The following information is provided in accordance with Articles 13 and 14 of Regulation (EU) No. 679/2016 ("GDPR"), relating to the processing of personal data of users who consult the website www.letteradibabbonatale.it, and who act with the website services. The information is related to the website www.letteradibabbonatale.it and external sites www.santagreetings.it and babbonatale.norama.it available through our links
1. Controller of Personal Data
Norama S.r.l., with registered office in Via Verdi 7, 24121 Bergamo, VAT No. 02882290162 (hereinafter, Norama or the "Data Controller"), as Data Controller, will process your Personal Data provided through the website www.letteradibabbonatale.it and external sites www.santagreetings.it and babbonatale.norama.it (hereinafter all referred to as "Site") in accordance with applicable privacy and personal data protection laws and this Policy.
2. Data Protection Officer (DPO)
The Data Controller has appointed a Data Protection Officer ("Data Protection Officer or "DPO") who can be contacted for the exercise of his rights, as well as to receive any information relating to them and/ or this Policy, by writing an email to: email@example.com
3. Data Processing rules
Navigation data: the computer and telematic systems and software procedures used to operate the Site acquire, during their normal operation, some data (e.g. the date and time of access, the pages visited, the name of the Internet Service Provider and the Internet Protocol (IP) address through which you access the Internet, the Internet address from which you have accessed our Website, etc.), whose transmission is implicit in the use of web communication protocols or is useful for the best management and optimization of the system of sending data and Email.
Contact details: first name, last name, email address, telephone number and other contact details, the content of the message sent by you and other Personal Data that you may have provided to us. We will process these Personal Data in case you need information, request the Letter of the True Santa Claus or send us different communications. The processing of these Personal Data is necessary to provide feedback to communications received or requests from you. The further provision of Personal Data must be considered absolutely optional.
The processing of your personal data will be carried out, in compliance with the provisions of the GDPR, using paper, IT and telematic tools, with logic strictly related to the purposes indicated and, in any case, in a manner that ensures its security and confidentiality in accordance with the provisions of Article 32 GDPR.
4. Purpose and legal basis of the processing
Norama will process your Personal Data for the achievement of precise purposes and only in the presence of a specific legal basis provided by the applicable law on privacy and protection of personal data. Specifically, Norama will only process your Personal Data when it uses one or more of the following legal bases:
• you have given your free, specific, informed, clear and express consent to the processing;
• processing is necessary for the execution of a contract to which you are a party or for the execution of pre-contractual measures taken at your request;
• in the presence of a legitimate interest of Norama;
• Norama is bound by a legal obligation to process Personal Data.
5. Recipients of Personal Data
Your Personal Data may be made accessible, for the purposes mentioned above, to the staff of the Data Controller, for this purpose appointed Data Processors, and to third-party companies or other entities that carry out outsourcing activities on behalf of the Owner to allow the operation of the Site, in their capacity as external data processors. In addition, the Data Controller may need to communicate his Personal Data to third parties who provide professional services of tax, legal and judicial advice and assistance and to the authorities and supervisory (police, consulates, etc.)
6. Transfer of Personal Data
Your Personal Data will be processed within the European Union and stored on servers located within the European Union. Should it become necessary to transfer the personal data of the data subject to third parties established in countries outside the EU, the Data Controller ensures the adoption of adequate safeguards with foreign companies receiving the data in accordance with the provisions of Chapter V of the GDPR.
7. Period of retention of Personal Data
The Personal Data processed for the above purposes will be stored in compliance with the principles of proportionality and necessity, and in any case until the purposes of the processing have been pursued.
8. Rights of data subjects
You have the right to access at any time the data concerns you, as per art. 15-22 GDPR. In particular, you may request the rectification, cancellation, limitation of the processing of the data in the cases provided for by art. 18 of the GDPR, the revocation of consent, to obtain the portability of data concerning you in the cases provided for by art. 20 of the GDPR, as well as lodge a complaint with the competent supervisory authority pursuant to Article 77 of the GDPR (Guarantor for the Protection of Personal Data).
You can make a request for opposition to the processing of your data pursuant to Article 21 of the GDPR in which to give evidence of the reasons justifying the opposition: the Data Controller reserves the right to assess your request, which would not be accepted if there are compelling legitimate grounds for processing that override your interests, rights and freedoms. Requests should be addressed in writing to the Data Controller or to the DPO to the contact details above.
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