Information on the processing of personal data pursuant to art. 13 of EU Regulation 2016/679
Dear user,
Costa Edutainment SpAhereby provides you with the following information, pursuant to Article 13 of EU Regulation 2016/679 (GDPR), regarding the processing of the personal data you provide when registering on this website (hereinafter also referred to as the "Site") and during the subsequent purchase, receipt, and use of the products and services marketed through it.
This processing of your personal data may also take place using IT and electronic tools.
Data controller
The Data Controller is Costa Edutainment SpA, VAT number 03362540100, with registered office in Riccione (RN), Via Ascoli Piceno n. 6, postcode 47838 (RN), in the person of its legal representative pro tempore (hereinafter referred to as the "Company" or "Data Controller").
Contact details of the Data Protection Officer (DPO)
The Data Protection Officer (DPO) can be reached at the email address: dpo@costaedutainment.com or by regular mail at the Company's administrative headquarters located in Genoa, Area Porto Antico – Ponte Spinola Ambrogio sn, postcode 16128 (GE), for the attention of the same.
Categories of data subject to processing
The Data Controller will process, by way of example and not limited to, the following categories of personal data provided by you during registration on the Site, during the purchase of products and services, and during order processing and provision of the purchased services:
personal data (e.g. name, surname);
contact details (e.g. email address);
login credentials for the personal area created following registration on the Site (e.g. username and password);
data relating to the products or services purchased;
data relating to the payment system used;
data acquired by the Data Controller during the execution of the product purchase contract;
data acquired by the Data Controller during the provision of the purchased service;
data acquired by the Data Controller relating to the operations and actions performed on promotional emails (e.g., IP address, time the email was opened, clicks on specific links contained in the email);
the result of your profiling based on your purchase history, where you have given your consent to such processing.
Purpose of processing personal data
Your personal data will be processed by the Data Controller for the following purposes:
to register on the Site and use the services associated with registration, such as a personal space where you can check your orders and purchases, express your satisfaction with the services offered by the Data Controller, and access the provision of additional services offered by the same;
to allow you to proceed with the purchase of products and services offered by the Data Controller through the Site;
to process and manage your purchase order;
to allow the Data Controller to manage any claims that may occur to you while using the services, or any complaints you may have;
to allow the Data Controller to send you communications on activities and promotions relating to services or products that are the same or similar to those already used and/or relating to offers or promotions relating to them, limited to the use, for this purpose, of the personal data represented by your email address provided by you during the conclusion of the contract;
to send you, with your prior consent, commercial information, including via newsletter, relating to products and/or services offered by the Data Controller, also using contact information other than your email address (e.g., mobile phone number, home or residential address), also using the results of the analysis carried out on your actions performed on promotional emails received (e.g., opening emails, clicking individual links);
for profiling and/or market analysis purposes, so that the Data Controller can create, with your prior consent, a profile of you to send you commercial communications selected based on your preferences, or other behavioral aspects of yours, as emerged from the profiling activity;
so that the Data Controller may disclose your personal data to third parties, with your consent, so that they can send you commercial information regarding their products or services. The third parties to whom your data may be disclosed are companies controlled, affiliated, or in which the Data Controller has a stake, or other third-party companies operating in the entertainment sector, which promotes quality leisure time, combining culture, science, education, entertainment, and nature;
so that the Data Controller can send you a "reminder" communication to inform you of the imminent cancellation of your account and the data you have saved through it, a circumstance which will require you to register again to access the related services;
so that the Data Controller can protect his rights both in and out of court;
to allow the Data Controller to fulfill the legal obligations to which it is subject.
Legal basis for processing
The legal basis for the processing of your personal data for the purposes referred to in point 1) above is the execution of the Site registration contract.
The legal basis for the processing of your personal data for the purposes referred to in points 2) and 3) above is the performance of the purchase contract for the goods or services or the implementation of pre-contractual measures adopted at your request.
The legal basis for the processing of your personal data for the purposes referred to in point 4) above is the Data Controller's legitimate interest in managing any claims that may arise during the use of the service, or any complaints related to the products or services it markets. If managing the claim involves the processing of your sensitive data (e.g., health data), the legal basis will be the Data Controller's need to ascertain, exercise, or defend legal claims.
The legal basis for the processing of your personal data for the purposes referred to in point 5) above is the provisions of Article 130, paragraph 4, of Legislative Decree 196/2003 and subsequent amendments and additions.
The legal basis for the processing of your personal data for the purposes referred to in points 6), 7) , and 8) above is your consent. Providing consent for these purposes is optional, meaning that failure to provide it will in no way limit your registration on the Site, the purchase of products and services, or your use of them. Please note that failure to provide the required consent, or its subsequent revocation, will prevent the Data Controller from carrying out the processing activities for which such consent is requested.
The legal basis for the processing of your personal data for the purposes referred to in point 9) above is the Data Controller's legitimate interest in ensuring that the account on which the loyalty relationship with the user is based is not deleted, balanced with the user's interest in continuing to use the related services without having to re-register and in not losing the data previously saved through their account, an interest deemed to prevail over the consequent restriction of their rights that such processing entails.
The legal basis for the processing of your personal data for the purposes referred to in point 10) above is the Data Controller's legitimate interest in protecting its rights, both in and out of court, in the event of any contractual breaches by you or damages caused by you to the Data Controller's assets or to third parties. If the Data Controller's protection of its rights involves the processing of your sensitive data (e.g., health data), the legal basis will be the Data Controller's need to ascertain, exercise, or defend its rights in court.
The legal basis for the processing of your personal data for the purposes referred to in point 11) above is the Data Controller's need to comply with legal obligations to which it is subject.
Mandatory provision of data and consequences of failure to provide data
Providing your personal data is necessary to enable your registration on the Site and to subsequently purchase the Data Controller's products and services through the Site. Failure to provide your personal data will prevent you from registering on the site and subsequently purchasing the Data Controller's products or services.
Data retention period
Your personal data processed for the purposes referred to in point 1) will be retained for the entire duration of your registration on the Site. Please note that, in any case, after 6 years from your last purchase on your account, it will be automatically deactivated, resulting in the deletion of your account and any associated data. Before the expiration of the effective deletion period, you will be sent a reminder to keep your registration on the Site active.
Your personal data processed for the purposes referred to in points 2) and 3) will be retained for the entire duration of the purchase process for the goods and services and, subsequently, for 10 years from the date of signing the relevant contract. After this period, they may be retained further if necessary for ongoing legal proceedings.
Your personal data processed for the purposes referred to in point 4) will be retained for the entire duration of the claim or complaint management and until its resolution.
Your personal data processed for the purposes referred to in points 5), 6), 7), 8) and 9) will be retained for the entire duration of your registration on the Site, unless you expressly request the deletion of your data, which you can exercise at any time according to the methods set out in the paragraph of this notice dedicated to the exercise of your rights.
Please note that, in any case, after 6 years from your last purchase, your account will be automatically deactivated, resulting in the deletion of the account itself and any data associated with it.
Your personal data processed for the purposes referred to in point 10) will be retained until the statute of limitations applies for the rights that the Data Controller may assert by means of such data.
Your personal data processed for the purposes referred to in point 11) will be retained for the entire duration necessary for the Data Controller to fulfill its legal obligations (e.g., 10 years for data contained in accounting documentation).
Data recipients
Your personal data may be disclosed to third-party companies that offer or manage, on behalf of the Data Controller, support services for the online sales of the Data Controller's products or services.
Your personal data may be disclosed, with your consent, to other third parties so that they can send you commercial information regarding their products or services. The third parties to whom your personal data may be disclosed are affiliated, affiliated, and/or controlled companies of the Data Controller, third-party companies operating in the entertainment sector aimed at promoting quality leisure time, combining culture, science, education, entertainment, and nature, as well as companies controlled or affiliated by the Data Controller.
Your personal data may also be disclosed to other third parties, such as lawyers, consultants, insurance companies, and public authorities.
Third-party companies that offer or manage, on behalf of the Data Controller, services related to the management of the website, registration on the same, and companies providing CRM or similar applications may have access to your personal data, limited to these purposes and subject to their appointment as data processors, pursuant to Article 28 of EU Regulation 2016/679.
The list of data controllers, which by its nature is subject to change, may be requested from the Data Controller at any time by writing to privacy@costaedutainment.com .
Company employees, designated as data processors, may also have access to your personal data if their duties require it. Each data processor is specifically identified, authorized, and trained, and acts on the basis of specific instructions provided by the Company regarding the purposes and methods of processing, and the security measures to be adopted to protect personal data.
Image acquisition for souvenir photos
The interested party is advised that, in order to allow them to purchase a souvenir photo of their visit to the facility managed by the Data Controller, photos may be taken, which they will subsequently be offered for purchase.
Image acquisition is automatic and, therefore, necessarily involves all subjects accessing the facility.
The souvenir photos in question will not be published and/or distributed under any circumstances.
The legal basis for image processing is the Data Controller's legitimate interest in selling souvenir photos, balanced against the visitor's interest in purchasing them as a memento of their experience, given the limited impact of such processing on their rights and freedoms. This impact is mitigated by not disseminating or displaying the images and by retaining them for a limited period of time, as indicated below.
The acquired images will be retained until they are purchased by the interested party and, in any case, for a period not exceeding 24 hours from their acquisition.
Only those responsible for managing the photography service offered by the Data Controller and those responsible for selling the photos will have access to the images. Each data processor is specifically identified, authorized, and trained, and acts on the basis of specific instructions provided by the Company regarding the purposes and methods of processing, and the security measures to be adopted to protect personal data.
Rights of the interested party
The Data Controller informs you that, as the Data Subject, you have the right, pursuant to Article 15 et seq. of EU Regulation 2016/679, and within the limits prescribed therein, to:
obtain data and information on the processing, in particular in relation to the type of personal data processed, the purposes for which the personal data are processed, the period of processing and the subjects to whom the data are communicated (so-called right of access);
obtain the rectification or integration of inaccurate personal data concerning you (so-called right to rectification);
obtain the erasure of your personal data in the following cases: (i) the personal data are no longer necessary for the purposes for which they were collected; (ii) you have withdrawn your consent to the processing of your personal data, if the data is processed on the basis of such consent; (iii) you have objected to the processing of your personal data if the data is not processed for a legitimate interest of the Data Controller; (iv) the processing of your personal data is unlawful. However, the Data Controller may lawfully retain your personal data if it is necessary to comply with a legal obligation or to establish, exercise, or defend legal claims (so-called right to erasure);
obtain that the personal data concerning you be only retained without any other use of them in the following cases: (i) you contest the accuracy of the personal data, for the period necessary to allow the Data Controller to verify the accuracy of such personal data; (ii) the processing of personal data is unlawful; you oppose, in any case, the erasure of personal data by the Data Controller; (iii) the personal data are necessary for the establishment, exercise or defense of a right in court; (iv) you have objected to the processing and are pending verification of whether the legitimate grounds of the Data Controller for the processing prevail over yours (so-called right to restriction of processing);
object at any time to the processing of personal data and in particular to the processing of data processed for marketing purposes and for profiling purposes (so-called right to object);
receive your personal data in a commonly used, machine-readable and interoperable format, if they are processed pursuant to a contract or on the basis of your consent, and/or request that the data be transmitted to another data controller, if feasible (so-called right to portability);
withdraw consent at any time for processing for which it is required. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal;
askthe Data Controller at any time not to send you any more commercial information relating to services that are the same or similar to those already used and/or relating to offers or promotions related to them (so-called “soft spam” pursuant to Art. 130 paragraph 4 of Legislative Decree 30 June 2003, no. 196);
not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her and furthermore the right to request, on any automated decision, including profiling, human intervention by the Data Controller on the automated intervention carried out by the latter, to express his or her point of view and to contest the decision.
You may exercise the aforementioned rights by writing to the Data Controller via email at the dedicated address privacy@costaedutainment.com or by post to the administrative headquarters of Costa Edutainment SpA, located in Genoa, Area Porto Antico – Ponte Spinola Ambrogio sn, postcode 16128 (GE).
Right to complain
If you believe that the processing of your personal data by the Data Controller violates the provisions of EU Regulation 2016/679, you have the right to lodge a complaint with the Office of the Data Protection Supervisor, pursuant to Article 77 of EU Regulation 2016/679 (by email to garante@gpdp.it, or by post to the Italian Data Protection Supervisor, based in Rome, Italy, at Piazza Venezia 11 Scala B, CAP 00187), or to take appropriate legal action, pursuant to Article 79 of EU Regulation 2016/679.
The Data Controller
Costa Edutainment SpA