(Art. 13 Regulation (EU) 2016/679 – GDPR)

1. Data Controller

Terra Piccinelli & C. Società semplice agricola
Via Monte Rosa 17, 21030 Brinzio (VA), Italia
P. IVA: 04074260128
Email: info@terrapiccinelli.it
PEC: terrapiccinelli@lamiapec.it

The Data Controller determines the purposes and means of processing personal data.
A Data Protection Officer (DPO) has not been appointed, as the conditions under Article 37 GDPR do not apply.

2. Categories of Personal Data

Depending on the interaction with the website, the following personal data may be processed:

• First name and last name
• Email address
• Telephone number
• Information voluntarily provided via contact forms or email
• Data necessary for accommodation or restaurant reservations (current or future)
• IP address and browsing data
• Data collected through cookies and tracking technologies

If online payments are implemented in the future, payment data will be processed exclusively by
external payment providers (e.g., Stripe). The Data Controller will not store credit card details.

3. Purpose and Legal Basis of Processing

Personal data are processed for the following purposes:

a) Responding to inquiries
Legal basis: Art. 6(1)(b) GDPR – pre-contractual measures.

b) Managing reservations (accommodation or restaurant)
Legal basis: Art. 6(1)(b) GDPR – performance of a contract.

c) Compliance with legal and administrative obligations
Legal basis: Art. 6(1)(c) GDPR – legal obligation.

d) Website security and proper functioning
Legal basis: Art. 6(1)(f) GDPR – legitimate interest.

e) Statistical analysis (e.g., Google Analytics)
Legal basis: Consent, where required (Art. 6(1)(a) GDPR).

f) Marketing communications (if activated in the future)
Legal basis: Explicit consent (Art. 6(1)(a) GDPR).

Consent may be withdrawn at any time.

4. Nature of Data Provision

Providing personal data for contact requests or reservations is voluntary; however, failure to provide the required data may make it impossible to respond or manage bookings.

Providing data for marketing purposes is entirely optional.

5. Processing Methods

Data are processed using electronic and IT tools in accordance with principles of lawfulness, fairness, transparency, and data minimization.

Appropriate technical and organizational measures are adopted to protect personal data from unauthorized access, disclosure, alteration, or destruction.

6. Data Retention

• Contact requests: up to 12 months
• Reservation and administrative data: for the period required by applicable tax and accounting laws
• Marketing data: until consent is withdrawn
• Technical and cookie data: according to the duration specified in the cookie settings

7. Recipients of Data

Data Processors, including:

• Hosting and IT providers
• Google LLC (Google Analytics)
• Meta Platforms Ireland Ltd. (Instagram e WhatsApp)
• Stripe Inc. (future payment provider)
• Accounting and tax consultants

Where required, processing agreements pursuant to Article 28 GDPR are in place.

8. Transfers Outside the EU

Some service providers may transfer personal data outside the European Union. Such transfers are carried out in accordance with GDPR safeguards, including Standard Contractual Clauses approved by the European Commission.

9. Data Subject Rights

Under Articles 15–22 GDPR, users have the right to:

• Access their personal data
• Request rectification or erasure
• Request restriction of processing
• Object to processing
• Request data portability
• Withdraw consent at any time

Requests may be sent to:
info@terrapiccinelli.it

Data subjects have the right to lodge a complaint with the competent supervisory authority pursuant to Article 77 GDPR.

10. Social Media and WhatsApp

The website may include links or widgets to Instagram and a WhatsApp contact button. Interaction with these platforms may result in the processing of personal data by their respective providers. Users are encouraged to review the privacy policies of those services.

11. Updates

This Privacy Policy may be updated at any time. The latest version will always be available on this page.