Privacy Policy of https://www.trapana.com

To obtain information about your personal data collected, the purposes, and the parties with whom the data is shared, please contact the Data Controller.

Data Controller: Robert Alan Potter Sanders

Registered Office: Strada vicinale Masseria Trapana – 9, 73100, Lecce, Italy

Data Controller’s Email Address: info@trapana.com

Types of Data Collected

The Data Controller does not provide a list of the types of Personal Data collected.

Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific informational texts displayed before the data is collected.  

Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application.  

Unless otherwise specified, all Data requested by this Application is mandatory. If the User refuses to provide it, it may be impossible for this Application to provide the Service. In cases where this Application indicates some Data as optional, Users are free to refrain from communicating such Data, without any consequence on the availability of the Service or its operation.  

Users who have doubts about which Data is mandatory are encouraged to contact the Data Controller.  

The possible use of Cookies – or other tracking tools – by this Application or by the owners of third-party services used by this Application, unless otherwise specified, is intended to provide the Service requested by the User, in addition to the further purposes described in this document and in the Cookie Policy, if available.  

The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through this Application and guarantees to have the right to communicate or disseminate them, releasing the Data Controller from any liability towards third parties.

Methods and Location of Data Processing

Processing Methods

The Data Controller adopts appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal Data.  

The processing is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other parties involved in the organization of this Application (administrative, commercial, marketing, legal personnel, system administrators) or external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) may have access to the Data, also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Data Processors can always be requested from the Data Controller.

Legal Basis of Processing

The Data Controller processes Personal Data relating to the User if one of the following conditions exists:

• The User has given consent for one or more specific purposes; Note: In some jurisdictions, the Data Controller may be authorized to process Personal Data without the User’s consent or another of the legal bases specified below, until the User objects (“opt-out”) to such processing. However, this does not apply if the processing of Personal Data is governed by European legislation on the protection of Personal Data;
  
• Processing is necessary for the performance of a contract with the User and/or the execution of pre-contractual measures;
  
• Processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
  
• Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
  
• Processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

It is always possible to request the Data Controller to clarify the concrete legal basis of each processing and, in particular, to specify whether the processing is based on law, provided for by a contract, or necessary to conclude a contract.  

Location

The Data is processed at the Data Controller’s operating offices and in any other place where the parties involved in the processing are located. For further information, please contact the Data Controller.  

The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the location of the processing, the User can refer to the section relating to details on the processing of Personal Data.  

The User has the right to obtain information on the legal basis of the transfer of Data outside the European Union or to an international organization governed by public international law or consisting of two or more countries, such as the UN, as well as on the security measures adopted by the Data Controller to protect the Data.  

The User can verify whether one of the transfers just described takes place by examining the section of this document relating to details on the processing of Personal Data or by requesting information from the Data Controller by contacting the contact details provided at the beginning.  

Retention Period

The Data is processed and stored for the time required by the purposes for which it was collected.

Therefore:

• Personal Data collected for purposes related to the execution of a contract between the Data Controller and the User will be retained until the execution of that contract is completed.
  
• Personal Data collected for purposes attributable to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User can obtain further information on the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.
  
• When the processing is based on the User’s consent, the Data Controller may retain Personal Data for longer until such consent is revoked. Furthermore, the Data Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
  
• At the end of the retention period, Personal Data will be deleted. Therefore, upon expiration of that term, the right of access, cancellation, rectification, and the right to data portability can no longer be exercised.  

User Rights

Users can exercise certain rights with reference to the Data processed by the Data Controller.

In particular, the User has the right to:

• Withdraw consent at any time. The User can withdraw consent to the processing of their Personal Data previously expressed.
  
• Object to the processing of their Data. The User can object to the processing of their Data when it occurs on a legal basis other than consent. Further details on the right to object are indicated in the section below.
  
• Access their Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing, and to receive a copy of the Data processed.
  
• Verify and request rectification. The User can verify the accuracy of their Data and request its update or correction.
  
• Obtain the limitation of processing. When certain conditions apply, the User can request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose than its storage.
  
• Obtain the cancellation or removal of their Personal Data. When certain conditions apply, the User can request the cancellation of their Data by the Data Controller.
  
• Receive their Data or have it transferred to another controller. The User has the right to receive their Data in a structured, commonly used, and machine-readable format and, where technically feasible, to obtain its transfer without obstacles to another controller. This provision is applicable when the Data is processed with automated tools and the processing is based on the User’s consent, on a contract of which the User is a party, or on contractual measures connected to it.
  
• Lodge a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or take legal action.  

Details on the Right to Object

When Personal Data is processed in the public interest, in the exercise of official authority vested in the Data Controller, or to pursue the legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.  

Users are informed that, if their Data is processed for direct marketing purposes, they can object to the processing without providing any reason. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.  

How to Exercise Rights

To exercise the User’s rights, Users can address a request to the Data Controller’s contact details indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within one month.  

Further Information on Processing

• Legal Defense

The User’s Personal Data may be used by the Data Controller in court or in the preparatory stages for its possible establishment for defense against abuses in the use of this Application or related Services by the User.  

The User declares to be aware that the Data Controller may be obliged to disclose the Data by order of public authorities.  

• Specific Information

At the User’s request, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.  

• System Logs and Maintenance

For needs related to operation and maintenance, this Application and any third-party services used by it may collect system logs, i.e., files that record interactions and may also contain Personal Data, such as the User’s IP address.  

• Information Not Contained in This Policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.  

• Response to “Do Not Track” Requests

This Application does not support “Do Not Track” requests.

To find out if any third-party services used support them, the User is invited to consult the respective privacy policies.  

Changes to This Privacy Policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Application, as well as, if technically and legally feasible.