Sintur s.a.s. is the company appointed by the Municipality of Sardara for the activation of the DMS platform and its integration into the website within the framework of the “VISIT SARDARA” Project.
RDP SARDINIA 2014-2022. INTERVENTION TYPE 19.2.1.7.5.1.1.10 Implementation of the hiking itineraries of Sardara.

 

Sintur sas, with registered office in Capoterra (CA) and operational headquarters in Cagliari (CA), via Piovella no. 31, Tax Code and VAT no. 02750140929 (hereinafter, “Data Controller”), in its capacity as data controller, informs you pursuant to Art. 13 of Legislative Decree no. 196 of June 30, 2003 (hereinafter, “Italian Privacy Code”) and Art. 13 of EU Regulation no. 2016/679 (hereinafter, “GDPR”) that your data will be processed with the methods and for the purposes following:

1. Object of Processing
The Data Controller processes personal and identification data (for example, name, surname, company name, address, telephone number, e-mail, bank and payment details) – hereinafter, “personal data” or also “data” – communicated by you upon the conclusion of contracts for the services offered by the Data Controller on its own behalf and on behalf of third-party companies. According to the aforementioned regulation, such processing will be based on the principles of fairness, lawfulness, transparency, and the protection of your privacy and your rights.

2. Purposes of processing
Your personal data is necessary for purposes strictly connected and instrumental to the management of business relations, for administrative and accounting purposes, and for purposes related to legal obligations.
In particular, we inform you that your personal data is processed:
Without your express consent and if directly provided by you (Art. 24, letters a), b), c) of the Italian Privacy Code and Art. 6, letters b), e) of the GDPR), for the following Service Purposes:
• to conclude contracts for the services of the Data Controller or of companies for which the Data Controller is an authorized intermediary;
• to fulfill pre-contractual, contractual, and tax obligations arising from existing relations with you;
• to comply with obligations provided for by law, regulations, EU legislation, or by an order of the Authority (such as, for example, anti-money laundering regulations);
• to exercise the rights of the Data Controller, for example, the right of defense in court.

B) Only subject to your specific and distinct consent (Art. 23 and 130 of the Italian Privacy Code and Art. 7 of the GDPR), for the following Marketing Purposes:
• to send you via e-mail, mail, and/or SMS, and/or telephone contacts, newsletters, commercial communications, and/or advertising material on products or services offered by the Data Controller, and to conduct satisfaction surveys on the quality of services;
• to send you via e-mail, mail, and/or SMS, and/or telephone contacts, commercial and/or promotional communications of third parties (for example, business partners).

Please note that if you are already our customer, we may send you commercial communications relating to services and products of the Data Controller similar to those you have already used, unless you object (Art. 130, paragraph 4 of the Italian Privacy Code).
In any case, if the data is provided via the web, we will request your consent through a checkbox/click, which will confirm both that you have read this privacy policy and your agreement to the processing.

The processing of personal data includes operations such as collection, recording, organization, storage, and destruction, executed via both paper-based and electronic or automated means [1]. This processing strictly adheres to the definitions outlined in Art. 4 of the Italian Privacy Code and Art. 4, no. 2) of the GDPR [1]. Read the full GDPR guidelines on data processing.

The Data Controller will process personal data for the time necessary to fulfill the aforementioned purposes, and in any case for no longer than 10 years from the termination of the relationship for Service Purposes, and for no longer than 2 years from data collection for Marketing Purposes.

Data may be accessed by the Data Controller’s employees and collaborators, both in Italy and abroad, as well as by third-party service providers (such as banks, consultants, and mailing companies) acting as external data processors for the purposes outlined in Art. 2.A) and 2.B). This access is authorized for authorized personnel, internal processors, and system administrators. You can proceed with the translation of Article 5 (Data Communication) to complete the privacy policy for Sintur sas’s Visit Sardara project.

According to Article 5, the Data Controller may disclose user data to judicial authorities or entities required by law for specified purposes without explicit consent, pursuant to GDPR and Italian Privacy Code regulations. The data will not be disseminated, and recipients will act as independent controllers.

Personal data is stored on servers within the European Union, with the Data Controller reserving the right to transfer data outside the EU in compliance with applicable legal provisions and standard contractual clauses [1]. Should such a transfer occur, the Data Controller ensures it will adhere to the regulations established by the European Commission [1]. Further information regarding the data controller’s policies can be found on their official website.

7. Nature of data provision and consequences of refusal to respond
The provision of data for the purposes referred to in Art. 2.A) is mandatory. In their absence, we cannot guarantee you the Services referred to in Art. 2.A).
The provision of data for the purposes referred to in Art. 2.B) is instead optional. You can therefore decide not to provide any data or subsequently deny the possibility of processing data already provided: in this case, you will not be able to receive newsletters, commercial communications, and advertising material relating to the Services offered by the Data Controller. You will, however, continue to be entitled to the Services referred to in Art. 2.A).

8. Rights of the data subject
As a data subject, you have the rights referred to in Art. 7 of the Privacy Code and Art. 15 of the GDPR, and precisely the rights to:
obtain confirmation as to whether or not personal data concerning you exist, even if not yet recorded, and their communication in intelligible form;
obtain indication of: a) the origin of the personal data; b) the purposes and methods of the processing; c) the logic applied in the case of processing carried out with the aid of electronic instruments; d) the identification details of the data controller, data processors and the representative designated pursuant to Art. 5, paragraph 2 of the Privacy Code and Art. 3, paragraph 1 of the GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of them in their capacity as designated representative in the territory of the State, data processors or persons in charge of processing;

3. obtain: a) the updating, rectification or, where interested therein, integration of the data; b) the erasure, anonymization or blocking of data processed in violation of the law, including those whose retention is not necessary in relation to the purposes for which the data were collected or subsequently processed; c) certification that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, unless this requirement proves impossible or involves an employment of means manifestly disproportionate to the protected right;
4. object, in whole or in part: a) on legitimate grounds, to the processing of personal data concerning you, even if pertinent to the purpose of the collection; b) to the processing of personal data concerning you for the purpose of sending advertising materials or direct selling or for the performance of market research or commercial communication, through the use of automated calling systems without the intervention of an operator, by e-mail and/or through traditional marketing methods by telephone and/or paper mail. Please note that the data subject’s right to object, as set out in point b) above, for direct marketing purposes through automated methods extends to traditional ones, and that in any case the data subject retains the possibility to exercise the right to object even only in part. Therefore, the data subject may decide to receive only communications through traditional methods, or only automated communications, or neither of the two types of communication.
Where applicable, you also have the rights referred to in Articles 16-21 of the GDPR (Right to rectification, right to be forgotten, right to restriction of processing, right to data portability, right to object), as well as the right to lodge a complaint with the Supervisory Authority.

9. Procedure for exercising rights
You may at any time exercise your rights by sending:
• a registered letter with acknowledgment of receipt (A.R.) to Sintur sas, via Piovella 31, Cagliari;
• an e-mail to the address info@sintur.com.

10. Data Controller, Data Processor and Persons in Charge of Processing
The Data Controller and internal Data Processor is Sintur sas, with operational headquarters in Via Piovella n. 31, Cagliari, in the person of its legal representative pro tempore.
The updated list of external data processors, if appointed, and persons in charge of processing is kept at the headquarters of the Data Controller.