Policy on personal data processing based on
REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 (“GDPR”)

Introduction
The Data Controller is Argo Società a responsabilità limitata semplificata, with registered office in Via Carlo Poerio 18,80121 Napoli (NA) – Italy, VAT number IT08878661217 owner of the website https://www.villavettica.com.

Purchasing through the Website
The Villa Vettica shall acquire and process your personal data to process your request to purchase through the Website.

Marketing
If you provide your explicit consent, Villa Vettica shall process your personal data to send you promotional communications and/or newsletter regarding services offered for sale by Villa Vettica or by third parties.

Profiling
If you provide your explicit consent, Villa Vettica shall process your personal data for the analysis of your consumer choices and purchasing habits (known as “profiling”), through a study of the type and frequency of your online purchases, in order to send newsletter and/or advertising material of Villa Vettica or third-parties that may be of particular interest to you.

Soft Spamming
Villa Vettica is entitled to sale its services using the email that you communicated during your first purchase on the Website, if this service is similar of the first sale (soft spamming). You may at any time notify Villa Vettica of your refusal to receive this type of communication.

Curriculum Vitae
Processing of personal data for CV management purposes

The personal data provided through the sending of the curriculum vitae (CV) will be processed by the Data Controller exclusively for purposes related to the management of the personnel selection process and the evaluation of applications in relation to job vacancies in our company. Data processing includes the storage, analysis and evaluation of the CV and the information contained therein, in order to determine the suitability of the candidate for the available positions.

Pursuant to Article 6(1)(f) of the GDPR, the legal basis for the processing is the legitimate interest of the Data Controller in reviewing and managing applications for recruitment, ensuring an efficient and fair assessment of candidates. Such processing is in accordance with the candidate’s interest in having their application assessed in relation to the professional opportunities on offer.

The provision of data is optional. However, failure to provide the data necessary to evaluate the application will make it impossible for the Data Controller to examine the CV and proceed with the selection process. We therefore invite candidates to provide true and accurate information.

CVs and personal data of unsuccessful candidates will be kept for a maximum period of 5 months from the date of receipt, after which they will be securely and permanently deleted from our systems. In some cases, and with the explicit consent of the candidate, we may retain data for a longer period in order to assess future job opportunities. However, in the absence of such consent, the data will be deleted after this period, unless longer retention periods are required by law.

Summary
Art. 1. Purpose of the processing. Legal basis. Mandatory or optional nature of data provision and consequences of any refusal.
Art. 2. Methods of Processing Personal Data
Art. 3. Data Disclosure
Art. 4. Data Controller
Art. 5. Data Storage
Art. 6. Transfer of Personal Data to Third Countries
Art. 7. Rights of the Data Subject
Art. 8. Amendments

Article 1. Purpose of the processing. Legal basis. Mandatory or optional nature of data provision and consequences of any refusal.
Villa Vettica shall process the personal data provided by you for the following purposes:

• for administrative/accounting purposes. The legal basis for the processing is Villa Vettica’s commitment to be compliance with a legal obligation or to take steps at the request of the data subject prior to entering into a contract, as the case may be;
• In the case of the execution of an purchase order, to allow the conclusion of the purchase contract and the proper execution of transactions related to the same (and, where necessary, to fulfill tax obligations). The legal basis for the processing is Villa Vettica’s commitment to be compliance with a legal obligation or to perform a contract to which the data subject is party;
• limited to the email address provided by you when purchasing services offered, to enable the direct sale of similar services (soft spamming), without requiring your express and prior consent and provided that you do not exercise your right to object. The legal basis for the processing is Villa Vettica’s legitimate interest to perform these activities. This legitimate interest is equal to the user’s interest to riceve “soft-spam” comunication;
• if you provide your explicit consent, for Villa Vettica to send you newsletter and for market research purposes also aimed at evaluating the level of customer satisfaction and to send you promotional communications in relation to the services of Villa Vettica and / or third-parties, by email (marketing purposes); if you provide your explicit consent, for the analysis of your consumer choices and purchasing habits (known as “profiling”), by Villa Vettica, through a study of the type and frequency of your online purchases, in order to send informative and/or advertising material about services of Villa Vettica and / or third-parties, that may be of particular interest to the user, by email (profiling purposes). The legal basis for the processing is your consent;
• in order to answer to your requests by email, by telephone. The provision of data is purely optional. However, as the said processing is necessary in order to respond to your request, your refusal to provide the relevant data will prevent you from obtaining answer from the customer care of Villa Vettica. The legal basis for the processing is Villa Vettica’s legitimate interest to perform these activities. This legitimate interest is equal to the user’s interest to receive answer by Villa Vettica.

The provision of data for the purposes set out in at Point b) is purely optional. However, as the said processing is necessary in order to enable you to provide the purchasing your refusal to provide the relevant data will prevent you from completing a purchase.

Consent to marketing and profiling purposes is purely optional. Failure to consent will have the following consequences.

Failure to consent to the processing of personal data for marketing purposes will prevent you to receive promotional communication and newsletter regarding services of Villa Vettica and/or third-parties and will prevent Villa Vettica to carry out market research purposes aimed at evaluating the level of customer satisfaction.

Failure to consent to the processing of personal data for profiling purposes will prevent Villa Vettica from studying the type and frequency of your online purchases, in order to send to you newsletter and/or advertising material that may be of particular interest to you regarding services of Villa Vettica and/or third-parties.

It is understood that Villa Vettica may use your personal data to comply with legal obligations and to perform the purchase contract.

You may revoke your consent using the relevant link indicated in any promotional email sent by Villa Vettica.

Credit card payments on the Website

In order to make a payment through one of the payment cards offered on the Website, you shall enter the data of the payment card directly on a page that will communicate through secure encryption protocol with the payment service provider (which will act as an independent data controller). These data will not pass through the server of Villa Vettica which, therefore, will not process such data in any way.

In execution of the legal obligations provided for by Directive 2015/2366/ (EU) on payment services in the internal market (PSD2), You are informed that, with reference to purchases made on the Web Site by credit card, data necessary for the conclusion of the purchase process may include the phone number communicated by You, or a different personal data necessary to complete the purchase process. In order to allow you to complete the purchase, the payment institution in charge of managing the transaction will send you an authentication code, which must be reported by You during the purchase process to meet the authentication criteria provided by PSD2 (Strong Customer Authentication). The processing of your personal data for these purposes has as its legal basis the fulfillment of legal obligations and does not require your consent.

To provide the above-indicated data is necessary to make purchases on the Website.

Special Categories of Personal Data. Judicial Data

Villa Vettica does not process special categories of personal data nor judicial data.

Article 2. Methods of Processing Personal Data
The processing of your personal data will be carried out by electronic or automated means, in the manner and with the appropriate tools to ensure the security and confidentiality in accordance with the GDPR.

The information and methods of processing will be relevant and not excessive in relation to the type of services provided. Data will be managed and protected in environments where access is under constant control.

Art. 3. Data Disclosure
For the purposes described in this privacy policy, the personal data provided by you may be disclosed or communicated to the following parties:

• to all those parties (including Public Authorities) that have access to the data by virtue of regulatory or administrative measures;
  to parties who process online payment transactions;
• to companies, consultants or professionals in charge of the installation, maintenance, updating and the management of Villa Vettica’s hardware and software or which Villa Vettica uses for the provision of its services;
• to the companies that send the newsletters and/or other informative communications transmitted on behalf of Villa Vettica;
  to the employees and/or collaborators of Villa Vettica;
• companies managing online payment transactions;
• to all those public and/or private parties, natural and/or legal persons (legal, administrative and tax consultancy firms), where the communication is necessary or of practical use for the correct fulfilment of contractual obligations undertaken in relation to the services provided through the Website, and of legal obligations.

The subjects to whom Villa Vettica transmits your data may be data processors who are designated by Villa Vettica by means of a specific contract or persons in charge of processing personal data under the direct authority of Villa Vettica or, in the case of third parties employed by the Data Processor, sub-processors, pursuant to art. 28.4 of the GDPR.

Your data may be disclosed only in anonymous and aggregated form for statistical or research purposes.

Art. 4. Data Controller

You can contact Villa Vettica, as Data Controller, at the following addresses:

Argo Società a responsabilità limitata semplificata,  Via Carlo Poerio 18,80121 Napoli (NA) – Italy
VAT number IT08878661217 
info@villavettica.com

The Data Controller has also appointed a Data Protection Officer (DPO), who can be contacted by you at the following email: info@villavettica.com

Art. 5. Data Storage

Personal data will be stored according to the following logics:

• for marketing and profiling purposes, personal data will be kept for 24 months. At the end of this period, the Company may ask you to renew your consent to the processing of your data or to make them anonymous and keep them only for statistical or historical purposes;
• for the purpose of executing the sales contract, for 10 years from the date of receipt of the purchase order;
  as provided for in Article 2220 of the Civil Code, invoices, as well as all accounting records in general, are kept for a minimum period of ten years from the date of registration, so that they can be presented in the event of an audit;
• for the purpose of defense in court, until the judgment becomes final;
• for the purpose of complying with legislation, for the time necessary for this purpose;
• for the purpose of performing any service requested through the Site, for the time necessary to execute the request.
• for customer care purposes, data will be deleted once the service is completed.
• for Curriculum Vitae purposes, the data will be kept until the end of the selection period and in any case for a period not exceeding 6 months from the sending of the curriculum vitae.

Art. 6. Transfer of Personal Data to Third Countries

Villa Vettica is based within the European Union. Therefore, the processing of your data is safe from a regulatory point of view as it is governed by the GDPR.

If the transfer of your personal data takes place in a non-EU country and for which the European Commission has issued an adequacy opinion, the transfer is in any case considered safe from a regulatory point of view. This Article indicates from time to time the countries to which your personal data may possibly be transferred and where the European Commission has issued an adequacy opinion.

Your data may also be transferred to countries outside the EU for which the European Commission has not issued an adequacy opinion. In order to allow for the proper functioning of the Site, your personal data may be transferred to the U.S.A.. In these cases, the Data Controller will take all appropriate contractual measures to ensure an adequate level of protection of personal data, including, among others, the Standard Contractual Clauses approved by the European Commission on June 4, 2021.

You are therefore invited to access this article regularly to check whether the transfer of your personal data takes place in a Third Countries.

Art. 7. Rights of the Data Subject

Pursuant to GDPR (Article 13), you have the right to:

• request access to and rectification or erasure of personal data or restriction of processing or object to their processing, in addition to the right to data portability
• withdraw consent at any time without prejudice to the lawfulness of processing based on consent given prior to the withdrawal
• lodge a complaint before a supervisory authority (for instance, the Italian Data Protection Authority).

The above-mentioned rights may be exercised by making a request to at the contacts indicated above.

Art.8. Amendments

Villa Vettica reserves the right to change this privacy policy at any time, giving suitable notice to users and ensuring in any case an adequate and similar protection of personal data. In order to view any changes, you are invited to regularly consult this privacy notice.