Privacy Sardinia Active

Privacy Sardinia Active

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Dear Sir or Madam,

According to the legislation on the protection of personal data (Regulation (EU) 2016/679, Legislative Decree 196/2003 and Legislative Decree 101/2018), the Data Controller would like to explain the following to you in a simple and clear manner:

  1. why we process your personal data;
  2. what personal data is processed;
  3. who processes your personal data;
  4. how we process your personal data and for how long is your personal data retained;
  5. how to exercise your rights regarding the processing of your personal data

The Data Controller is the Autonomous Region of Sardinia, in the person of its Legal Representative, the pro-tempore President of the Sardinia Region - presidenza@pec.regione.sardegna.it

With resolution of the Regional Council No. 51/3 of 16 October 2018, the President of the Region has delegated the tasks and functions of the Data Controller to the General Managers responsible for the matter.

The Data Processing Delegate, on behalf of the Data Controller, is the Director of the Marketing and Communications Service of the Department of Tourism, Crafts and Commerce – tur.marketing@pec.regione.sardegna.it.

The information below concerns the processing of your personal data collected during the ‘Sardinia Active’ communication campaigns through the completion of the online form accessible at the web address https://www.sardegnaturismo.it/sardinia-active or through the completion of the a specific questionnaire, distributed during promotional events and trade fairs.

WHY DOES THE REGION OF SARDINIA PROCESS YOUR DATA

Your personal data is processed for the following purposes:
  • in order to carry out administrative, technical and control functions in the context of institutional tasks assigned by law;
  • for institutional information and communication activities;
  • to allow you to use the services you requested: specifically, to receive the editorial content you selected and to send you newsletters via email relating to your interests in active tourism;
Only with your specific consent, for the following other purposes:
  • to analyse, also automatically, your preferences in order to provide you with information on services or initiatives in line with your interests. These preferences, expressed by selecting the types of active tourism you are interested in, will be analysed through an automatic decision-making process, in order to send you the editorial contents corresponding to your selected interests, and possibly offer you news, information and invitations to events or suggestions regarding registration for events that the Data Controller organises or is a part of, or to allow direct communication with you, based on your tastes and preferences.

The aforementioned data processing, when configurable as an automated decision-making process - within the limits of the type of content sent and suggested based on user profiling - does not produce any legal effect for the parties involved and, in the same way, does not affect them.

Legal basis for the processing

We process your personal data legally:

  • because it is needed for the execution of a public interest task or connected to the exercise of public powers vested in the Region of Sardinia – including the purposes of Regional Law No. 16 of 28 July, 2017, “Regulations on Tourism and subsequent amendments. -, as the Data Controller – article 6, paragraph 1, letter e) of the Regulation.
  • because you have given your consent to the processing of your personal data – Article 6, paragraph 1, letter a).

WHICH DATA DOES THE REGION OF SARDINIA PROCESS

Within the scope of the purposes indicated, the Data Controller processes the following data provided voluntarily, described below:
  • Name;
  • Email address;
  • Area of interest in active tourism.
This data is processed as part of the activities for the provision of the service included therein.
This data is also processed, exclusively in aggregate form, for the purpose of obtaining statistical information on the origin and areas of interest regarding active tourism.
The data requested from you must be provided on a mandatory basis, as it is necessary for the provision of the relevant service requested and, in any case, for the achievement of the institutional purposes assigned by law. Refusal to provide the mandatory data makes it impossible for the Data Controller to carry out the services and tasks for which this data is necessary.

WHO PROCESSES YOUR DATA

For the purposes communicated to you, your data may be made accessible to:
  • employees and/or collaborators of the Sardinia Region, expressly designated and authorised with differentiated levels of access, depending on the specific tasks;
  •  any data processing managers for the creation and management of newsletters and email marketing campaigns. The entities responsible for the data processing are:
  1. MailUp S.p.A., registered office Viale Pola 9, 20124 Milan (Italy), VAT number 09480090159;
  2. Net7 S.r.l., registered office Via G. Arcangeli 4, 56124 Pisa (Italy), VAT number 01577590506 (as sub-manager).

HOW WE PROCESS AND STORE YOUR DATA

Your personal data is processed electronically through collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, deletion and destruction of data.

The Data Controller strives to guarantee the logical and physical security and privacy of the personal data processed, implementing all of the appropriate technical and organisational measures for the processing.

FOR HOW LONG DO WE RETAIN YOUR DATA

The personal data collected for the purposes referred to above will be processed and stored for the time necessary to pursue the purposes indicated above, including the protection of rights and, therefore, in any case no later than the statutory period of limitations established for the rights.
The data of people who do not subscribe to the newsletter will only be stored for statistical purposes for a maximum of 24 months.
The data collected for statistical purposes is only stored in aggregate form

TRANSFER OF DATA TO OTHER COUNTRIES

No data transfers to non-EU countries or to international organisations will be made. Any transfer of your data to non-EU countries will be communicated to you with a specific notice.

HOW TO EXERCISE YOUR RIGHTS IN RELATION TO THE PROCESSING OF PERSONAL DATA

The Sardinia Region informs you that, as an interested party, if the limitations set out by law do not apply, you have the right to gain knowledge of the processing of your personal data and, for this reason, you have the right to:
  • obtain confirmation of the existence or non-existence of your personal data, even if not yet registered, and that such data be made available to you in an intelligible form;
  •  obtain information and, if necessary, a copy of:
  1. the origin and category of personal data;
  2. the purposes and methods of the data processing;
  3. the identity of the Data Controller and Managers;
  4. the individuals or categories of individuals to whom the personal data may be communicated or who may gain knowledge of the personal data, particularly if they are recipients of third countries or international organisations;
  5. when possible, the data retention period or the criteria used to determine this period;
  6. the existence of an automated decision-making process, including profiling, and in this case the logic used, the importance and consequences for you, as an interested party;
  7. the existence of adequate guarantees in the event of transfer of your data to a non-EU country or to an international organisation;
  • obtain, without undue delay, the updating and correction of inaccurate data or, if interested, the integration of incomplete data;
  • revoke the consent given at any time, easily, without hindrance and, if possible, using the same channels used to provide them;
  • obtain the cancellation, transformation into anonymous form or blocking of data processed unlawfully, no longer necessary in relation to the purposes for which they were collected or subsequently processed or, in the event that the consent on which the processing is based is revoked and if there is no other legal basis, if you have opposed the processing and there is no legitimate overriding reason to continue the processing, in case of fulfilment of a legal obligation;
  • obtain the limitation of processing in the case of:
  1. challenging of the accuracy of personal data;
  2. unlawful processing by the Data Controller to prevent its deletion;
  3. exercising of your right in judicial matters;
  • verification of the possible prevalence of the Data Controller’s legitimate reasons with respect to your rights;
  • receive, without hindrance and in a structured, commonly used and legible format, if the processing is carried out by automatic means, your personal data to be transmitted to another Data Controller or, if technically possible, obtain direct transmission to another Data Controller;
  • object, in whole or in part:
  1. to the processing of your personal data, for legitimate reasons, even if pertinent to the purpose of its collection;
  2. to the processing of your personal data, without giving any reasons, if it occurs for marketing purposes, including profiling linked to the same data.
  • lodge a complaint with the Personal Data Protection Authority.
In the cases mentioned above, where necessary, the Region of Sardinia, as Data Controller, will inform the third parties to whom your personal data is communicated of the possible exercising of rights by you, with the exception of specific cases (e.g. when fulfilling this action proves impossible or involves the use of means manifestly disproportionate compared to the protected right).

You may exercise your right by sending to the Data Controller:

  • a registered letter with return receipt or alternatively a Certified Electronic Email.

It is possible to use the specific model available on the institutional website of the Autonomous Region of Sardinia in the section entitled - Documents and regulations/model for the exercising of rights of interested parties or by clicking on the following link DPO - Documents and regulations 

The address to which to send the registered letter is Viale Trieste n. 105 – 09123 Cagliari, or send a Certified e-mail to: tur.marketing@pec.regione.sardegna.it.

For information about your rights to protect your personal data, you can contact the Data Protection Officer of the Autonomous Region of Sardinia at the following addresses:

viale Trieste 186 – 09123 Cagliari, telephone +39 070 6065735 or by e-mail to rpd@regione.sardegna.it or to rpd@pec.regione.sardegna.it