PRIVACY POLICY AND COOKIES NOTICE

DATA CONTROLLER

Following consultation of this website, data relating to identified or identifiable persons may be processed. The Data Controller is CATS Srl, with registered offices at Via Brindisi 20, 47924 Rimini, Italy. For any request concerning the processing of personal data, you may contact the Data Controller using the details provided above.
DATA PROCESSOR
Mr. Luigi Sanese has been appointed as Data Processor pursuant to Article 29 of the Italian Personal Data Protection Code, as he is responsible for maintaining the technological infrastructure of the website.
PLACE OF DATA PROCESSING
Data processing related to the web services of this website takes place at the aforementioned premises of CATS Srl and is carried out exclusively by authorized company personnel. If necessary, data related to the newsletter service may also be processed by the personnel responsible for maintaining the technological infrastructure of the website.

TYPES OF DATA PROCESSED

During browsing or when using the services offered by the website, the following categories of data may be collected:

• BROWSING DATA (IP address, browser used, date and time of access, pages visited): the computer systems and software procedures used to operate this website acquire, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected in order to be associated with identified individuals; however, by its very nature, it may, through processing and association with data held by third parties, allow users to be identified. This category includes IP addresses or domain names of the computers used by users connecting to the website, URI (Uniform Resource Identifier) addresses of requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical status code indicating the outcome of the server's response (successful, error, etc.), and other parameters relating to the user's operating system and IT environment.

These data are not processed directly by CATS Srl, which uses annual web hosting services provided by Aruba S.p.A., Weebly, and SiteGround. Statistical data relating to website traffic on CATS Srl websites are processed anonymously through the Google Analytics platform, accessible only through protected and restricted access.

• DATA VOLUNTARILY PROVIDED BY THE USER through contact forms, information requests, bookings, or newsletter subscriptions: the optional, explicit, and voluntary sending of emails to the addresses indicated on this website results in the subsequent acquisition of the sender's email address, which is necessary to respond to requests, as well as any other personal data included in the communication.

Specific summary notices may be progressively displayed on pages dedicated to particular services upon request.

• DATA COLLECTED THROUGH COOKIES AND SIMILAR TECHNOLOGIES: no personal user data is acquired by the website through cookies.

No cookies are used for the transmission of personal information, nor are any persistent cookies or user-tracking systems employed.
The use of session cookies (which are not permanently stored on the user's computer and disappear when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to enable secure and efficient browsing of the website.
The session cookies used on this website avoid the use of other IT techniques that could potentially compromise users' browsing privacy and do not allow the acquisition of personally identifiable user data.
PURPOSES AND LEGAL BASIS OF PROCESSING
Personal data are processed for the following purposes:

• Responding to information requests and contact enquiries.
  Legal basis: performance of pre-contractual measures requested by the data subject (Art. 6(1)(b) GDPR).
• Managing bookings, events, and requested services.
  Legal basis: performance of a contract or pre-contractual measures (Art. 6(1)(b) GDPR).
• Sending newsletters and promotional communications.
  Legal basis: consent of the data subject (Art. 6(1)(a) GDPR).
• Compliance with legal obligations.
  Legal basis: compliance with a legal obligation (Art. 6(1)(c) GDPR).
• Statistical analysis and website improvement.
  Legal basis: user consent where required under cookie regulations, or the legitimate interest of the Data Controller regarding aggregated and anonymized data (Art. 6(1)(f) GDPR).

METHODS OF PROCESSING

Data are processed using electronic and organizational tools appropriate to ensure their security, confidentiality, and integrity, in compliance with GDPR requirements.
Data Retention
Personal data are retained only for as long as necessary to achieve the purposes for which they were collected and, in particular:

• contact requests: up to 12 months;
• bookings and services: for the period necessary to provide the requested service and comply with legal obligations;
• newsletter subscriptions: until consent is withdrawn;
• browsing data: according to the retention periods established by technical service providers and website settings.

Discolure of data
Personal data may be disclosed to parties providing services necessary for the operation of the website and the activities of the Data Controller, including:

• hosting providers;
• email and newsletter service providers;
• analytics service providers;
• consultants and professional advisors.

Where required, such parties act as Data Processors pursuant to Article 28 GDPR.
Data transfer
Some service providers may process data outside the European Economic Area (EEA). In such cases, transfers will be carried out in accordance with Articles 44 and following of the GDPR and subject to appropriate safeguards.
Data subject rights
Data subjects may exercise at any time the rights provided for under Articles 15–22 GDPR, including:

• right of access;
• right to rectification;
• right to erasure;
• right to restriction of processing;
• right to object to processing;
• right to data portability;
• right to withdraw consent.

How can you control the personal data you have shared with Carnaby Club? We want you to remain in control of how your personal data is processed.
You can do this in the following ways:

• You may request a summary of the personal data we hold about you;
• You may inform us of any changes to your personal data, or ask us to correct any personal data we hold about you. We are also working on a platform that will allow you to access your data easily and make changes or request deletion;
• You may request that we delete, block, or restrict the processing of your personal data, or object to specific processing activities involving your personal data.

Whenever we process your personal data based on your consent, you have the right to withdraw that consent at any time in accordance with applicable law.
We rely on you to ensure that your personal data are complete, accurate, and up to date. Please inform us immediately of any changes or inaccuracies regarding your personal data.
Requests should be addressed:

• by email to: [email protected]
• by post to: CATS Srl, Via Brindisi 20, 47924 Rivazzurra di Rimini, Italy

COMPLAINT TO THE SUPERVISORY AUTHORITY
Data subjects have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali): www.garanteprivacy.it

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