Our work philosophy is always to approach the customer with information deemed to be of actual interest, avoiding invasive or insistent actions that would conflict with our goal of informing and supporting our customers in making the best choices for their own purposes. This document provides information on the processing carried out for communication and marketing activities by the HUMAN COMPANY Group.
1. Data Controller
2. Data processed and its origin
3. Purpose of the processing and legal basis(*) of the processing
4. Methods of data processing and storage
5. Data processors and appointees
6. Who the data may be communicated to
7. Provision of data and consent
8. Rights of the data subject - Contacts
Titolari del trattamento in parola sono le aziende del Gruppo HUMAN COMPANY, in particolare:
> hu Holding s.r.l. sede legale: Via Generale C. A. Dalla Chiesa 13 - 50136 Firenze, Italia - Dati di contatto del Data protection officer: [email protected]
> Elite Vacanze Gestioni S.r.l. con sede in Figline ed Incisa Valdarno (FI), Via Norcenni n.7, c.f./p.iva 06196120486 - Dati di contatto del Data protection officer: [email protected]
e le società dalla stessa controllate:
- Figline Agriturismo S.r.l. (Via Spadini 31 – Prato - P. IVA 01681640973) gestione Norcenni Girasole Village e Villa La Palagina
- Roma Camping S.r.l. (Via Aurelia 831-Roma - P.IVA 00954081006) gestione I Pini Family Park e Roma Camping in Town
- Elite Livorno Gestioni S.r.l. -(Via Norcenni 7 - Figline Incisa V.no (FI) - P.IVA 05813780482) gestione Park Albatros Village e Montescudaio Village
- Delta S.r.l. (Via G.Leopardi 31 - Montevarchi (AR) - P.IVA 01954310510) gestione Jolly Camping in Town
- Società Agricola Le Driadi S.r.l. (Via Norcenni 21 - Figline Incisa V.no P.IVA 05627800484) gestione Agriturismo Le Corti
- Plus Prague S.r.o. (Privozni 1562/1 - Praga - P.IVA CZ699003294) gestione Plus Prague
- Adakitalia S.r.l. (Via Norcenni 7 - Figline Incisa V.no (FI) P.IVA 04719560486) gestione Norcenni Tour e Human Travel
- Plus Berlin G.m.b.h (Warschauer Platz 68 - Berlino - P.IVA DE270699817) gestione Plus Berlin
- Elite Veneto Gestioni S.r.l. (Via Norcenni 7 - Figline Incisa V.no –FI- P.IVA 05813690483) gestione Altomincio Family Park
- Roma Gestioni S.r.l. (Via Aurelia 831 – Roma - P.IVA 08219321000) gestione Fabulous Village
- Elite Firenze Gestioni S.r.l. (Figline Incisa V.no (FI) P.IVA 05813700480) per Plus Florence e Firenze Camping in Town
- La Quarta S.r.l. (Via Generale C. A. Dalla Chiesa 13 - 50136 Firenze) P.IVA e C.F. 06441820484, Gestione attività di ristorazione e bar
- ECV Shops S.r.l. (Via Generale C. A. Dalla Chiesa 13 - 50136 Firenze) P.IVA e C.F. 06441810485 Gestione dei market e dei bazar
- O’Tel S.r.l. (Via Generale C. A. Dalla Chiesa 9 - 50136 Firenze) [P. IVA 05467430483] | Proprietà immobiliare – affitto d’azienda
- Holding Terza S.r.l. (Via Generale C. A. Dalla Chiesa 13 - 50136 Firenze) C.F. 06438440486, Holding ramo ristorazione e market
- La Terra dei Sensi S.r.l. (Via Generale C. A. Dalla Chiesa 13 - 50136 Firenze) C.F. 06717970484, Gestione programma ANTS
- Camping International S.A. (Um Birkelt n.1, Larochette, Lussemburgo) N° TVA: LU13005324, Gestione Camping Birkelt
di seguito tutti definiti unitariamente HUMAN COMPANY
The contact details used to send this communication were acquired directly from the data subject themselves, or from parties authorised by them, at the time of the data subject's previous contact with one of the Human Company facilities.
Furthermore, any information acquired during subsequent contact with the data subject and interviews/market surveys carried out by any means (paper questionnaires, phone interviews, completion of online forms, etc.) may be processed.
The purposes of the processing referred to in this statement are:
a. making first contact in order to request an expression of interest from data subjects and to comply with the obligations imposed by the legislation on the protection of personal data - legal basis(*): -legal- fulfilment [Article 6, paragraph 1, letter c, EU Regulation 2016/679]
b. commercial activity: marketing, advertising, promotional activities. In particular, contact details, postal and email addresses may be used to send courtesy communications and/or promotional/information material about HUMAN COMPANY's products and commercial initiatives - legal basis: legitimate interest consisting in processing, for direct marketing purposes, the email address used by the data subject to purchase a product or service from HUMAN COMPANY [Article 6, paragraph 1, letter f - Italian Legislative Decree 196/2003, Article 130, paragraph 4] – with regard to other addresses: consent of the data subject [Article 6, paragraph 1, letter a, EU Regulation 2016/679].
d. conducting market surveys to improve our products/services - legal basis: legitimate interest coinciding with the purpose [Article 6, paragraph 1, letter f, EU Regulation 2016/679]
f. satisfying requests for information from data subjects - legal basis: legitimate interest of the data subject coinciding with the subject of the request [Article 6, paragraph 1, letter f, EU Regulation 2016/679].
In relation to the aforementioned purposes, the personal data may be processed, including when managed on behalf of other data controllers by hu Holding SRL, with paper, IT and telematic tools. This will always be done ensuring utter confidentiality and relevance, and not exceeding the purposes described above in terms of data recording and retention periods.
The email addresses and other contact details for which the data subject has granted use, including for commercial purposes, will be processed and stored for 12 months following the last sending/contact vis-à-vis the data subject or the revocation of consent; in the latter case, for data subjects with no contractual relationship with the Data Controller, in order to satisfy the data subject's request and not repeat unwanted communications even incidentally.
For the same purposes, the data may be processed by the following categories of appointees and/or data processors:
- commercial and IT systems management staff
- our external consultants or suppliers involved in the above activities, appointed as data processors (Article 28, EU Regulation 2016/679) or designated appointees (Article 28, EU Regulation 2016/679)
The personal data in question may always be communicated within the European Union:
- to our consultants, within the limits necessary to carry out their assignment at our Company, subject to our letter of appointment which imposes the duty of confidentiality and security
- to other entities who need to access the data for purposes related to organising events or conducting market surveys
who will have full control of the processing carried out at their own facilities.
Naturally, all the communication described above is limited only to the data necessary for the recipient to carry out their duties and/or to achieve the purposes connected to the communication itself.
Communicating and updating your data, as well as consenting to its processing, are obviously optional.
Not doing so will have no consequence except that the data subject will not be involved in the initiatives promoted by HUMAN COMPANY. It should be noted that any consent given may be revoked at any time without prejudice to the lawfulness of the processing carried out before the revocation.
The data subject has the right:
> to ask the Data Controller to access and rectify or erase personal data (where no longer necessary; incomplete, incorrect or collected in breach of the law) or limit the processing of personal data concerning them and oppose its processing
> where the processing is carried out by automated (computer) means and to the extent technically possible, to receive any information concerning it in a structured format or have it sent to them or to third parties indicated by them
> to withdraw consent at any time (without prejudice to the lawfulness of the processing based on consent prior to withdrawal), obviously for processing performed on this basis
> if the response to their requests is unsatisfactory or if they deem it necessary, to lodge a complaint with the Italian Personal Data Protection Authority (http://www.garanteprivacy.it/) To exercise their rights, data subjects may send a communication to [email protected], bearing in mind that it will not be possible to respond to requests received by phone if there is uncertainty about the applicant's identity.