Privacy policy

This privacy policy (hereinafter, the “Privacy Policy”) relates to the processing of your personal data while browsing the website www.raigaaglientu.it  (hereinafter, the “Site”) carried out by Caprera & Partners spa, with registered office in Milano Corso di Porta Ticinese 3, VAT number 09668720965 email info@capreraepartners.it (hereinafter, the “Data Controller”), in accordance with the applicable data protection regulations, including the EU Regulation 2016/679 (“GDPR”).  

1. Identity and contact details of the Representative

The Data Controller is Caprera & Partners spa.
Since the Data Controller is established in the territory of the EU, no representative has been appointed.  

2. Means of processing

In order to complete the connection to the Site, some of your personal data are acquired. This set of data includes, for example:

  • the IP address of the device you are using;
  • the date and time of access;
  • the type of browsing browser;
  • the operating system used.

To subscribe to the newsletter of the Data Controller, the following data will be processed:  

  • first name, surname;  
  • email.

To complete the ‘contact form’ request, the Data Controller will process personal and contact information (first name, last name, email and phone number.

In order to carry out re-marketing activities, the following data will be processed by the Data Controller:

  • firstname, lastname;
  • email address

3. Purpose of processing and legal basis for processing

Your personal data will be processed for the following purposes:

a) Personal data processed while browsing the Site: the provision of such personal data is a contractual obligation, without which the Site’s own services could not be made available properly.

b) Personal dataprocessed through the Data controller’ newsletter subscription for the purpose of sending commercial information by traditional and electronic means, such as e-mail, SMS, social networking sites, instant messaging, mobile apps, banner ads, post and telephone: the provision of such personal data is optional, and is based on your consent, without which you could not finalise your subscription to the newsletter service offered by the Data Controller.

c) Personal data processed through the contact form: the communication of such personal data is optional and is based on the legitimate interest of the Data Controller in following up your contact requests through the contact form on the Site. In its absence, the Data Controller will not be able to respond to such requests.

d) Personal dataprocessed through the third-parties’ newsletter subscription for the purpose of sending commercial information by traditional and electronic means, such as e-mail, SMS, social networking sites, instant messaging, mobile apps, banner ads, post and telephone: the provision of such personal data is optional, and is based on your consent, without which you could not finalise your subscription to the newsletter service offered by  third parties (“Third-parties marketing purpose”).

e) Personal data processed through contact form for individual or aggregated profiling activities and market research, by sharing the data with Google Analytics: the provision of such personal data is optional and is aimed at analysing habits, interests and purchasing behaviour, as well as compiling statistics in order to develop products and/or services, improve the commercial offer in a targeted manner and send proposals adapted to your preferences. The provision of such personal data is optional and is based on your consent, without which it will not be possible to carry out aggregated profiling activities and market research ("Re-Marketing Purposes").

4. Source of personal data

Only personal data provided in accordance with the Privacy Policy will be processed. The Data Controller will not process personal data from publicly accessible sources.  

5. Recipients and categories of recipients of personal data

Personal data may be communicated to:

  • companies offering information society services, including, in particular, those offering hosting services, newsletters;  
  • companies that provide commercial and marketing services on behalf of the Data Controller;
  • companies that provide the cloud software;
  • company that manages and maintains the website.
  • Third party customer insight analytics providers for remarketing purposes, such as Google Analytics.
  • parties who perform the duties and services of real estate agents on behalf of or for the Data Controller;
  • Companies directly or indirectly affiliated with the Data Controller.

Those in the above categories may act as data processors when acting on behalf of the Data Controller or may act independently as separate data controllers.  The Data of the data subject processed by the data controller will not be published or otherwise disclosed.

6. Categories of personal data

Personal data necessary for completing your connection to the Site, subscribing to the newsletter and sending your request via the contact form will be processed. Under no circumstances may special personal data as defined in Article 9 of the GDPR be processed.

7. Data Transfer

The Data Controller intends to transfer Personal Data to entities established in a country outside the European Union, in particularly in the United States [and Canada].
In accordance with Articles 44 et seq. of the GDPR, the transfer of personal Data to countries outside the European Union is subject to the existence of an adequate level of protection of your rights for the purposes of such transfer.

 Such entities could be represented, by way of example, by:

  • communications companies that carry out communications activities on behalf of the Controller;  
  • companies offering information society services;
  • companies offering hosting services;
  • the service providers of the communication company;

To obtain a copy of this data or the place where it was made available, simply send a request to the Data Controller at the addresses listed above.

8. Personal data retention period

  • Personal data processed and stored for the purposes referred to in point 3.a (contractual purposes) shall be processed and stored by the Data Controller in accordance with the provisions of the legislation in force, in any case for a period of time not exceeding 10 years from the termination of the effects of the contract in the event of its conclusion, unless otherwise required by law.
  • Personal data processed and stored for the purposes referred to in point 3.b (marketing purposes) are processed and stored by the Data Controller until consent is revoked, unless otherwise required by law.
  • The personal data processed for the purposes referred to in point 3.c (purpose of responding to requests) voluntarily provided by email or form and processed to respond to your requests will be kept for a period of time strictly necessary to achieve this purpose and, in any event, no longer than 12 (twelve) months from the date of individual collection.  
  • Personal data processed for the purposes referred to in point 3.d (Marketing purposes) of this information notice will be processed and stored until the data subject requests their cancellation and/or revocation. The Data Controller reserves the right to periodically request the renewal of the consent given;  
  • Personal data processed for the purposes referred to in point 3.e (Re-Marketing purposes) of this information notice will be processed and stored until the data subject requests their cancellation and/or revocation. The Data Controller reserves the right to periodically request the renewal of the consent given;  

9. Methods of expressing consent, optional nature of consent, and consequences of withholding consent

Consent can be expressed by signing a paper or electronic document, or even by using special flagboxes.

  • In relation to personal data processed for the purposes set out in point 3.a of this Privacy Policy (contractual purposes), the disclosure of personal data is an obligation. If you do not communicate such personal data, it will not be possible to provide the service of connecting and browsing the Site.
  • With regard to personal data processed for the purposes set out in Section 3.b of this Privacy Policy (consent), the disclosure of personal data is optional. If you do not provide such personal data, it will not be possible to provide the newsletter service.
  • With regard to personal data processed for the purposes set out in Section 3.c of this Privacy Policy (legitimate interest), the disclosure of personal data is optional. If you do not provide such personal data, it will not be possible to reply to requests via the contact form.
  • With regard to personal data processed for the purposes set out in Section 3.d of this Privacy Policy (consent), the disclosure of personal data is optional. If you do not provide such personal data, it will not be possible to provide the newsletter service.
  • In relation to personal data processed for the purposes set out in point 3.e of this Privacy Policy (consent), the provision of personal data is optional and subject to your prior consent. Failure to consent will make it impossible for us to provide you with and keep you updated on new products or services, promotions that may be of interest to you.

10. Right of opposition

As a Data Subject, you have the right to object in the following terms:

  • the right to object at any time, on grounds relating to your particular situation, to the processing of Personal Data relating to you pursuant to Article 6(1)(e) or (f) of the GDPR. The Data Controller shall refrain from further processing your Personal Data, unless the Controller demonstrates the existence of compelling legitimate grounds for processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims;
  • if personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you carried out for such purposes, including profiling insofar as it is related to direct marketing;
  • if you object to processing for direct marketing purposes, your personal data will no longer be processed for such purposes. You may object to the processing of your personal data for direct marketing purposes even in part, e.g. by objecting only to the sending of promotional communications by automated and/or digital means, or to the sending of paper communications and/or the receipt of telephone communications;
  • if your personal data are processed for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) GDPR, you have the right to object to the processing of your personal data on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out in the public interest.

11. Other Rights

The Data Controller also wishes to inform you of the existence of the following rights:

  • Right of access: you have the right to obtain confirmation from the Data Controller as to whether or not personal data relating to you is being processed and to access your personal data and specific information, in accordance with Article 15 of the GDPR;
  • Right of rectification: you have the right to obtain from the Data Controller the rectification of inaccurate personal data concerning you without undue delay. Taking into account the purposes of the processing, you have the right to obtain the integration of incomplete personal data, including by providing a supplementary declaration, in accordance with Article 16 of the GDPR;
  • Right to data deletion, including the right to withdraw consent: you have the right to obtain from the Data Controller the deletion of your personal data without undue delay or to withdraw your consent to the processing, if the grounds defined in Article 17 of the GDPR exist. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on the consent you gave before the withdrawal;
  • Right of restriction of processing: you have the right to obtain from the Data Controller the restriction of processing, when the cases defined in Article 18 of the GDPR apply;
  • Right to data portability: you have the right to receive, in a structured, commonly used and machine-readable format, your personal data provided to the Data Controller, and you have the right to transmit it to another Data Controller without hindrance from the Data Controller indicated in this Privacy Policy, as provided for in Article 20 of the GDPR;
  • Contractor’s right to object to commercial communications: as a contracting party, you have the right to object at any time, free of charge, to receiving commercial communications from the Data Controller;  
  • Right to lodge a complaint with the Data Protection Authority: you have the right to lodge a complaint with the Data Protection Authority to complain about a breach of data protection regulations, in accordance with Article 77 of the GDPR.  

12. How to exercise your rights

You may exercise the rights indicated in the Privacy Policy by addressing your requests directly to the Data Controller at the e-mail address info@capreraepartners.it, or by sending the relevant communication by registered letter with return receipt to the address Caprera & Partners spa Corso di Porta Ticinese 3 20123 Milano. You may lodge a complaint with the Personal Data Protection Authority in accordance with the procedures set out on the official website, addressing it to the contact details available at https://www.garanteprivacy.it/home/footer/contatti.  

13. Accessibilità dell’Informativa Privacy

The Privacy Policy is available within the Site or at the Data Controller’s premises. If expressly requested, the Data Controller may provide the information orally, subject to proof of your identity, with a telephone request to the following number 3358062688

14. Modifications

The Data Controller may amend the Privacy Policy, also to adapt to changes in national and/or European Union legislation, or to technological innovations. Any new versions of the Privacy Policy will be posted on the Site. We encourage you to periodically check the Privacy Policy. Any changes will be communicated to you by means of a pop-up on the Site or by other methods and/or IT tools.  
If the Data Controller substantially modifies the Privacy Policy, providing for new processing purposes and/or categories of personal data processed, it will inform you, requesting the necessary consents, by means of a pop-up on the site or different modalities and/or IT tools.

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All graphic and textual materials are purely illustrative and do not constitute a contractual obligation.