Andrea Tarsi​, in his capacity as the owner of the homonymous sole trader, with registered office in Rome, – Vat n:10338790586 in his capacity as the data controller, informs you, in compliance with the obligations determined by the national law (Legislative Decree 30 June 2003 n. 196, Code concerning personal data protection) and European law, (European rules about personal data protection n. 679/2016, General rules about data protection) as amended, about the modalities for site management and web platforms with respect to the processing of personal data. Andrea Tarsi considers that, in fact, it is necessary that those who visit the website: info@sanpietrovaticanapartments.it
feel protected both during the browsing and in the case in which they choose to communicate information and their data in order to use specific functions and/or services. For these reasons, we invite you to read carefully the following policy prior to the transmission/communication of any kind of personal data and/or filling in electronic forms on the same web sites. In particular, in this document we will inform you about:

1. THE SUBJECT-MATTER OF THE PROCESSING
2. THE PURPOSE OF THE PROCESSING
3. THE TREATMENT MODALITIES
4. THE DATA RETENTION
5. THEDATAACCESS
6. THE COMMUNICATION OF DATA
7. THE DATA TRANSFER
8. THERIGHTSEXERCISABLE
9. THE ARRANGEMENTS FOR THE EXERCISE OF THE RIGHTS
10. THE OWNER, THE DATA CONTROLLER AND THE DPO (Data protection officer)

1. The subject-matter of the processing

What data will be used? The Owner treats:

• the personal data, identification and not sensitive data, in particular, name, surname, tax code, Vat number, e-mail address or PEC email (Certified e-mail), telephone and fax number, house address, domicile address, the data necessary to provide the services inside the portal itself, included the browsing data, as well as any other data that you will provide during the filling of the various f​ orms;
• the browsing data acquired by the information systems and by the software procedures to operate on the usability of the web sites above mentioned.

These are information that are not acquired to be associated to identified person concerned, but by their nature may, throughout processing and associations with data held by third parties, allow the identification of the users. In this category of data are included the IP addresses or the domain names of the computers used by the users that get connected to the site, the addresses in URI (Uniform Resource Identifier) of the requested resources, the hour of the request, the method used giving the request to the server, the file dimension obtained as response, the numeric code indicating the status of the response provided by the server (success, error, etc.) and other parameters relating to the operative system and the computing environment of the user;

• the data linked to your preferences and interests, in particular: the contents used, the use of the services, the features used, the connection times, the traffic data, the browsing data on websites and social profiles of the Owner or commercial partners or third parties, the IP address, the devices and the connections used. This data can be collected also through cookies and metadata;
• The data provided voluntarily by the user:
  to access certain services/features or to send requests, the person who browse the site may send to Tarsi Andrea their personal data (e.g. own e-mail address).This data will be processed by the owner just to provide the use of services/features involved and to manage the requests, as long as it takes to these purposes. If those data may be collected for other purposes, this condition will be, time to time, indicated by specific disclosures and, where necessary, you will be asked to consent to data processing.

2. The purpose of the processing Your personal data will be processed:

1. without Your consent (art. 6, letter b, c, f, General Rules About Data Protection), for the following purposes:

• to implement a service or to perform a service or one or more operations contractually agreed, with particular reference to the registration to the websites above mentioned and to the corresponding use of the services;
• the fulfillment of any fiscal or tax obligation;
• to reach you back, through the data you supply, to satisfy yourpotential request expressed in the forms available on the websites;
• to follow up legal requirements (national or european), or to obey anorder by the judicial Authorities or by supervisory bodies;
• to exercise or defend the rights of the Owner in a Court of Law;

1. with Your consent (art. 7, General Rules About Data Protection), for the following purposes:

• to promote products and services by Andrea Tarsi to send advertising, information, promotional material and updates about initiatives and special offers aimed at rewarding the Customers, market research, economic and statistical analysis;
• reports to third parties in order for them to send advertising, information and promotional material concerning their products or services.The provision of data for the purposes referred to above lett. a) is mandatory. Lack of data and/or the possible rejection to data processing will make it impossible for the Owner to follow up your requests or to fulfil the requests of the competent Authorities.On the contrary, the provision of data for the purposes referred to the lett. b) is optional, with the consequence that You may decide to not give your consent, namely to revoke it anytime.There are no automated decision-making processes concerning physical persons. Whenever Andrea Tarsi would proceed in this way, he will provide, prior to the processing, to the collection of the relative consent from the data subject.

3. Treatment modalities

How Your data will be used?

Your personal data processing will be put in place with or without the help of computer systems.

Andrea Tarsi is committed to ensuring the logical and physical security of data and, generally, the privacy of the processed personal data, by putting in place all the technical and organising measures needed to grant their privacy.

4. Data retention

How long your data will be stored?

The personal data collected for the purposes referred to this policy will be processed and stored for the entire duration of the possible relationship established and even further to the extent permitted by law, for administrative and accounting purposes, as well as to assert or to protect the rights of the Owner, where necessary.

5. Dataaccess

Who can access such data?

Your data are accessible by.

• employees and/or assistants of Andrea Tarsi;
• Subsidiary companies and/or associated companies and/or relatedand/or affiliates that contribute to create, maintain and improve all Owner’ services in their capacity as representatives and/or in-house officers of the processing and/or system administrators;
• Commercial partners and services providers that carry out outsourcing activities on behalf of Andrea Tarsi in their capacity as external data processors – performing related, exploitative or supportive activities to the Owner’s, i.e.: operation and mainteinance of the contents of the websites and Apps, customer service, Information Technology systems operations, publishing services, credit recovery, data processing services for the invoicing, storage of documents related to the customers relations, etc.

6. Communication of data Who can see Your personal data?

Andrea Tarsi can disclose Your data without Your explicit consent for the service purposes:

• to the judicial authorities, upon their request;
• to the subsidiaries and/or associated companies and/or relatedand/or affiliates, to the Owner’ sales network and to all the other subjects to whom is necessary to notify it, by law or by contract, in order to allow the purposes above mentioned to be carried out (as for example, credit institutions, professional practices, commercial partners).The Owner can disclose Your data with Your explicit consent to the subsidiaries and/or associated companies and/or related and/or affiliates by/to Andrea Tarsi in order to allow the marketing purposes mentioned in point 2 lett. b to be carried out).These subjects will process Your data in their capacity as independent Data Controller.In any case, we want to reassure You that Your data will not be disclosed.

7. Data transfer

Where Your personal data are transferred?

Your personal data may be transferred outside the European Union to the subjects indicated in the paragraph 5 and 6. In order to protect Your data under these transfers, the Owner uses appropriate safeguards, including adequacy decisions and the standard contract terms approved by the European Commission.

8. Rightsexercisablebythedatasubject
In Your capacity as data subject, you can exercise your rights referred to the

articles 15 to 22 General Rules About Data Protection.

Where the limitations as prescribed by law do not exist, You have every right to:

• have confirmation of the existence or otherwise of Your personal details, even if they have not yet been registered and to to request that these are being made available in plain and intelligible language
• ask for informations and, in the event, a copy:

1. of the origin of Your personal data;
2. of the logic of use, in the event that Your information are processedwith electronic means;
3. about data treatment purposes and mode;
4. of the identification details of the Owner and the Data Controllers;
5. ofthesubjectsandthecategoriesofsubjectstowhomYourpersonaldata may be transmitted and they may become aware of it;
6. of the period in which Your data have been stored or the standardsused to define such period, whenever possible;
7. of the existence of an automated decision ​–​ making, including theprofiling. In that case you may require the logics used, the importanceand the consequences provided for you;
8. oftheexistenceofappropriatesafeguardsincaseofYourdatatransfer to a non-EU country, to an international organization;

• to obtain, unless there is a justifiable delay, the update, the change, the correction of Your incorrect data or the integration of Your not complete data, if you are interested;
• to obtain the deletion, the block of Your data or, where possible, the transformation in anonymous way:

9. if treated by infringing the law;

2. if no longer needed for the purposes for which it was collected or further processed;
3. in case of withdrawal of the consent on which the processing is based and if there is no other legal basis;
4. in case you opposed to treatment and there are no other justifiable reason to continue using your data;
5. incaseitisrequiredbylaw;
6. in case it is related to minors.