Privacy policy my Bibione

PRIVACY POLICY IN ACCORDANCE WITH REGULATION (EU) 2016/679, hereinafter also referred to as GDPR

1. GENERAL INFORMATION

The undersigned company (A.B.A. Servizi Coop. – ABA Viaggi e Vacanze, hereinafter referred to briefly as the “Company”) hereby informs you that, for the purposes indicated below, it will process your personal data, which you have provided in your registration form or that has been subsequently added to the form. Only the data that is necessary for the attainment of the purposes set out in this privacy policy will be requested from you and processed.

2. PURPOSES AND LEGAL BASIS

the Company may process your data:

a) in order, subject to your consent, to register you to my bibione and use the dedicated functions. The legal basis for processing your data is your consent (which you may withdraw at any time by contacting the Company);

b) in order to carry out marketing communications (commercial and advertising) that inform you about the offers (including dedicated discounts) of the structures present on the portal also connected to initiatives taking place in the territory, to the e-mail address indicated by you in the form (please remember that e-mails can also be sent electronically with the aid of automated tools). The processing has consent as its legal basis;

c) in order to create, based on the information relating to the user in possession of the Company (including purchasing habits), your profile (profiling) that includes a study of your consumption habits and choices, to send you, if you consent to the processing for the purposes indicated in point 2 B, marketing communications (as indicated in point 2 B) by the Company, in accordance with the specific needs emerging from the profiling and also aimed at analysing users’ choices and consumption habits to improve business development. The processing for this purpose will also take place in automated databases.

A profile of both the individual user and homogeneous classes of users can be created. The legal basis on which the processing is based is consent (always freely revocable by contacting the Company). Profiling through cookies is excluded from this point and can only be carried out on the basis of specific consent given by continuing to browse the website as per the privacy policy and information banner;

d) in order to fulfil a legal obligation, regulation or EU rule. The legal basis for processing your data is the fulfilment of law obligations;

e) in order to assert or defend a right of the Company (i.e. for legitimate interests, consisting precisely in defending or exercising a right). The legal basis on which the processing is based is the pursuit of legitimate interests of the Company. In considering these legitimate interests, it was analysed that they do not compromise or interfere with the interests or fundamental rights and freedoms of the interested party (the legitimate interest was assessed on the basis of a Triple Test available by contacting the Company).

f) in order to, in the event that you are entitled to benefit from a discount voucher, recognize you in order to allow you to use the voucher itself. The legal basis on which the processing is based is the pursuit of legitimate interests of the Company which consist in allowing the voucher to be used only by those who are entitled to it. In considering these legitimate interests, it was analysed that they do not compromise or interfere with the interests or fundamental rights and freedoms of the interested party (the legitimate interest was assessed on the basis of a Triple Test available by contacting the Company).

3 WHETER OR NOT DATA PROVISION IS COMPULSORY

The provision of your data (name, surname, e-mail) for the purposes under point 2, item a) of the privacy policy is optional but failure to provide it will make it impossible to register on my Bibione and use the dedicated functions. Consent for the purposes referred to in point 2, item a) of this privacy policy is always optional and revocable at any time by contacting the Data Controller, but failure to consent will make it impossible to register.
The provision of name, surname and e-mail for the purposes under point 2, item b) of the privacy policy and the related consent are optional and thus the failure to provide and consent will have no consequence other than that of not being subject to the activities indicated in this point (i.e. it will not affect the other purposes). Furthermore, if you consent to the processing for the purposes referred to in point 2, item b) of this privacy policy, please remember that you can always freely and without any reason revoke the consent given (and therefore oppose the sending of the communications in question) by contacting the Company at the addresses indicated in point 6. Other methods of revocation-opposition may be also communicated through other notices. For the purposes indicated in point 2 item c) consent (always revocable by contacting the Company at the addresses indicated in point 6) and provision of data are optional and the user therefore remains free to register and possibly be subject to the activities listed in point 2 item b) of this privacy policy, even without providing the data and without consenting to the processing of the data for the purposes listed in that point of the privacy policy (point 2 item c) of this privacy policy). The only effect of not supplying data and not agreeing to its processing will be that you may not use the services provided for in that point. If you give consent but do not provide some data, any missing data will not be processed for profiling purposes.

For the purposes referred to in point 2 items d) and e) the provision of personal data and contact details as well as further data that may be requested in the future for this purpose is necessary and failure to provide them will exclude you from all activities.

The provision of your data (name, surname, mail) for the purposes under point 2, item f) is optional but failure to supply data will prevent you from using the discount voucher.

4 CATEGORIES OF DATA RECIPIENTS

The data collected and processed for the purposes referred to in the previous point 2 letter. a), b), c) of the privacy policy, will not be communicated to third parties by the Company. For the purposes indicated in point 2 item d) of this privacy policy, the data may be communicated by the Company to public bodies. Your data may be disclosed for the purposes under point 2 item e) of this privacy policy to lawyers, legal advisors, public bodies, courts, the police and post offices (as the latter can see the address of our written communications). The Company will only disclose data that is essential to the achievement of the purposes set out in this privacy policy.

In addition, the Company may delegate the processing of your data to subjects specifically designated in data treatment on the Company’s behalf (website operators, even if external to the Company; marketing personnel, even if external to the Company; consultants, even if external to the Company – e.g. legal consultants, IT technicians, information systems workers, even if external to the Company, PR staff, even if external to the Company; trainees) and data processing managers always appointed by the Company (such as IT outsourcing companies, marketing consultancy companies). You can obtain a list of all involved subjects by contacting the Company at the below-stated contacts.

5 DATA RETENTION

The Company may retain and process your data for as long as necessary to achieve the purposes contained in this privacy policy. Data retention period will be as follows:

• for the purposes under point 2 item a), until you withdraw your consent or request the cancellation of your account, without prejudice to conservation for evidentiary purposes for the period provided for by Italian civil law;
• for the purposes under point 2 item b), until you withdraw your consent or request to no longer be subject to the activities indicated in such points (which you can do at any time by contacting the Company)

By 31st December of the second year following that of registration, you will in any case be sent a communication to ask if there is still your interest in being subject to the activities under point 2 item b) and therefore in the retention of data from on our part for the purposes indicated in this point and in the case of renewal of your will, the data will be deleted without prejudice to conservation for evidentiary purposes for the period provided for by Italian civil law. However, if there is still your interest in being subject to the activities under point 2 item b) and therefore in the retention of data by us for the purposes indicated in that point, by 31st December of the second year following the communication of above, you will be sent a further communication of the same nature and so on for as long as your interest remains.

• for the purposes under point 2, item c), until you withdraw your consent or request the cancellation of your account or for a maximum of 12 months from their registration, without prejudice to the actual transformation into anonymous form which does not allow, even indirectly or by connecting other databases, to identify interested parties;
• for the purposes under point 2, item f), until your voucher has been used. In any case, all data may be retained for as long as necessary to assert or defend a right of the Company, based on Italian civil and criminal regulations and therefore for a maximum of 10 years from the termination of the relationship, except for litigations or disputes that require a further retention period and without prejudice to further retention if required by the local regulations applicable to the interested parties.

6 DATA CONTROLLER AND DATA PROTECTION OFFICER

The Data Controller is A.B.A Servizi Soc. Coop. – Aba Viaggi e Vacanze, with registered office at Corso del Sole 6/1, Bibione (Venice); there is also a Data Protection Officer, whom you may contact via e-mail at rpd@bibionehotels.it or at the Data Controller’s postal address.

7 YOUR RIGHTS

We inform you that the GDPR provides that you can ask us (by contacting the Company at the contact details under point 6) for permission to access and change your personal data, cancel it, or limit the processing that concerns you, the portability of the data; you may also have the possibility, by contacting the Company, to oppose the processing of data and to exercise the other rights contained in chapter 3 section 1 of the GDPR, including that of withdrawing consent, where provided: the revocation of consent will not affect the legitimacy of data processing that was based on your preceding consent.

8 COMPLAINTS

Where you believe that the data processing is in violation of the provisions of the GDPR, you have the right to file a complaint with the Italian Data Protection Authority (whose contacts can be found on the website www.garanteprivacy.it), as provided for by the art. 77 of the GDPR, or to take action in the appropriate judicial offices (art. 79 of the GDPR). Furthermore, you can also contact the supervisory Authority of the state in which you habitually reside or work. The list of the Supervisory Authority can be found at the link www.garanteprivacy.it/home/footer/link.

9 LOGIC USED FOR PROFILING

The profiling referred to under point 2 item c) takes place by the Company through the analysis, even in an automated manner, of your data and your characteristics (for example age, geographical area, sex, participation in an event, participation in particular initiatives, reservations, period of stay, purchase of services, filling out questionnaires, actions carried out while browsing our websites if you have accepted profiling cookies on our websites). We therefore create a consumption profile also included in specific groups (clusters). Profiling has the purposes indicated under point 2 item c); however, said processing does not constitute a particular risk for you considering the type of basic profiling which does not require data of a particularly delicate nature or which allows the detailed reconstruction of particularly confidential aspects of private life. However, you will always have the right to obtain human intervention, to express your opinion, to obtain an explanation of the decision reached and to contest the decision.

10 METHODS OF DATA PROCESSING

The Company may process your data in paper, manual, computer and electronic forms (i.e. data is stored and processed by means of both paper and computer). The Company will retain and process your data taking all necessary protection measures, in accordance with all applicable laws (i.e. in compliance with the principles of correctness, lawfulness, transparency and protection of your privacy and rights) and with logic strictly related to the purposes indicated in this privacy policy. Only the operations needed for the achievement of the purposes included in this privacy policy will be carried out using your data. As far as the Company is concerned, your data will be retained at the Company’s offices or by the data processors appointed by the Company (this includes any third parties mentioned in this privacy policy, to which your data may be disclosed and who will process it as independent data controllers). The data will also be organized in databases – including computer databases.

Information updated as of 05/30/2023. This update is carried out within a policy of constant review of the information. Versions of the previous information can be found by contacting the Company.