Mr Francesco Bifolco, as Managing Director of WIP AP– S.r.l., registered office in Via Generale Orsini, 46 – 80132 Naples (NA) – Italy - Tax Code and VAT N. 04188940631(hereafter, the “Data Controller”), as the data controller, pursuant to the L.D 30.6.2003 n. 196 (hereafter “Privacy Code”) and to articles 12, 13and 14 of General Data Protection Regulation (hereafter “GDPR”),here informs that your data will be processed in the manner and for the following purposes:

1. Content of data processing

The Data controller handles personal data identification (for example, name, surname, company name, address, telephone number, e-mail, tax code and / or VAT number, bank and payment references such as credit and debit cards provided as guarantee and / or on balance, also with reference to minors accompanied by the holder of parental responsibility or to minors at least fifteen years old;

- general information and details of the identification documents, date of arrival and number of overnight stays, kinship degree and in general the data necessary for the public security regulatory compliance; here after, "Personal data" or also "data") communicated by you on the occasion of offers, orders and contracts for the services of the Data controller. 

2. Purpose of data processing

Your personal data are processed:

A) without explicit consent ((art. 24 let. a), b), c) Privacy Code), e) GDPR), for the following Service Purposes and with different means of communication (e.g. telephone, mobile phone, sms, Email, fax, certified email, mail):

- conclude contracts for the services of the Data controller;

- fulfil the pre-contractual obligations, contractual and financial obligations arising from the relations in place with you;

- fulfil the obligations established bylaw, by the EU legislation or by an order of the Authority (such as for anti-money laundering).In particular, the obligations provided by the "Consolidated Act on Public Security Laws" (article 109 of R.D. 18.6.1931 n. 773) which requires, for public security purposes, to communicate the personal details of customers stays to the Central police station, according to the procedures set by the Ministry of Internal Affairs (7 January 2013 Decree)

- exercise the rights of the Data controller, for example the right to defence in court;

- for the purpose of protecting people, property and company assets through a video surveillance system of some areas of the structure, pinpointed by specific signs.

B) Only prior to your specific and clear consent (arts. 23 and 130 Privacy Code and art. 7 GDPR), for the following Marketing Purposes:

- 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 the detection of satisfaction level on the quality of services;

- send via e-mail, mail and / or SMS and / or telephone contacts commercial and / or promotional communications of third parties (for example, business partners, insurance companies, other companies of the Card Protection Plan Group).Please note that if you are already one of our customers, we may send you commercial communications about services and products of the Data controller similar to those you have already used, except if you disagree(art. 130 p.4 Privacy Code).

3. Modality of data processing

The processing of your personal data is carried out by means of the operations specified in art. 4 Privacy Code and art. 4 n. 2) GDPR and precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data are subject to both paper and electronic and / or automated processing. 

4. Access to data

Your data may be made accessible for the purposes referred in art. 2.A) e 2.B):

- to employees and collaborators of the Data controller in Italy as authorized persons and / or internal data processors and / or system administrators;

- to third-party companies or other subjects (as an indication, credit institutions, professional firms, consultants, insurance companies for the provision of insurance services, etc.) who carry out outsourced activities on behalf of the Data controller, in their capacity as Independent data controllers or as Data Processors.

5. Data communication

Without the need for an express consent (ex.art. 24 lett. a), b), d) Privacy Code and art. 6 b) and c) GDPR), the Data controller can communicate your data for the purposes referred in art. 2.A) to Public Bodies and Supervisory Bodies, Judicial Authorities, to insurance companies for the provision of insurance services, as well as to those subjects to whom disclosure is mandatory by law for the accomplishment of the said purposes, including the fulfilment of contracts for the services of the Data controller. The above-mentioned subjects will process data as independent external data controllers or if the case, as external data processors. Your information will not be disseminated.

6. Data transfer

Personal data are stored on servers located at the headquarters within the European Union and on servers owned by Cloud Services providers, who will process the data in their capacity as independent data controllers. In any case, it is understood that the Data Controller, if necessary, will have the right to move the servers even outside the EU. In this case, the Data Controller hereby ensures that the data transfer to non-EU countries will take place in accordance with the applicable legal provisions, upon stipulation of the standard contractual clauses provided by the European Commission.

7. Nature of data provision and consequences of refusing to answer

Data provision for the purposes referred in the art. 2.A) is mandatory. In their absence, we cannot guarantee the services of the art.2.A). Data provision for the purposes referred in art. 2.B) is optional. You can therefore decide not to give any data or subsequently to 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. However, you will continue to be entitled to the Services referred to in art. 2.A).

Your consent is not required for the video surveillance processing, as it pursues our legitimate interest in protecting people and goods against possible assaults, thefts, robberies, damages, vandalism and for fire prevention and work safety. The recorded images are deleted after 24 hours, except on holidays or other cases of closing periods, and in any case not later than one week. They are not subject to communication to third parties, except in the case we must support a specific investigation by the legal authority or police.

8. Rights of the interested party

As an interested party, you have the rights set forth in art. 7 Privacy Code and art. 15 GDPR and precisely the rights to:

i. obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;

ii. get the indication: a) of personal data origin; b) of the purposes and methods of processing; c) of the logic applied in case of processing carried out with electronic means; d) of the identification details of the controller, of the processors and of the designated representative pursuant to art. 5, paragraph 2 Privacy Code and art. 3, paragraph 1, GDPR; e) the subjects or the categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the territory of the State, managers or agents;

iii. to obtain: a) the updating, rectification or, when interested, integration of data; b) 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. c) the declaration that the operations referred to in letters a) and b) have been brought to the attention, also with regard to their content, to those to whom the data have been communicated or disseminated, except in the case where the fulfilment proves impossible or involves a use of means manifestly disproportionate to the protected right;

iv. oppose in whole or in part: a) for legitimate reasons, 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 or direct sales material or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by e-mail and / or through traditional marketing methods by telephone and / or paper mail. It should be noted that the right of opposition of the interested party, set out in point b) above, for direct marketing purposes through automated methods extends to the traditional ones and that in any case the possibility remains open to the interested party to exercise the right to oppose even partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or none of the two types of communication.

Where applicable, it also has the rights referred to in Articles 16-21 GDPR (Right of rectification, right to be forgotten, right of limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.

9. How to exercise rights

You can exercise your rights at any time by sending:

- a registered mailto the headquarters of the Data Controller, in Via Generale Orsini, 46 – 80132 Napoli (NA)

- an e-mail to the address: info@wipap.it

12. Limitations

The rights of the interested party, referred to in point 8, may be subject to limitations as per art.23 GDPR to safeguard, among others, national security; the defence; public safety and other specific cases envisaged.

13. Duration of data processing and storage

The Data Controller will process the personal data for the time necessary to fulfil the aforementioned purposes and in any case for no more than 10 years from the termination of the Service Finality relationship and not later than 2 years from the collection of data for Marketing Purposes.

13. Data Controller, processor and authorized persons

The updated list of data processors and authorized persons is kept at the registered office of the Data Controller