PRIVACY POLICY


This policy (hereinafter, “Privacy Policy”) concerns the processing of your personal data during your navigation of the website www.ar92landcoproperty.com (hereinafter, the “Site”) carried out by AR92 s.r.l., with registered office at Largo Antonio Giusti 13, 16038 Santa Margherita Ligure (GE), VAT no. 02114890995, email info@ar92.com (hereinafter, the “Data Controller”), in compliance with current regulations on personal data protection, including EU Regulation 2016/679 (“GDPR”).

‍

  1. Identity and contact details of the Representative

The Data Controller is AR92 s.r.l.  

As the Data Controller is established within the EU, no representative has been appointed.

‍

  1. Processing methods

To complete your connection to the Site, some of your personal data is collected. This data set includes, for example:

  • the IP address of the device you are using;
  • the date and time of access;
  • the type of browser used;
  • the operating system used.

To subscribe to the Data Controller's newsletter, the following will be processed:  

  • first name, last name;  
  • email.

To subscribe to the third-party newsletter, the following will be processed:  

  • first name, last name;  
  • email

To complete your ‘Contact Form’ request, personal and contact details will be processed (first name, last name, email, and phone number [and any further information you may include in the “Message” field of the Contact Form

‍

The following data will be processed for remarketing activities:  

  • first name, last name;  
  • email.

‍

  1. Purposes of processing and legal basis for processing

Your personal data will be processed for the following purposes:

  1. Personal data processed during website navigation: providing this personal data is a contractual obligation, without which the services of the website could not be made available and function correctly.
  1. Personal data processed via newsletter subscription to send commercial communications via traditional and remote means of communication, including email, SMS, social networks, instant messaging, mobile applications, banners, mail, and telephone, for the promotion and/or sale of products and/or services marketed by the Data Controller: providing this personal data is optional and is based on your consent, without which you would not be able to complete your subscription to the newsletter service offered by the Data Controller.  
  1. Personal data processed via the Contact Form: providing this personal data is optional and is based on the Data Controller's legitimate interest in responding to your contact requests via the form on the Site. If not provided, the Data Controller will be unable to respond to such requests.  
  1. Source of personal data

Only personal data provided in accordance with the Privacy Policy will be processed. The Data Controller will not process personal data obtained from publicly accessible sources.

‍

  1. Recipients and categories of recipients of personal data  

Personal data may be disclosed to:

  • companies that offer information society services, including, in particular, those providing hosting and newsletter services;  
  • companies that provide commercial and marketing services on behalf of the Data Controller;
  • companies that provide cloud software;
  • the company responsible for website management and maintenance.
  • third-party service providers for the analysis of so-called client insight, for Re-Marketing purposes, such as Google Analytics.
  • parties performing real estate brokerage tasks and services on behalf of or for the benefit of the Data Controller;
  • companies directly or indirectly affiliated with the Data Controller.

The parties belonging to the categories mentioned above may act as data processors when acting on behalf of the Data Controller, or operate independently as separate data controllers. The Data Subject's data processed by the Data Controller will not be published or disseminated in any other way.

‍

  1. Categories of personal data

Personal data necessary to complete your connection to the Site, newsletter subscription, and submission of requests via the Contact Form will be processed. Under no circumstances will special categories of personal data as defined in Article 9 of the GDPR be processed.

‍

  1. Data transfer  

The Data Controller intends to transfer Personal Data to entities established in a country outside the European Union in compliance with applicable regulations, specifically: the United States of America [and Canada]. Any transfer of your Data to countries located outside the European Economic Area will, in any case, take place in compliance with appropriate and suitable safeguards for the transfer, pursuant to Articles 44 et seq. of the GDPR.

These parties may include, for example:

  • communication companies performing communication activities on behalf of the Data Controller;  
  • information society service providers;
  • hosting service providers;  
  • communication service providers;

To obtain a copy of such data or information on where it has been made available, simply send a request to the Data Controller at the addresses provided above.

‍

  1. Data retention period  
  • Personal data processed and stored for the purposes referred to in point 3.a (contractual purposes) are processed and stored by the Data Controller in accordance with applicable regulations, and in any case for a period not exceeding 10 years from the termination of the contract, unless otherwise required by law.
  • Personal data processed and stored for the purposes referred to in point 3.b (marketing purposes) are processed and stored by the Data Controller until consent is withdrawn, unless otherwise required by law.
  • Personal data processed for the purposes referred to in point 3.c (responding to requests), provided voluntarily via email or forms and processed to address your requests, will be stored for the period strictly necessary to achieve this purpose and, in any case, for no longer than 12 (twelve) months from the date of collection.

‍

  1. Methods of giving consent, optional nature of consent, and consequences of withholding consent

Consent may be given by signing a paper or electronic document, or by using specific checkboxes.

  • In relation to personal data processed for the purposes referred to in point 3.a of this Privacy Policy (contractual purposes), the provision of personal data is mandatory. If you do not provide such personal data, it will not be possible to provide the connection and website browsing service.
  • In relation to personal data processed for the purposes referred to in point 3.b of this Privacy Policy (consent), the provision of personal data is optional. If you do not provide such personal data, it will not be possible to provide the newsletter service.
  • In relation to personal data processed for the purposes referred to in point 3.c of this Privacy Policy (legitimate interest), the provision of personal data is optional. If you do not provide such personal data, it will not be possible to respond to requests made via the Contact Form.

‍

  1. Right to object  

As a Data Subject, you have the right to object under the following terms:

  • The right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you pursuant to Article 6(1)(e) or (f) of the GDPR. The Data Controller shall no longer process your personal data unless the Data Controller demonstrates compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.
  • Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • In the event of an objection to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes. You may object to the processing of your personal data for direct marketing purposes either in whole or in part, for example by objecting only to the sending of promotional communications via automated and/or digital tools, or to the sending of paper-based communications and/or the receipt of telephone communications.
  • Where your personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1) of the GDPR, you have the right, on grounds relating to your particular situation, to object to the processing of personal data, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

‍

  1. Other rights

The Data Controller also wishes to inform you of the existence of the following rights:

  • Right of access: You have the right to obtain from the Data Controller confirmation as to whether or not personal data concerning you are being processed, and to access your personal data and specific information, in accordance with Article 15 of the GDPR.
  • Right to rectification: You have the right to obtain from the Data Controller the rectification of inaccurate personal data concerning you without undue delay. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by providing a supplementary statement, in accordance with Article 16 of the GDPR.
  • Right to erasure of data, including the right to withdraw consent: you have the right to obtain from the Data Controller the erasure of your personal data without undue delay or to withdraw your consent to processing, if the grounds defined by Article 17 of the GDPR exist. You have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
  • Right to restriction of processing: you have the right to obtain from the Data Controller the restriction of processing when the conditions defined by Article 18 of the GDPR are met;
  • Right to data portability: you have the right to receive the personal data you provided to the Data Controller in a structured, commonly used, and machine-readable format, and you have the right to transmit those data to another controller without hindrance from the Data Controller indicated in this Privacy Policy, as provided for by Article 20 of the GDPR;
  • Subscriber's right to object to commercial communications: as a subscriber, you have the right to object at any time, free of charge, to receiving commercial communications from the Data Controller;  
  • Right to lodge a complaint with the Data Protection Authority: you have the right to lodge a complaint with the Italian Data Protection Authority if you believe there has been a breach of personal data protection regulations, in accordance with Article 77 of the GDPR.

‍

You may exercise the rights set out in the Privacy Policy by addressing your requests directly to the Data Controller at the email address dpo@ar92.com, or by sending a registered letter with return receipt to Largo Antonio Giusti 13, 16038 Santa Margherita Ligure (GE). You may lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei dati personali) according to the procedures provided on their official website, using the contact details available at https://www.garanteprivacy.it/home/footer/contatti.

  1. How to exercise your rights  

‍

  1. Accessibility of the Privacy Policy

The Privacy Policy is available on the Website or at the Data Controller's premises. Upon express request, the Data Controller may provide the information orally, provided your identity is verified, by calling the following number: +39 0185 290331

‍

  1. Changes  

The Data Controller may modify this Privacy Policy to comply with changes in national and/or European Union legislation, or to reflect technological innovations. Any new versions of the Privacy Policy will be posted on the Website. We encourage you to check the Privacy Policy periodically. You will be notified of any changes via a pop-up on the Website or other digital methods and/or tools.  

If the Data Controller makes substantial changes to the Privacy Policy, such as introducing new processing purposes and/or categories of personal data, they will inform you and request the necessary consents via a pop-up on the website or other digital methods and/or tools.