Policy on the processing of users' personal data

of the website www.whitehouseimmobiliare.com

The following information ("the Privacy Policy") is provided to you, pursuant to article 13 of EU Reg. 2016/679 ("GDPR"), in order to illustrate the purposes and means of the processing of personal data related to users accessing the website www.whitehouseimmobiliare.com ("the Website") and carried out by Whitehouse Immobiliare S.r.l..

This Privacy Policy only governs the processing of personal data relating to users of the Website ("the Data Subjects"), and does not govern the processing of personal data carried out by third parties when the Data Subjects visit pages and websites accessible through links embedded on the Website.

The Website is NOT intended for navigation or use by persons under 18 years of age.

In addition to this Privacy Policy, the Data Controller may provide more specific information concerning certain processing operations that are carried out through forms embedded on the Website. 

DATA CONTROLLER

The data controller is Whitehouse Immobiliare S.r.l. (P.I. 02491080905), with a registered office in Viale Aldo Moro, 62 - 07026 Olbia (SS) ("the Data Controller"). 

For the purposes of this Privacy Policy, the contact details of the Data Controller ("Contact Details") are: 

e-mail address: info@whitehouseimmobiliare.com

tel. nr. +39 339 739 0844

TYPE OF DATA PROCESSED AND PURPOSES OF PROCESSING

Whenever a user visits the Website, the following information relating to them may be subject to processing:

       A) data related to the navigation of the Website, detected and collected by the Data Controller through the use of software applications that are necessary to ensure the ordinary functionality of the Website.

The processing of these pieces of information (such as the Internet Protocol address, the domain names of the computers and devices used by users, the browser used, the Uniform Resource Identifier and other data that, by providing information on the device and connection used to visit the Website, may indirectly allow the identification of the Data Subject), is essential to the proper functioning of the Website and is, therefore, necessary to allow users to enjoy the services offered.

Failure to provide these data will impede the navigation of the Website and the use of the services offered.

The technical parameters of the Website have been designed in order to minimize the collection and use of users’ personal data.

           B) personal Data provided voluntarily by the Data Subjects through the submission of personal information via forms available on the Website, the sending of e-mails or communications to the Data Controller’s addresses displayed on the Website and the use of the Website’s features and functions.

These personal data shall be processed:

• in order to provide the services which are being offered to the Data Subjects through the Website, and therefore in order to respond to requests sent via the form embedded in the "Contacts" subsection.

These processing operations concern information such as name and surname, cell phone number, e-mail address as well as further information voluntarily provided.

The provision of such data is optional, but it is nevertheless necessary in order for the Data Controller to be able to fulfil requests and to offer its services.

• in order to send Data Subjects newsletters promoting the services offered by the Data Controller, limited to contact details.

These processing operations are only carried out with the consent of the Data Subject, expressed by entering name, surname and his e-mail address in the appropriate form and by ticking the box. The Data Subject may revoke their previously given consent at any time, using the appropriate function at the bottom of each e-mail received or by contacting the addresses indicated in this policy. Consent to the processing operations described above is optional; if the Data Subject prefers not consent, she will not be affected by any kind of prejudice or repercussion regarding the use of the other services offered through the Site (clearly, the Data Subject will not be able to receive newsletters from the Data Controller);

        C) data such as the Internet Protocol (IP) address and the technical features of the browser used for navigation, which are collected and communicated by the Data Controller to Facebook Ireland Ltd. (owner of Instagram) for the purpose of increasing the commercial visibility of the services offered and the commercial image of the Data Controller.

Limited to the processing operations above mentioned, the Data Controller is also Facebook Ireland Ltd., with a registered office in 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Republic of Ireland (EU). This implies, moreover, that the liability for any further processing operations carried out after the transmission of such data falls exclusively on Facebook Ireland Ltd., to which the Data Subject may turn to in order to exercise its rights in relation to such processing operations.

These processing operations are carried out in pursuit of the legitimate interest of the Data Controller to promote its services and its commercial image on the social network Instagram.

Personal Data will be processed mainly by automated means (e.g. management software) and residually by non-automated means (e.g. paper filing systems) chosen in order to ensure the security of the data, by individuals who operate under the direct authority of the Data Controller and who have been properly authorized and instructed in this regard by the latter.

DATA STORAGE PERIOD

Personal data processed for the purposes referred to in point A) will be stored for the time necessary to allow navigation of the Website and in any case no further than 7 days from collection, except when a longer storage period is required for purposes of detection of crimes by public authorities or for purposes of exercising or defending a legal claim of the Data Controller.

Personal data processed for the purposes referred to point B) will be stored for the time strictly necessary to achieve the purposes for which they were collected; contact details shall be processed for the purpose of sending promotional newsletters until consent is withdrawn by the Data Subject or, in any case, for no longer than 24 months after those data has been registered for such purposes. 

RECIPIENTS OF PERSONAL DATA AND TRANSFERS TO THIRD COUNTRIES

Personal data relating to the Data Subjects may be disclosed to:

• suppliers of information technology (IT) services, such as websites’ management and maintenance support;

• Data Controller's staff tasked with managing the Website and providing feedback to requests made through the Website;

• public authorities, such as police forces and judicial offices, when required by law or by a legitimate order.

Please note that if an advertisement is published upon request by the Data Subjects, information regarding the real estate properties that are being advertised will be published in the "Properties" section of the Website.

If the conditions established by the GDPR are met, the Data Controller shall enter into specific contracts with those recipients, among those listed above, who receive disclosure of your personal data so that they may process them on behalf of the Data Controller ("Data Processors"), aimed at ensuring that the operations carried out are performed consistently with the instructions given by the Data Controller and that appropriate technical and organisational measures are implemented to safeguard the security of the personal data processed.

Your personal data will not be transferred to countries outside the European Economic Area ("Third Countries").

RIGHTS OF THE DATA SUBJECTS

At any time, the Data Subject may exercise the rights attributed to him or her by articles 15 et seq. GDPR by reaching out to the Data Controller. Namely the user, as a Data Subject and within the limits established by the GDPR, may exercise the following rights:

• the right of access, i.e. the right to obtain confirmation as to whether or not your data are being processed, as well as the right to receive any information related to the processing operations and a copy of the personal data undergoing processing;

• the right to rectification, i.e. the right to obtain the rectification or the completion of the personal data undergoing processing, if they are inaccurate or incomplete taking into account the purposes of the processing;

• the right to erasure ("right to be forgotten"), i.e. the right to obtain the erasure of the personal data undergoing processing when they are no longer necessary in relation to the purposes for which they were collected or otherwise processed, or when another ground established by article 17 GDPR applies;

• the right to restriction of processing, i.e. the right to obtain the restriction of the processing of personal data, when the requirements set out in article 18 GDPR are met;

• the right to data portability, i.e. the right to receive personal data concerning the Data Subject, which he/she has provided to the Data Controller, in a structured, commonly used and machine-readable format, and to have the personal data transmitted directly from one controller to another, where technically feasible;

• the right to object to the processing, i.e. the right of the Data Subject to object at any time, on grounds relating to his or her particular situation, to the processing operations of personal data concerning him or her which are necessary to the performance of a task carried out in the public interest, to the exercise of official authority or for the purposes of the legitimate interest of the Data Controller, unless the latter demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims;

• the right not to be subject to solely-automated individual decision-making, i.e. the right not to be subject to decisions, which produce legal effects on the Data Subject or which in any case similarly significantly affect him or her in a similar way, which are based solely on automated processing, including profiling. The Data Controller does not rely on solely-automated individual decision-making; 

• the right to withdraw consent, i.e. to revoke consent to the processing of personal data at any time, without affecting the lawfulness of processing based on consent before its withdrawal;

• the right to lodge a complaint with a Supervisory Authority, such as the Garante per la Protezione dei Dati Personali, with offices in Piazza Venezia 11 - 00187, Rome (RM), Italy (IT), E-mail: garante@gpdp.it, P.E.C.: protocollo@pec.gpdp.it.

These rights may be exercised free of charge, by sending a written request to the Data Controller at the Contact Point. However, in case manifestly unfounded or excessive requests are filed, in particular, because of their repetitive character, the Data Controller may charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested, or refuse to act on the request altogether.

POLICY CHANGES

Over the course of time, the Data Controller may make changes to this Privacy Policy, in order to ensure it is updated to the processing operations being performed or merely in order to improve its clarity; in such cases, the Data Controller shall promptly inform users of the Website employing the most effective and appropriate tools to that end.

LAST AMENDED: 4 April 2023