PERSONAL DATA PROCESSING NOTICE
Club House Italia S.p.A., with registered office in Via Condotti 71 00187 Rome, and headquarters in via Balzella 56, Forlì, tax code: 04223370372; VAT ID 06271501006 acting as data controller (“Club House” or the “Controller”), pursuant to art.13 of the Italian Legislative Decree no.196 of 30 June 2003 (“Personal Data Protection Code”) and to art. 13-14 of the EU Regulation no.2016/679 (General Data Protection Regulation “GDPR”) wish to inform you that your personal data shall be processed according to the following terms and conditions:
1. Data subject to processing
The personal identifying data acquired through our website, may be received by us during exhibitions, events or exchange of correspondence, are collected for the conclusion of contracts, or received from third parties such as the companies of the Luxury Living Group, and may be processed by Club House in its capacity of Data Controller. The personal identifying data include for example first name, family name, company name, address, profession, phone number, e-mail, payment and bank details, profession or business (“personal data” or also “Data).
2. Purpose of data processing
Your data may be processed with or without your consent depending on the purpose:
(i) Without your express consent, for purposes necessary to: negotiate, finalise, conclude and manage agreements and contracts; comply with pre-contractual, contractual, legal and tax obligations; fulfil the obligations provided for by laws, regulations, legislation or by order of any Authority having jurisdiction over the Controller (as for example in anti-money laundering); exercise the rights of the Controller (before Courts o regulatory bodies).
(Ii) Only upon your express consent for marketing purposes such as: transmission of email, mail and/or text messages and/or phone calls, newsletter, commercial communications and/or advertising material concerning events or products offered by Club House, its subsidiaries, business partners, licensors of our brands. Please note that if you are already our clients, we may send you the commercial communications concerning services and products you already benefited in the past, unless you expressly dissent .
(iii) Only upon your express consent, your data may be used to enable Club House to carry on activities aimed at setting selections, preferences and interests of the data subject and to use such information to focus its marketing and commercial activities and customise them for the data subject, and in addition to conduct market researches and statistical surveys with aggregate data, provided in an anonymous form. The data processed for such purposes shall be collected from the data subject (also in public places or in locations accessible to the public) or from third parties or from registers, lists, records or public documents, by electronic means and supported by forms, coupons and questionnaires, organised in databases mainly computerised, associated and compared with data coming from different public or private databases. The data shall include in particular the following elements: first name and family name, email, sex, phone number, date of birth, information concerning the residence/domicile (town, postal code, country, province/region) family status, level of education, information concerning any eventual registration to the website and to its use, products purchased, participation in events.
If you wish to authorise such activities and then withdraw your consent, you may do so at any time by sending an email to Privacy@luxurylivinggroup.com, if the electronic data provided does not allow you to operate immediately
On no account shall your data be processed for purposes of profiling or automatic decision-making processes.
3. Data processing methods
Your personal data shall be processed as indicated in art.4 of the Personal Data Protection Code and in art.4 no.2 of the GDPR and namely through the collection, recording, organisation, retention, consultation, processing, modification, selection, mining, comparison, use, interconnection, blocking, disclosure, cancellation and destruction of data. Your personal data shall be processed both through paper and electronic or automated means. The data Controller shall process the personal data for the time necessary to fulfil the above-mentioned purposes and anyway for a maximum of 15 years from the termination of the contractual relations and for a maximum of 5 years from the data collection for marketing purposes. Different terms provided for by the law or resulting from specific and legitimate interests of the data controller shall remain unaffected (e.g.: disputes or possibility of investigation by a public authority).
4. Data accessibility (by third parties)
For the purposes described in art.2 hereinabove, your data may be accessed by employees and partners of the Controller, by the companies of the Luxury Living Group (the list of the Companies is available on the website www.luxurylivinggroup.com) both in Italy and abroad, by third parties such as, for example, credit institutions, professional firms, consultants, insurance companies. For the purposes described in art.2. (ii) and 2. (iii) here above, the data may be provided to contractors or consultant of the Controller such as companies specialised in market researches, advertising companies, Internet Service Providers, (communication, data processing companies, IT and services providers) performing services for the Controller. Those parties shall receive the data as external controllers of the process.
5. Data preservation
The personal data shall be kept on servers located in Italy and abroad. It is understood that the Controller, may move the servers to other countries both inside and outside the EU. In this latter case, the Controller ensures that the data transfer outside the EU shall be subject to the applicable legal provisions and or subject to the conclusion of the standard agreements provided for by the European Commission.
6. Supply of data and consequences of the refusal to reply
The supply of data for the purposes described in art. 2 (i) is necessary and mandatory. In the absence of data, we shall not be able to pursue the relations, to carry out any performance, to assume obligations or exercise rights.
The supply of data for the purposes described in art. 2 (ii) and 2 (iii) is instead discretionary. Therefore, you can decide to supply no data or to eventually deny the possibility to process data already supplied: in this case, you shall not receive any newsletter, commercial communication and advertising material concerning the Services provided by the Controller.
7. Your rights – Rights of the data subject
As a data subject you shall have the rights provided for in art.7 of the Personal Data Protection Code and art. 15 of the GDPR; briefly, you shall always have the right:
(i) to obtain confirmation of the existence or non-existence of your personal data and to have such data disclosed in an intelligible form;
(ii) to obtain an indication on : a) the origin of the personal data, b) the purposes and processing methods; c) the method applied in case of processing carried out with the support of electronic means; d) the identification details of the controller, of the managers and of the designated representative pursuant to art. 5 paragraph 2 of the Personal Data Protection Code and art.3 paragraph 1 of the GDPR; e) the parties and categories to whom the personal data might be disclosed or who may become aware of it as designated representative in the Country, as managers or delegates;
(iii) to obtain: a) the updating, amendment or, when interested, the integration of the data; b) the cancellation, the conversion into anonymous form or the blocking of data processed in breach of the law, including any data whose retention is not required in relation to the purposes for which the same have been collected or subsequently processed; c) the attestation that the operations referred to in a) and b) have been brought to the attention of those to whom the data have been disclosed, even with reference to their contents, except where such performance shall prove to be impossible or implies the use of means that would be clearly out of proportion to the right being protected.
(iv) to oppose, totally or partially: a) to the processing of your personal data for legitimate reasons although relevant to the purpose of the collection; b) to the processing of your personal data for the dispatch of advertising material or for direct sale or for the conduction of market researches or for commercial communications. As a data subject you shall also have the rights, where applicable, provided for in art.17-21 of the GDPR (Right of reply, right to be forgotten, right to restriction of processing, right to data portability, right to object), as well as the right to claim to the competition Authority.
8. Procedure for the exercise of the rights
You may exercise your rights at any time by sending an e-mail to firstname.lastname@example.org, or a registered letter return receipt requested to Club House Italia S.p.A – Via Balzella 56, 47122 Forlì (FC) Italy – Headquarters. In both cases, we kindly ask you to provide your most recent contact details in particular your email address to reach you.