal rights and rules of this site or to protect its business, property and activities
Trullilovely guarantees the anonymity of the data collected both through the creation of pseudonyms – whose name is subject to the user’s free choice – and through the commitment not to disseminate and / or communicate the data collected except for the purposes specified herein.
SUBJECTS TO WHOM PERSONAL DATA MAY BE COMMUNICATED
The data collected as part of the service provision may be disclosed to:
- companies that perform functions strictly connected and instrumental to the operations – including technical ones – of Trullilovely’s services, such as suppliers that provide services aimed at reviewing and verifying the services, suppliers of customer care services, companies that provide technical components for the provision of some features of the service,
- administrative and judicial bodies and authorities by virtue of legal obligations.
For the performance of the above purposes, personal data may be transferred outside the European Union to be processed by some service providers. In this case, Trullilovely ensures that this transfer takes place in compliance with current legislation and that an adequate level of protection of personal data is guaranteed based on an adequacy decision, on standard clauses defined by the European Commission.
Apart from the above mentioned communication hypotheses, Trullilovely does not transfer or sell personal data to third parties.
DURATION AND METHOD OF TREATMENT
Personal data are processed with automated tools for the time strictly necessary to achieve the purposes for which they were collected.
The processing of personal data is carried out mainly using procedures and supports, in compliance with the principles of lawfulness, correctness, non-excess and relevance provided for by current privacy legislation.
In particular, the data associated with the user profiles created by those who register on the site will be processed until the existence of the aforementioned profiles in order to allow access to restricted areas of the site and the use of exclusive content reserved for registered users.
Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access.
In order to preserve the privacy and security of users, Trullilovely has put in place physical, electronic and managerial procedures to safeguard itself and prevent unauthorized access, maintain data security and correct use of the information collected online.
Having said this, the user, before entering their data, is however required to consider that no data transmission on the internet or in any wireless network is ever 100% secure, consequently, despite Trullilovely’s commitment to protect the personal information provided by users, it is not possible to ensure and guarantee the security of any information transmitted directly to Trullilovely or transmitted by it to other subjects authorized to receive it. This operation must therefore be considered and carried out at the user’s own risk.
POSSIBLE REDIRECT TO EXTERNAL SITES
The website can use the so-called social plug-in. Social plug-ins are special tools that allow you to incorporate the features of the social network directly into the website (eg the “like” function of Facebook).
All social plug-ins that may be present on the site are marked with the respective logo owned by the social network platform (eg Facebook, Google, Youtube, Linkedin).
LINK TO / FROM THIRD PARTY SITES
From this website it is possible to connect, through specific links, to other websites or it is possible from third party websites to connect to our website.
The Data Controller declines any responsibility for any request and / or release of personal data to third party sites and for the management of authentication credentials provided by third parties.
By giving the specific consent required, the user consents to the collection and use of their personal information, as described in this privacy protocol.
Where in compliance with the provisions of the 2016/679 EU REGULATION the Italian State provides for particular adaptation regulations in such a way as to involve significant changes to the personal data processing policy, Trullilovely will adapt to any legal dictates informing users by specific warning published prominently on the Site.
However, the user has the right to examine this privacy protocol whenever he intends to use the website so as to always be informed of any changes made to the policies established therein.
QUESTIONS RELATING TO THE PROTECTION OF PRIVACY
RIGHTS OF THE INTERESTED PARTIES
The subjects to whom the personal data refer have the right at any time to obtain confirmation of the existence or otherwise of the same data and to know its content and origin, verify its accuracy or request its integration or updating, or the rectification / cancellation (article 7 of the Code regarding the protection of personal data and article 17 of EU REGULATION 2016/679).
Pursuant to the above provisions, the data owner has the right to request:
- access: you can ask for confirmation as to whether or not data concerning you is being processed, as well as further clarifications about the information referred to in this Notice, as well as to receive the data, within the limits of reasonableness;
- rectification: you can request to rectify or supplement the data you have provided or in any case in our possession, if inaccurate;
- cancellation: you can request that your data acquired or processed by Trullilovely be deleted, if they are no longer necessary for our purposes or where there are no disputes or disputes in place, in case of revocation of consent or its opposition to processing, in case of unlawful processing, or if there is a legal obligation to cancel;
- limitation: you can request the limitation of the processing of your personal data, when one of the conditions referred to in art. 18 of the GDPR; in this case, your data will not be processed, except for storage, without your consent except as specified in the same article in paragraph 2.
- opposition: you can oppose the processing of your data at any time on the basis of our legitimate interest, unless there are legitimate reasons for proceeding with the processing that prevail over yours, for example for the exercise or our defense in judicial seat; your opposition will always prevail over our legitimate interest in processing your data for marketing purposes;
- portability: you can ask to receive your data, or to have them transmitted to another owner indicated by you, in a structured format, commonly used and readable by an automatic device.
Requests should be send via email to:
clearly specifying whether the request concerns “VERIFICATION” or “ACCESS”, “CORRECTION” or “CANCELLATION”, “LIMITATION”, the “TRANSFORMATION IN ANONYMOUS FORM”, “OPPOSITION” or the “PORTABILITY” of the data processed, and then specifying in the text of the email which data is requested.
Due to the process time of emails, you may receive emails from us even after your removal request.
Pursuant to art. 7, par. 3, GDPR, we inform you that you can exercise your right to revoke your consent at any time, without prejudice to the lawfulness of the treatment based on the consent given previously. Finally, we inform you that you have the right to lodge a complaint with the Supervisory Authority, which in Italy is the Guarantor for the Protection of Personal Data.
We also inform you that it is possible to forward your requests by post, by writing to the data controller, Philip Ernest Rowe, C.da San Salvatore 129 – 72017 Ostuni (BR).
and can be updated and revised on the basis of current regulations and additions required by the adaptation of the Italian legal system to the needs established at EU and international level.
Every effort will be made to make the processing of personal data carried out by Trullilovely as current and efficient as possible with respect to data provided voluntarily by users and automatically acquired by the site.
Users are therefore invited to regularly check the updating of the following conditions as well as the conditions relating to the newsletter service in order to verify any changes and modifications.