We at Cala Del Forte S.r.l. (hereinafter "CALA DEL FORTE" or "Controller ") take seriously care of the protection of your personal data and, for this reason, we process your personal data scrupulously, exclusively according to the applicable data protection law, in particular according to the EU Regulation 2016/679, so called “GDPR”. In the following privacy policy, which is related to the website https://caladelforte-ventimiglia.it (hereinafter the “Site”), we would like to inform you about how we process your personal data and what your rights are.

 

1. THE SUBJECTS OF THE PROCESS

1.1 The Data Controller

The “data controller” is CALA DEL FORTE, in the person of the pro-tempore legal representative, with registered office in  Via Roma, 166, 18038 Sanremo, VAT number 01238780082.

For the purpose of the following point 2, the Controller makes use of some data processors.  The updated list of data processors is kept at the registered office of the Controller.

1.2 Subjects (and countries) to which personal data may be communicated

CALA DEL FORTE transfers your personal data, you provide or collected automatically as described herein, to the recipients and / or categories of recipients as listed below:

• external IT service providers providing IT maintenance, server infrastructure or extensive IT solutions (eg cloud services) and software solutions on behalf of CALA DEL FORTE;
• external service providers for the purpose of filing invoices;
• Governmental authorities, courts, external consultants and similar third parties that are public bodies or other authorized third parties, provided that the necessary circumstances are present (eg in the event of an illicit act on your part with CALA DEL FORTE or for information obligations established by law);
• service providers for the organization of marketing and promotional activities;
• external service providers for market research purposes;
• logistics company if the processing is necessary for communications and mailings;
• external service providers to provide customer service (customer care).

In any case, CALA DEL FORTE processes your data in countries where the European Commission has established that there is an adequate level of personal data protection. Your personal data may also be transferred outside the European Union to be processed by some of our service providers. In this case, we make sure that this transfer takes place in compliance with current legislation and that an adequate level of personal data protection is guaranteed based on an adequacy decision, on standard clauses defined by the European Commission or on Binding Corporate Rules. Under no circumstances do we transfer or sell personal data to third parties.

 

2. HOW WE USE THE COLLECTED DATA

CALA DEL FORTE processes your personal data if this is necessary for the execution of the service required or for the execution of pre-contractual measures with CALA DEL FORTE adopted upon your request (Article 6 paragraph 1 b, GDPR).

We use the collected data mainly to offer you information about our services, activities and business proposals.

2.1. To guarantee you access to our services and improve their provision

In particular, we use your data to ensure the use of our services provided through the Site and their provision, including:

• registration and creation of the reserved area;
• communications related to the provision of the services;
• communications on the availability of specific products or service at your request;
• use of "favorite" and "saved search" features;
• contact with the Customer Care;
• activities of an administrative, financial or accounting nature, such as those relating to the purchase of services, if necessary, and possible recovery of credit and reimbursements.
• Customer Care: If you contact our customer service by e-mail or telephone, CALA DEL FORTE collects the information and data (including personal data) provided by you in order to process your request. Further collection and processing of your personal data, such as recording calls to improve our customer service, will only take place if you have expressly given your consent.

If you use third-party services (for example the services of the partners of CALA DEL FORTE) as part of the contractual relationship with CALA DEL FORTE, the latter transfers personal data to these third parties in order to fulfill the contractual relationship with you.

In any case, the processing of your personal data is carried out by means of the operations indicated in art. 4 n. 2) GDPR and more precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data are subjected to both paper and electronic and / or automated processing.

These processings are necessary to correctly deliver the services of CALA DEL FORTE towards users who join the Site.

We also use your data to improve and implement the service, through the following processings: market research, optional surveys and user satisfaction surveys;

These processings are based on the c.d. "Legitimate interest" of the Controller (see Article 6 GDPR); you can oppose at any time.

2.2. To offer you a "tailor-made" service (so-called Profiling)

We process the collected data, if you have expressly provided your consent, to analyze your habits or consumption choices in order to propose an increasingly personalized service and in line with your interests and to improve our commercial offer. These analyzes are not the result of automated decision-making.

2.3. Polls and market research

We may ask you, while browsing our website, to participate in targeted surveys in order to know your opinion and the degree of satisfaction with regards to the services provided by CALA DEL FORTE. These surveys can be carried out directly on CALA DEL FORTE or through the use of external platforms.

Within the polls, you may be asked, optionally, to provide an e-mail address in order to receive news and information on CALA DEL FORTE's services.

We remind you that participation in surveys is completely optional and that you can always oppose and revoke this processing.

2.4. MARKETING

The Controller with your express consent, free and unequivocal pursuant to Article 6, paragraph 1, point a) of the GDPR, may request, in addition to the above data, additional Personal Data such as, by way of example and not exhaustive, data related to tastes, preferences, habits, needs and consumption choices, for marketing purposes. This term means the will of the Controller to carry out promotional and / or marketing activities for you also on behalf of third parties. This data can be used to perform analysis and reporting activities related to promotional communication systems, such as the detection of the number of open e-mails, clicks made on links within the communication, the type of device used to read the communication and its operating system or the list of newsletter subscribers. The processing of your Personal Data for the purposes referred to in paragraph 2.5 we will require obtaining your consent that will necessarily comply with the conditions set out in Article 7 of the GDPR, thus determining the lawfulness of the processing of your Personal Data. The contact modalities aimed at marketing activities may be either automated (email, sms, mms, fax, telephone calls without operator) or traditional (telephone calls with operator, postal items). In any case, and as detailed below, you can revoke your consent, even partially, for example by consenting to traditional methods of contact.

With regard to the contact methods that provide for the use of your telephone contacts, we remind you that marketing activities by the Controller will be carried out after verification of your possible registration in the Register of Oppositions as established pursuant to and for the effects of the Presidential Decree September 7, 2010, n. 178 and subsequent modifications.

 

3. PROTECTION OF YOUR DATA

The data are collected by the subjects indicated in point 1 (The Subjects of the Processing) according to the indications of the GDPR, with particular regard to the security measures provided for by article 3 of the GDPR, for their processing by means of computerized, manual and automated tools and with logic strictly related to the purposes indicated in point 1; in any case, always in order to guarantee the security and confidentiality of your data.

 

4. TYPES OF DATA WE COLLECT

When you use our services, you accept that our company collects some of your personal data.

We treat two types of data:

• data provided by the user
• data that we collect automatically

Your data will be the subject of processings inspired by the principles of correctness, lawfulness, transparency, protection of privacy and your rights, in full compliance with current legislation on the protection of personal data.

4.1 Data provided by the User

If you are a private individual, when you register on the Site and you use the services of the Site, we ask you to provide us the following data:

a) If you are a private individual: your prename and surname; e-mail; phone number; user agent; Yacht Beam; Yacht Draft; Yacht Length; Yacht name; Affinity; 

b) If you are a Professional: your prename and surname; e-mail; phone number; user agent; Yacht Beam; Yacht Draft; Yacht Length; Yacht name; Affinity; 

c) Data of children under 16 years: If you are under the age of 16, you cannot provide us with any personal data and you cannot register on the Site, and in any case we do not assume any responsibility for any false statements that you provide. Should we notice the existence of untruthful declarations, we will proceed with the immediate cancellation of any personal data acquired.

4.2 Data collected automatically

Through the services of the Site you use, we also collect the following data:

• data collected using the c.d. cookies or similar technologies. For more information on these techniques, please read the contents below.
• technical data: such as: IP address, geolocation, ie data relative to the current (approximate) position of the instrument you are using, type of browser, information on your device.

 

5. THE CONFERRAL OF YOUR PERSONAL DATA

Mandatory: the provision of personal data is mandatory only for the processing necessary for the provision of the Services offered by CALA DEL FORTE and the Site.

In this regard, we inform you that any refusal for the purpose of providing the service makes it impossible to use the service.

Optional: The provision of data is optional for marketing, promotional and profiling purposes and any refusal to provide such consent does not have negative consequences on the provision of the service offered on the website https://caladelforte-ventimiglia.it and related, any, applications.

Failure, partial or incorrect provision of personal data could result, as a consequence, the failure or partial execution of the service.

Your personal data are processed:

Without your express consent (pursuant to Article 6 letter b), e) GDPR), for the following Service Purposes:

• sign contracts for the services offered by the Controller through the Site;
• fulfill the pre-contractual, contractual and tax obligations deriving from relations with you;
• fulfill the obligations established by national or community law or by an order of the Authority;
• exercise the rights of the Controller, for example the right to defense in court;

Only subject to your specific and distinct consent (pursuant to Article 7 GDPR), for the Marketing Purposes (see point 2.4 hereof).

We point out that if you are already our customer, we can send you commercial communications related to services and products of the Controller similar to those you have already used, except your disagreement (Article 130, paragraph 4 of the Italian Privacy Code).

 

6. DATA RETENTION

The Controller retains your personal data as long as these are necessary for the achievement of the purposes for which they were collected. Furthermore, the Controller retains personal data if this is required by regulatory obligations. In addition, the Controller retains your personal data until the expiry of the prescription terms in order to be able to enforce any existing legal claims.

• The retention of personal data will take place in paper and / or electronic / IT format and for the time strictly necessary to fulfill the purposes set out in point 2, in compliance with GDPR.
• Invoices, accounting documents and transaction data are held for 11 years in accordance with the law (including tax obligations).
• For purposes of analysis directed to the development and improvement of the services provided by Cala del Forte through the Site, the user's personal data may be subject to the 36-month retention period.
• For direct marketing and profiling purposes we keep your data for a maximum period equal to that foreseen by the applicable legislation (respectively equal to 24 and 12 months).
• In the case of exercise of the right to be forgotten through the request for explicit cancellation of personal data processed by the Controller, we remind you that such data will be kept, in a protected form and with restricted access, only for purposes of ascertainment and repression of crimes; period not exceeding 12 months from the date of the request and subsequently will be erased securely or anonymised irreversibly.

We also inform you that for these purposes, the data relating to electronic traffic, excluding the contents of communications, will be kept for a period of no more than 6 years from the date of communication, pursuant to art. 24 of the Law n. 167/2017, which implemented the EU Directive 2017/541 on anti-terrorism.

The Controller will process the 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 Service Finality relationship and no later than 2 years from the collection of data for the Marketing Purposes.

Personal data is stored on servers located at the data center operated by ovh. ( https://www.ovh.de) at Gravelines. ( NIMBLE AND MAILCHIMP) 

In any case, it is understood that the Controller, if necessary, will have the right to move the servers even outside the EU. In this case, the Controller hereby ensures that the transfer of non-EU data will take place in accordance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses provided by the European Commission.

 

7. CAN YOU HAVE INFORMATION ON YOUR DATA, CHANGE IT, DELETE IT OR HAVE A COPY? YES! THAT'S HOW

7.1. Cancellation and export of personal data

You can request the cancellation of your data or export them by sending the relevant request to the following e-mail address:  privacy@caladelforte-ventimiglia.it

The cancellation will be made within the expected technical times and in accordance with the retention period specified in the following point 5 (Storage of your data).

Your personal data will be exported within 30 days or, in case the export becomes particularly complex, within three months.

7.3. Your rights (Article 15 and subsequent GDPR)

At any time you can:

• obtain by the Controller information about the confirmation that it is or it is not undergoing processing of your data and, in this case, obtaining access to them and the existence of your personal data, the origin of the same, the purposes and methods of processing and information referred to in Article 15 of the GDPR;
• request rectification, integration, updating, deletion, limitation of data processing if one of the conditions provided for in Article 18 of the GDPR occurs, the transformation into anonymous form or blocking of personal data, processed in violation of the law, including those that do not need to be kept for the purposes for which the data were collected and / or subsequently processed;
• object, in whole or in part, for legitimate reasons, to the processing of data, even if pertinent to the purpose of the collection and processing of personal data provided for the purposes of commercial information or sending advertising material or direct sales or for the carrying out market research or commercial communication (marketing).
• withdraw the consent at any time without prejudice to the lawfulness of the processing based on the consent given prior to the revocation;
• receive personal data, provided knowingly and actively or through the use of the service, in a structured format, commonly used and readable by an automatic device and to transmit them to another data controller without hindrance;
• propose a complaint with the Italian Data Protection Authority.

 

8. CHANGES OF THIS PRIVACY POLICY

This privacy policy may be subject to change. In case of substantial changes to the use of your data by the Controller, the latter will warn you by publishing them with the maximum evidence on their pages or via alternative means equally effective.

We remind you that for any question or request related to your personal data and to the respect of your privacy you can write to the dedicated address privacy@caladelforte-ventimiglia.it

 

9. COOKIE POLICY

caladelforte-ventimiglia.it

Pursuant to Article. 13 of UE Regulation 2016/679 (“GDPR”) the following notice explains both what cookies are and the various types of cookies on the website caladelforte-ventimiglia.it (hereinafter, the“Site”).  The Site uses cookies.

 

WHAT IS A COOKIE?

Cookies are small text files designed to store information about your online browsing on the site and to improve the browsing itself.

Therefore, cookies are sent from websites visited by a user (YOU) to his device(s), where they are stored to be (re) transmitted again to the same websites during subsequent visits.

Thanks to cookies, the Site remembers the actions and preferences of the user (such as, for example, login data, the chosen language, other display settings, etc.). In this way, such information must not be indicated again on subsequent access to the Site.

Some actions could not be accomplished without using cookies, so they are technically necessary to the site operation.

To have more info about cookies click on the following link: http://www.allaboutcookies.org/
 

TYPES OF COOKIES AND THEIR DURATION

PERSISTENT COOKIES are cookies (SDK for mobile devices) that are stored permanently on your device.

FIRST-PARTY COOKIES are cookies installed by Cala del Forte S.r.l. (hereinafter "Cala del Forte").

THIRD-PARTY COOKIES are cookies installed by third parties, other than Cala del Forte.

SESSION COOKIES are cookies which are deleted at the end of the browser session or have a duration limited to a single browser session.

 

COOKIES ON THE SITE AND THEIR PURPOSES

FIRST-PARTY COOKIES

First-party cookies are those installed by Cala del Forte S.r.l. (hereinafter “Cala del Forte”).

Their purpose is:

A) Technical: the cookies are therefore used for purposes related directly to the provision of the service and to allow or improve the browsing on the Site or store the searches made by the user. These cookies are essential and necessary to ensure our platform is working properly.

B) Analytical: in order to collect statistical information on the use of the service by users (for example: number of visitors, pages visited, etc.). We use these cookies to analyze the traffic on our pages anonymously, without however storing personal data.

THIRD-PARTY COOKIES

Third-party cookies are installed by subjects other than Cala del Forte. Their purpose is:

• ANALYTICAL: aimed at collecting statistical information on the use of the service by users (for example: number of visitors, pages visited, etc.). These cookies are used to analyze the traffic on our pages anonymously, without storing personal data.

THIRD PARTIES: Google Analytics

• PERFORMATIVE: through these cookies it is possible to develop and implement the service, improving your browsing experience and therefore the use of the same.
• PROFILING:
  • Tailored Advertising: through these cookies we show you advertisements according to your preferences, habits or consumption choices.
  • Marketing: we analyze your online actions so that you can provide, through third-party partners, content and commercial offers in line with your interests, also based on your previous browser session. This information is managed separately from the identification data held by Cala del Forte.

THIRD PARTIES: i.e. Google, Adwords

Furthermore, cookies related to social networks could be introduced. They permit to the user to interact through the social networks (i.e., through the option “share” on Facebook). When a page contains such a possibility, it is established a direct link with the selected social network.

The utilization of these technologies is ruled by the privacy policies of the social network companies.

 

HOW TO GIVE YOUR CONSENT (OPT-IN) TO THE USE OF COOKIES

The consent to the use of cookies is provided by the user through the following methods:

• closing the banner containing the brief information;
• scrolling the page hosting the banner;
• clicking any of its elements.

The Consent can be revoked at any time.
(All) Technical cookies do not require consent, so they are installed automatically as a result of any access to the Site.

 

HOW TO REVOKE (OPT-OUT) CONSENT TO THE USE OF COOKIES

Cookies can be completely disabled by the browser using the appropriate function provided in most browsers.
We inform you, however, that by disabling cookies some of the features of the Site may not be usable and the same may not work properly.

For your convenience, we indicate below the links to the information of the most used browsers in order to have more information on the deactivation of cookies, so as to facilitate you even more.
Chrome, Firefox, Internet Explorer, Safari, Edge.

To disable performance cookies and third-party profiling cookies individually click on the links to the information provided by the Third parties expressly indicated in paragraph 2 of this cookie policy.

With reference to profiling cookies aimed at offering you personalized advertising, we inform you that, if you exercise the opt-out, you will continue in any case to receive generic advertising.

To opt-out and deactivate personalized advertisements by changing the settings of your mobile devices, follow the instructions to deactivate cookies above.

 

SUPPORTED BROWSER

We remind you that the Site supports browsers and / or applications identified below for the purposes of proper service delivery. For best results we recommend downloading the latest version of your browser and / or app.
We remind you that Cala del Forte cannot guarantee the correct functioning of the service and the effectiveness of the indications contained in this information for previous versions of browsers and / or apps are not supported.

 

Third parties:

Please note that this website contains embedded content from third parties which also use their own cookies. We have no control over these cookies and no knowledge about the full content of the transmitted data or its use by the relevant third parties. We therefore recommend that you find out from the relevant third-party websites which cookies are used and which control options are available to you.

Videos on our website are embedded by the video service Vimeo. You can find information about your options for controlling the cookies stored by this website by visiting: https://vimeo.com/privacy

If you make use of the option to share content from this website with friends via social media networks such as Facebook or Twitter, cookies may be stored by these third parties. In particular, your visit to our website may be associated with your user account. For more information, please go to: https://facebook.com/policy.php as well as http://twitter.com/privacy.

 

Legal information:

The content of this website has been created with care. However, no liability can be accepted for the accuracy, validity, completeness or availability of the information provided on this website. The website contains links to external, third-party websites. The operators of these third-party websites are solely responsible for the contents of these.

The contents of this website are protected by copyright. The information provided is intended for personal use only. Our permission is required for any other form of use.

 

Data protection:

As at: 30.11.2017

If you continue to use our website and if your browser is set to accept our cookies, we will assume that you consent to the use of cookies.

 

Date of last modification: 25.05.2018