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Information on the handling of personal data according to article 13 of the personal data privacy code (Legislative Decree 196/03)

Dear User,
according to article 13 of the personal data privacy Code (Legislative Decree196/03), please find below the information regarding the handling of your personal data that will be performed by Belvedere Village SpA in order to provide the services requested..

1) The personal data that you provided in requesting the services of Belvedere Village or collected subsequently during use of such services, shall be handled for communication and contact purposes by Belvedere Village SpA with service subscribers.

The data provided by users will be processed by Belvedere Village SpA with the aid of computerised, ITC and paper means.

The data contained in the database will not be disclosed or disseminated to third parties, however it may be used by Trustees of the offices of Belvedere Village SpA (including credit recovery, legal and consumer care staff) appointed to pursue such purposes.

In compliance with applicable regulations, according to Legislative Decree 196/03 and subsequent amendments, the data relating to ITC traffic (data relating to the position of and connection to the Internet - otherwise known as log files) shall be stored for six (6) months for invoicing or payment demand (for charged services) purposes, as envisaged by article 123 of the above Legislative Decree 196/03 and subsequent amendments thereof. The period starts from the invoice deadline date. 

Conferral of your data is compulsory for the pursuit of the above purposes; partial, lacking or inexact conferral of data may make it impossible for us to provide the requested services. 

2) Subject to your consent, and until such time as consent is withdrawn, your personal data may be handled either directly or through third parties, including using one or more remote telecommunications techniques (e.g. e-mail, telephone, automatic operator-free calling systems and fax) in addition to the purposes set forth in point 1) also for purposes not strictly connected to the provision of the services requested, i.e. for:  

a) employment by associated hospitality facilities
b) transmission of advertising, information and sales notices by text message, e-mail and/or telephone;
c) direct and indirect sales and placement activities through the different retail channels; 
d) interactive sales information;
e) measurement of customer satisfaction of the quality of services provided (including through third parties);
f) promotional initiatives on products and/or services of third party companies;
g) surveys and market research.
Consent to the handling and purposes set forth in point 2 is not compulsory. Should you refuse Belvedere Village SpA shall only handle the data for those purposes indicated in point 1) above. 

The treatment specified in points 1) and 2) above may be performed using printed and/or ITC media and in any case using methods and procedures such as to guarantee conformity to applicable regulations.

Within Belvedere Village SpA, your personal data shall be handled by customer Care, Sales, Marketing, Invoicing and Technology staff. Such staff, who operate under the direct authority of the respective Data Manager, have been appointed as Data Trustees and have received adequate operative instructions as regards the subject.

In addition to Belvedere Village SpA staff, some handling of your personal data may be also performed by third parties, with offices in Italy and/or abroad, to which Belvedere Village SpA may appoint certain functional activities (or parts thereof) to provide the above services. In such cases, the subjects will operate as autonomous Data Controllers or may be designated as Data Managers or Trustees. The designated Managers and Trustees shall receive adequate operative instructions, with specific reference to the minimum safety measures, in order to be able to guarantee the confidentiality and safety of data. The abovementioned third parties essentially belong to the following categories: Credit recovery firms, invoicing data processing companies, companies appointed to print and send invoices to customers, Consultancy firms, Credit transfer companies, companies performing telemarketing and call centre activities, Agents and Business Solicitors. 

The Data Controller is: 
Belvedere Village SpA
In relation to the treatment of your personal data, you may, directly and at any time, exercise your rights pursuant to art.  7 of the Code, which for your convenience is given in full below, by writing to:

Belvedere Village SpA 
Via XXV Aprile, 52 - Fr.Cavalcaselle | 37014 Castelnuovo d/G. (VR) Italy
“Article 7. Right of access to personal data and other rights. 

1. The Data Subject is entitled to obtain confirmation as to whether or not data relating to him/her is held, even if it has not yet been recorded, and notification of the same in an intelligible form.

2.The data subject is entitled to obtain the following information:
a) the origin of the personal data;
b) handling purposes and methods;
c) the logic applied in the case of treatment performed using electronic tools;  
d) the details of the Data Controller, Managers and designated representative within Italy, when necessary;  
e) the subjects and categories of subject that personal data may be disclosed to or that may become privy to them in their capacity as designated representative in Italy, Data Managers and/or Data Trustees.  

3. The data subject is entitled to obtain:
a) the updating, correction, or, when it is in his/her interest, the integration of data; 
b) the deletion, transformation into an anonymous form or freezing of data handled in breach of the law, including that not required in relation to the purposes for which the data was collected and subsequently treated; 
c) confirmation that the operations described in letters a) and b) above have been brought to the knowledge, including as regards their content, of those to whom the data has been disclosed or disseminated, unless such fulfilment proves to be impossible or entails evidently disproportionate means to the right protected.  

4. The data subject is entitled to object:
a) for legitimate reasons, to the handling of all or part of the Data Subject?s personal data, when pertinent to the purpose of collection. 
b) to the handling of his/her personal data for the transmission of advertising or direct sales material or for the conduction of market research or sales information.?   
The above rights may be exercised either directly or by conferring, in writing, a proxy or power of attorney to persons or organisations.”
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