Privacy policy


INFORMATION PURSUANT TO ART. 13 AND 14
EU REGULATION 2016/679 AND LAW 171/2018 OF THE REPUBLIC OF SAN MARINO

BUSINESS NAME: TITANKA! Spa
Data subjects: users of websites

Below, the methods of management of the website www.abcvacanze.it are outlined, whose owner is TITANKA! Spa, a company located in San Marino, a non-EU country, with reference to the processing of personal data of the users information provided pursuant to Article 13 of Regulation 2016/679 of the European Parliament and of the Council from April 27, 2016 on the protection of individuals with regard to the processing of personal data, as well as Art. 13 of Law no. 171 from December 21, 2018 on the protection of individuals with regard to the processing of personal data approved by the Grand and General Council of the Republic of San Marino.

A description of how your data will be processed:
www.abcvacanze.it is the main website to help you better plan your holidays on campsites and in holiday villages all over Italy. You will find carefully selected properties, based on high quality standards, and all the necessary tools to find the one that best meets your needs. www.abcvacanze.it allows you to select the accommodation establishments that match your needs, and forward a request for an offer to those selected, as well as to one in particular. Your requests will be immediately communicated to the respective accommodation establishments, which will respond to your request directly via email. In addition, you will have the opportunity to subscribe to a newsletter that will enable you to receive offers and promotions from the www.abcvacanze.it website.

The purpose of the processing and the legal basis

Delivery of the service
The personal data provided by users who make use of the services provided by www.abcvacanze.it (e.g.: through navigation on the website, filling out forms for various requests, etc.) is used for the sole purpose of performing the service or performance requested.
Following the request for a quote, through www.abcvacanze.it the accommodation establishments that receive your request will respond with the best offers available for you. On a legal basis, the processing of pre-contractual actions commences in order to respond to your requests, your data will then be processed by TITANKA! Spa company; located in San Marino, a non-EU country.

Direct marketing from www.abcvacanze.it
By registering for the newsletter from www.abcvacanze.it (either on the quotation request form or from the special area on the website where you can enter your email address) you can receive information on promotions and special offers directly from the www.abcvacanze.it website.
You may deactivate the newsletter reception service at any time through the appropriate procedure and/or the methods below to exercise your rights, as indicated at the bottom of each email that you receive. The legal basis of the above-mentioned processing & the consent of the data subject.

Optional provision of data
Apart from what has been specified regarding data for navigation, the user is free to provide www.abcvacanze.it with the personal data required to use the services provided through the website. Failure to provide data relating to fields marked with an asterisk (mandatory) means that it will be impossible to use the service offered.

Implications of not providing consent for optional purposes
Failure to consent to the promotional purposes of direct marketing does not affect the processing of the data necessary for the provision of the basic service that provides for the receipt of quotes based on your requests.

Methods and security of the processing
The processing of personal data is carried out by means of IT tools suitable for ensuring the security and confidentiality of the data and in accordance with the appropriate security measures as required by Art. 32 GDPR and Art. 33 of Law 171/2018 of San Marino, by means of secure communication protocols with SSL encryption algorithms. You can view HERE the GDPR compliance policies of TITANKA!.

Period of data retention
The data retention period is necessary for the purposes of the services requested and for a further period of 36 months. If the requested information is the subject of an online transaction, such data may be kept for economic and fiscal reporting purposes, for a period of 10 years. Regarding the technical data managed by the website, such as cookies, the storage period is defined by the technical properties of the cookies themselves as specified in the table “Site cookies”. The data retention period is extended for a further period of 36 months each time a new consent is given to the processing of data and/or each time services are accessed with your credentials (e.g. logging into your personal area).

Your personal data will be processed in compliance with the legislative provisions of the above-mentioned law and with the confidentiality obligations provided for therein. The provision of the Italian Privacy Guarantor is considered to be "good practice", with guidelines on promotional activities and spam prevention - July 4, 2013 (Published in the Official Gazette no. 174 of July 26, 2013), guidelines on the processing of personal data for online profiling - March 19, 2015, and guidelines on automated decision-making processes and profiling - WP251, defined according to the provisions of Regulation (EU) 2016/679.

Data transfer to non-EU countries and guarantees of adequacy
TITANKA! Spa is a company that guarantees compliance with the GDPR established in San Marino, a non-EU country that has implemented European legislation on the processing of personal data, through the adoption of Law No. 171 dated December 21, 2018 on the same guarantees provided by the same GDPR. Pending the initiation of procedures for a suitability assessment by the European Commission, data processing is permitted if the data subject is a party to a contract or pre-contractual measures, or has given consent, and is informed of the possible risks of such a data transfer (Art. 49 GDPR - derogations in specific situations).
Further data transfer is possible due to the use of the services of Facebook, Google and any other external social or processing providers located in the USA. Such data processing is covered under the "Privacy Shield" agreements signed by the individual companies.

The location of data processing
The processing connected to the web services of TITANKA! Spa takes place in ITALY on the servers of Farm KPN Quest and CD Lan in via Caldera, 21 Milan, these parties are suppliers to Semplify Srl with headquarters in Strada degli Angari, 46 47891 Falciano RSM. Semplify Srl is the service provider for the technological infrastructure (controller). Data processing for the maintenance and management of the website is carried out by TITANKA!, who is the controller of data processing.

Receivers:
For the purpose of carrying out and providing support for the operation and organisation of the activity, some data may be brought to the attention of, or communicated to, the receivers. These parties are divided into: Third parties, controllers and sub-controllers, and authorized personnel under the control of the owner or controller.

Third parties:
are defined as natural or legal persons, public authorities, departments or other bodies other than the data subject, the owner of the processing, the controller of the processing and the authorised persons responsible for the processing.
For the processing of data relating to administrative purposes, accounting, legal obligations, customer management, and contracts the data may be communicated to:
- Companies operating traditional or computerised postal services both in the Republic of San Marino and in Italy
- Any entities and public administrations of the Republic of San Marino for tax obligations
- Registrars of domain names
- Any other persons for whom the communication of data is necessary to achieve the above purposes, or to fulfil legal obligations

Controllers and sub-controllers of the processing:
are defined as natural or legal persons, public authorities, departments or other bodies which process personal data on behalf of the owner of the processing operation
- Semplify Srl is the primary controller of the processing; there are also sub-controllers, service providers for technology infrastructure, connectivity, and hosting services.
- The sub-controllers of the processing provide services such as those of KPN Quest and CD Lan – server farm managers in c/o Milan - Italy, the location of the stored data.
- Other possible providers of IT services necessary for the provision of the service

Within our internal business structure:
Your data will be processed only by personnel expressly authorized by the Owner, with assurance of adoption of appropriate instructions, training, confidentiality agreement and, in particular, by the following categories of employees:
- Administration personnel, technical system administrators, and any other authorized personnel who need to process data for the proper management of the services.

Dissemination
Your personal data will not be disseminated in any way.

Owner of the data processing
TITANKA! Spa - Strada degli Angariari, 46 - 47891 - Falciano - Rep. San Marino

The Data Protection Officer (DPO)
is designated by the controller pursuant to Art. 37 of the GDPR and pursuant to Law 171/2018 of San Marino, Studio Paci & C. Srl (contact person: Luca Di Leo) Via Edelweiss Rodriguez Senior, 13 - 47924 Rimini (RN) - Italy - Tel. 0541 1795431, cell. 3931019939, email: dpo@studiopaciecsrl.it

Representative in the area
Paci Rappresentante Privacy Srl – offices at Via E.Rodriguez Senior, 13 - 47924 Rimini (RN) – legal seat at Piazzetta Gregorio da Rimini, 1 - 47921 Rimini (RN) - tel. 0541 1795431 – email: dpo@studiopaciecsrl.it

Rights of data subjects:
You have the right to request from the controller the cancellation (right to be forgotten), the limitation, updating, rectification, transferability, as well as to object to the processing of personal data that concerns you; in general, you can exercise all the rights provided for in Articles. 15, 16, 17, 18, 19, 20, 21, 22 of the GDPR, and for the same articles of the Law 171/2018 of San Marino.
Rights of the data subject
1. The data subject shall have the right to obtain confirmation as to whether or not personal data concerning him/her exist, regardless of it already being registered, as well as a communication of such data in an intelligible form.
2. The data subject has the right to obtain information:
about the origin of the personal data; the purposes and methods of processing;
about the logic applied to the processing of personal data using electronic means; about the identity of the owner of the data processing, the controller of the data processing and the representative designated in accordance with article 5, paragraph 2;
about the parties or categories of parties to whom the personal data may be communicated or who may become aware of it as the appointed representative in the territory of the State, as managers or agents.
3. The data subject has the right to obtain:
the updated, corrected or, when necessary, integrated data; the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;
a certification that the activities referred to in points a) and b) have been communicated, also in regard to their content, to those to whom the data were communicated or disseminated, unless this requirement proves impossible or involves a clearly disproportionate use of resources compared to the protected right; the portability of data.
4. The data subject has the right to object, in whole or in part:
on legitimate grounds, to the processing of personal data concerning him/her, even if pertinent to the purpose of the collection; to the processing of personal data concerning him/her for the purpose of sending advertising materials or direct selling or for the performance of market or commercial communication surveys.
The data subjects, if the requirements are met, also have the right to lodge a complaint with the Guarantor as supervisory authority in accordance with the procedures laid out. For any further information, and to assert the rights granted to you by the European Regulation, or by the law of San Marino, you can contact the owner of the data processing using the contact information provided above.

Having reviewed the information and the method for obtaining consent from the data subject
The undersigned, having received the information provided by the owner of the data processing in accordance with Article 13-14 and the GDPR and Law 171/2018, hereby confirms that he/she has read this information on data processing, for the purposes essential to the continuation of the relationship relating to the provision of the service as requested by him/her, indicated in the above information, as necessary to allow the co-owners a proper management and proper processing of the data, in order to provide the service, manage and respond to its requests, also considering that TITANKA! Spa, the owner of the data processing is located in the Republic of San Marino, a country outside the EU that has adopted Law 171/2018 in accordance with the GDPR, whose guarantees of adequacy are in the process of being requested from the European Commission.

Consent
As proof of your explicit and unequivocal consent for optional purposes such as direct marketing, and jointly the processing of your data in non-EU countries (Republic of San Marino), we will record the time, date, IP address, and your email address. We would like to remind you that you may exercise your rights at any time (as set out above) through the link at the bottom of the notifications you receive, or through the channels of communication.

Extended information on the use of cookies

Extended information on the use of cookies with reference to "good practices" relating to the provision of the Privacy Guarantor no. 229/2014, and the fact that cookies are considered to be the same as personal data, as defined in recital no. 30 of the GDPR referred to in art. 4, paragraph 1, for those who use the web services of TITANKA! Spa, is accessible from the addresses www.abcvacanze.it. The TITANKA! Spa website uses cookies and similar technologies to ensure proper operation of procedures and improve the user experience of online applications. This document provides detailed information about the use of cookies and similar technologies, how they are used by TITANKA! Spa and how to manage them.

Definitions

Cookies are small text strings that the websites you visit send to your computer (usually your browser), where they are stored and then sent back to the same websites the next time you visit. Cookies are stored, according to the user's preferences, by the individual browser on the specific device used (computer, tablet, smartphone).

Different types of cookies

Depending on their characteristics and use, cookies can be divided into different categories:

Necessary cookies
These cookies are essential to manage the login and access to the restricted functions of the website, typically for updating pages by web editors. The duration of these cookies is strictly limited to the work session (when the browser is closed they are deleted). Their deactivation compromises the use of the services accessed through the login. The public part of the websites, on the other hand, remains usable at all times.
Technical cookies (for analysis and performance)
These are cookies used to collect and analyse anonymous traffic and website usage. These cookies, while not identifying you, allow us, for example, to detect if the same user returns to connect at different times. They also allow us to monitor the system and improve its performance and usability. Some pages of the www.abcvacanze.it website may store the user's preferences regarding the font size and the preferred viewing method (graphics, high contrast or text) in order to make the content more accessible. The deactivation of these cookies can be performed without any loss of functionality.
Profiling cookies
These are permanent cookies used to identify (anonymously or not) your preferences and improve your browsing experience.
Duration of cookies
Some cookies (session cookies) remain active only until the browser is closed or the logout command is executed. Other cookies "survive" when you close your browser and are also available on subsequent visits by the user. These cookies are called persistent and their duration is fixed by the server at the time of their creation. By browsing through the pages of www.abcvacanze.it, you may interact with websites operated by third parties that may create or modify persistent and profiling cookies. The temporal storage of each individual cookie is visible in the list "cookies".  
Management of cookies
The user can decide whether or not to accept cookies using the settings of their browser. Disabling all or part of the cookies may compromise the use of the website's features, but may not prevent you from browsing the website. The settings can be specifically defined for different websites and web applications. Below are web resources that illustrate how to proceed for each of the major browsers: Chrome, Firefox, Internet Explorer, Opera, Safari. 

List of cookies

Cookie name	Type	Service name	Description	Length	Domain
cookieAccepted	technical	Privacy policy	Hide the privacy policy bar	1 year	www.abcvacanze.it
newsletter-first	technical	Popup newsletter	Record the timestamp of the first page visited	1 year	www.abcvacanze.it
newsletter-pages	technical	Popup newsletter	Record the number of pages visited	1 year	www.abcvacanze.it
newsletter-popupHide	technical	Popup newsletter	Register the closure and keep the newsletter subscription popup closed	1 year	www.abcvacanze.it
newsletter-popupSended	technical	Popup newsletter	Register the newsletter subscription	1 year	www.abcvacanze.it
PHPSESSID	technical	WebServer	Identification Number of the web session	up to the end of the web session	www.abcvacanze.it, admin.abc.sm
SERVERID	technical	WebServer	Identification Number of the server that managed the user enquiry	up to the end of the web session	www.abcvacanze.it, admin.abc.sm

Exercise of users' rights