NEWSLETTER INFORMATION
pursuant to Article 13 of the GDPR – General Data Protection Regulation EU 2016/679
Version updated on 29/01/2025
Data Controller
The data controller is RAPHAEL S.R.L., with head office in Piazza de Giovanni, 4 – 38050 Roncegno (TN)
Contacts:
- Email: info@casaraphael.com
- PEC [certified address]: casaraphael@pec.it
- * Telephone +39 0461/772000.
Data Protection Officer
The Data Protection Officer (DPO) designated, pursuant to Art. 37 of Reg. EU 2016/679, is Giovanni Poletto, at Studio Gadler S.r.l. – Via Graberi 12/A – 38057 Pergine Valsugana (TN)
Contacts:
- Email: dpo@studiogadler.it
- Telephone: +39 0461-512522
Purpose and legal basis of processing
The personal data collected are processed for the following purposes:
– Management of newsletter subscription and sending of informative and promotional communications relating to Casa Raphael services and special initiatives (data subject’s consent, Art. 6, (1) (a) GDPR);
– Sending electronic communications of a commercial nature based on Art. 130 (4) of Legislative Decree no. 196/2003, on the legitimate interest of the Data Controller (legitimate interest, Art. 6, (1) (f) GDPR);
– Handling of any requests to unsubscribe from the newsletter (legal obligation: Art. 6, (1) (c) GDPR-);
– Management of any legal disputes and litigation, including the defence of the Data Controller’s rights in and out of court (legitimate interest, art. 6, (1) (f) GDPR).
The customer may unsubscribe from the mailing service at any time, pursuant to Art. 7 (3), GDPR, by means of the appropriate unsubscribe link in the communications received.
Nature of data provision and consequences of refusal.
The provision of personal data to subscribe to the newsletter is optional; however, failure to do so will result in the impossibility to receive updates and promotional communications.
Methods of treatment
The data will be processed by means of computerised and electronic tools, with logic strictly related to the aforementioned purposes, in compliance with the security measures provided for by the regulations in force to guarantee the confidentiality, integrity and availability of the data.
Newsletters are sent via MailChimp, an online marketing platform operated by The Rocket Science Group LLC (Georgia, USA). More information on MailChimp’s privacy policy can be found here.
Cancellation of service
To unsubscribe from the newsletter, it is possible to use the ‘unsubscribe’ link at the bottom of each newsletter. In case of technical problems, please contact: info@casaraphael.com.
Retention period
Personal data will be kept for the period of time strictly necessary for the processing purposes described in this notice. In particular:
– The data collected for the purpose of sending the newsletter will be stored until the data subject exercises their right to unsubscribe, or at the latest for a period of 24 months from the date of the last interaction (open, click or reply) with a newsletter.
– Data processed for legal or administrative obligations will be retained for the time stipulated by the relevant regulations, in accordance with the retention periods established by law.
The customer may, at any time, exercise the right to erasure of data by sending a request to the Data Controller or by using the unsubscribe link in any communication.
Recipients of personal data
Personal data may be disclosed to third parties who provide newsletter management and marketing services. In particular:
– Persons authorised by the Data Controller, bound by confidentiality;
– Any third parties to whom it is necessary to communicate the data due to legal obligations or at the request of the competent authority;
– MailChimp, provided by The Rocket Science Group LLC, based in the United States, for managing the sending of newsletters.
– Other data processors designated by the Data Controller for specific purposes, such as the management of the website or support systems, to whom the data may be transferred for the performance of contracts or services requested.
Place of processing.
Personal data will generally be processed within the European Union. However, the Data Controller may transfer the computer files to countries outside the EU, guaranteeing that any transfer will only take place to states that provide an adequate level of protection, in accordance with Art. 45, 46 and 49 of Regulation (EU) 2016/679 (GDPR).
In particular, personal data may be transferred to and processed by MailChimp in the United States in compliance with the Standard Contractual Clauses (SCCs ) approved by the European Commission and, where applicable, EU-U.S. provisions. Data Privacy Framework.
Surveys and statistical analyses
Our emails contain a web beacon (e.g., a pixel file) that is retrieved by the MailChimp server every time you open one of our emails.
This means that, upon receipt of our e-mail, certain technical information is collected, including:
– the type of browser and operating system used,
– the IP address,
- the time that the email was opened.
This data is only used to improve the Newsletter distribution service and can only be associated with the recipient in case of technical necessity.
Statistical analysis allows us to know whether newsletters are opened and when, and which links are clicked on. This information helps us to tailor the content of our communications, sending you emails that are more relevant to your interests.
Data subject’s rights with regard to data processing
Pursuant to Articles 15, 16, 17, 18, 19, 20, 21, and 77 of the EU Regulation, the Data Subject is hereby informed that
– has the right to request access to, rectification, deletion or restriction of personal data concerning them, or to object to the processing of same, and the transfer to another data controller in the cases provided for;
– any rectification or deletion or restriction of processing carried out at the request of the data subject – unless this proves impossible or involves a disproportionate effort – will be communicated by the writer to each of the processors to whom the personal data have been transmitted;
– has the right to lodge a complaint with the Privacy Authority, following the procedures and instructions published on the Authority’s official website at www.garanteprivacy.it.
The exercise of rights is not subject to any formal constraints and is free of charge.
