Your data and our Newsletter

How does it work?

Transparency first of all!

We will use Your data only to send you our Newsletter also based on your interests and consumer habits.

On this page you will find all information about the processing of your personal data, where, when, how and why we process your data, as well as the list of your rights.

Your data will not be sold or transferred to Third Parties

Your data (data You entrust to us) will only be used by Vita S.r.l.

We will never sell or transfer your data.

In case we avail ourselves of external providers, they will only operate on our behalf and in accordance with our requirements.

How to contact us

Data Controller is Vita S.r.l., based in Via Giacomo Puccini 3 - 20121 Milano

You may contact us anytime writing to our Data Protection Officer (RPD – DPO) at dpo@halldis.com

Why this policy?

The present policy, provided in accordance with articles 13 and 14 GDP describes the modalities of the processing of personal data belonging to our Newsletter’s recipients and is provided by Vita S.r.l., with registered office in Via Giacomo Puccini 3 - 20121 Milano FC 13361100962, VAT-Number 10537050964, as Data Controller for the Processing of personal data.

In the present policy, the singular definitions also include the plural ones, and vice versa.

Data Controller

Vita S.r.l., as Data Controller for the Processing of personal data may be contacted at:

• Address: Vita S.r.l. - Via Giacomo Puccini 3 - 20121 Milano

• Telephone: +39 02 3859 2848 (Monday-Friday 9.30-13.30 and 15.00-18.00)

• E-mail: privacy.team@halldis.com

Vita S.r.l., in accordance with the current legislation, has appointed a Data Protection Officer who may be contacted any time at dpo@halldis.com

What information do we collect, for what purpose and on what legal bases?

Vita S.r.l. will process personal data collected and/or provided through the Site and/or during the pre-contractual and/or contractual phase according to the modalities and for the purposes described in this section.

Marketing Activities

• Processed data. Some of the data provided by Users upon registration to the Newsletter or upon purchasing a product through the Site, as: e-mail address, telephone number, and postal addresses.

• Purchase of the processing. Vita S.r.l. will be able to process the personal data mentioned in this paragraph to fulfil marketing activities, that may be realized in the following ways:

  • limited to the customers of Vita S.r.l., by sending e-mail messages – to the coordinates provided by them in the context of the purchase of a stay in a property through the Site or upon registration - referred to services similar to the ones bought through the Site (so-called soft-spam)

  • by sending promotional newsletters, carrying out market surveys, also aimed at evaluating the level of users satisfaction, and by sending advertising material related to products and/or services by Vita S.r.l., also by means of automated systems, such as e-mails, or through traditional modalities (e.g. paper mail or brochures ) (marketing purposes), referred to services different from the ones bought from a customer through the Site or addressed to users that are not yet customers of Vita S.r.l.. The promotional messages and communications under consideration may refer, besides products and/or services by Vita S.r.l., also to products and/or services by companies belonging to the same group as Vita S.r.l.. In this regard, Vita S.r.l. will not share data belonging to data subjects with these companies but will directly send messages and communications related to their own products. In this case the legal base of the processing is the consent of the date subjects to the execution of such activities;

• Legal bases of the processing. The legal bases on which the processing of personal data of Vita S.r.l. for direct marketing purposes is based, are respectively:

  • the legitimate interest of Vita S.r.l. in case of communications related to products similar to the ones bought from their customers on the Site (soft-spam), in accordance with what is foreseen from art. 6, par. 1, lett. f) GDPR and from art. 130, comma 4 D.lgs. 196/2003 (“Privacy Code”). The users have the possibility to object to the processing in the modalities referred to in the following paragraph and

  • the consent of data subjects in case of promotional messages sent to interested parties that are not customers of Vita S.r.l. or related products different from the ones bought from a customer of Vita S.r.l. (art. 6, par. 1, lett. a) GDPR).

Data subjects can object to the processing of their own personal data for such purposes sending an e-mail to the Company’s Data Protection Officer at dpo@halldis.com or through the specific link at the end of any-email with promotional content sent by Vita S.r.l.. The objection expressed with these modalities extends to communications sent by postal service.

• Need to provide data. Providing the data mentioned in this paragraph, as well as giving consent to the processing where required, is optional and, the possible lack will not affect neither the registration of a user on the Site, nor the completion of a purchase through the same.

• Data retention. Data processed for direct marketing purposes will be retained until the withdrawal of consent to the processing. Vita S.r.l., in case the time frame from the sending of a newsletter to the next one is more than 6 months, will ask for the renewal of consent. In case the processing changes or develops significantly, Vita S.r.l. will ask for the renewal of consent for the processing of such data. Vita S.r.l. can extend the above-mentioned retention period in case this is necessary to comply with a legal obligation retained by Vita S.r.l. or to protect a right of Vita S.r.l. in front of a competent authority.

Processing modalities

The Processing of data subjects personal data will be mainly carried out with the aid of electronic or in any case automated means, with the modalities and with the appropriate tools to grant data security and confidentiality according to GDPR. In particular, all technical, IT, organizational, logistical and procedural security measures will be taken to ensure the minimum level of data protection required by law, enabling the access only to persons in charge of processing or Data processors appointed by Vita S.r.l..

The data acquired and the processing modalities will be relevant and not excessive for the typologies of services provided. Moreover, data will be managed and protected in environments under constant control.

Who do we share data with?

Data subjects’ personal data processed within the meaning of the present policy may be disclosed:

• to all those subjects (including Public Authorities) who have access to the personal data pursuant to administrative and regulator measures;

• to banking institutions managing national and international payment circuits through which users make payment online for products purchased through the Site;

• to companies, consultants or professionals in charge for installing, maintaining, updating and, in general, managing hardware and software that Vita S.r.l. owns or use to provide their services;

• to external companies in charge for sending advertising communications on behalf of Vita S.r.l.;

• to employees and/or collaborators of Vita S.r.l.;

• to subjects managing on-line payment transactions;

• to all public and/or private subjects, natural and/or legal persons (legal, administrative and tax consultancies, Judicial Offices, Chambers of Commerce, Trades Councils, etc), in case the communication turns out to be necessary or functional to the correct fulfillment of the contractual obligations, as well as legal obligations.

Data subjects’ personal data will not be disclosed, except in anonymous and aggregated form, for statistics or research purposes.

Data transfer outside the EEA

Vita S.r.l. will not transfer data subjects’ personal data towards Countries outside the European Economic Area (“EEA”), that includes, besides the member states of European Union, Norway, Lichtenstein and Iceland.

In case it is necessary to fulfill the purposes of the processing described in this policy, Vita S.r.l. grants that all potential transfers of data outside the EEA will take place in order to grant the complete protection of rights and freedoms thereof. Where, with respect to the third Country of destination, the European Commission has not issued adequacy decisions, data transfer will be carried out adopting the guarantees provided by articles 46 and following of GDPR including standard contractual clauses approved by the European Commission, and a considered evaluation of the legislation of the third Country of destination.

Your data and how to contact us

We would like to remind you that you have the right to obtain from Vita S.r.l., where applicable, the access to personal data, their rectification and cancellation or the restriction of processing concerning you or to object to the processing (articles 15 and following of the Regulation).

Requests shall be addressed:

• by e-mail, to the subject responsible for dealing with data subjects: privacy.team@halldis.com

• or by post, in Vita S.r.l. - Via Giacomo Puccini 3, 20121 Milano (Italia)

Right to complain

Data subjects who believe that the processing of their personal data is in violation of what is provided by the Regulation, have the right to lodge a complaint with the Data Protection Authority, as foreseen by art. 77 of the same Regulation or to take the appropriate judicial seats (art. 79 of the Regulation).

Changes

Vita S.r.l. has the right to make changes to this policy at any time, providing a suitable notification to the site users and granting in any case an adequate and similar protection of personal data.

In order to view any updates, please consult this policy on a regular basis. In any case, if Vita S.r.l. should make substantial changes to the present policy (e.g. processing of personal data for different and further purposes), they will inform data subjects by e-mail.