Data Controller

Villa Leolò
Localita’ San Giuseppe 67, 12067 Monforte D'Alba - Cuneo (Italy)

Owner contact email: info@villaleolo.com

Types of Data Collected

Among the Personal Data collected by this Website, either independently or through third parties, there are: Usage data; Cookie; first name; surname; e-mail; telephone number.

Full details of each data type collected are provided in the dedicated sections of this privacy policy or by means of specific information texts displayed before the data is collected.
Personal data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Website.
Unless otherwise specified, all the Data requested by this Website are mandatory. If the User refuses to communicate them, it may be impossible for this Website to provide the Service. In cases where this Website indicates certain Data as optional, Users are free to refrain from sending such Data, without this having any consequence for Service availability or its operation.
Users who have any doubts about what Data is compulsory are encouraged to contact the Data Controller.
The possible use of Cookies - or other tracking tools - by this Website or by the owners of third-party services used by this Website, unless otherwise specified, is to provide the Service requested by the User, in addition to any additional purposes described in this document and in the Cookie Policy, where available.

The User assumes the responsibilities for Personal Data of third parties obtained, published or shared through this Website and warrants that the he has the right to disclose or disseminate, freeing the Controller from any liability to third parties.

Method and location of processing for collected Data

Processing Methods

The Data Controller shall take appropriate security measures to prevent the unauthorised access, disclosure, modification or destruction of Personal Data.
Processing is carried out using electronic and/or telecommunication tools in line with organizational procedures and on the basis of principles strictly related and limited to the stated purposes. In addition to the Data Controller, other parties involved in the organization of this Website may also have access to the Data (administrative, commercial, marketing, legal, system administrator personnel) or external parties (such as third-party technical service providers, couriers, hosting providers, IT companies, communication agencies) and where necessary, a Data Manager appointed by the Data Controller. The updated list of Data Protection Officers can be requested from the Data Controller.

LEGAL BASIS FOR DATA PROCESSING

More specifically, the Data Controller processes Personal Data relating to the User if one of the following conditions is satisfied:

• the User has given consent for one or more specific purposes; Note: in some jurisdictions the Owner may be authorized to process Personal Data without the User's consent or another of the legal bases specified below, as long as the User does not object ("opt-out") to this treatment. However, this is not applicable if the processing of Personal Data is regulated by European legislation regarding the protection of Personal Data;
• the processing is necessary for the execution of a contract with the User and / or the execution of pre-contractual measures;
• processing is necessary for compliance with a legal obligation to which the controller is subject;
• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;
• processing is necessary for the pursuit of the legitimate interest of the Controller or of third parties.

However, the Data Controller may be asked to clarify the specific lawful basis for any processing and to specify in particular whether the processing is for legal purposes, in execution of a contract or necessary for its conclusion.

Location

Personal Data is processed at the Data Controller's operational headquarters and in any other location where those involved in the processing are located. For further information, please contact the Data Controller.
Personal Data may be transferred to a country other than that in which Users are located. More information on the place of the User's Data processing is available in the section regarding the details of the Personal Data processing.

The User has the right to obtain information on the legal basis for the transfer of Data outside the European Union or to an international organisation governed by public international law or consisting of two or more countries, such as the UN, and on the security measures taken by the Data Controller to protect the Data.

The User can check if one of the transfers described above takes place by examining the section of this document concerning the details on the Personal Data processing or request information from the Data Controller by contacting him/her at the addresses indicated herein.

Storage Period

Data is processed and stored for the time required for the purposes for which it was collected.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Data Controller and the data subject will be retained until the performance of such contract is completed;
• Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is met. The User can obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Data Controller.

Where the Personal Data processing is based on the User's consent, the Data Controller may retain the Data for longer, until such consent is revoked. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the storage period your Personal Data will be deleted. Therefore, upon expiry of this term, the right of access, cancellation, rectification and the right to portability of the Data may no longer be exercised.

Purposes of Data Processing

The User Data is collected to allow the Owner to provide the Service, comply with legal obligations, respond to requests or executive actions, protect their rights and interests (or those of Users or third parties), identify any malicious activities. or fraudulent, as well as for the following purposes: Displaying content from external platforms, Statistics, Platform and hosting services, Registration and authentication and Contacting the User.

To obtain detailed information on the purposes of the processing and on the Personal Data processed for each purpose, the User can refer to the section "Details on the processing of Personal Data".

Details on Personal Data processing

Personal Data is collected for the following purposes and using the following services:

• CONTACT THE USER

  Contact form (this Website)

  The User, by filling in the contact form with his/her Data, consents to their use in order to respond to requests for information, quotes, or any other category indicated in the header of the form.

  Personal Data processed: surname; e-mail; first name.

  Category of personal data collected under the CCPA: identifiers.

  CONTACT BY PHONE (THIS WEBSITE)

  Users who have provided their phone number may be contacted for commercial or promotional connected to this Website, as well as to satisfy requests for support.

  Personal data: phone number

  Category of personal data collected under the CCPA: identifiers.

  Mailing list or newsletter (this Website)

  By registering for the mailing list or newsletter, the User's email address is automatically included in a list of contacts to which email messages, including commercial and promotional information, relating to this Application may be sent. The User's email address may also be added to this list after registering to this Website or after making a purchase.

  Personal Data processed: surname; e-mail; first name.

  Category of personal data collected under the CCPA: identifiers.

• Sign up and authentication

  By registering or authenticating, the User allows this Website to identify him and to give him access to dedicated services.
  Depending on what is indicated below, registration and authentication services may be provided with the help of third parties. If this occurs, this application may access some data stored by the third party service that was used for registration or identification.
  Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to learn more, please refer to the description of each service.

  WordPress.com Single Sign On (Automattic Inc.)

  WordPress.com Single Sign On is a registration and authentication service provided by Automattic Inc. and connected to the WordPress.com network.

  Various types of data as specified by the service's privacy policy

  Processing location: United States - Privacy Policy.

  Category of personal data collected under the CCPA: Internet information.

  This type of processing constitutes a "sale of data" ("sale") within the meaning of the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out of the sale.

• Platform and hosting services

  These services are intended to host and operate key components of this Website, making it possible to provide this Website from a single platform. These platforms provide the Owner with a wide range of tools such as, for example, analytical tools, for managing user registration, for managing comments and the database, for e-commerce, for processing payments etc. The use of these tools involves the collection and processing of Personal Data.
  Some of these services operate through servers geographically located in different places, making it difficult to determine the exact place where Personal Data is stored.

  WordPress.com (Automattic Inc.)

  WordPress.com is a platform provided by Automattic Inc. that allows the Owner to develop, run and host this Application.

  Various types of data as specified by the service's privacy policy

  Processing location: United States - Privacy Policy.

  Category of personal data collected under the CCPA: Internet information.

• Statistics

  The services contained in this section allow the Data Controller to monitor and analyse traffic data in order to monitor User behaviour.

  WordPress Stat (Automattic Inc.)

  WordPress Stats is a statistical service provided by Automattic Inc.

  Personal Data processed: Cookies; Usage Data

  Processing location: United States - Privacy Policy.

  Category of personal data collected under the CCPA: Internet information.

  This type of processing constitutes a "sale of data" ("sale") within the meaning of the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out of the sale.

  Google Analytics with anonymised IP

  Google Analytics is a web analytics service provided by Google LLC or by Google Ireland Limited, depending on the location in which this Application is used ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports and sharing them with other services developed by Google.
  Google may use the Personal Data to contextualise and customise ads on its own advertising network.
  This Google Analytics integration makes your IP address anonymous. Anonymisation works by shortening the IP address of the Users within the member states of the European Union or in other countries that are parties to the Agreement in the European Economic Area. Only in exceptional cases will the IP address be sent to Google's servers and abbreviated within the United States.

  Personal Data processed: Cookies; Usage Data

  Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

  Category of personal data collected under the CCPA: Internet information.

  This type of processing constitutes a "sale of data" ("sale") within the meaning of the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out of the sale.

  Google Analytics

  Google Analytics is a web analytics service provided by Google LLC or by Google Ireland Limited, depending on the location in which this Application is used ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports and sharing them with other services developed by Google.
  Google may use the Personal Data to contextualise and customise ads on its own advertising network.

  Personal Data processed: Cookies; Usage Data

  Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

  Category of personal data collected under the CCPA: Internet information.

  This type of processing constitutes a "sale of data" ("sale") within the meaning of the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out of the sale.

• Displaying content from external platforms

  This type of service allows you to view content hosted on external platforms directly from the pages of this website and to interact with it.
  This type of service could still collect traffic data for the web pages where the service is installed, even when users do not use it.

  Google Fonts

  Google Fonts is a font style visualization service managed by Google LLC or by Google Ireland Limited, depending on the location in which this Website is used, which allows this Website to integrate such contents within its pages.

  Personal Information: Usage data and various types of data as specified by the privacy policy for the service

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

  Category of personal data collected under the CCPA: Internet information.

  This type of processing constitutes a "sale of data" ("sale") within the meaning of the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out of the sale.

Rights of the USer

Users may exercise certain rights with regard to the Data processed by the Data Controller.

In particular, the User has the right to:

• withdraw their consent at any time. The User may revoke their consent to the processing of their Personal Data as described above.
• the right to object to the processing of their data. The User may object to the processing of their Data when it is done on a lawful basis other than consent. More details on the right to object are given in the section below.
• the right to access their data. The User has the right to obtain information on what Data is processed by the Controller and on particular aspects of the processing, and to obtain a copy of any Data processed.
• the right to rectification of inaccurate personal data. The User may check that their Data is correct and ask for it to be updated or corrected.
• the right to restriction of processing. In certain circumstances, users may ask for restrictions to be set on the processing of their data. In this eventuality, the Data Controller may not process the Data for any purpose other than for its retention.
• the right to have their personal data removed or erased. When certain conditions are met, the User may request the cancellation of their Data by the Data Controller.
• the right to receive the personal data concerning him or her or transferred to another controller. Users have the right to receive their data in a structured, commonly used and machine-readable format, where technically feasible, and to have it transferred without hindrance to another controller. This instruction is applicable where the Data is processed by automated means, and the processing is based on the User's consent, in respect of a contract to which the User is a party or contractual provisions connected to this.
• the right to lodge a complaint. Users may lodge a complaint with the competent supervisory authority responsible for personal data protection or take legal action.

DETAILS ON THE RIGHT OF OBJECTION

When the Personal Data is processed in the public interest, in the exercise of public powers vested in the Data Controller, or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users are reminded that, if their Data is processed for direct marketing purposes, they may oppose the processing without giving any reason. To find out if the Data Controller is processing data for direct marketing purposes, Users can refer to the respective sections of this document.

HOW TO EXERCISE THE RIGHTS

In order to exercise their rights, Users may address a request to the Data Controller at the contact details indicated in this document. Requests will be filed free of charge and processed by the Data Controller as soon as possible and in any event within one month.

Cookie Policy

This Website uses Tracking Tools. To find out more, the User can consult the Cookie Policy.

Additional information on processing

LEGAL DEFENCE

User Personal Data may be used by the Data Controller in legal proceedings or in the preparatory stages for its possible establishment to defend against misuse of this Application or related Services by the User.
The User acknowledges that the Controller may be obliged to disclose Data by order of the public authorities.

SPECIFIC INFORMATION

At your request, in addition to the information contained in this privacy policy, this Application may provide the User with the additional and contextual information regarding specific Services or the collection and processing of Personal Data.

MAINTENANCE AND SYSTEM LOGS

Out of necessity related to operation and maintenance, this Website and any third-party services used by it may collect system logs, which are files which record the interactions and may also contain Personal Data, such as the IP address of the User.

INFORMATION NOT CONTAINED IN THIS POLICY

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller through the contact details.

Response to "Do Not Track" requests

This Website does not support "Do Not Track" requests.
Some involved third-party services you use may support such a request. Please consult their respective privacy policies for further information.

CHANGES TO THIS PRIVACY POLICY

The Data Controller reserves the right to make modifications to this privacy policy at any time by informing Users on this page and, if possible, on this Website and, where technically and legally feasible, by sending a notification to Users through one of the contact details held by the Data Controller. Please consult this page regularly, referring to the date of the last modification as indicated at the bottom.

Some change may affect processing where consent is the legal base. In such a case, and if necessary, the Data Controller shall obtain the User's consent again.

INFORMATION FOR CALIFORNIAN CONSUMERS

This part of the document integrates and completes the information contained in the rest of the privacy policy and is provided by the company that operates this Website and, where applicable, by its parent company and its subsidiaries and affiliates (for the purposes of this section collectively referred to as "we "," our "or" our ").

The provisions contained in this section apply to all Users who are considered consumers resident in the state of California, United States of America, pursuant to the "California Consumer Privacy Act of 2018" (such Users are referred to below simply as "you "," Your "," you "or" your "), and, for them, these provisions prevail over any other divergent or conflicting provision contained in this privacy policy.

This part of the document uses the term "personal information" as defined by the California Consumer Privacy Act (CCPA).

CATEGORIES OF PERSONAL INFORMATION COLLECTED, DISCLOSED OR SOLD

This section summarizes the categories of personal information that we have collected, communicated or "sold" pursuant to the CCPA and the related purposes of the processing. You can find detailed information on these activities in the section entitled "Details on the processing of Personal Data" in this document.

INFORMATION WE COLLECT: THE CATEGORIES OF PERSONAL INFORMATION WE COLLECT

We have collected the following categories of personal information about you: identifiers and information on the Internet.

We will not collect additional categories of personal information without first communicating a new policy to you.

HOW WE COLLECT INFORMATION: WHAT ARE THE SOURCES OF THE PERSONAL INFORMATION WE COLLECT?

We collect the above categories of personal information, directly or indirectly, from you when you use this Website.

For example, you provide us with your personal information directly when you submit inquiries via any form on this Website. Furthermore, you indirectly provide us with personal information when you browse this Website, as personal information concerning you is automatically observed and collected. Finally, we may collect your personal information from third parties who work with us in connection with the provision of the Service or the operation of this Website and its features.

HOW WE USE THE INFORMATION COLLECTED: SHARING AND COMMUNICATING YOUR PERSONAL INFORMATION WITH THIRD PARTIES FOR OPERATIONAL PURPOSES.

We may disclose your personal information to third parties for operational and service purposes. In this case, we enter into a written contract with that third party which obliges the recipient of your personal information to keep such information confidential and not to use it for purposes other than those necessary for the performance of the contract.

We may also disclose your personal information to third parties when you ask us or authorize us to do so in order to provide you with our Service.

We may also disclose your personal information to third parties when you ask us or authorize us to do so in order to provide you with our Service.

SALE OF YOUR PERSONAL INFORMATION

For the purposes of this document, the term "sale" means "sell, transfer, release, make public, disclose, disseminate, make available, transfer or otherwise communicate orally, in writing or by electronic means, personal information of a consumer by a company to another company or to third parties, for consideration or obtaining another type of profit ".

This means that, for example, a sale can take place whenever an application publishes advertisements, performs statistical analysis on its traffic or views or, simply, uses tools such as social network plug-ins and similar tools.

YOUR RIGHT TO OPT-OUT THE SALE OF YOUR PERSONAL INFORMATION

You have the right to opt out of the sale of your personal information. This means that whenever you ask us not to sell your data, we will execute your request.
Such requests can be made freely, at any time, and without submitting any request subject to verification, simply by following the instructions below.

INSTRUCTIONS FOR OPT-OUT THE SALE OF PERSONAL INFORMATION

If you wish to have further information or to exercise your right to opt-out in relation to all sales made from this Website, both online and offline, you can contact us using the contact details provided in this document.

WHAT ARE THE PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION?

We may use your personal information to allow this Website and its features to function properly ("operational purposes"). In such cases, your personal information will be processed in an appropriate and proportionate manner to the purposes for which it was originally collected and strictly within the limits of compatible purposes.

We may also use your personal information for other reasons, such as for commercial purposes (as indicated in the "Details on the processing of Personal Data" section of this document), as well as to comply with the law and defend our rights. before the competent authorities when our rights or interests are threatened or when we suffer damage.

We will not use your personal information for any other, unrelated or incompatible purpose without first communicating a new policy to you.

YOUR CALIFORNIA PRIVACY RIGHTS AND HOW TO EXERCISE THEM

RIGHT TO KNOWLEDGE AND PORTABILITY

You have the right to know the following:

• the categories of personal information we collect about you and the sources of that information, the purposes for which we use your personal information and who we share it with;
• in the event of the sale or disclosure of personal information to third parties for operational purposes, we will provide you with two separate lists in which we will notify you:
  • for sale, the categories of personal information communicated to each category of recipients;
  • is for communication to third parties for operational purposes, the categories of personal information obtained from each category of recipients;

The above information will be limited to personal information collected or used in the past 12 months.

In the event that our response is provided electronically, the information contained therein will be "portable", ie delivered in a compatible format so that you can transmit the information to other entities without hindrance - provided this is technically feasible.

RIGHT TO REQUEST THE DELETION OF YOUR PERSONAL INFORMATION

You have the right to request the deletion of any of your personal information, subject to the exceptions provided by law (such as, by way of example and not limited to, in the event that the information is used to identify and repair errors on this Website, to detect security incidents, for the purpose of protection from fraudulent or illegal activities, to exercise certain rights, etc.).

If no statutory exception applies, following the exercise of your right, we will delete your personal information and ask our suppliers to do the same.

HOW TO EXERCISE THE RIGHTS

To exercise the rights described above, you must submit a verifiable request by contacting us using the contact details provided in this document.

In order to respond to your request, it is necessary for us to be able to identify you. For this you can exercise the above rights only by submitting a verifiable request which must:

• provide sufficient information to enable us to reasonably verify that you are the person to whom the personal information we have collected relates or an authorized representative;
• describe your request with a degree of detail that is sufficient to make us understand, evaluate and respond correctly to what you ask us.

We will not respond to any requests if we are unable to verify your identity and, therefore, to confirm that the information in our possession actually refers to you.

If you cannot personally submit a verifiable request, you can delegate a person registered with the California Secretary of State to do so on your behalf.

If you are an adult, you can make a verifiable request on behalf of whoever falls under your parental responsibility.

A maximum of 2 requests can be submitted within 12 months.

HOW AND IN HOW LONG WE WILL MANAGE YOUR REQUEST

Within 10 days we will confirm that we have received your request and provide you with information on how we will process it.

We will respond on the merits of the request within 45 days of receiving it. If we need more time, we will explain why and let you know how much time we need. In this regard, please note that it may take up to 90 days to fulfill your request.

Our communications will cover the period of the previous 12 months.

Should we deny your request, we will explain the reason for the denial.

We will not charge any fees to process or respond to your verifiable request unless it is manifestly unfounded or excessive. In such cases, we may apply a reasonable fee, or deny the request. In both cases, we will notify you of our decisions and explain the reasons.