Sintur s.a.s is the company appointed by the Municipality of Serramanna for the activation of the DMS platform and its integration into the website within the framework of the ‘VISIT SERRAMANNA’ Project.
RDP SARDINIA 2014-2022. TYPE OF INTERVENTION 19.2.1.7.5.1.1.10 Execution of the hiking and excursion itineraries of Serramanna

 

Sintur sas, with registered office in Capoterra (CA) and operational headquarters in Cagliari (CA), via Piovella 31, Tax Code and VAT number 02750140929 (hereinafter, the ‘Data Controller’), in its capacity as Data Controller, hereby informs you pursuant to Art. 13 of Legislative Decree no. 196 of June 30, 2003 (hereinafter, the ‘Privacy Code’) and Art. 13 of EU Regulation no. 2016/679 (hereinafter, the ‘GDPR’) that your data will be processed in the following manner and for the following purposes:

The Data Controller processes personal and identifying data (such as name, surname, company name, address, telephone number, email address, banking and payment details) — hereinafter, ‘personal data’ or simply ‘data’ — communicated by you upon the conclusion of contracts for services offered by the Data Controller on its own behalf and on behalf of third-party companies. In accordance with the aforementioned legislation, such processing will be based on the principles of correctness, lawfulness, transparency, and the protection of your privacy and your rights.

2. Purpose of processing
Your personal data is necessary for purposes strictly connected and instrumental to the management of business relations, for administrative and accounting purposes, and for purposes related to legal obligations.
In particular, we inform you that your personal data is processed:
Without your express consent and if directly provided by you (Art. 24, letters a), b), c) of the Italian Privacy Code and Art. 6, letters b), e) of the GDPR), for the following Service Purposes:
• to conclude contracts for the services of the Data Controller or of companies for which the Data Controller is an authorized intermediary;
• to fulfill pre-contractual, contractual, and tax obligations arising from existing relations with you;
• to comply with obligations provided for by law, regulations, EU legislation, or by an order of the Authority (such as, for example, anti-money laundering regulations);
• to exercise the rights of the Data Controller, for example, the right of defense in court.

B) Only subject to your specific and distinct consent (Art. 23 and 130 of the Italian Privacy Code and Art. 7 of the GDPR), for the following Marketing Purposes:
• to send you via e-mail, mail, and/or SMS, and/or telephone contacts, newsletters, commercial communications, and/or advertising material on products or services offered by the Data Controller, and to conduct satisfaction surveys on the quality of services;
• to send you via e-mail, mail, and/or SMS, and/or telephone contacts, commercial and/or promotional communications of third parties (for example, business partners).

Please note that if you are already our customer, we may send you commercial communications relating to services and products of the Data Controller similar to those you have already used, unless you object (Art. 130, paragraph 4 of the Italian Privacy Code).

In any case, if the data is provided via the web, we will request your consent through a checkbox/click, which will confirm both that you have read this privacy policy and your agreement to the processing.

3. Methods of processing
The processing of your personal data is carried out by means of the operations indicated in Art. 4 of the Italian Privacy Code and Art. 4, no. 2) of the GDPR, namely: collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of data. Your personal data is subject to both paper-based and electronic and/or automated processing.

The Data Controller will process personal data for the time necessary to fulfill the aforementioned purposes, and in any case for no longer than 10 years from the termination of the relationship for Service Purposes, and for no longer than 2 years from data collection for Marketing Purposes. [1, 2, 3]

4. Access to data
Your data may be made accessible for the purposes referred to in Art. 2.A) and 2.B):
• to employees and collaborators of the Data Controller in Italy and abroad, in their capacity as persons authorized to process data and/or internal data processors and/or system administrators;
• to third-party companies or other entities (by way of example, credit institutions, professional firms, consultants, mailing companies, etc.) that carry out outsourcing activities on behalf of the Data Controller, in their capacity as external data processors. [1, 2, 3, 4, 5]

5. Disclosure of data
Without the need for express consent (pursuant to Art. 24, letters a), b), d) of the Italian Privacy Code and Art. 6, letters b) and c) of the GDPR), the Data Controller may disclose your data for the purposes referred to in Art. 2.A) to judicial Authorities, as well as to those entities to whom disclosure is mandatory by law for the fulfillment of the said purposes. Said entities will process the data in their capacity as independent data controllers.
Your data will not be disseminated.

6. Data transfer
Personal data is stored on servers located within the European Union. In any case, it is understood that the Data Controller, should it become necessary, shall have the right to move the servers even outside the EU. In such case, the Data Controller ensures from now on that the transfer of data outside the EU will take place in accordance with the applicable legal provisions, subject to the signing of the standard contractual clauses provided by the European Commission. [1, 2]

7. Nature of data provision and consequences of refusal to respond
The provision of data for the purposes referred to in Art. 2.A) is mandatory. In their absence, we cannot guarantee you the Services referred to in Art. 2.A).

The provision of data for the purposes referred to in Art. 2.B) is instead optional. You can therefore decide not to provide any data or subsequently deny the possibility of processing data already provided: in this case, you will not be able to receive newsletters, commercial communications, and advertising material relating to the Services offered by the Data Controller. You will, however, continue to be entitled to the Services referred to in Art. 2.A).

8. Rights of the data subject
In your capacity as a data subject, you have the rights referred to in Art. 7 of the Italian Privacy Code and Art. 15 of the GDPR, and precisely the rights to:
obtain confirmation as to whether or not personal data concerning you exists, even if not yet recorded, and its communication in an intelligible form;
obtain indication of: a) the origin of the personal data; b) the purposes and methods of the processing; c) the logic applied in the case of processing carried out with the aid of electronic instruments; d) the identification details of the data controller, data processors, and the representative designated pursuant to Art. 5, paragraph 2 of the Italian Privacy Code and Art. 3, paragraph 1 of the GDPR; e) the entities or categories of entities to whom the personal data may be communicated or who may become aware of it in their capacity as designated representative in the territory of the State, data processors, or persons authorized to process data;

3. obtain: a) the updating, rectification or, when interested therein, integration of data; b) the erasure, anonymization, or blocking of data processed in violation of the law, including data whose retention is unnecessary for the purposes for which the data was collected or subsequently processed; c) certification that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data has been communicated or disseminated, except in the case where such fulfillment proves impossible or involves a use of means manifestly disproportionate to the protected right;
4. object, in whole or in part: a) on legitimate grounds, to the processing of personal data concerning you, even if pertinent to the purpose of collection; b) to the processing of personal data concerning you for the purpose of sending advertising materials or direct selling, or for carrying out market research or commercial communication, through the use of automated calling systems without the intervention of an operator, by e-mail and/or through traditional marketing methods by telephone and/or paper mail. Please note that the data subject’s right to object, as set out in point b) above, for direct marketing purposes through automated methods extends to traditional ones, and that the data subject nevertheless retains the possibility to exercise the right to object even only in part. Therefore, the data subject may decide to receive only communications through traditional methods, or only automated communications, or neither of the two types of communication.
Where applicable, you also have the rights referred to in Articles 16-21 of the GDPR (Right to rectification, right to be forgotten, right to restriction of processing, right to data portability, right to object), as well as the right to lodge a complaint with the Supervisory Authority.

9. Procedures for exercising rights
You may exercise your rights at any time by sending:
• a registered letter with acknowledgment of receipt (AR) to Sintur sas, via Piovella 31, Cagliari;
• an e-mail to the address info@sintur.com.

10. Data Controller, Data Processor, and Persons Authorized to Process Data
The Data Controller and internal Data Processor is Sintur sas, with operational headquarters at Via Piovella no. 31 in Cagliari, in the person of its legal representative pro tempore.
The updated list of external data processors, where appointed, and of persons authorized to process data is kept at the headquarters of the Data Controller. [1]