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1. Introduction

1.1 We care and are committed to protecting the personal data of visitors of our website and users of our services. With this document we provide the data subjects with the information on the processing provided for by art. 13 and 14 of the Regulation EU 2016/679 — General Data Protection Regulation ("GDPR").

1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service user; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

1.4 The Controller of the processing is the ARS Unipersonale srl and its legal representative, who can be contacted at the email address info@vaticanars.com. In this document we refer as “we”, “us” and “our” to ARS Unipersonale srl or the Data Controller or the website Vaticanars.com.

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2. How we use your personal data

2.1 In this Section we describe:

(a) The general categories of personal data that we may process;

(b) the purposes for the processing of personal data; is

(c) the legal basis we use for processing personal data.

2.2 We may use personal data relating to your browsing on our website ("usage data"). Usage data may include your IP address, geographic location, browser type and version, operating system, referral source, visit duration, page views and website navigation paths, as well as information on the timing, frequency and configuration of your use of the service. Our analytical tracking system (Google Analytics) processes this data and provides us with reports in anonymous aggregate form that is used to monitor and improve the website and develop new services.

The legal basis for this treatment is the pursuit of our legitimate interest in monitoring and improving our website and our services (art. 6.1.f), applicable since the anonymous form of the reports does not present risks for the individual freedoms of the concerned.

2.3 We may process the personal data you provide us by telephone, web or social networks to request information on the goods and/or services offered by us ("request data"). The request data can include the Name, Surname, language, telephone number, fax number, email address. Request data is processed to offer, market goods and services to interested parties.

The legal basis for this treatment is the need to carry out pre-contractual measures adopted at the request of the interested party (art. 6.1.b)

2.4 We may process information relating to transactions, including purchases of goods and services, which you enter into with us and/or through our website ("transaction data"). Transaction data can include contact, transaction and payment etails. The transaction data can be processed for the purpose of providing the goods and services purchased and to keep adequate records of such transactions.

The legal basis for this treatment is the execution of a contract between you and us (art. 6.1.b) and a legal obligation (tax accounting) to which the Owner is subject (art. 6.1.c).

2.5 Within the transaction data, only the Name, Surname, email and telephone could be used by us to carry out direct marketing activities for the proposal of goods or services similar to those already purchased by you.

The legal basis for this treatment is art. 130 of the Italian Code of Privacy (Legislative Decree 108/18) which allows the sending of direct marketing in these cases without the specific consent of the interested party, provided that the right to interrupt such sending is guaranteed at the request of the interested party.

2.6 We may process the information you provide to us for the purpose of subscribing to our e-mail and/or newsletter notifications ("notification data"). The notification data are Name, Surname and Email and can be processed for the purpose of sending you notifications and/or newsletters. The legal basis for this treatment is consent.

2.7 We may process your personal data identified in this document where necessary for the establishment, exercise or defense of legal claims, both in judicial proceedings and in an administrative or extrajudicial procedure. The legal basis for this treatment is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of third parties.

2.8 We may process your personal data identified in this document in aggregate form where necessary for the purpose of obtaining or maintaining insurance coverage, managing risks or obtaining professional advice. The legal basis for this treatment is our legitimate interests, or the adequate protection of our company against risks.

2.9 In addition to the specific purposes for which we may process personal data indicated in this section, we may also process your personal data where such processing is necessary to fulfill a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.

2.10 Please do not provide us with personal data of other people, unless you are asked to do so.

3. Technical and Organizational Measures

3.1 In processing your personal data,  we have taken all the necessary precautions to the maximum possible security, adopting the technical and organizational measures prescribed by art. 32, 33, 34, 35 and 36 of the GDPR. In particular:

  1. All operators who have access to personal data have been properly trained and have been authorized to process by the Controller.
  2. All computers on which personal data is processed are protected by login credentials (username and password)
  3. All computers on which personal data is processed are protected by malicious software (viruses and malware) through software programs updated to the latest available releases.
  4. All personal data is subject to periodic backups to guarantee availability.
4. Trasfer of personal data to third parties

4.1 We may disclose your personal data to our insurers and/or professional consultants to the extent reasonably necessary in order to obtain or maintain insurance coverage, manage risks, obtain professional advice, or establish, operate or defend legal claims, whether in court proceedings or administrative or extrajudicial proceedings.

4.2 Financial transactions related to our services can be managed by our payment service providers or primary credit institutions based in the EU. We will share transaction data with our payment service providers only to the extent necessary for payment processing, reimbursing such payments and handling complaints and claims related to such payments and refunds. Information on the privacy policies and practices of payment service providers can be found on the respective websites.

4.3 In addition to the specific disclosure of personal data referred to in this Section, we may disclose your personal data where such disclosure is necessary to comply with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal requests, whether in legal proceedings or in administrative or out-of-court proceedings.

5. Retention and deletion of personal data

5.1 This Section defines our data retention policies and procedures, which are designed to help ensure compliance with our legal obligations in relation to the storage and deletion of personal data. In general, this limit is 10 years.

5.2 The personal data we process in order to carry out direct marketing will be kept until your request to suspend the sending.

5.3 Notwithstanding the other provisions of this Section, we may store your personal information where such retention is necessary to fulfill a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another physical person.

6. Modifications

6.1 We may update this document from time to time by posting a new version on our website.

6.2 You should check this page from time to time to make sure you are satisfied with any changes to this policy.

6.3 We may inform you of changes to this document via e-mail.

7. Your rights

7.1 In this Section, we have summarized your rights under the GDPR. Some of the rights are complex and not all details have been included in our summaries. Accordingly, it is necessary to read the relevant laws and guidelines of the regulatory authorities for a complete explanation of these rights.

7.2 Right of access - you have the right to have confirmation whether or not we process your personal data and, where we do so, access to such personal data, together with some additional information. This additional information includes details on the purpose of the processing, the categories of personal data involved and the recipients of personal data.

7.3 Right of rectification - you have the right to correct any personal data that is inaccurate and, taking into account the purposes of the processing, to have completed personal information that is incomplete.

7.4 Right to cancellation - in some circumstances you have the right to have your personal data deleted without undue delay. These circumstances include: personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; withdraw consent to consent-based processing; you object to processing under certain rules of the applicable data protection law; the processing is for direct marketing purposes; and personal data have been processed illegally. However, there are exclusions of the right to cancellation. General exclusions include when processing is necessary: ​​for compliance with a legal obligation; or for the establishment, operation or defense of legal disputes.

7.5 Right of limitation - in some circumstances you have the right to limit the processing of your personal data. These circumstances are: disputed the accuracy of personal data; processing is illegal but you oppose the cancellation; we no longer need personal data for the purposes of our processing, but we request personal data for the establishment, exercise or defense of legal claims; and you disputed the processing, pending verification of this objection. Where the processing has been limited on this basis, we may continue to store your personal information. However, we will only process it differently: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

7.6 Right of opposition - You have the right to object to the processing of your personal data for reasons relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: performing a task performed in the public interest or the exercise of any official authority attributed to us; or the purposes of the legitimate interests pursued by us or by a third party. If this objection is made, we will cease to process personal information unless we are able to demonstrate valid legitimate reasons for processing that override your interests, rights and freedoms, or the processing is for the establishment, the exercise or the defense of legal claims.

You have the right to object to the processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If this objection is made, we will cease to process personal data for this purpose.

You have the right to object to the processing of your personal data for scientific or historical research purposes or for statistical purposes for reasons related to your particular situation, unless the processing is necessary for the execution of a task performed for reasons of public interest .

7.7 Right to portability - To the extent that the legal basis for processing personal data is:

  1. consent; or
  2. that the processing is necessary for the execution of a contract of which one is a member or to take measures upon request before entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured format, commonly used and readable by a machine. However, this right does not apply in the event of prejudice to the rights and freedoms of others.

7.8 Right to complain to a supervisory authority - if you believe that our processing of your personal information violates data protection laws, you have a legal right to file a complaint with a supervisory authority responsible for data protection. You can do it in the EU member state of your habitual residence.

7.9 Right to revoke consent - to the extent that the legal basis for the processing of personal data is consent, you have the right to revoke this consent at any time. Withdrawal does not affect the lawfulness of processing before consent is withdrawn.

7.10 You can exercise your rights in relation to your personal data by sending a written notice to our email address info@vaticanars.com.

8. Cookie Policy

8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a Web server to a Web browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2 Cookies can be "persistent" or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until the expiration date set, unless it is deleted by the user before the expiration date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3 Cookies generally do not contain any information that personally identifies a user, but the personal information we store about you may be linked to information stored and obtained from cookies.

9. Cookie we use

9.1 We use cookies for the following purposes:

(a) strictly necessary: we use cookies to provide necessary information on our site (the cookies used for this purpose are: );

(b) customization: we use cookies to store information about your preferences and to personalize the website for you (the cookies used for this purpose are: Polylang);

(c) analysis: we use cookies to help us analyze the use and performance of our website and our services (the cookies used for this purpose are: Google Analytics);

(d) targeting - we use cookies to store your behavior and searches about your preferences (the cookies used for this purpose are: Google Doubleclick).

10. Cookies used by our service providers

10.1 Our service providers use cookies and these cookies can be stored on your computer when you visit our website.

10.2 We use Google Analytics to analyze the use of our website. Google Analytics collects information on the use of the website through cookies. The information collected about our website is used to create reports on the use of our website. The Google privacy policy is available at: https://www.google.com/policies/privacy/.

11. Managing Cookies

11.1 Most browsers allow you to refuse acceptance of cookies and to delete cookies. The methods to do this, vary from browser to browser and from version to version. However, it is possible to obtain updated information on these following links:

(a) Chrome;

(b) Mozilla Firefox;

(c) Opera;

(d) Microsoft Internet Explorer;

(e) Apple Safari; and

(f) Microsoft Edge.

11.2 Blocking all cookies can have a negative impact on the usability of many websites.

11.3 Activating cookie blocking may reduce the functionality of our website.

12. Our Contacts

11.1 The Data Controller is ARS Unipersonale srl.

11.2 Our head office is at Borgo Vittorio 85A, 00193 Rome - Italy.

11.3 You can contact us:

  1. by mail, to our address above;
  2. by phone, to the numbers shown on our website; or
  3. by email, to the email address published on our website.